2012/2013 First Quarter Report July – September 2012 1 QUARTERLY REPORT Information Commissioner’s Office 2012/2013 FIRST QUARTER REPORT 1 July – 30 September 2012 PURPOSE OF THIS DOCUMENT The Cayman Islands’ Freedom of Information Law, 2007 (FOI Law) came into effect on 5 January 2009. The objective of the FOI Law is to make Government more accountable by giving the general public the right to access records held by Government, and by requiring that public authorities follow a uniform set of rules when deciding whether or not to disclose information in response to an access request. The burden of proof is on the public authority to show that when withholding information it acts in accordance with its legal obligations. The Law also requires public authorities to ensure that decisions and the reasons for those decisions are made public, as well as proactive disclosure. The purpose of this Report is to provide the Legislative Assembly and the public with an account of how this legislation is being administered, and to ensure ongoing transparency and accountability of the Information Commissioner’s Office (“ICO”) itself, in the discharge of its statutory responsibilities under the FOI Law. The ICO is a quasi-judicial body, responsible for hearing appeals, monitoring compliance, and promoting and enforcing the FOI Law. Under the FOI Law, the Information Commissioner may: (a) Hear, investigate and rule on appeals filed under the Law; (b) Monitor and report on the compliance by public authorities with their obligations under the Law; (c) Make recommendations for reform both of a general nature and directed at specific public authorities; (d) Refer to the appropriate authorities cases where it appears that a criminal offence has been committed; (e) Publicise the requirements of the Law and the right of individuals under it.
Transcript
2012/2013 First Quarter Report July – September 2012 1
QUARTERLY REPORT
I n f o r m a t i o n
C o m m i s s i o n e r ’ s O f f i c e
2012/2013 FIRST QUARTER REPORT 1 July – 30 September 2012
PURPOSE OF THIS DOCUMENT The Cayman Islands’ Freedom of Information Law, 2007 (FOI Law) came into effect on 5 January 2009. The objective of the FOI Law is to make Government more accountable by giving the general public the right to access records held by Government, and by requiring that public authorities follow a uniform set of rules when deciding whether or not to disclose information in response to an access request. The burden of proof is on the public authority to show that when withholding information it acts in accordance with its legal obligations. The Law also requires public authorities to ensure that decisions and the reasons for those decisions are made public, as well as proactive disclosure. The purpose of this Report is to provide the Legislative Assembly and the public with an account of how this legislation is being administered, and to ensure ongoing transparency and accountability of the Information Commissioner’s Office (“ICO”) itself, in the discharge of its statutory responsibilities under the FOI Law. The ICO is a quasi-judicial body, responsible for hearing appeals, monitoring compliance, and promoting and enforcing the FOI Law. Under the FOI Law, the Information Commissioner may:
(a) Hear, investigate and rule on appeals filed under the Law; (b) Monitor and report on the compliance by public authorities with their obligations under
the Law; (c) Make recommendations for reform both of a general nature and directed at specific
public authorities; (d) Refer to the appropriate authorities cases where it appears that a criminal offence has
been committed; (e) Publicise the requirements of the Law and the right of individuals under it.
2012/2013 First Quarter Report July – September 2012 2
GENERAL CONSIDERATIONS APPLICABLE
GENERAL CONSIDERATIONS APPLICABLE TO ALL AREAS OF RESPONSIBILITY
1. Independence of the Information Commissioner Due to limited resources, the Information Commissioner’s Office has not been able to make further progress with organizational and legislative changes that would enable it to meet accepted international levels of independence. The practical reasons for this are budgetary, as the ICO is tied to the Government budget process. The ICO is subject to the provisions of the Public Management and Finance Law for the administration of its budget, and to some degree to the Public Service Management Law for it Human Resources management. Nonetheless, the Information Commissioner has not experienced any political interference or problems with lack of independence with respect to her obligations to hear and rule on appeals. 2. Training A staff training retreat was held on 17 July, which focused on the ICO’s internal policies and procedures. A new series of Information Manager Seminars (Series II) - Personal Information Exemption commenced on 27 September, in conjunction with Right to Know Week activities. The seminar offers an in-depth look at personal information, and will be available to all Information Managers over the next year. Public authorities which participated in the first seminar were:
▪ Deputy Governor’s Office ▪ Government Information Services ▪ Ministry of Educations, Training & Employment ▪ Portfolio of Internal & External Affairs ▪ Public Service Pension Board
3. Staffing As at 30 June 2012 staffing of the ICO was as follows:
▪ Information Commissioner – Jennifer Dilbert, MBE JP ▪ Deputy Information Commissioner– Jan Liebaers ▪ Senior Appeals and Policy Analyst – Vacant ▪ Appeals and Compliance Analyst – Clara Smith ▪ Operations Administrator / Registrar of Hearings – Nadira Lord ▪ Administrative and Finance Manager – Christina Smith
The post of Senior Appeals and Policy Analyst remains vacant, as no funds were allocated for it in the 2012/13 financial budget. There are also no funds available to bring current salaries up to the minimum level recommended in the ICO Compensation Review carried out by Deloitte.
