Growth

Summary

A request was made for details on growth areas identified in external validations of Isle of Man high schools and the support provided, but the Department of Education, Sport and Culture withheld all information citing exemptions related to audit functions, policy formulation, and the conduct of public business.

Key Facts

• The request was received on 2025-02-19 and the response was issued on 2025-03-04.
• The Department determined that all requested information was held but exempt from disclosure.
• The external validation process is described as 'live' and ongoing.
• Etio is the body responsible for carrying out the external validation of schools.
• The Department argued that disclosure would prejudice the effectiveness of the audit and hinder open professional dialogue.

Data Disclosed

• 2025-02-19
• 2025-03-04
• 4456481
• 5
• 1

Exemptions Cited

• Section 33 (a)(b) – Audit Functions
• Section 34 (a) Formulation of Policy
• Section 35 (c) – Conduct of Public Business

Original Request

In reference to written questions in Tynwald: What areas of growth were identified in the external validation of each of the island's high schools and what support the department is providing to help achieve these aims.

Data Tables (1)

Full Response Text

Policy, Strategy and Governance Division Department of Education, Sport and Culture Thie Slieau Whallian Foxdale Road St Johns IM4 3AS

Telephone: (01624) 685808 Website: www.gov.im/dec Email: dec@foi.gov.im

Our ref: 4456481 4th March 2025

Dear ###,

We write further to your request, received 19 February 2025, which states:

"In reference to written questions in Tynwald: What areas of growth were identified in the external validation of each of the island's high schools and what support the department is providing to help achieve these aims."

Our response to your request is as follows:

While our aim is to provide information whenever possible, in this instance the Department determines the requested information is exempt from disclosure under:

Section 33 (a)(b) – Audit Functions
In this instance the information is exempt under section 33 of the Act as disclosure would be likely to prejudice the examination of the economy, efficiency and effectiveness with which other public authorities use their resources in discharging their functions.

As section 33 is a qualified exemption, it is subject to a public interest test. The public interest must be something that is of serious concern and benefit to the public at large.

Factors in favour of disclosure • To further public understanding of decisions made by public authorities.

• To promote accountability and transparency in relation to decision making and the use of public funds by public authorities.

• Disclosure of the requested information could lead to a greater public confidence in the integrity of the external validation process.

Factors in favour of withholding • There is a clear public interest in protecting the effectiveness and integrity of any audit process.

• The Department considers the public interest clearly rests in protecting Etio’s ability to carry out its external validation of all schools and educational services. The external validation team require a ‘safe space’ in which to assess the accuracy of the self-evaluation judgements formed by schools or educational services against the quality assurance framework and enable implementation of continued well – informed improvement. Disclosure may prejudice this process.

• Full disclosure would hinder the open, professional dialogue between Etio, schools, educational services and the Department.

• Full disclosure would be likely to harm and disrupt the ability of Etio to carry out its ongoing validation of the schools and educational services. Whilst this process is ongoing it would be likely to hinder the external validation team’s ability to carry out further robust validation visits of schools or educational services.

• It is in the public interest for Etio to assist and work with the schools and educational services to enable growth and development priorities to be put in place as quickly and as efficiently as possible.

• Full disclosure of findings could prejudice the implementation of growth priorities which schools and educational services need an opportunity to fully consider, implement, and test recommendations away from the public gaze.

• Full disclosure of the requested information would be likely to hinder ongoing monitoring and improvement by shifting focus backwards to the validation process rather than forward to growth and development.

• The external validation process is live.

In taking these factors into account the Department of Education, Sport and Culture determined that the factors in favour of maintaining the exemption outweigh the factors in favour of disclosing the information.

Section 34 (a) Formulation of Policy
In this instance the Department determines the information is also exempt from disclosure under section 34 of the Act as it is held by the Department and it relates to the formulation or development of government policy.

As section 34 is a qualified exemption, it is subject to a public interest test. The public interest must be something that is of serious concern and benefit to the public at large.

Factors in favour of disclosure
• There’s a public interest in disclosing factual information used to provide an informed back-ground to decision taking.

