25-26/006

I refer to your request for information (FOI 25-26/006) dated 03 April 2025 for records related to the MyGTCS platform which we have handled under the Freedom of Information (Scotland) Act (FOISA).

Specifically, you asked for "consultation data for the new MyGtcs profile” as GTC Scotland had “shared the upcoming changes to the profile and it was stated that ‘extensive’ consultation was undertaken for this to happen.”

On 29 April, we requested clarification as we had been unable to locate a record with reference to “extensive consultation” for response. You indicated that this was held during an “online meeting” for “all probation managers and those involved in probation support.” By way of advice and assistance, in a Probation Managers’ meeting with GTC Scotland on 19 March 2025, there was reference made to user testing, specifically:

Since then we've considered all the feedback and what came out of user testing.

We have conducted a search and confirm that we do not hold a record related to the “extensive consultation” query of your request and apply section 17(1)(b) as this information is not held.

However, you clarified on 01 May 2025, that you wished to receive records related to user testing as referenced above. Please find the records labelled “FOI 25-26-006-Records" accompanying this response. This contains several records related to the “user testing”, specifically, a research report conducted on our behalf by BJSS, a register of interest from participants and several interviews conducted with users.

You will note that various portions of the records have been redacted to protect the personal information of individuals as disclosing this information would identify individuals. FOISA does not require us to provide this sort of information as it is exempt under section 38(1)(b) (read with section 38(2A)(a), where disclosure would be in breach of one or more of the data protection principles contained in Article 5(1) of the UK GDPR. We consider that disclosure of this personal data in this instance would be beyond the reasonable expectation of, and therefore unfair to, the data subjects concerned. By being unfair, it would also be unlawful and in breach of the data protection principle in Article 5(1)(a) (fairness, lawfulness and transparency).

Our search has also identified a survey synthesis containing all the responses from participants to the user testing. We have elected to withhold this document. In relation to the information that constitutes advice contained in the report, we consider that disclosure of this information into the public domain would substantially inhibit the free and frank provision of advice on key matters for GTC Scotland. In respect of that information, we have applied section 30(b)(i) of FOISA.

In relation to information included in the report that is simply factual information, we consider that the exemption in section 30(c) of FOISA applies, as disclosure of this information into the public domain at this time would substantially prejudice our ability to perform our statutory functions which include preparation of material such as that contained in the disclosure. If this were to be placed in the public domain, we consider that there would be a reluctance to share factual details in the future in the submission of responses.

If you are dissatisfied, you may contact informationgovernance@gtcs.org.uk to request GTC Scotland conduct a review of this response. You should describe the original request and explain your grounds of review. You have 40 working days from receipt of this response to submit a review request. When the review process has been completed, if you are still dissatisfied, you may use the Scottish Information Commissioners guidance on making an appeal to do so.