2012/2013 First Quarter Report July – September 2012 3
4. Finances A financial report for this quarter is attached at Appendix I. The audit of the financial statements for the 2011/12 financial year is underway and due to be completed by the end of October as required. 5. Data Protection Public consultation on the draft Data Protection Bill commenced on 3 September, with a closing date for feedback of 2 November 2012. The Deputy Information Commissioner continued to participate in the activities of the Data Protection Working Group, and took part in presentations on the draft Bill to the Constitution Commission and the Chamber of Commerce, with more presentation scheduled before the end of the consultation period. Although requested, the ICO did not receive any additional resources in the 2012-13 budget for consultation on, or implementation of the anticipated Data Protection legislation.
RESPONSIBILITY A:
HEAR, INVESTIGATE AND RULE ON APPEALS FILED UNDER THE LAW A.1 Development of Policies & Procedures The ICO notes a worrying trend of increasing response times on the part of public authorities, and also the length of time that some appeals are taking to be investigated, resolved, and/or heard by the Commissioner. These delays are caused by a number of factors including public authorities’ failure to properly identify and examine responsive records, involvement of legal counsel late in the process, and non- or delayed responsiveness to both applicants and the ICO resulting in non-adherence to agreed timetables for investigation and hearing. The ICO is considering what changes are necessary to existing procedures in order to deal with these issues. Since inception of the Office, the ICO’s internal guidelines have continually been under review and amendment as the need occurs. Due in part to the decreasing resources of the Office, and in part to the type, complexity and volume of appeals being received, the ICO’s internal policies and procedures covering intake, investigation and hearing of appeals are currently being updated. The ICO welcomes input from those involved in the appeals process to ensure that the process remains effective, user-friendly and fair to all parties. Once the update has been completed public authorities and applicants involved in appeals will be provided with these new policies and guidelines as necessary.
2012/2013 First Quarter Report July – September 2012 4
A.2 Investigation of Appeals As a matter of policy, the ICO seeks to resolve appeals informally at the investigation stage. In view of the limited resources available to the Office, this course of action has significant benefits in terms of efficiency and effectiveness, as many appeals can be successfully resolved without involving a formal hearing before the Information Commissioner. During the period 1 July to 30 September 2012, 1 new appeal was opened, 4 were closed, and 2 moved to a formal hearing before the Commissioner. As at end September there were 5 pre-hearing investigations in progress. The following is a summary of the 4 closed appeals.
• 01012 General Registry
An applicant requested records on a local company. During the pre-hearing investigation the public authority clarified that the company had been struck off the register of companies, and that all the relevant records were destroyed in 2006 under the authority of section 159 of the Companies Law. As no responsive record was held, the appeal was closed, but the matter was referred for further investigation under section 44 of the FOI Law.
• 01312 Ministry Finance, Tourism and Development (Financial Services) An applicant requested records in relation to the hiring of the Director of the Cayman Islands Representative Office in London. During the ICO’s investigation of the appeal, the public authority released some records while redacting other information. The applicant failed to communicate further with ICO and the appeal was closed administratively.
• 01412 Customs Department An Applicant requested a listing of all recipients of an import duty waiver during a particular period of time, including details of the goods and their value, which was disclosed in part. During the appeal, the public authority contacted all listed individuals in accordance with the requirements of the FOI Regulations regarding third party personal information. Following this, Customs Department made further information available to the applicant, while continuing to protect certain appropriate information. The applicant indicated satisfaction with this outcome and the appeal was closed.
• 01912 Governor’s Office
An applicant requested information from the Governor’s Office about a police matter. Records were not provided and the applicant appealed the matter to the ICO. In the course of the appeal the two parties discussed the matter and the applicant withdrew the appeal indicating their satisfaction with the response.
