A) Introduction
1. Positive Action Group (P A G) is an IOM political lobby group which has been campaigning, since its formation in 2006, for a Freedom of Information Act. We contributed to the Preliminary Public Consultation in February 2007
2. The current ‘Code of Access to Government Information’ is inadequate and we welcome this move to replace it. In the last 2 years P A G has made 2 innocuous requests to government under the Code. Both were refused. Following complaint the information was released on the recommendation of the Commissioner. In both cases there was nothing in the information that was prejudicial to government. We believe that this Bill will shift the culture of government to be be more accepting of the “right to know” by the public.
3. Comment has been made on 25 of the 73 clauses in the Bill by direct reference to the draft legislation rather than the summary of the provisions given the consultation document.
4. When considered appropriate reference is made to the UK FOI Act upon which this Draft Bill is modelled.
5. Similarly reference is made to the Scottish FOI Act.
6. Recently the States of Jersey published a Report “Draft Freedom of Information (Jersey) Law 201_”. We refer to this and recommend it for excellent background information on FOI.
7. P A G wholeheartedly endorses the Office of Data Protection Supervisor’s response to this consulation.