FOI Request - Review of 101003811464 LFR Series Returns

Request 101003826844

Review of 101003811464 LFR Series Returns

I am writing to request an internal review of Moray Council’s response to my Freedom of Information request dated 25 June 2025, reference 101003811464, concerning the Council’s Local Financial Return (LFR) submission and reconciliation process for the year 2023/24.

While I appreciate the summary spreadsheet that was provided and the link to the Scottish Government’s published LFR, the response falls short in several key areas, and I am therefore requesting a review of the Council’s decision and a reassessment of the information held. My grounds are outlined below.

1. Internal Mapping and Reconciliation Documentation (Questions 2 and 3)

The Council has not provided any internal mapping, allocation logic, or procedural documentation that links cost centres, subjective codes, or departments to the published LFR categories. Many other councils have supplied:

Code hierarchies or mapping tables

Step-by-step procedural notes used in compiling the LFR

Working papers or Excel files showing adjustments, service allocations, or reconciliations from general ledger to LFR

Your response indicates that the ledger is structured to follow the LFRs, but no evidence has been provided to support this. If such documentation is not held, that should be clearly stated under Section 17 of FOISA. If it is held but not disclosed, I request a justification and a reconsideration of its release.

2. Correspondence or Validation Feedback (Question 4)

The Council has stated that no correspondence exists "other than final acceptance of the submission." However, many local authorities receive validation queries or feedback emails from the Scottish Government during the return process. These include:

Queries regarding anomalies or flagged inconsistencies

Requests for clarification or amendments

Confirmation or formal sign-off messages

Please confirm whether such communications were received and provide copies where held.

3. FOISA Section 15 – Duty to Advise and Assist

I also raise concern that the Council has not fulfilled its duty under Section 15 to advise and assist. For example:

You could have indicated whether internal reconciliations exist in extractable form

You might have offered clarification or redaction options for partially linked files

There was no suggestion of a phone call or partial disclosure option, which several other councils offered proactively

I ask that the Council reviews its approach in line with its statutory duty to support public access to financial decision-making.

Public Interest Rationale