The ICO continues to receive a growing number of requests from members of the public to assist with various FOI-related issues. Over the quarter 18 such requests were received, many of which involved several meetings or communications. These requests do not fall within the
2012/2013 First Quarter Report July – September 2012 5
category of an “appeal“ under the Law, and can range from helping an applicant to formulate a freedom of information request to informing an applicant of their rights under the Law. Given the amount of time spent by staff on these requests, the ICO will consider whether the budget output measures should be adapted to reflect this activity. ICO appeal statistics can be found at Appendix II. A.3 Hearing of Appeals Hearings Commenced Three Hearings commenced during this reporting period:
• Hearing 23 – 00512 National Pensions Office • Hearing 25 – 00812 Port Authority of the Cayman Islands • Hearing 26 – 00312 Office of the Auditor General
Hearing Decisions Issued
• Decision: Hearing 21 – 01212 Portfolio of the Civil Service and The Office of the Deputy Governor 24 July 2012
The Portfolio of the Civil Service and the Office of the Deputy Governor withheld and partially withheld records relating to the recruitment exercise resulting in the appointments of three Chief Officers. The Information Commissioner upheld the decision of the Public Authorities to redact some information but required that some redacted information be disclosed. She also identified further responsive records and ordered their disclosure. She further found that the Portfolio of the Civil Service and the Office of the Deputy Governor were in contravention of the Freedom of Information Law with respect to the record keeping for the recruitment exercise for Chief Officers conducted in January 2012.
24 August 2012 This hearing required a preliminary decision, namely whether “Cabinet papers” which were requested by the Applicant but withheld by the Cabinet Office, are in fact “held” under section 2 of the Freedom of Information Law 2007. The Acting Information Commissioner considered this matter, and decided that “Cabinet papers” are “held” under the Law, and required that the Cabinet Office consider the records under the Law and submit a new submission for consideration.
Release of Responsive Records
• Decision: Hearing 21 – 01212 Portfolio of the Civil Service and The Office of the Deputy Governor Responsive records were released on 7 September, 2012.
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Judicial Review
No Judicial Review of any of the Commissioner’s Decisions has been sought to date.
RESPONSIBILITY B:
MONITOR AND REPORT ON THE COMPLIANCE BY PUBLIC AUTHORITIES WITH THEIR OBLIGATIONS UNDER FREEDOM OF INFORMATION LEGISLATION B.1 Compliance Reports Being the end of the financial year, a full statistical analysis was conducted as at end June 2012, which is included in this report at Appendix III. As customary, compliance reports which provide details of requests made under the FOI Law from July through September 2012 will be recorded, analysed and included in next quarter’s report. B.2 Investigations Section 44 Investigations
• Investigation 11 was commenced but suspended as the related appeal went to a hearing before the Commissioner.
• Investigation 12 was undertaken in response to the destruction of records by the
General Registry in 2006. This investigation was not completed before the end of the quarter.
Own-initiative investigations
• Own Initiative Investigation 5 - Website Re-evaluation has not been completed as planned due to the pressures of a large number of appeals and complex investigations and hearings.
B.3 Publication Schemes The ICO continues to encourage public authorities to keep their publication schemes up to date and in the standard format that can be published at the end of the year. Public authorities are also reminded to use their websites to provide the required information on FOI to the public.
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RESPONSIBILITY C:
MAKE RECOMMENDATIONS FOR REFORM BOTH OF A GENERAL NATURE AND DIRECTED AT SPECIFIC PUBLIC AUTHORITIES
C.1 Legislative Reform Section 58 of the Freedom of Information Law, 2007 stipulates that the Law must be reviewed from time to time by a Committee of the Legislative Assembly, created especially for that purpose. A Committee of the whole Legislative Assembly, created on 30 June 2010 to review the FOI Law, has met and formed a law Review Sub-Committee, chaired by the Attorney General. The Information Commissioner’s recommendations for the Law Review were submitted to this Committee in September 2010, and a position paper on the subject of and anonymity and fees was sent to the FOI Law Review Committee in January, 2011. These Reports can be found in the ICO website’s document library www.INFOCOMM.ky. The report of the Law Review Committee has been submitted to the Committee of the whole House, which has not yet convened to consider the report. RESPONSIBILITY D:
REFER TO THE APPROPRIATE AUTHORITIES CASES WHERE IT APPEARS THAT A CRIMINAL OFFENCE HAS BEEN COMMITTED While Commissioner continues to hope that her duties under this section will rarely present, unfortunately on at least two occasions, it appears as if a public authority may have failed to identify and provide records responsive to a request. The Commissioner reminds public authorities of section 55 of the FOI Law which states:
55. (1) A person commits an offence, if in relation to a record to which a right of access is conferred under this Law, he-
(a) alters or defaces; (b) blocks or erases; (c) destroys; or (d) conceals,
the record with the intention of preventing its disclosure. (2) A person who commits an offence under subsection (1) is liable on
summary conviction to a fine of one hundred thousand dollars or to imprisonment for a term not exceeding six months or to both such fine and imprisonment.
