Freedom of Information Publication Scheme - SimplyTeeth Essex

Freedom of Information Publication Scheme

The Freedom of Information Act 2000 aims to promote a culture of openness and accountability amongst public authorities (in this case dentists who provide NHS treatment) by providing
people with rights of access to information held by them.
▪ Every dentist working under the NHS must make certain information available through a publication scheme to anyone who asks for it
▪ The Information Commissioner’s Office (ICO) has published guidance which is provided unedited in pages 2-4 of this document
▪ The ICO provides a model template on which the template below is based
▪ The user remains responsible to ensure that their final version complies with the legislation
▪ The information contained in the publication scheme must be published, or made public. The manner or format in which that information will be made available should be specified
within each class (e.g. by hard copy, via memory stick, via a website or via CD Rom)
▪ Much of the information covered by the scheme will be available at no charge as it will already be available in the practice (e.g. in the practice leaflet) or on the practice website.
However, where a practice will charge for information the cost must be reasonable and included in the scheme
▪ Dentists should also consider appropriate ways of publishing their schemes other than on the internet and take into account the needs of disabled people. If you have a website, the
model scheme should be available online and easy to find. Otherwise, make sure it is publicised in another way, for example by announcing the new scheme in a newsletter or on a
public notice board
▪ Changes to the Freedom of Information Act have added a requirement for practices to publish ‘data-sets’, upon request, in an electronic format that can be re-used, unless it would not
be appropriate to do so. For more information see the ICO guidance on page 3 of this document
▪ It would not be appropriate for a practice to publish a ‘data-set’ if publication would breach data protection requirements or patient confidentiality
▪ A practice must publish information in accordance with its publication scheme
▪ A practice must perform periodic review of its publication scheme
Guidelines
Having read through this module you will need to elect a publication scheme leader who could be the practice manager. This person is the point of contact for information enquiries and is
responsible for keeping the scheme up to date. Once the publication scheme leader has modified and completed the template to suit the practice situation, s/he should produce several
copies of the document and keep them at reception for easy access by the members of the public. A few copies in a large print should be made available for visually impaired people. You can
also upload the completed version to your website for download.
Further information
Publication scheme guidance – ICO website
Telephone the ICO: 0303 123 1113

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Freedom of Information Act 2000

Guide to information provided by NHS dentists under the model publication scheme (England, Wales and Northern Ireland)

Introduction
The Freedom of Information Act 2000 (FOIA) requires all public authorities to adopt and maintain a publication scheme. In 2008 the Information Commissioner’s Office (ICO) introduced a
single generic model publication scheme, for adoption by all public authorities that are subject to FOIA.
The model publication scheme commits a public authority to ‘produce and publish the method by which the specific information will be available so that it can be easily identified and
accessed by members of the public’. This is a very general scheme based on the principle that all public authorities need to recognise the public interest in the transparency of the services
provided for and paid for by the general public. It is a commitment to make information easily available to the public.
Dentists providing dental services under contracts with the NHS in England, Wales and Northern Ireland are public authorities in respect of information relating to those services.
Note: The publication scheme is only for information held as a public authority.
The Model publication scheme is available on the ICO website. Further details are available in ICO guidance: Using the definition documents.
The model scheme must be adopted in full, unedited and promoted alongside the guide to information. Public authorities are not required to inform the ICO that they have adopted the
scheme; we will assume they have done so unless we hear otherwise.
A public authority is in breach of FOIA if it has not adopted the model scheme or is not publishing in accordance with it.
To assist dentists, we have produced this template guide to information. The template will help them to draw up their guide to information, indicating what information they will provide, how
it will be provided and whether any charge will be made for its provision. They should consider expanding elements of it to provide greater explanation and additional information, where this
can be done. For example, if there are specific plans for the provision of NHS services these could be detailed. It is not necessary to submit the guide completed by the practice to the ICO for
approval.
This and the model scheme document itself form the basis of the publication scheme commitment by NHS dentists.

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Information included in the guide to information
The template lists the information we think that dentists should hold and make available within each class. When completed, this will provide a list of all the information the dentist will make
routinely available, explain how it can be accessed and whether or not a charge will be made for it. Dentists must:
▪ state how the specific information can be obtained and if there is a cost involved;
▪ complete the relevant columns in the template guide; and
▪ ensure the public can access the completed guide and the information listed in it.
The guide, like the model scheme document itself, does not need further approval by the Information Commissioner.
Dentists should note that they are not expected to routinely publish all information; for example, where they do not hold it or where it is publicly available elsewhere or is exempt. We list
such circumstances below.
We would expect dentists to make the information in the guide available unless:
▪ they do not hold the information;
▪ the information is exempt under one of the FOIA exemptions or Environmental Information Regulations 2004 (EIR) exceptions, or its release is prohibited under another statute;
▪ the information is readily and publicly available from an external website; such information may have been provided either by the dentist or on their behalf. The dentist must provide a
direct link to that information;
▪ the information is archived, out of date or otherwise inaccessible; or
▪ it would be impractical or resource-intensive to prepare the material for routine release.
If the information is only held by another public authority, the dentist should provide details of where to obtain it.
For guidance on responding to requests for personal data, please refer to the Subject Access code of practice.
Datasets: publishing datasets for re-use
The law requires public authorities, including dentists, to publish under their publication scheme any dataset they hold that has been requested, together with any updated versions, unless
they are satisfied that it is not appropriate to do so. So far as reasonably practicable, they must publish it in an electronic form that is capable of re-use.
FOIA requires public authorities, including dentists, to publish under their publication scheme any dataset they hold that has been requested, together with any updated versions, unless they
are satisfied that it is not appropriate to do so.

