Scottish Government bond programme accountable officer documents: FOI release

Information requested

Who is the Accountable Officer responsible for authorising spending associated with the Scottish Government’s bond programme? Please provide all documentation this person has relied on to decide the spending represents value for money, and thus does not require a ministerial direction.

Response

The Scottish Government Director General for Exchequer, Strategy and Performance (DG ESP), is the Accountable Officer responsible for authorising spending associated with the Scottish Government’s Bond Programme. The interim DG ESP is Shona Riach, and has been in post since 25 September 2025. Prior to this, the Accountable Officer was DG Exchequer, Alyson Stafford.

Your request for ‘all documentation this person has relied on to decide spending represents value for money’ is interpreted to mean documents which the current AO would reasonably have relied on to inform any decision-making about spending and value for money for the bond programme. We have therefore conducted what we consider to be proportionate searches and information has been identified as being in the scope of your request. I enclose a copy of the information at Annex A.

Our aim is to provide information whenever possible. In this instance we are unable to provide some of the information you have requested because exemptions under section 25(1) (information otherwise accessible), section 29(1)(a) (formulation of government policy), section 33(1)(b) (commercial interest) and section 38(1)(b) (third party personal data) of FOISA apply to some of the information you have requested. The reasons why these exemptions apply are explained below. In addition, some material has been redacted as it is out of scope of your request.

For all publicly accessible information on the bonds programme more generally, please visit: Scottish Government bonds - Investment finance - gov.scot.

• Exemptions under section 25(1) (information otherwise accessible) Some of the information you have requested is available from Scottish Government Bonds Programme: Summary Outline Business Case. Under section 25(1) of FOISA, we do not have to give you information which is already reasonably accessible to you.
• Exemptions under section 29(1)(a) of FOISA (formulation or development of government policy) apply to some of the information requested. These exemptions apply because the information relates to the formulation of the Scottish Government's fiscal policy. This exemption 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 exemption. We have found that, on balance, the public interest lies in favour of upholding the exemption. 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 need in officials having a safe space to discuss policy development which outweighs public interest in releasing information.
• Exemptions under section 33(1)(b) of FOISA (commercial interest) apply to some of the information requested. This exemption applies because disclosure of this particular information would, or would be likely to, prejudice substantially the commercial sensitivities of the Scottish Government. This exemption 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 exemption. We have found that, on balance, the public interest lies in favour of upholding the exemption. We recognise that there is a public interest in disclosing information as part of open and transparent government, and to help account for the expenditure of public money. However, there is a greater public interest in protecting the commercial interests of the Scottish Government to ensure that we are always able to obtain the best value for public money.
• Exemptions under section 38(1)(b) of FOISA (third party personal data) applies to some of the information requested because it is personal data of a third party, i.e. names and contact details, 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 exemption 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 exemption.

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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.

FOI 202600504056 - Information Released - Annex A

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