In addition, section 43(3) of the FOI Law states that in her decision on any appeal, the Commissioner may –
(c) in cases of egregious or wilful failures to comply with an obligation under this Law, refer the matter to the appropriate disciplinary authority.
The Commissioner will not hesitate to enforce these sections of the Law where necessary.
2012/2013 First Quarter Report July – September 2012 8
RESPONSIBILITY E:
PUBLICISE THE REQUIREMENTS OF THE LAW AND THE RIGHTS OF INDIVIDUALS UNDER IT E.1 Outreach & Promotion Right to Know Week 2012 took place in September, as a result a large number of promotional and educational activities were carried out this quarter.
July - September 2012 Educating
Information Manager Training 1 Presentations on Data Protection 2 Communicating Press releases 5 Newspaper & online adverts 7
Internet & Web Presence 2
Articles in the local media 20
Printed Matter distribution outlets 4
Radio & Television Appearances 3
Publishing ICON newsletters published 2
RTK Flyers 1
RTK Posters 4
FOI Banner 1
RTK Community Calendar 2
Reports Published 1 Monitoring Training 4 Compliance Reports 1 Hearings 2 Law Review 1 Total 63
E.2 Right to know Week 2012 Although branded Right to Know Week 2012, the ICO’s programme of activities around Right to Know Day on 28 September spanned the period 12 September to 6 October 2012. By all accounts RTK 2012 was very successful, reaching a wide audience with this year’s message of “It’s Yours...Just Ask!”. The Project Report is attached at Appendix IV.
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E.3 ICO Website and Social Media ICO staff is now able to upload some contact to the website, resulting in more timely updates, but some restrictions still apply. The public is invited to give any feedback on the website or experiences by emailing the ICO on [email protected]. Additionally, to subscribe to receive the ICO quarterly Newsletter ICON, Reports of the ICO, Hearing Decisions or Investigation Reports please email [email protected]. The ICO Facebook page http://www.facebook.com/ICO.CaymanIslands has been revived and consistently maintained. The page is currently connected to over 230 people and can be viewed by any member of the public worldwide without them having to be a member of Facebook. The impact remains positive and user statistics report that each post typically receives 40-50 individual views. The highest viewed post to date was on Right to Know day 2012 which registered 86 individual views. The ICO will continue to use this tool as an inexpensive means of outreach to the public.
Jennifer Dilbert Information Commissioner Cayman Islands 31 October 2012
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APPENDIX I
July – September 2012 Financial Report
*This figure represents most of the costs associated with the financial audit for the year 2011/2012. .
Description
Annual Budget
2012/2013
Jul - Sep 2012
Budgeted (KYD $)
Jul – Sep 2012
Actual (KYD $)
Staffing includes: salary, healthcare and pension contributions
455,518.00 113,873.50
103,152.61
Accommodation includes: rent, rates and services, janitorial, security and depreciation
86,726.00 21,681.50
15,997.44
Office Supplies, Printing and Stationery
10,404.00 2,601.00
2,615.33
Information Technology and Telecommunications
7,980.00 1,995.25
1,509.17
Specialist assistance, Legal Fees and Financial Charges
25,000.00 6,250.00
22,516.49*
TOTAL
585,628.00
146,407.00
145,791.04
2012/2013 First Quarter Report July – September 2012 11
APPENDIX II
The Information Commissioner’s Office Quarterly Appeal Statistics:
1 July 2011 – 30 September 2011
Files opened 1
Files closed (Being opened this quarter) 1
Files closed (Being opened in previous quarters) 5
Files successfully mediated 1
Files referred back to Public Authority/ No Further Action 0
Files in active mediation (At the end of the quarter) 5
Appeal files Re-Opened 0
Files sent to hearing before the Commissioner 2
Files in hearing before the Commissioner (At the end of the quarter) 5
Hearing Decisions issued by Commissioner 2
Investigation Decisions issued by Commissioner 0
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APPENDIX III
Freedom of Information Statistics
Jan Liebaers MA CA LLM
Deputy Information Commissioner
September 2012
2012/2013 First Quarter Report July – September 2012 13
1. METHODOLOGY
The ICO believes that the impact of the FOI Law over the last three and a half years has been significant. The statistics in this report only tell part of that story. The overall amount of information provided to the general public since 2009 is much greater than before the Law came into effect, and not only in response to formal requests under the Law. Public authorities are increasingly disclosing information in a proactive (and therefore far more efficient) manner, and are also providing more information upon request outside of the FOI law. The statistics in this report are based on data entered into the central FOI tracking system (JADE) by Information Managers (IMs) across Government, The tracking system is maintained by the FOI Unit of the Cabinet Office, and the Information Commissioner’s Office (ICO) is grateful to the FOI Unit for providing the raw data for this report. The statistics in this report are only as good as the data on which they are based. The ICO is aware of anecdotal evidence that suggests that not all requests for information are entered into the system, and that the available data are not completely reliable. This is particularly the case where:
- The IM responds to a request outside of the FOI Law, as allowed under certain circumstances;
- A request is dealt with as an FOI request, but is not logged. This issue has not yet been thoroughly investigated by the ICO, in part due to the limited access the ICO has to the tracking system despite a statutory mandate to monitor compliance;
- Subsequent actions following the initial request are not always logged into the system, or are not logged on time. This is the case with internal reviews conducted by Chief Officers, and appeals to the Information Commissioner.
