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Glasgow School of Art (GSA) Correspondence and Restoration Options: EIR release

Information request and response under the Environmental Information (Scotland) Regulations 2004


Information requested

1. Correspondence and Briefings – 1 June 2025 to Present

Please provide all correspondence, meeting notes, internal emails, briefings, and analysis held by the Scottish Government (including within the Directorate for Culture and Heritage and any related departments) from 1 June 2025 to the present, relating to:

  • The Mackintosh Building at the Glasgow School of Art (GSA),
  • Including all correspondence with or about GSA, whether or not directly related to the restoration project or Strategic Outline Business Case (SOBC).

2. Restoration / Rebuild Options

In FOI 202500461994, some detail regarding the SOBC options under consideration was withheld under the “free and frank provision of advice” exemption.

I therefore request that you now provide a verbal or high-level written summary of each of the restoration or redevelopment options considered in the current SOBC Addendum or other live internal documentation.

This could include, for example:

  • The general number or range of options considered,
  • A high-level outline of each option’s scope (e.g. restoration, partial rebuild, alternate uses),
  • An indication of the current lead/preferred option (if identified),
  • Timelines or constraints attached to each.

3. Regulatory and Practical Constraints

Please also provide any documents, internal advice, or correspondence that:

  • Discuss the impact of current building or fire regulations on reinstating the Mackintosh Building,
  • Refer to dependencies on third-party land, access, or legal constraints,
  • Comment on the realism or deliverability of the proposed reinstatement.
  • As the information you have requested is 'environmental information' for the purposes of the Environmental Information (Scotland) Regulations 2004 (EIRs), we are required to deal with your request under those Regulations. We are applying the exemption at section 39(2) of the Freedom of Information (Scotland) Act 2002 (FOISA), so that we do not also have to deal with your request under FOISA.

Response

I enclose a copy of some of the information you requested under Annex A, attached separately.

Some of the information you have requested is available from the Glasgow City Council website (Glasgow_Golden_Z_-_Summary_Document_FINAL_ISSUE.pdf), and the Scottish Government’s Planning and Environmental Appeals Division website (https://www.dpea.scotland.gov.uk/CaseDetails.aspx?ID=126695). Under regulation 6(1)(b) of the EIRs, we do not have to give you information which is already publicly available and easily accessible to you in another form or format. If, however, you do not have internet access to obtain this information from the website(s) listed, then please contact me again and I will send you a paper copy.

While our aim is to provide information whenever possible, in this instance the Scottish Government does not have some of the information you have requested.

An exception under regulation 11(2) of the EIRs (personal information) applies to some of the information requested because it is personal data of a third party and disclosing it would contravene the data protection principles in Article 5(1) of the General Data Protection Regulation and in section 34(1) of the Data Protection Act 2018. This exception is not subject to the 'public interest test', so we are not required to consider if the public interest in disclosing the information outweighs the public interest in applying the exception.

An exception under regulation 10(4)(e) of the EIRs (internal communications) applies to some of the information you have requested, because it relates to internal communication between Scottish Government officials and Ministers regarding the planning application at 292-332 Sauchiehall St.

This exception is 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 exception. We have found that, on balance, the public interest lies in favour of upholding the exception. We recognise that there is a public interest in disclosing information as part of open, transparent and accountable government, and to inform public debate. However, there is a greater public interest in allowing a private space within which officials can provide free and frank advice and views to Ministers regarding the planning application. It is clearly in the public interest that Ministers can robustly defend the Government’s policies and decisions. They need full and candid advice from officials to enable them to do so. Premature disclosure of this type of information could lead to a reduction in the comprehensiveness and frankness of such advice and views in the future, which would not be in the public interest.

An exception under regulation 10(5)(f) of the EIRs (substantial prejudice to interests of person who provided the information) applies to some of the information you have requested. This exception applies because disclosure of this particular information would, or would be likely to, prejudice substantially the interests of the Scottish Funding Council, who provided that information to the Scottish Government. They:

  • were not under any legal obligation to give us that information;
  • did not supply it in circumstances in which it could, apart from the EIRs, be made available; and
  • have not consented to disclosure.

This exception is 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 exception. We have found that, on balance, the public interest lies in favour of upholding the exception. We recognise that there is a public interest in disclosing information as part of open and transparent government. However, there is a greater public interest in protecting the interests of anyone, such as the Scottish Funding Council, who provides the Scottish Government with information on a confidential basis. Disclosing such information against the express wishes of the stakeholder is likely to undermine their trust in the Government and make them reluctant in future to share information with us on issues such as the Glasgow School of Art’s Mackintosh building project. This would significantly impair the Scottish Government’s ability to develop policies and make decisions on the basis of fully informed advice and evidence. This would not be in the public interest.

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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