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For the purpose of this guide to information, a dataset is a collection of factual raw data held electronically that has been obtained or recorded in connection with providing NHS dentistry. The
dataset provisions are about making information that is released under FOIA available for re-use. Dentists do not have to publish in their publication schemes any information that would be
exempt from disclosure in response to a FOIA request eg patient records.
If dentists are making a dataset routinely available under their publication scheme, then so far as reasonably practicable, they must publish it in an electronic form that is capable of re-use. If
the dataset or any part of it is a relevant copyright work and the dentist is the only owner of the copyright, they must make it available for re-use under the terms of a specified licence. The
Datasets Code of Practice recommends that public authorities make datasets available for re-use under the Open Government Licence.
The term ‘dataset’ is defined in section 11(5) of FOIA. The terms ‘relevant copyright work’ and ‘specified licence’ are defined in section 19(8) of FOIA. The ICO has published guidance on the
dataset provisions in FOIA. This explains what is meant by “not appropriate” and “capable of re-use”.
Fees and charging
Information available through a dentist’s publication scheme should be readily available at a low cost or at no cost to the public. If a dentist does charge for this information, we expect the
charges to be justifiable, clear and kept to a minimum.
Charges may be made for activities such as printing, photocopying and postage as well as information that the dentist is legally authorised to charge for. Anyone requesting information must
be informed of any charge before the information is provided. Dentists may ask for payment before providing the information. Guidance on our website: Charging for information in a
publication scheme provides more details.
If the dentist charges a fee for licensing the re-use of datasets, they should state in the guide to information how this is calculated and whether the charge is made under the Re-use Fees
Regulations or under other legislation. The dentist cannot charge a re-use fee if they make the datasets available for re-use under the Open Government Licence.
FOI requests and the publication scheme
It is important to note that a publication scheme simply sets out the information that is routinely available. Information that is not listed in the guide to information can still be requested and
should be made available unless it can be legitimately withheld.

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Information to be published How the information can be obtained

(e.g. hard copy, website)

Cost

Class 1 – Who we are and what we do
(Organisational information, structures, locations and
contacts)
This will be current information only
Who’s who in the practice Team member information is available [on the practice website at http://www.simply-teeth.co.uk] [in the

practice information leaflet].

No charge

Contact details for the practice (named contacts where
possible with telephone number and email address (if
used))

Contact details are available [on the practice website at http://www.simply-teeth.co.uk ][in the practice
information leaflet]. No charge

Opening hours

Our current opening hours are available [on the practice website at http://www.simply-teeth.co.uk ][in the
practice information leaflet]. No charge

Class 2 – What we spend and how we spend it
(Financial information relating to projected and actual
income and expenditure, procurement, contracts and
financial audit)
Current and previous financial year as a minimum

Details on NHS funding received by the practice and the
cost of operating the NHS contract. We would expect
dentists to consider publishing as much information as
possible, including as much detail as possible.

[England and Wales: The value of our GDS/PDS contract with the NHS and targets are available from [the
practice owner].
[Northern Ireland: Information regarding the funding we receive from the NHS through our GDS contract is
available from [the practice owner].

10p per
photocopy
£4 per CD
£4 per memory
stick

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Total annual expenditure on the provision of our
contracted services (since most practices also provide
care to patients on a private basis, the costs have been
apportioned)

The practice provides both NHS and private treatment to patients. Information regarding the annual costs to
the practice to deliver our NHS services is available from Sunny Sihra

10p per
photocopy
£4 per CD
£4 per memory
stick

Audit of NHS income, if held The practice is not audited and no information is held.
Class 3 – What our priorities are and how we are
doing
(Strategies and plans, performance indicators, audits,
inspections and reviews)
Current and previous year as a minimum

Plans for the development and provision of NHS
services

[The practice has a strategic action plan in place (G 151A) with objectives to develop our NHS service] [The
practice currently has no plans regarding the development and provision of NHS services].