Given these shortcomings, it is likely that the data in this report are somewhat skewed, in that:
- Most likely the actual numbers of requests are higher than the reported numbers;
- Most likely the response times for initial decisions are marginally better than reported, since internal reviews, appeals and late data entry may artificially lengthen the reported time periods.
Notwithstanding these issues, the statistics in this report demonstrate some interesting trends and facts.
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2. TABLES (January 2009 – June 2011)
Table 1 – FOI requests per quarter (2009-2012)
Following an initial spike shortly after the FOI Law came into effect in 2009, the number of requests received by Government has oscillated between 100 and 200 per quarter. The overall trend is slightly downward. By the end of June 2012 2,318 applications had been made under the Law.
The ICO does not have detailed access to the data in the tracking system, including the names of the requestors, but in any event there is no way of knowing who the most frequent users of the Law are. Anecdotal evidence suggests that the Law is popular – amongst other things - for:
• Applying for one’s own personal information; • Inquiring about public authorities’ expenditures, recruitment processes, statistics
and minutes. Table 2 - Spread of FOI requests across public authorities (2009-2012)
The top 20 of 92 public authorities (22%) received 72% of total requests since January 2009. Of these, most requests were received by Immigration Department, the RCIPS, the Ministry of Finance, Tourism and Development, the Portfolio of Legal Affairs and the Health Services Authority.
Note: for the purposes of this table only, ministries and portfolios include their predecessors (January – May 2009) as well as their constituent parts, e.g. the Portfolio of
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Legal Affairs includes the Office of the Director of Public Prosecutions, but they do not include subordinate departments that have a separate Information Manager.
Table 3 – Requests received per quarter (2009-2012)
Only 22 public authorities received 25 or more requests since the FOI Law came into effect (i.e. fewer than 2 per quarter). There are still some public authorities that have not entered a single FOI request into the tracking system.
Tables 4a and b – Average response times (2009-2012)
The FOI Law requires an initial decision within 30 calendar days. Only about three in five applications made between 2009 to 2012 meet this standard.
Since 2009 there is a worrying trend towards longer and longer response times. This can only in small part be explained by the increasing number of internal reviews and appeals.
22%
35%
36%
7% More than 25 requests received
11-25 requests received
1-10 requests received
No requests received
4% 21%
37%
21%
18% Same day
1-10 days
11-30 days
31-60 days
more than 60 days
26.8
45.3 43.2
59.2
21.0
29.0
27.0 30.0
0 10 20 30 40 50 60 70
Mean average response
Median average response
2012/2013 First Quarter Report July – September 2012 16
Tables 5a, b and c - Resolution of FOI requests (2009-2012)
In responding to an FOI request, public authorities can grant access to the requested records in full or in part. They can also apply a number of exemptions, or other reasons for withholding the records. Between 2009 to 2012 about half of access requests were granted.
The proportion of requests granted in full or in part has gradually risen since 2009.
The proportion of requests granted in full or in part is larger when certain cases are discounted, i.e. requests for which no records were found, where records were already in the public domain, or where the request was administratively closed because it was a duplicate or was withdrawn by the applicant.
