The Freedom of Information (Scotland) Act 2002 (FOISA) [1] requires all public authorities to adopt and maintain a publication scheme approved by the Scottish Information Commissioner. This is a document that describes, for the public, the type of information the practice publishes (i.e. holds and can make available to the public) in relation to its NHS work, the manner in which the information is published and whether there is a charge for this information. Types of information may include, for example, the services provided and practice policy for handling complaints. The information should be made available on the practice website, if possible, although it could also be via a practice information leaflet, available at the practice or links to other sources.
Under the FOISA, information can be requested by anyone, anywhere in the world, and so a publication scheme can serve to reduce the administrative burden of dealing with freedom of information requests in addition to publicising the services provided by dental practices.
Dental practices should adopt the current approved Model Publication Scheme (MPS) [2] which is a standard framework provided by the Scottish Information Commissioner for all Scottish public authorities. The MPS is structured such that information for publication is classified into nine classes:
Class 1: About the authority/practice
Class 2: How you deliver your function and services
Class 3: How you take decisions and what you have decided
Class 4: What you spend and how you spend it
Class 5: How you manage your human, physical and information resources
Class 6: How you procure goods and services from external providers
Class 7: How you are performing
Class 8: Your commercial publications (where applicable)
Class 9: Your open data (where applicable)
To adopt the Scottish Information Commissioner’s MPS, you must make available the MPS [2], exactly as provided, produce a Guide to Information which describes the information that you publish in each class and where it can be accessed, ensure that you have made available all the information described, and keep the scheme up to date. Even if you do not have any information for a given class, you must still include the class of information and state that you do not hold information in the class.
The way in which the information is made available should meet the MPS Principles. A Model Publication Guide for Scottish Public Authorities [3] explaining the MPS and how to prepare a Guide to Information [4] is provided on the Scottish Information Commissioner’s website and should be consulted. SDCEP has developed a Model Publication Scheme Guide to Information template specifically for dental practices to adapt. Individual dental practices do not have to inform the Information Commissioner that they have adopted the approved MPS. Arrangements should be put in place to ensure that your Guide to Information is kept up to date and that it is consistent with any changes to the MPS, which do take place periodically.
To adopt the Model Publication Scheme:
Refer to the Model Publication Scheme Guide for Scottish Public Authorities [3].
Adapt the SDCEP Model Publication Scheme Guide to Information template to list the information that your practice publishes and include a review date.
Make the Model Publication Scheme [3] and your Guide to Information [4] (together these comprise the practice’s publication scheme) available to the public (ideally on the practice website, through a Freedom of Information link).
Ensure that you publish all of the information outlined in the publication scheme and make this available to the public.
Review your publication scheme regularly and ensure it remains up to date.
Sources of information
- Freedom of Information (Scotland) Act 2002
- Model Publication Scheme. Scottish Information Commissioner
- Model Publication Scheme Guide for Scottish Public Authorities. Scottish Information Commissioner (2021)
- Guide to Information. Scottish Information Commissioner