Freedom of Information Policy

1. Introduction

The Freedom of Information Act 2000 (“FOIA”) is an Act of Parliament that sets out a member of the public’s “right to know” in relation to public bodies, including Non-Departmental Public Bodies (“NDPBs”). The FOIA also sets out certain exemptions to those rights. 

The purpose of this Freedom of Information Policy (hereinafter referred to as “the or this Policy”) is to outline the Education Buying Group Limited’s (“THE PSBO”) approach to its FOIA obligations to create a climate of openness and dialogue with its stakeholders and customers. 

This Policy is applicable to all of THE PSBO Directors, Board, and staff (including all permanent, temporary and contract workers employed or engaged by THE PSBO or any 3rd party organisations while at work or engaged on THE PSBO business) and any members of the public who request information under the FOIA. 

2. Managing Requests

THE PSBO is included in the definition of a public authority for the purposes of the FOIA. 

THE PSBO is required to respond to requests for information. Information is defined in the FOIA as meaning “information recorded in any form”. This is interpreted as including paper records, e-mails, information stored on computer, voicemail messages, handwritten notes or any other form of recorded information. Information, which is known to staff, however not recorded, is not covered by the FOIA. 

All official information which is recorded is covered by the FOIA, irrespective of classification or format. 

The dedicated route for FOI requests are by email to: This inbox is monitored by the PSBO Company Secretary, currently Claire Easun, and legal staff from our procurement partner If a FOI request is received, all Directors will be informed. The request will be processed by the Legal & Compliance Team at with approval obtained from two PSBO Directors before a response is made. 

THE PSBO staff who receive written requests for information under the FOIA (including any requests which do not specifically mention the FOIA) must forward these immediately to the email Where an oral request is made, the requester should be advised to put their request in writing. 

The FOIA imposes strict time limits for dealing with a request for information. THE PSBO will issue a response within 20 working days from the date upon which the written request is received by THE PSBO unless clarification of the request has been sought from the requester or an extension to the statutory timescales is sought by THE PSBO under section 10(3) of the FOIA. 

3. Other Regimes

The FOIA covers rights of access to and requests for non-personal data. Data protection legislation (including the General Data Protection Regulation) covers the rights individuals have in respect of their personal data, including rights of access. Personal information is exempt under section 40 of the FOIA and the processing of personal data will continue to be regulated by applicable data protection legislation. Any application for access to personal information of which the requester is the subject will be classed as a request under data protection legislation and treated accordingly. The requester will be advised to this effect. 

The Environmental Information Regulations (“EIRs”) deal specifically with information relating to any decisions, activities and policy formulation that may have an impact on the environment. Environmental information is exempt information under section 39 of the FOIA. Requests for environmental information will be handled in an analogous manner to requests for information made under the FOIA. However, it should be noted that the EIRs do not specify that requests must be in writing. This means that telephone requests on environmental matters will also be valid (although in practice it is advisable to make a written record of any verbal requests received). 

4. THE PSBO FOI Publication Scheme

Under the FOIA, all public authorities are obliged to adopt and maintain a Publication Scheme specifying: 

  • the classes of information that they publish or intend to publish; and 
  • how the information is or will be published. 

THE PSBO’s FOI Publication Scheme is available by request and a copy can be requested by contacting THE PSBO by email or at the end of this Policy. 

The FOI Publication Scheme lists THE PSBO business-related information that THE PSBO considers should be publicly available. 

THE PSBO will periodically review the FOI Publication Scheme and make amendments and updates where appropriate

5. Fees

Where possible, THE PSBO will not charge requesters a fee for complying with requests however it reserves the right to do so. If THE PSBO determines that a fee will be charged for complying with the request, a fee notice will be issued to the applicant in accordance with section 9 of the FOIA. 

6. Provision of information

THE PSBO will seek to provide the requested information, subject to the application of any statutory exemption under the FOIA. 

In responding to requests for information, THE PSBO will have regard to any preferences expressed by the requester as to the form of communication. Where it is not reasonably practicable to comply with any preference expressed, THE PSBO will notify the requester of the reasons for this determination. 


7. Advice and assistance

THE PSBO has a duty, so far as it is reasonable to do so, to give advice and assistance to anyone who has made a request or is considering making one. 

8. Procedure for making a request

Requesters are required to put a request in writing – in the form of a letter / email / facsimile, supplying their name and address and an address for correspondence and describing the specific information they are seeking. Requests need not refer to/quote FOI legislation (but it may be helpful to do so). Requesters should address their requests to THE PSBO’s FOI email address. 

THE PSBO’s staff may contact the requester to clarify the terms/scope of the request and to give advice and assistance as needed. 

9. Exemptions

Where information is held by THE PSBO, the information will not be withheld unless: 

  • an exemption to disclosure under Part II of the FOIA applies; 
  • it would cost too much to comply with the request; 
  • the request is considered vexatious; and/ or 
  • the request is repeated. 