37%
13% 19%
1%
11%
3%
2% 1% 10% 2%
Granted in full
Granted in part
Exemption applied
Exclusion applied
No records found
Already in public domain
0% 20% 40% 60%
2011-2012
2010-2011
2009-2010
Jan-Jun 2009
39%
32%
40%
33%
16%
15%
11%
11%
Granted in full
Granted in part
0% 50% 100%
2011-2012
2010-2011
2009-2010
Jan-Jun 2009
49%
42%
53%
50%
20%
19%
14%
16%
26%
29%
21%
24%
5%
10%
12%
10%
Granted in full
Granted in part
Exemption applied
Otherwise withheld
2012/2013 First Quarter Report July – September 2012 17
Tables 6 – Breakdown of exemptions claimed (2009-2012)
Public authorities may apply one or more exemptions to requested records in order to withhold them from applicants. The most popular exemptions have remained the same since 2009.
Table 7 – Exceptions or exclusions claimed (2009-2012)
Besides exemptions, the FOI Law allows public authorities to use other reasons for withholding requested records. These are either exceptions (e.g. where a request is vexatious or unreasonably costly) or exclusions (where the FOI Law does not apply). Since 2009 exceptions and exclusions have been used in a handful of cases only.
36%
15% 13%
10%
8%
3% 3%
3% 2%
2% 5%
s.23 Personal information
s.16 Law enforcement
s.21 Commercial interests s.20 Effective conduct of public affairs s.17(a) Legal privilege
s.17(b)(i) Breach of confidence s.15 Security, defence or int. relations s.19 Deliberative process of Cabinet s.24 Health and safety
s.18 National economy
0 5
10 15 20 25 30 35 40 45 50
Already in the public domain
Vexatious
Unreasonable diversion of resources
2012/2013 First Quarter Report July – September 2012 18
Tables 8a and b – Appeals and hearings per quarter (2009-2012)
After an initial spike and drop-off in 2009, there has been a gradual increase in the number of appeals made to the Information Commissioner’s Office (ICO) per quarter. The number of formal hearings undertaken by the Information Commissioner has also seen a steady rise.
To date, the Information Commissioner has made 21 formal Hearing Decisions. The outcome of these is as follows:
Introduction The theme for the fourth annual Right to Know (RTK) Week held during September 2012 was It’s Yours...Just Ask. The purpose of this campaign, as in prior years was to educate the public about the Freedom of Information Law (FOI) and the role of the Information Commissioner’s Office (ICO), as per the requirements of the ICO set out in the law. Activities spanned the period 12 September to 6 October 2012. In keeping with the previous year’s RTK events, the ICO focused on making a large impact with limited resources and enlisted professional assistance from Government Information Services (GIS). 1. Staffing The ICO is currently operating with a staff compliment of five, one less than during the previous year’s RTK campaign in 2011 and also with a reduced promotional budget. This made it a challenge to deliver a creative, dynamic and interesting campaign to increase the public’s awareness of FOI whilst also maintaining a high level of service and managing an increased workload, with a record number of ongoing appeals including four hearings in progress before the Commissioner. Nonetheless, given the positive feedback the ICO has received and continues to receive from members of the public, the campaign was a successful undertaking. The entire ICO staff is to be commended for their efforts to produce a successful RTK campaign.
Right to Know Week 2012 – Project Report 2
2. Calendar of Events
The calendar of events was used internally by the ICO team. This captured events, activities, attendance/responsibility and ICO uniform. The final version appears below.
Right to Know Week 2012 – Project Report 3
3. Outreach Initiatives
A worship service, four meet & greets and a dress down day were held to provide an opportunity for outreach to the community to educate the public further about FOI and the work of the ICO.
- Worship Service - Market at Camana Bay - Coconut Festival, Market at the Grounds, Lower Valley - Health Services Authority - Government Administration Building & Dress Down Day
Future recommendations: • Continue to host public meet & greets at busy public places. • Host a meet & greet at a popular Cayman Brac supermarket or Faith Hospital
Church Service Three members of the ICO were warmly welcomed by Kings Seventh Day Adventist Church on Saturday 22 September. The scripture message and readings were complimentary to the spirit of openness and transparency. As the Minister stated, “…when truth is exposed it challenges corruption” and referring to Galations 4:16 he said, “I am not your enemy because I speak the truth”. Market at Camana Bay The attendance was disappointing due to inclement weather, however the team still managed to speak with 60-70 people and handed out ICO bags containing a brochure, pen, notepad and a copy of the ICO newsletter (ICON). Coconut Festival,Market at the Grounds, Lower Valley When the ICO approached the Agricultural Society to host a booth at a Saturday market during RTK, we were informed of a Coconut Festival to be held one week after RTK. They asked that we consider waiting and join forces to attract a wider audience and the ICO agreed. Due to inclement weather the Coconut Festival was postponed to Saturday 6 October. To promote the event the ICO distributed flyers, promoted on Facebook, issued CS Messages to the core Civil Service, mentioned the event during each radio opportunity, as did the organizers of the event who also had an article in the Caymanian Compass newspaper. On the spot feedback from members of the public was encouraging and it was a great opportunity for the Commissioner to meet with an estimated 150 people in a relaxed setting.