• Information disclosed prior to decisions being taken will facilitate more informed public debate.

Factors in favour of withholding • The timing of the request – the external validation process is live and ongoing.

• For schools and educational services to implement any growth priorities, schools and educational services need a safe space and time to fully consider, implement, and test recommendations without the need to defend them.

• Public exposure of the information may compromise candid and robust discussions between Etio and the Department’s schools, educational services and the Department.

• To protect the deliberative process and provide a safe space to protect information for internal use only which may contribute to formulation of policy and development.

• Disclosure of the information in the format provided to schools and educational services could be misinterpreted and therefore misleading the public.

Section 35 (c) – Conduct of Public Business Further, in this instance the Department determines the information is also exempt under section 35 of the Act, as disclosure would be likely to otherwise prejudice the effective conduct of public business.

As section 35 is a qualified exemption, it is subject to a public interest test. The public interest must be something that is of serious concern and benefit to the public at large.

Factors in favour of disclosure
• Disclosure of the information would support transparency and promote openness and accountability to the general public.

• Informing public debate on important matters.

Factors in favour of withholding

• Disclosure would be likely to inhibit the ability of Etio, schools, educational services and the Department to express themselves openly, honestly and completely as part of the external validation process. The authority needs a ‘safe space’ in which to develop ideas or make decisions and disclosure may prejudice this and/or interfere with or distract from the process, or would prejudice or undermine the information itself, rather than the frankness of the information specifically.

• The timing of the request – the external validation process is live and ongoing.

• The authors and contributors know and understand the exact context of the information. There is a risk that should the Department disclose the information

in the format provided to schools and educational services that the information could be misinterpreted and therefore may be misleading the public.

In taking these factors into account the Department of Education, Sport and Culture determined that the factors in favour of maintaining the exemption outweigh the factors in favour of disclosing the information.

Advice and Assistance

By way of advice and assistance, in total four secondary schools, eleven primary schools and one educational service have completed their external validation process at present. The parent information following completion of the external validation process can be found on the individual school or the Department website for educational services. The information published following the external validation visit includes the key findings, themes, any areas of growth, and detail of the information provided to the school or educational service, but does not include personal data and is provided in such a way to provide clarity in a language that is appropriate and accessible, so not to be misinterpreted.

The Department is of course keen to understand the themes which have been identified during the external validation process, whether that be areas of strength or areas for growth and development. The Department will be publishing an annual overview compiled by Etio, which will provide an analysis of the themes, a compelling narrative around the priorities emerging and highlight key considerations.

By acknowledging these areas, a foundation can then be created with constructive dialogue and targeted interventions into schools and educational services, that will enhance learner outcomes and continue to establish a self-improving education system. Providing an understanding of areas for growth and development will allow the Department to provide focused growth support, which will enable the provision of additional or focused support for a school or educational service to ensure the capacity for future improvement.

Please quote the reference number 4456481 in any future communications.

Your right to request a review

If you are unhappy with this response to your freedom of information request, you may ask us to carry out an internal review of the response, by completing a complaint form and submitting it electronically or by delivery/post.

An electronic version of our complaint form can be found by going to our website at https://services.gov.im/freedom-of-information/Review . If you would like a paper version of our complaint form to be sent to you by post, please contact me and I will be happy to arrange for this. Your review request should explain why you are dissatisfied with this response, and should be made as soon as practicable. We will respond as soon as the review has been concluded.
If you are not satisfied with the result of the review, you then have the right to appeal to the Information Commissioner for a decision on;

1. Whether we have responded to your request for information in accordance with Part 2 of the Freedom of Information Act 2015; or
2. Whether we are justified in refusing to give you the information requested.
   In response to an application for review, the Information Commissioner may, at any time, attempt to resolve a matter by negotiation, conciliation, mediation or another form of alternative dispute resolution and will have regard to any outcome of this in making any subsequent decision. More detailed information on your right to a review can be found on the Information Commissioner’s website at www.inforights.im. Should you have any queries concerning this letter, please do not hesitate to contact me. Further information about freedom of information requests can be found at www.gov.im/foi.

I will now close your request as of this date.