The exemptions to disclosure set out in the FOIA include non-disclosure in matters of a sensitive commercial nature or where disclosure would prejudice the effective conduct of public affairs. 

Some of the FOIA exemptions are absolute exemptions, for example, if the information is personal data. If an absolute exemption applies, then THE PSBO does not need to release the information. The remaining exemptions are qualified exemptions that require THE PSBO to apply the public interest test in deciding whether to release the information. In considering the public interest, THE PSBO will take into account: 

  • whether the public interest in maintaining the exclusion of the duty to confirm or deny that information is held outweighs the public interest in disclosing whether THE PSBO holds the information; and/or 
  • whether the public interest in withholding information outweighs the public interest in releasing it. 

Where the public interest test is relevant, THE PSBO will apply it separately to each piece of potentially exempt information. 

Where a document cannot be released in its entirety, THE PSBO will endeavour to release what it is able to, in as intelligible a format as possible. 

Where information is not held, THE PSBO will seek to provide appropriate advice and assistance to the requester. 


10. Consultation with Third Parties

THE PSBO may consult with a third party if: 

  • the views of that third party may assist THE PSBO to determine whether an exemption under the FOIA applies to the information requested; and/or 
  • where the views of the third party may assist THE PSBO to determine where the public interest lies under section 2 of the FOIA. 


11. Refusal of requests

Where THE PSBO refuses a request, it will give the requester a notice setting out the reasons for the refusal. 

When any written request is refused, THE PSBO will notify the requester of the internal review process and their right under section 50 of the FOIA to apply to the Information Commissioner for a Decision Notice. 

THE PSBO reserves the right to refuse to respond to a request for information if it exceeds the value of £450 to process in terms of staff time and disbursements. The £450 is calculated to be 18 hours of staff time based on an hourly rate of £25 per hour, which is provided for by Regulation 4 of the Freedom of Information and Data Protection (Appropriate Limit and Fees) Regulations 2004. 

12. Internal review process

If a requester is unhappy with: 

  • the way in which his/her request has been handled; 
  • is dissatisfied with the decision made regarding disclosure or non- disclosure of information; and/or 
  • is of the opinion that THE PSBO is not compliant with its Publication Scheme, 

they are able to request an internal review. All responses issued by the PSBO will provide the requester with details on how to request such an internal review. 

THE PSBO’s Director representing Church Marketplace, currently Jennifer Louise Williamson, has overall responsibility for the internal review procedure. This Director will therefore remain independent of FOI requests. This Director will be the internal reviewer unless they are unable to undertake the review due to circumstances such as, however not limited to, absence, illness or prior involvement. In the event that this Director is unable to undertake the review, an alternative internal reviewer will be appointed, and the requester duly notified. 

The internal reviewer will review the manner in which the request was dealt with and is empowered to either uphold or overturn the original decision. 

THE PSBO will only consider requests for an internal review which are made within 2 months of the date of the response to the requester. 

The requester will be notified as to the outcome within a reasonable timescale. THE PSBO aims to deal with internal reviews within 20 working days of receipt thereof. If it becomes clear at any stage of the internal review that THE PSBO will not be able to meet this target, the requester will be notified. 

13. The Information Commissioner

The Information Commissioner’s Office (“ICO”) is the UK’s independent authority set up to promote access to official information. If the requester remains dissatisfied with the decision made as a result of the internal review procedure, they can, under section 50 of the FOIA, complain to the Information Commissioner by writing to the ICO at Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF ( to apply for a decision as to whether the request has been dealt with in accordance with the requirements of Part 1 of the FOIA. 

A Decision Notice will be served if the Information Commissioner decides that THE PSBO has failed to: 

  • communicate information; 
  • confirm or deny where required to do so by section 1(1) of the FOIA; 
  • comply with requirements of section 11 of the FOIA (which refers to the manner of communication in response to a request for information); or 
  • comply with any of the requirements of section 17 of the FOIA (which refers to the refusal of a request for information). 

The Decision Notice will specify the steps, which must be taken by THE PSBO to comply with the FOIA and the timescale for compliance. 

The Information Commissioner can serve an Information Notice on THE PSBO requiring the provision of specified information to him/her (unless legal professional privilege applies). 

If the Information Commissioner is satisfied that THE PSBO has failed to comply with any of the requirements under Part 1 of the FOIA, he/she may serve an Enforcement Notice on THE PSBO, requiring THE PSBO to take particular steps within a specified time to comply with those requirements. 

All public authorities may appeal to the First–Tier Tribunal (Information Rights) against Decision Notices and Information and Enforcement Notices. 

14. Reasonable adjustments and alternative formats

THE PSBO is committed to equal opportunities and our aim is to make this Policy easy to use and accessible to all. We will take reasonable steps to accommodate any reasonable adjustments require to: 

  • enable access to this Policy; 
  • provide responses to requests in other formats; or 
  • provide such assistance as may reasonably be required. 

Should a copy of this Policy be required in an alternative format, such as Braille, audio CD or large print, please get in touch using the contact details set out in section 2 above. 