Right to Know Week 2012 – Project Report 4
Information Commissioner Mrs. Jennifer Dilbert with a member of the public at Market at the Grounds.
Appeals and Compliance Analyst Mrs. Clara Smith with a member of the public at Market at the Grounds.
Market at the Grounds, Coconut Festival flyer
Right to Know Week 2012 – Project Report 5
Health Services Authority The ICO held a well received Meet & Greet at the lobby of the HSA in cooperation with the HSA Information Manager. The ICO gratefully received a donation of fruit from Fosters Food Fair and handed out apples and oranges at this event which was hugely popular with visitors to the booth.
Le
Left: ICO team with Ms. Lizette Yearwood, HSA CEO and Sharaine Chin, Information Manager Right: Information Commissioner Mrs. Jennifer Dilbert and Deputy Commissioner Mr. Jan Liebaers with members of the public at the hospital. Government Administration Building & Dress Down Day A Meet & Greet was held in the lobby on Right to Know Day which was also earmarked as Dress Down Day for civil servants. The ICO promoted this with an ad which was designed by GIS and distributed via CS Messages. The initiative was open to the public as well and all were invited to wear blue in support of transparency. The impact of the booth, the ICO team and civil servants dressed in blue shirts was very impressive. The ICO team met with members of the public and assisted with FOI requests/queries on the spot.
Left: ICO team with His Excellency the Governor Mr. Duncan Taylor and Penny Knight Right: ICO team with the Deputy Governor Mr. Franz Manderson
Right to Know Week 2012 – Project Report 6
CS Message Dress Down Day ad
Post Office Displays In keeping with annual RTK campaigns, the ICO had variations of the different “It’s Yours…Just Ask!’ posters put in Post Offices around Grand Cayman and Cayman Brac.
4. Government Training
Training & Presentations
The Chief Officer presentation and Information Manager seminars were not held this year. Throughout the year prior to RTK week, the Commissioner met with most of the Chief Officers on an individual basis so it was deemed that another presentation would not be an effective use of time or resources.
IM Network Seminars Rather than hold a half day seminar to the larger IM population as in past years, it was decided to launch the second series of IM training seminars on Personal Information, with the first one taking place during RTK week on 27 September. IMs from eight public authorities were invited to attend a small group seminar at the ICO, of those five attended.
Future recommendations: • Promote the 3rd series of IM training sessions during RTK week and launch the
actual seminar shortly thereafter.
Right to Know Week 2012 – Project Report 7
Information Manager Tips Information Managers were sent an email each day throughout RTK week with useful information regarding FOI and the handling of FOI requests.
5. Promotional Materials
The ICO continues to receive positive feedback from members of the public regarding existing promotional items – ICO branded bags, folders, pens and notepads. The existing stock of folders, pens and notepads purchased in 2011 was used during September 2012 and 300 additional bags were purchased for use during the remainder of this fiscal year. Of these, 200 were distributed during RTK Week.
In order to increase visibility and further improve brand recognition, the ICO selected two new promotional items – lanyards and sunshades, which were at an affordable price point and will have high visibility. The lanyards were purchased for distribution to the general public. The sunshades were purchased in limited supply and are intended primarily for distribution to Information Managers.
This year the ICO purchased two banners for use in Cayman Brac which read, “Brackers have the right to know.” The layout and design was furnished by GIS and these were placed in high visibility areas in Cayman Brac with the assistance of the local Information Managers.
Four posters were designed in conjunction with GIS and all were printed in-house at the ICO.
Future recommendations: • Complete orders for promotional items in May 2013 to avoid delays. • Offer new items which are attention grabbers and items which may appeal to
school children (crayons, seeds, flashlights etc.) ICO Grocery Bags The ICO reprinted 300 of the same grocery bags that were designed in-house for RTK 2010. Posters In conjunction with the ICO, GIS produced 3 new posters and updated 1 past RTK poster. These were printed in-house. The ICO was exceptionally pleased with the designs and final result which included combining the ICO and RTK logos. Of particular note is the poster featuring the children and grandchildren of ICO staff representing the future of Cayman, and the poster with members of the public and their candid comments on freedom of information.
Right to Know Week 2012 – Project Report 8
Right to Know Week 2012 – Project Report 9
Pay Stub Footer All government pay stubs distributed on 21 & 25 September contained a special RTK full colour message.
