FOI Request - Review of 101003973033 GIS / Spatial / Gazetteer Roles

Request 101003993521

Review of 101003973033 GIS / Spatial / Gazetteer Roles

Thank you for your response to my request.

I write to request an internal review of the decision to withhold information under Sections 38(1)(b) (personal data) and 30(c) (effective conduct of public affairs) of FOISA
While I am grateful for the information provided, I do not consider that the exemptions have been appropriately applied in this case.
1. Section 38(1)(b) – Personal Data
The response states that disclosure of job evaluation scores or related information could lead to the identification of an individual's specific grade and salary placement, which constitutes third-party personal data.
I do not consider this position to be justified.
The information requested relates to posts, not individuals. The evaluation score of a role, along with its grade and salary band (the latter two elements having already been disclosed in the Council’s response) are structural attributes of roles within an organisation and do not, in themselves, identify any individual or disclose specific personal financial information. This is particularly relevant in the context of local government, where:
• Grades and salary bands are routinely published in job advertisements;
• Many councils have previously published job titles and grades in response to FOI requests, including Moray Council in early 2023;
• The information requested does not include names, specific salaries of individuals, or any directly identifying information.
In this context, it is not clear how disclosure of a job evaluation score would result in any meaningful identification of an individual, or how such disclosure would be unfair or unlawful under the data protection principles.
If the exemption is maintained, I would be grateful for a fuller explanation of:
• how identifiability has been assessed in this case; and
• how disclosure would contravene the data protection principles, particularly in light of prior disclosure and the routine publication of such information.

2. Section 30(c) – Effective Conduct of Public Affairs (JODs, FLLs and Evaluation Outputs)
The response withholds Job Overview Documents (JODs), Factor Level Listings (FLLs), and related evaluation outputs on the basis that disclosure would undermine the integrity of the COSLA Scottish Joint Council (SJC) Job Evaluation Scheme.
I would be grateful if this could be reconsidered.
JODs and FLLs are job-specific evaluation outputs describing the demands of a role. They are materially analogous to a role profile or person specification and therefore relate to the post rather than any individual.
Section 30(c) requires a real and likely risk of substantial prejudice to the effective conduct of public affairs. The reasoning provided does not demonstrate that this threshold is met.
 

In particular:
• The suggestion that disclosure may lead to challenge or scrutiny does not constitute substantial prejudice; rather, it is a normal and legitimate consequence of transparency in public administration;
• No evidence has been provided to demonstrate how disclosure of job evaluation outputs (JODs, FLLs or equivalent outputs) would undermine the operation of the Council’s job evaluation arrangements in practice;
• The assertion that disclosure "could lead to a volume of speculative challenges that would disrupt the Council’s ability to maintain a consistent and fair job evaluation process" is not supported by the structure of the SJC scheme, which requires evaluation and re-evaluation of roles to pass a threshold test. For example, re-evaluation of a role requires job-content to be a substantive change over a prolonged period of time, evidenced, verified or qualified by line management and head of service, and assessed against defined factor criteria as part of a structured process. It is a structured and evidence-based process with defined procedural safeguards, and is not susceptible to speculative or unsupported challenge on a systemic or widespread basis.

Furthermore, disclosure of evaluation outputs for a post does not alter internal relativities between posts within an authority, and therefore does not prejudice the Council’s ability to apply the scheme internally. The focus of my request is job content and benchamarking of GIS and related roles, not on the Council’s internal processes for managing job evaluation, associated appeals or maintaining grading structures. In that context, the suggestion that disclosure would undermine internal administration is not directly relevant to the information requested. 

3. Consistency with the SJC Job Evaluation Scheme 

The position taken in the response appears inconsistent with the principles underpinning the SJC Job Evaluation Scheme. 

The Scheme emphasises that job evaluation should:

 • evaluate jobs, not individuals; 

• be based on agreed and verified job facts; and

 • operate in a manner that is inclusive, open and transparent. The SJC guidance (2024) states that job evaluation gains acceptance and credibility when it is “inclusive, open and transparent". JODs form part of the evidential basis of evaluation and are intended to reflect the agreed demands of a role. In that context, it is not clear how disclosure of such documents would undermine the integrity of the scheme, particularly where they relate to posts rather than individuals. 

4. Completeness of the Response 

Separately, I would be grateful if the review could confirm the completeness of the response. I note references in publicly available National Planning Improvement Framework documentation to: “a highly integrated GIS mapping system supported by the Systems Support team within Economic Growth & Development” I would therefore be grateful if the review could confirm whether the roles identified correspond to the Systems Support team referenced above, and whether any relevant roles were excluded, and if so, the reasons for this. B

By way of context, I have submitted similar requests to a number of Scottish local authorities as part of a benchmarking exercise of similar roles. In most cases, the information requested has been disclosed without reliance on the exemptions cited. For the reasons set out above, I respectfully request that the Council: • reconsider the application of Sections 38(1)(b) and 30(c); • disclose the requested information where possible; and • provides further clarification where exemptions are maintained. I look forward to your response.