First council compliance review – What can we learn?
The first compliance review of a local government, Rockhampton Regional Council (RRC), was reported to Parliament on 6 May 2014. The review against the RTI and IP Act obligations identified one issue that is likely to be relevant for all other local governments – the importance of all business units communicating well with individuals seeking information – to be promoted by the adoption of an agency-wide communication strategy and through training for all staff.
In short, RRC had good information management practices: releasing information proactively, while also being mindful of the need to protect personal information. In particular, the website was easy to use and information rich. Governance structures, policies and practices for information management within RRC were clear and effective, with projects under way to make further good use of new technologies for information release and re-use. The policy, procedure and framework for community engagement was so useful and easy to follow that the Community Engagement Matrix was considered an example of good practice, and was appended to the report as a resource for others. Interactions and information exchanges with industry and community service organisations were positive. RRC was generally compliant with the requirements of the RTI Act and IP Act. A review of a sample of files found the application handling process to be compliant with the legislation.
OIC identified one key issue that required attention, which RRC has agreed to address. During the public consultation OIC found a number of private individuals expressed disappointment, frustration and anger towards RRC regarding their information request and the level of service provided to them. RRC also had a relatively higher rate of applications for review of RTI and IP Act decision making. However, not all the comments received related to applications for information made under the RTI Act or IP Act. Some comments related to individuals’ experiences more generally in trying to obtain information from RRC. OIC considered that this highlighted one aspect of RRC’s operations that might have contributed to the reported negative client experience – the need to ensure that all sections within RRC understood and met their responsibilities when communicating with individuals seeking information.
For example, in general, when an individual seeks information from an agency, they might start by approaching a customer service centre and/or the relevant business unit. If an individual has a positive client experience during the initial request, they may be satisfied with the result, whether or not they obtained all of the information they were seeking. In this scenario, an individual receiving clear and accurate information might be satisfied sufficiently to resolve the matter and avoid escalation to a formal application under the RTI or IP Acts. The converse is also true. OIC’s experience is that individuals who have a negative client experience can lose trust with the agency, become adversarial and continue to pursue the matter, even if they have received as much or even more information than they asked for.
To address this general, agency-wide service delivery issue, OIC recommended that RRC develop and implement a communication strategy applicable to all information requests. OIC further recommended that the communication strategy be supported with training and awareness for all staff.
OIC recommended that the communication strategy address these issues:
- all business units have a role in dealing proactively with clients, encouraging co operative interactions and dealing with requests for information administratively to the greatest extent possible
- within the context of communicating effectively with clients, all business units need to understand their role in recognising and responding to right to information and information privacy issues, including potential applications, but also other right to information issues, for example releasing information administratively and publishing significant, appropriate and accurate material to the publication scheme
- all business units need to be agile in matching service delivery to individual client needs, for example, managers need to quickly identify when an interaction is deteriorating, for whatever reason, and to respond appropriately
- tailoring communications to individuals includes providing a heightened level of communication to some individuals early, ensuring that these individuals have access to a person of sufficient seniority and with delegated authority to negotiate on behalf of the agency as a whole, to communicate in such a way so as to improve the client’s experience and resolve matters as efficiently as possible; and
- where an individual’s information needs involve multiple business units, procedures are needed to ensure that the response is correct and consistent from an agency wide perspective.
This approach is aimed at streamlining the processing of some requests for information, reducing workload associated with applications by preventing escalation of issues, reducing the likelihood of any workload associated with any consequential adversarial activities and improving service delivery by the agency and the service experience of the agency’s clients.
With this issue and other minor improvement opportunities addressed, OIC would consider that the RRC to be a benchmark of good practice in information management for right to information and information privacy.