15. Review

This Policy is subject to review annually, or in response to any relevant changes. 

The Freedom of Information Publication Scheme

(ICO Model Publication Scheme)

This model publication scheme has been prepared and approved by the Information Commissioner. It may be adopted without modification by any public authority without further approval and will be valid until further notice. 

This publication scheme commits an authority to make information available to the public as part of its normal business activities. The information covered is included in the classes of information mentioned below, where this information is held by the authority. Additional assistance is provided to the definition of these classes in sector specific guidance manuals issued by the Information Commissioner. 

The scheme commits an authority: 

  • To proactively publish or otherwise make available as a matter of routine, information, including environmental information, which is held by the authority and falls within the classifications below.
  • To specify the information which is held by the authority and falls within the classifications below.
  • To proactively publish or otherwise make available as a matter of routine, information in line with the statements contained within this scheme.
  • To produce and publish the methods by which the specific information is made routinely available so that it can be easily identified and accessed by members of the public.
  • To review and update on a regular basis the information the authority makes available under this scheme.
  • To produce a schedule of any fees charged for access to information which is made proactively available.
  • To make this publication scheme available to the public.
  • To publish any dataset held by the authority that has been requested, and any updated versions it holds, unless the authority is satisfied that it is not appropriate to do so; to publish the dataset, where reasonably practicable, in an electronic form that is capable of re-use; and, if any information in the dataset is a relevant copyright work and the public authority is the only owner, to make the information available for re-use under the terms of the Re-use of Public Sector Information Regulations 2015, if they apply, and otherwise under the terms of the Freedom of Information Act section 19.The term ‘dataset’ is defined in section 11(5) of the Freedom of Information Act. The term ‘relevant copyright work’ is defined in section 19(8) of that Act.


Classes of Information

Who we are and what we do  

Organisational information, locations and contacts, constitutional and legal governance. 

What we spend and how we spend it  

Financial information relating to projected and actual income and expenditure, tendering,  

procurement and contracts. 

What our priorities are and how we are doing  

Strategy and performance information, plans, assessments, inspections and reviews. 

How we make decisions  

Policy proposals and decisions. Decision making processes, internal criteria and procedures,  


Our policies and procedures.  

Current written protocols for delivering our functions and responsibilities. 

Lists and registers  

Information held in registers required by law and other lists and registers relating to the  

functions of the authority. 

The services we offer  

Advice and guidance, booklets and leaflets, transactions and media releases. A description of  

the services offered. 

The classes of information will not generally include: 

  • Information the disclosure of which is prevented by law, or exempt under the Freedom of Information Act, or is otherwise properly considered to be protected from disclosure.
  • Information in draft form.
  • Information that is no longer readily available as it is contained in files that have been placed in archive storage, or is difficult to access for similar reasons.

The Method by Which Information Published Under This Scheme Will Be Made Available

The authority will indicate clearly to the public what information is covered by this scheme  

and how it can be obtained. 

Where it is within the capability of a public authority, information will be provided on a  

website. Where it is impracticable to make information available on a website or when an  

individual does not wish to access the information by the website, a public authority will  

indicate how information can be obtained by other means and provide it by those means. 

In exceptional circumstances some information may be available only by viewing in person.  

Where this manner is specified, contact details will be provided. An appointment to view the  

information will be arranged within a reasonable timescale. 

Information will be provided in the language in which it is held or in such other language that  

is legally required. Where an authority is legally required to translate any information, it will  

do so. 

Obligations under disability and discrimination legislation and any other legislation to  

provide information in other forms and formats will be adhered to when providing  

information in accordance with this scheme. 

Charges Which May Be Made for Information Published Under This Scheme

The purpose of this scheme is to make the maximum amount of information readily available  

at minimum inconvenience and cost to the public.  Charges made by the authority for routinely published material will be justified and transparent and kept to a minimum. 

Material which is published and accessed on a website will be provided free of charge. 

Charges may be made for information subject to a charging regime specified by Parliament. 


Charges may be made for actual disbursements incurred such as: 

  • photocopying
  • postage and packaging
  • the costs directly incurred as a result of viewing information


Charges may also be made for information provided under this scheme where they are  

legally authorised, they are in all the circumstances, including the general principles of the  

right of access to information held by public authorities, justified and are in accordance with  

a published schedule or schedules of fees which is readily available to the public. 

Charges may also be made for making datasets (or parts of datasets) that are relevant  

copyright works available for re-use. These charges will be in accordance with the terms of  

the Re-use of Public Sector Information Regulations 2015, where they apply, or with  

regulations made under section 11B of the Freedom of Information Act, or with other  

statutory powers of the public authority. 

If a charge is to be made, confirmation of the payment due will be given before the  

information is provided. Payment may be requested prior to provision of the information. 

Written Requests

Information held by a public authority that is not published under this scheme can be  

requested in writing, when its provision will be considered in accordance with the provisions  

of the Freedom of Information Act.