Banners Two new banners were designed by GIS for placement in Cayman Brac year round.
Lanyards Lanyards were purchased as giveaways to the general public. Car Sunshades ICO car sunshades were purchased as high end giveaway for the Information Managers who attend the IM Seminars this year.
Right to Know Week 2012 – Project Report 10
6. Media Presence
This year the ICO enlisted the professional services of GIS to design and implement a more modern, vibrant and from all accounts a well received media campaign. This incorporated a fresh take on a new GIS Spotlight video which aired twice, a 60 second public service announcement, a radio advertisement, a web banner, design and layout of 4 posters and assistance with writing newspaper articles.
Newspaper – Print and Online The ICO purchased quarter page ad space in the Caymanian Compass newspaper for five days, and Cayman Free Press generously donated article space on each of those days. They also included, at no cost to the ICO, a link on the main page of their website www.caymancompass.com to the Right to Know Week page on the ICO website www.infocomm.ky and a complimentary thank you message the week following. Cayman News Service kindly donated a rolling advert on their website www.caymannewsservice.com which also linked directly to the RTK page on the ICO website.
Television This year the ICO did not appear on Daybreak, the local daily morning show as there whilst two attempts were made, both failed due to technical failure at the Cayman 27 news studio.
Radio The ICO had a more impactful radio presence this year with the significant airplay of the new radio advert on Radio Cayman. The Commissioner also made well received radio appearances on Radio Cayman’s Talk Today programme and Vibe FM.
Future recommendations: • Develop a scripted instructional video which could be reused by editing RTK specific
information. • Hold a Media Day at the ICO as feedback from the press suggests individual
interviews with the Commissioner is preferred. • Reduce the number of days for paid advertisements in newspapers and increase use
of online media exposure. Press Conference A press conference was held to discuss RTK and the Statistical Report written by Deputy Commissioner Mr. Jan Leibaers.
A concerted effort was made to make more effective use of the ICO website www.infocomm.ky during this year’s campaign. The RTK banner was placed on the homepage in the month leading up to RTK week and when clicked on led the user to a dedicated RTK page.
The RTK page was updated throughout the week with posters and articles as well as a calendar of events.
The Information Commissioners International (ICIC) website http://info-commissioners.org/ was also updated throughout the week with content from the Cayman Islands.
Better use was also made of the ICO Facebook page to promote RTK events including the civil service dress down day.
Future recommendations: • Improve the design and layout of the RTK page and leave the information on the
ICO website throughout the year as articles and information are quite relevant and useful.
• Create a Facebook ad at minimal cost to promote RTK and increase readership.
8. Outputs & Expenses
The amount spent on advertising, promotion and products for use throughout the year including RTK Week 2012 totaled $6808.00. This is $3904.23 less than in 2011.
As in past years a significant portion of the cost relates to general branding and year round promotional products that are not specific to the RTK campaign. With these taken out of consideration, the costs specific to RTK 2012 totalled $2235.00. This is a third of the amount spent specific to RTK in 2011 ($6,712.85).
1/4 page full colour x 5 Donated Daily, 24-28 September
Online link to ICO website Donated Daily, 24-28 September
Thank You ad Donated 9 October
News Articles 220.00 Daily, 24-28 September $2200.00
Total Caymanian Compass $2200.00
Cayman News Service
Online sidebar ad Donated Daily, 16-29 September
Total Cayman News Service $0.00
Total Advertising $2200.00 PROMOTIONS
Printing Number Description Total ICO Posters Printing posters in-house
ICO Market Flyer Printing flyers in-house
Total Flyer Printing $0.00 Promotional Products Number Description Total Brac canvas banners 2 ICO logo and design (to be used year round) $354.90 ICO Grocery Bags 300 For general distribution and branding $885.00 ICO Lanyards 1000 For general distribution at meet & greet events $2350.001 ICO Sunshades 100 For IM gift at network meetings $782.001 ICO Shirts 1pp 5 For ICO branding and recognition $202.00 Total Promotional Products $4,573.90 ICO Costs & Consumables for IM Presentation and Meet & Greet Events Subway Sandwiches and cookies $25.002 Kirks Supermarket Tea, Juice & Water $10.002 Fosters Donated 200 Oranges & Apples $0.00 Total ICO RTK Presentations $35.00
Total Promotions $4,573.00
TOTAL EXPENSES $6,808.00 1These amounts do not include freight, insurance & duty for these products, which will need to be billed out at a later date; paid vendor for purchase of supplies only – June 2012 Items highlighted are to be paid for from 12-13 budget
