Conclusion and Next Steps
For the reasons set out above, we consider that RSLs should be brought within scope of Scotland's Freedom of Information legislation.
However, a decision on whether to lay a draft order extending coverage to RSLs will only be taken following this consultation exercise and related stakeholder engagement. Any order would be subject to affirmative procedure in the Scottish Parliament.
In the event of an order being agreed to by the Scottish Parliament, to allow sufficient preparation time for the RSLs, we would not propose that the order came into effect until 1 April 2018.
An important part of this consultation process will be an assessment of the practical impact of these proposals, for example the administrative consequences of extending coverage on the RSLs themselves. Annex A consists of a partial business and regulatory impact assessment ( BRIA) and we would welcome comments on the BRIA to inform this element of the consultation process.
It would be the intention to include in an order a 'class description' covering registered social landlords and setting out the function(s) considered to be covered by the order. A class description is intended to provide for flexibility and avoids the need for further orders each time a social landlord is added to (or removed from) the register.
Annex B of this consultation paper provides information on how to respond - as well as the questions you are invited to respond to.