10p per
photocopy
£4 per CD
£4 per memory
stick

Performance data including performance against
targets

[England and Wales: Information regarding targets and our performance against them is available from [the
practice owner].
[Northern Ireland: We are not set any targets by the NHS and have no information].

10p per
photocopy
£4 per CD
£4 per memory
stick

Practice inspection. Inspection reports by regulators
[for England: the Care Quality Commission
(CQC); Wales: Healthcare Inspectorate Wales;
or Northern Ireland: the Regulation and Quality
Improvement Authority (RQIA)]

[Our latest CQC/RQIA/HIW inspection report is available on the CQC/RQIA/HIW website at: insert link to
report]. No Charge

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Class 4 – How we make decisions
(Decision making processes and records of decisions)
Current and previous year as a minimum

Records of decisions made in the practice/firm affecting
the provision of NHS services.

[The practice carries out an annual management review each year (G 170-TM2). Information regarding
decisions made as a result of the review, which affect the provision of NHS services, is available from Sunny
Sihra.
[As a small company management decisions are not always recorded. Information may be available
from Sunny Sihra.

10p per
photocopy
£4 per CD
£4 per memory
stick

Class 5 – Our policies and procedures
(Current written protocols, policies and procedures for
delivering our services and responsibilities)
Current information only.
Here we have listed the policies we would expect
practices to have. Any additional policies should also be
listed.
Mark “not held” against any policies that are not
actually held.

Policies and procedures about customer service Our Patient experience policy (M 233-PEX) is available from reception.

10p per
photocopy
£4 per CD
£4 per memory
stick

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Policies and procedures about employment of staff

Information available from reception includes, but is not limited to:
▪ Recruitment and selection policy and procedure (M 222H)
▪ Employment and induction policy (M 233-EIN)
▪ Disciplinary (M 227A), Grievance (M 227B) and Capability (M 227D) procedures

10p per
photocopy
£4 per CD
£4 per memory
stick

Equality and diversity policy Our Equality, dignity and human right policy (M 233-EQD) is available from reception.

10p per
photocopy
£4 per CD
£4 per memory
stick

Health and safety policy Our Health and safety policy (M 250C) is available from reception.

10p per
photocopy
£4 per CD
£4 per memory
stick

Infection control policy Our Infection control policy (M 257A) and procedures (M 257B) are available from reception.

10p per
photocopy
£4 per CD
£4 per memory
stick

Radiation protection checklist Information from our Radiation protection folder is available from Jas Sond.

10p per
photocopy
£4 per CD
£4 per memory
stick

Complaints procedures (including those covering
requests for information and operating the publication
scheme)

Our complaints procedure [England and Northern Ireland: (G 110C)][Wales: G110CW] is displayed in
reception and [http://www.simply-teeth.co.uk]. Copies are available from reception. No charge

Records management policies (records retention,
destruction and archive) Our Record management policy (M 233-REM) is available from reception.

10p per
photocopy
£4 per CD
£4 per memory
stick

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Confidentiality and data protection policies Our Confidentiality (M 233-CON) and Data protection (M 233-DPT) policies are available from reception.

10p per
photocopy
£4 per CD
£4 per memory
stick

Policies and procedures for handling requests for
information

Requests for information are covered in our Data protection policy (M 233-DPT), which is available from
reception.

10p per
photocopy
£4 per CD
£4 per memory
stick
Practice information leaflet Our practice information leaflet is available at reception. No charge
Class 6 – Lists and Registers
Currently maintained lists and registers only
We recognise that it is unlikely that dentists are going
to have registers available for public inspection and
while this remains the case “none held” can be entered
in this section.
Any publicly available register or list (if any are held this
should be publicised; in most circumstances existing
access provisions will suffice).

None held

Class 7 – The services we offer
(Information about the services we offer, including
leaflets, guidance and newsletters produced for the
public)
Current information only

The services provided under contract to the NHS

Information about the services we offer is outlined in [on the practice website at http://www.simply-
teeth.co.uk ][in the practice information leaflet].

No charge

Charges for any of these services Information regarding charges for NHS services is displayed on posters in reception, in our practice No charge
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information leaflet, which is available from reception [and on the practice website at http://www.simply-
teeth.co.uk.

Information leaflets

We have a range of leaflets, free of charge and available at reception, including:
▪ Patient information leaflet on gum disease
▪ Patient information leaflet on childrens Teeth
▪ Patient information leaflet on mouth cancer
▪ Patient information leaflet on Diet
▪ Patient information leaflet on Root Canal
▪ Patient information leaflet on Smoking
▪ Patient information leaflet on oral hygiene
▪ Take home instructions for after surgery
▪ Take home instructions for antibiotics
▪ Take home instructions for new dentures

No charge

Out of hours arrangements

Information about out-of-hours emergency care is available in the practice information leaflet, which is
available from the practice reception and published on the practice website.

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