Information Commissioner's Office
What to consider when using online forms to receive information requests
Are you using online forms to receive information requests?
As freedom of information (FOI) practitioners, you have a responsibility to help requesters clarify what it is they want from you. You need to support them to submit requests in a way that enables you to provide a comprehensive and timely response.
Some organisations have begun using online forms to help guide requesters. This can be a useful approach as it prompts requesters to provide the details you need to effectively handle their request. Depending how it is set up, the form can direct the request to the right team straight away, avoiding delays that could impact your FOI compliance. If the form integrates with your request handling software, it could even cut down on your administrative workload.
There are many positives to helping people make their requests in this way. However, there are some key things that you need to consider if you are thinking about using an online form.
Valid requests require responses.To comply with the FOIA, a request simply has to be submitted in writing and include a name and address for correspondence. Having a form on your website doesn’t mean you can ignore valid requests that arrive through different routes.
Do not redirect requesters to use your form if they contact you using a different method. You can suggest that they use the form in the future, but you cannot demand that they do so.
Provide a copy of the request.When a requester submits a request through your form, they should receive a copy of their request and confirmation of the date. This will allow them to reference the request easily if they need to discuss it with you. It will also ensure their right to redress if they need to complain to us, as we will ask them to provide a copy of the original request.
Don’t take down your email address.
An online form is an additional mechanism through which you can facilitate public access to information. But it shouldn’t be the only mechanism.
Completely phasing out email and other methods to rely exclusively on online forms would be a step backwards. You cannot force people to use it because it is your preferred method. What if there is a problem with your online portal or your website was down temporarily? How could people make requests if the form is the only option?
An email address gives requesters a clear way to get in touch with you if they need advice and assistance, to chase a late response or request an internal review. Remember, if anyone tells us they struggled to get in touch with you, we will consider that fact as part of any complaint and it is likely to count against you.
You may also be unwittingly excluding people from exercising their right to access information. A report from Age UK highlighted that online-only services can exclude older people, so exclusively accepting requests through an online form is not appropriate.
Do not gather excessive personal data through your request form.
It might be tempting to ask requesters to provide personal information over and above that necessary to make the request. For example, asking them to identify if they are a journalist.
Asking for extensive information from requesters, especially if you make it mandatory, may act as a disincentive. Be careful not to put systems in place that could act as a barrier to people exercising their information rights.
There may be some limited situations where you need to find out more information about a requester to respond to their request. There is specific guidance on that on our website that explains when you should consider the requester’s identity.
At the ICO we always like to highlight good practice where we see it. Manchester City Council is a great example of a public authority that offers a variety of routes to make a request, including an online form.
There are things to consider, but that doesn’t mean that online forms can’t be a helpful tool in your approach to FOI. Just keep our simple guidance in mind.
Latest News from
Information Commissioner's Office
Statement on Court of Appeal judgment on Freedom of Information Act appeal24/11/2023 09:20:00
The Court of Appeal has ruled against the Information Commissioner’s Office (ICO) in a Freedom of Information Act 2000 appeal regarding the ability to aggregate public interest factors for and against disclosure when applying exemptions under the Act.
Statement regarding the outcome of the Independent External Review of Lancashire Police’s handling of the Nicola Bulley case21/11/2023 12:25:00
Statement regarding the outcome of the Independent External Review of Lancashire Police’s handling of the Nicola Bulley case.
Information Commissioner seeks permission to appeal Clearview AI Inc ruling20/11/2023 12:25:00
The UK Information Commissioner is seeking permission to appeal the judgment of the First Tier Tribunal (Information Rights) (Tribunal) on Clearview AI Inc (Clearview).
Former NHS secretary found guilty of illegally accessing medical records17/11/2023 12:25:00
A former NHS employee has been found guilty and fined for illegally accessing the medical records of over 150 people.
‘Be smarter than your smart tech’ – ICO issues top tips for consumers buying smart devices on Black Friday16/11/2023 10:10:00
The Information Commissioner’s Office (ICO) has shared its top tips to support consumers shopping smart tech this Black Friday.
Assessing data protection practices of UK tracing agents14/11/2023 12:25:00
Blog posted by: Anthony Luhman, ICO Director of PACE Projects and Interim Director of Investigations, 14 November 2023.
ICO and European Data Protection Supervisor (EDPS) sign Memorandum of Understanding09/11/2023 12:25:00
The UK Information Commissioner’s Office (ICO) and the European Data Protection Supervisor (EDPS) have signed a Memorandum of Understanding (MoU), which reinforces their common mission to uphold individuals’ data protection and privacy rights, and cooperate internationally to achieve this goal.
An apology from the ICO to Dame Alison Rose06/11/2023 16:20:00
The ICO recently investigated a complaint from Nigel Farage.
Information Commissioner’s Office issues three fines totalling £170,000 for illegal direct marketing02/11/2023 12:25:00
Three companies offering financial services have been fined £170,000 collectively by the Information Commissioner’s Office (ICO) for illegal direct marketing under the Privacy and Electronic Communications Regulations (PECR).