We asked subsequent requests of the FSA- both relating to their role within the CHaIRS group and concerning the publication of minutes on the FSA website (which we had directly influenced being put there. There were also issues of redacted material, whilst also seeking to find out if there was any new information contained in these minutes with reference to Rattlechain.
WHAT DID WE ASK?
“I am seeking clarification on whether the CHaIRS group, to which the FSA provided secretarial support as a member, met on October 16th 2011, the minutes of which have yet to be published on the FSA website.
On 30th September last, John Caseley of the FSA stated in an email following a request for minutes of CHaIRS meetings that “it is intended that all future agendas and minutes of meetings re- CHaIRS will be placed on the website”
Can you clarify if the minutes of this and other subsequent meetings have been finalised and when these will be placed on the website?
I can confirm that the ~ meeting was held on 06 October and that the minutes of the meeting were agreed by CHaIR’s members at the 11th meeting on 05 December 2012. Whilst it is our intention that all minutes of CHaIR’s meetings are published on the FSA’s website, I am afraid that due to an administrative oversight these had not been published on the FSA website.
We are grateful to you for bringing this to our attention and will endeavour to ensure that in future the final minutes of meetings are published promptly after they have been agreed. The final minutes of the lO~’~ Meeting of the CHaIR’s Group are now available on the PSA’s website at:
The minutes of the 11th CHaIRS meeting will be finalised at the next meeting of CHaIRS which is scheduled for the end of April I beginning of May and will be published on the website shortly afterwards.”
These minutes appeared on the FSA website October 6th 2011 CHaIRS MEETING 10
We were concerned about one aspect within the minutes.
Could I clarify the following point based upon the now published CHaIRS minutes on the FSA website Under wildlife poisoning it is stated;
“Another member agreed that sensitive information should not be widely circulated. One member commented that, when handling information, there was a responsibility on the owner of the data to ensure the information was handled appropriately. This may mean
marking it clearly as ‘restricted’ or ‘sensitive’ (not for further dissemination). Another member agreed, but also pointed out that marking something ‘restricted’ meant that not all members could be emailed the information, as not everyone was on the GSI network.”
Does this mean that any incidents minuted will be shown as “redacted” when they appear on the FSA website under CHaIRS minutes, or that they will not be minuted at all?
“The section of the minutes you refer to relates to concerns that information relating to an ongoing incident investigation had been circulated without the correct security markings. As you will appreciate, in some instances incident investigations may lead to legal proceedings and the release of information relating to an ongoing incident could be detrimental to a successful prosecution. In such instances the information obtained will also be classified as ‘commercial in confidence’ or may relate to individual’s personal data (i.e. names and addresses) and as such it would be inappropriate for this information to be published and may indeed contravene the law (e.g. the Data Protection Act).’
The majority of incidents discussed at CHaIRS have already concluded, however, if it is felt that the publication of information relating to an ongoing investigation could jeopardise the outcome in any way, then this information would be redacted accordingly. I hope this clarifies matters.”
I am seeking some clarification concerning information relating to the due process of redaction of material, which presumably is recorded in a group protocol format.
“The majority of incidents discussed at CHaIRS have already concluded, however, if it is felt that the publication of information relating to an ongoing investigation could jeopardise
the outcome in any way, then this information would be redacted accordingly. I hope this clarifies matters.”
Can you confirm that it is The Chairman of CHaIRS who decides on the redaction, a consensus view amongst all members or a veto is in place for one member to ask for redaction? If the latter is the case will that member and their reason for asking for redaction be minuted?
In terms of how the information appears on the FSA website under CHaIRS minutes,will the minutes ONLY be published when ALL information within the minutes has been deemed to be concluded, which could prolong their publication considerably?
If minutes not including redacted material are published, will redaction be highlighted by blanking out the relevant sections deemed to be subject to potential future prosecutions, and this stated clearly in the minutes, or will these matters simply not be published and therefore not seen on the published minutes on the website?
When investigations have been deemed to be concluded, will the redacted minutes, either blanked out or not including the sections omitted be revisted to update the original redacted material, or will the issues be minuted only in the minutes after they have
deemed to have been concluded?”
“In accordance with our standard operating procedures, the CHaIRS Secretariat drafts a note of each meeting. The Secretariat then asks for the draft to be commented on by members and the Chair before being confirmed as an accurate record of the meeting at the next meeting.
Prior to the note being placed on the FSA website, all members are consulted on whether any elements of the note relating to ongoing incidents need to be redacted. Information may be redacted, if for example the information is commercial in confidence and/or its disclosure in the media may prejudice an ongoing investigation, potentially resulting in the breakdown of a prosecution. Therefore, in answer to your specific question, the decision to redact information is taken by the group as a whole, following recommendations from the Secretariat.
If it is agreed to redact details relating to an incident investigation from the note of the meeting, this will in future be clearly indicated in the published note. I can confirm that there are no plans to revisit notes of meetings to re-introduce redacted material.
Finally, in answer to your question regarding whether the minutes are only published when all the information referred to is deemed to be concluded, I can confirm that this is not the case, although, as stated previously, the status of the incident(s) being discussed will have a bearing on what information is disclosed within the published minutes.”
WHAT DOES THIS MEAN?
Our questions revealed information which was not straightforward as recorded in the original versions of the published minutes. This has helped to flesh out the protocols involving multiple agencies meeting together, whereby the public may not get to know the whole sum of the parts that made it.
Redacting information and not making it public could only serve the interests of the business community and not the public.