ARTICLE 19 Information Disclosure Policy

Adopted April 2007, last amended November 2017.

Introduction

ARTICLE 19, has for many years campaigned for a right to access information held by public and private  bodies as a basic human right. We believe that public these bodies have an obligation to disclose information and that every member of the public has a corresponding right to receive information. Access to information enhances democracy and participation, reduces wrongdoing and leads to better public policies and practices.

In keeping with the spirit and beliefs of our organisation, we have drafted adopted our own Information Disclosure Policy. This Policy is fully consistent with our policies and standards on access to information held by public and private bodies. In particular, it is drafted with a view to respecting the public’s right to know and it is based on the principle of maximum disclosure. In accordance with those principles, two main means of providing access are envisaged: first, we disclose a wide range of information on a routine basis, via our website (www.article19.org). Second, all of the information we hold, subject to limited exceptions, will be made available upon request.

Application

This policy applies to all information held by ARTICLE 19 and its staff as part of its work regardless of its form, including but not limited to documents, files, data, databases, emails, etc.

This policy applies to information held by the ARTICLE 19 International Office and subsidiaries and staff. It applies to Information held by ARTICLE 19 Affiliate Offices in the absence of them adopting their own policies.

Routine disclosure

The categories of information and documents listed in Annex 1 are available on our website and are, as relevant, routinely updated. Annex 1 itself is subject to a regular, no more than bi-annual review and updating. In rare cases, a document, or a part thereof, otherwise subject to routine publication may fall within the scope of the regime of exceptions, in which case it will not be made available or will be provided in redacted form.

We also produce financial reports though the International Aid Transparency Initiative (IATI). Those reports are available here (link)

Process for requesting documents

Making a request

Anyone may request information from ARTICLE 19 though the following means:

  • by the telephone (+44 (0)20 7324-2500),
  • by email ([email protected]),
  • by fax (+44 (0)20 74900566),
  • by mail (60 Farringdon Road, London, EC1R 3GA United Kingdom),
  • or via any other practical means such as official ARTICLE 19 social media accounts if clearly identified.

A request may be directed to any ARTICLE 19 staff or board member. Where a request is not clear, we will ask for further clarification and, where necessary, provide assistance to a requester in formulating his or her request.

Time limits

ARTICLE 19 endeavours to respond to all requests promptly. We will normally deal with requests within five ten working days. Where requests are not directed to the central contacts noted above (i.e. where they are directed to specific staff members), they will be dealt with within ten working days of actual receipt of the request by that staff member, which may be delayed because of travel, sickness, holidays or such like.

Urgent Requests. We will attempt to deal with urgent requests, where an adequate case for urgency has been made by the requester, as soon as possible.

Form of communicating information

We will endeavour to provide the information in any form in which we hold it (normally electronic or print) or can generate it through an automated process (e.g. printing an electronic document), and in any language in which we have it.

Fees

No fees will be charged for requests which are satisfied electronically (i.e. where the information is emailed). No fees will be charged for the first 100 pages of printed or photocopied material. Reasonable fees, based on actual costs relating to copying and dissemination, may be charged for requests which involve larger amounts of information. Where a request is for a document that we offer for sale, the regular price may be charged for that document.

Exceptions to disclosure

We recognise only these legitimate grounds for refusing access to information:

Personal information

We will not disclose personal information about a natural third party which would unreasonably breach a legitimate privacy interest unless that person has consented or the information was provided on the clear understanding that it might be made public or is already available publicly from another source. This does not affect any person making a request for their own information held by ARTICLE 19 under the UK Data Protection Act, 1998 or nationally relevant laws as applicable.

Legal privilege

We will not disclose information which is privileged from production in legal proceedings unless the person who is entitled to the privilege waives it. ARTICLE 19 will waive its own legal privilege unless to do so would put it at a disadvantage in legal proceedings or breach one of the other exceptions in this policy.

Confidentiality

We will not disclose information where to do so would constitute an actionable breach of confidence or other legal obligations. We will also not disclose information where it was provided to us in confidence and to disclose it would seriously prejudice our relations with the body that provided it, to the detriment of ARTICLE 19’s interests.

Ability to operate effectively

We will not disclose information where to do so would seriously undermine our ability to operate effectively, for example by seriously harming our relations with a third party, by inhibiting sensitive discussions within the organisation or with partners, releasing information prior to its completion of the task which would inhibit its completion, or the provision of which creates a substantial and unreasonable administrative burden or is vexatious.

Safety and security

We will not disclose information which likely puts the safety or security of our partners, contacts, staff, or any other person at risk.

Information already available

When a request for information is made for information that is already available publicly on the ARTICLE 19 website or another location, we will provide the relevant link or location for access unless the information is requested in a form or language that is different from that in which it is already available and we hold it in that form or language.

Severability

Where only part of a record or other form of information falls within the scope of an exception, the rest of the information, to the extent it may be reasonably severed from the exempt information, will still be disclosed.

Public interest override

Information will still be disclosed even if it falls within the scope of an exception where the public interest in doing so outweighs the harm in release.

Appeals

Anyone who believes that an ARTICLE 19 staff member has failed properly to apply this policy may appeal to the Executive Director (email: [email protected], 60 Farringdon Road, London, EC1R 3GA United Kingdom) or the senior management person acting in their absence.

Any such appeal shall be decided within ten working days. Where the Executive Director is away from the office, the ten working days shall commence from the date of his or her return, but no longer than 30 working days from the original request.

If the requestor is not satisfied, they have a further appeal to Chair of the International Board (create email address). Appeals will be dealt with wishing 30 working days.


Reuse and licensing

ARTICLE 19 typically publishes under the Creative Commons Attribution-Non-Commercial-ShareAlike3.0 licence. Unless otherwise stated, you are free to copy, distribute and display information received from ARTICLE 19 and to make derivative works, provided you:

  1. Provide appropriate credit, provide a link to the license, and indicate if changes were made. You may do so in any reasonable manner, but not in any way that suggests the licensor endorses you or your use.
  2. May not use the material for commercial purposes.
  3. If you remix, transform, or build upon the material, you must distribute your contributions under the same license as the original.

To access the full legal text of this licence, please visit: https://creativecommons.org/licenses/by-nc-sa/3.0/

ARTICLE 19 would appreciate receiving a copy of any materials in which information from the organisation is used.

Information available on a proactive basis

We aim to make available the following categories of information and documents on our website and update them regularly, including but not exclusive to:

  • Organisational information:
  • Strategy
  • Staff and board including biographies and register of interests
  • ARTICLE 19 Organisational Policies (list out which ones with links)
  • Financial statements
  • Reporting
  • Newsletters
  • Partnerships
  • Project output

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