Board of Disclosure Scotland training: FOI release

Information request and response under the Freedom of Information (Scotland) Act 2002


Information requested

Please supply the following information for the period 1 April, 2020 to 10 July, 2025, inclusive in respect of the Board of Disclosure Scotland:

1. A summary of all training offered to each member of the Board with a summary of the objectives of each training session;

2. What training offered was compulsory for Members of the Board to complete and what training offered was discretionary for Members to determine for themselves whether to take part in training offered;

3. What proportion of Members undertook and completed compulsory and discretionary training respectively for each of the financial years above;

4. How the training needs of Members are identified; and

5. The training material supplied in respect of each training session offered.

Without prejudice to the foregoing generality information I am looking for may include:

1. Corporate induction (how Disclosure Scotland works and the role of its Members);

2. Conflicts of interest and how to deal with them;

3. Anti-bullying and prevention of harassment of staff and other Members;

4. Data protection;

5. Financial and risk management oversight;

6. Freedom of information oversight roles; and

7. Oversight of corporate complaints.

Disclosure Scotland's website advises that one "can use the Scottish Government's process to request Disclosure Scotland information" and does not have its own email address for freedom of information enquiries, hence the reason this request is directed to the Scottish Government.

Response

I enclose some of the information you requested.

Disclosure Scotland is a Scottish Government executive agency. Its Board is made up of its Chief Executive, six executive directors who are all employed civil servants, and five non-executive directors (one of whom is a civil servant and does not receive additional remuneration as a non-executive). Board members recruitment is designed to find potential Board members with specific skills appropriate to the organisation at that time but include for example in areas such as Public Sector Finance, digital and governance. Executive members training is not specifically focused on being a Board member, so we have focused our answer on non-executive members.

1. a summary of all training offered to each member of the Board with a summary of the objectives of each training session.

I enclose a copy of Disclosure Scotland’s Non-Executive Director Board member induction pack which gives full details of mandatory training members are required to complete. Non-executive Board members are also provided with a copy of “Scottish Governments On Board: a guide for member of management advisory boards”.

Board members are also signposted to a Scottish Government Board induction workshop, this is not compulsory, and we do not have a log of who attended. The Scottish Government also have a Governance Hub that Board members have access to that includes other optional training.

An exemption under section 30(c) (prejudice to effective conduct of public affairs), section 39(1) (Healthy and Safety) and section 38(1)(b) (third party personal data) applies to some of the information requested. This has resulted in redactions being made to the enclosed induction pack.

With respect to section 30(c), disclosing internal e-mail addresses and meeting schedules into the public domain could prejudice our ability to effectively managed our processes.

With respect to section 39(1), releasing building floor plans into the public domain could put the physical safety of staff at risk.

Both of these exemptions are subject to the ‘public interest test.’ Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exemption. We have found that, on balance, the public interest lies in favour of upholding the exemption.

2. what training offered was compulsory for Members of the Board to complete and what training offered was discretionary for Members to determine for themselves whether to take part in training offered

We provide compulsory training for non-executive directors in “data protection and information security” which is noted in the induction pack. All other training is discretionary.

3. what proportion of Members undertook and completed compulsory and discretionary training respectively for each of the financial years above;

Disclosure Scotland does not have a log of what training was taken up each year by members. This is a formal notice under section 17(1) that Disclosure Scotland does not hold the information requested. Board members are taken through the process of accessing the training when they attend one of their first few Board meetings. The governance team are required to do this as the Board members do not have Scottish Government laptops, and the training is only accessible on a Scottish Government device. Other than the noted formal training our Board members are regularly involved in strategic sessions held during Board meetings and previously on Board away days. I have included some examples of those strategic sessions below however these are not training sessions;

Away day in 2022:

Sessions on Equality, Diversity and inclusion, Governance, Target Operating Model, Cyber awareness and Safeguarding were held.

Strategic sessions held this year:

Act Delivery: Pathway to 1 April 2025.

Disclosure Scotland Corporate Strategy: Starting the process to identify more mid- term, long-termstrategies for 2030 along key operating themes.

People services: Reviewing the structure of our People Services and people management goingforward;

4. how the training needs of Members are identified 

Non-executive Board member training needs are identified through a skills gap assessment process and Board self-assessment process which happens when there are significant changes to the Board members or Disclosure Scotland’s objectives. I have enclosed a copy of the skills gap document.

5. the training material supplied in respect of each training session offered.

For the compulsory online training (access provided to an online portal with tailored subject matter and knowledge test) no materials are required other than access to a Scottish Government laptop which is done under supervision. During the strategic sessions the only materials required are supplied by Disclosure Scotland and are items such as pens, post it notes, white boards etc.

Items noted above under “information I am looking for may include” are signposted below.

1. corporate induction (how Disclosure Scotland works and the role of its Members) – Induction pack attached.

2. conflicts of interest and how to deal with them – Included in the Scottish Government On Board guidance linked above in section – Conflicts of interest. Board members also provide information for
Disclosure Scotland’s Register of interest regularly during Board meetings.

3. anti-bullying and prevention of harassment of staff and other Members – Included in the Scottish Government On Board guidance linked above in section - Ethics and Standards of Behaviour: Guidance Note 5.

4. data protection – completed through the training noted above.

5. financial and risk management oversight – Included in the Scottish Government On Board guidance linked above in sections – Effective Financial Management and risk management and internal controls.

6. freedom of information oversight roles – not specifically covered in the training documents. However Board members are aware of FOI performance through a KPI report.

7. oversight of corporate complaints – Included in the Scottish Government On Board guidance linked above in section – Valuing Complaints.

About FOI

The Scottish Government is committed to publishing all information released in response to Freedom of Information requests. View all FOI responses at https://www.gov.scot/foi-responses.

Contact

Please quote the FOI reference
Central Correspondence Unit
Email: contactus@gov.scot
Phone: 0300 244 4000

The Scottish Government
St Andrew's House
Regent Road
Edinburgh
EH1 3DG

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