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Information & Public Affairs White Paper Prepared for the Ministry of Defence By Aruna Kulatunga & iMeetingpoint Pty. Ltd. Melbourne, Australia

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Page 1: Defence white paper

Information & Public Affairs White Paper

Prepared for the Ministry of Defence

ByAruna Kulatunga & iMeetingpoint Pty. Ltd.

Melbourne, Australia

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Information and Public Affairs White Paper for Ministry of Defence, Sri Lanka

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Introduction

In modern governance where freedom of information is guaranteed by leg-islation while privacy of the individual is somewhat paradoxically considered paramount, affairs concerning the general public, (Public Affairs) take on a form of complexity hitherto little understood in the government service, other than in high level political propaganda exercises.

The Ministry of Defence (MoD) has become a focal point in terms of han-dling the public affairs component of its many responsibilities, in a scenario fraught with fragility and even more complexity of waging peace and keeping peace.

While the Peace Secretariat should be the primary driver of the information fl ow regarding the peace initiative, the MoD is being drawn into situations where credibility and timeliness of information provided to the public through the media, the access and control of such information and the correct fl ow of the information itself has taken on critical proportions. Such instances can af-fect the peace negotiations and the very important opinion formation process of the public.

In normal circumstances, when there is no confl ict and “crisis” is considered only on ad-hoc basis, information management and the provision of informa-tion to both internal and external stakeholders including the public and the media, is demoted in the list of priorities. In confl ict circumstances, this is revised.

In a situation where a country is coming out of confl ict, but where inappro-priate or non-credible information can damage the processes that are involved in boot-strapping confl ict resolution, it becomes imperative that information management under a comprehensive and coherent public affairs policy is rap-idly implemented, if not already in place.

In order to help achieve the objective of implementing such a policy for the Ministry of Defence, research was carried out utilising available resources including existing diplomatic and defence linkages, of the Public Affairs poli-cies and infrastructures of the Defence and defence related organisations in the United States, United Kingdom, Australia, Sweden, Republic of Macedonia, India and Pakistan.

In each of these countries, there exists a central department within the Ministry of Defence (or its equivalent) covering public affairs and information, providing an umbrella cover for all the organisations that come under each Ministry of Defence. In each of the organisations studied, it was noted that the Ministry supersedes the military organisations in terms of public affairs functions and responsibilities, with very high priority given to the relationship between the Ministry personnel and the military personnel and within the mili-

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tary organisations with the ministry acting as the primary conduit.In most cases, the head of the unit responsible for public affairs is a civilian,

with representatives from the various military and other Ministry of Defence components grouped under the civilian command.

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Proposal

In order to achieve a streamlined, effective, comprehensive and coherent public affairs and information policy for the Ministry of Defence, it is proposed that a new unit within MoD, provisionally named as Directorate of Information & Public Affairs (DIPA) is immediately established.

The unit will be headed by a professional with at least 15 years of experience in Public Affairs, including at least 5 years of experience in senior management positions, either in the public sector or the private sector.

It will initially consist of six other senior staff, including a Deputy Director, who would be from the Sri Lanka Administrative Service (or the Sri Lanka Foreign Service) with at least some experience in Public Affairs, three assistant directors who will be attached to the Unit from the Armed Forces and would be of the seniority of Lt. Colonel or above, a senior operative from the Directorate of Internal Intelligence or its current equivalent and a senior operative from the Directorate of External Intelligence or its current equivalent.

General administrative staff and a librarian will support the unit.The general policies, functions, role and operating procedure for Director

and by extension of the Directorate are enumerated in Annexure 1. Some emphasise is laid on the provision and enhancement of Combat Camera (or COMCAM) operations, due to recent operational “incidents” and the heavy reliance of COMCAM by other agencies.

Linkages to other agencies are specifi cally left out of this report due to con-tingencies of confi dentiality.

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Background

In 1997, the Ministry of Foreign Affairs tasked former Director of Information at the Ministry, Mr. Ravinatha Aryasinghe to come up with a comprehensive plan to revamp the information management structure of the Ministry, supply and management of information to external (foreign) sources and the resourc-es available to achieve a comprehensive counter-propaganda campaign.

At Mr. Aryasinghe’s request, two reports were submitted by myself in my capacity as a corporate communications executive to look at information man-agement in times of crisis and to provide a coherent external “web window” bringing together all of the government’s resources in one external portal with internal linkages. Subsequent to submitting these reports, a “web window” was launched under the url: www.lk following a number of meetings held at the Ministry of Foreign Affairs where all government agencies that have an ex-ternal linkages participated (including the Ministry of Defence – represented by then additional secretary W.A.Silva) under my general guidance. However, the project came to a standstill following CINTEC insistence on control and my departure as counsellor (information) to the UK High Commission. I am happy to see that subsequently Policy Research & Information Unit (PRIU) of the Presidential Secretariat created a series of sites under its umbrella and also initiated the .gov.lk campaign, which was one of the initial suggestions made in my report.

Some of the ideas enumerated below is from the fi rst report with additional material gathered in the past two weeks from the US Department of Defence (US DoD) and the UK Ministry of Defence (UK MoD). Sections 1 to 8 in annexe 1, setting out the policies, responsibilities etc of a new functionary role of a Director (Information and Public Affairs) in the Ministry of Defence is some-what a direct adaptation from US DoD Public Affairs directives and policies as currently set out and Annexure 2 detailing a Code of Practise on access to MoD information is an adaptation of work done for the Ministry of Foreign Affairs and the current Code of Practise for access to government information in the UK.

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The need for information management

Information management in times of Crisis

In times of severe stress or crisis it is important that the public are provided with fast, clear and complete information from authorities and the media. In extreme circumstances, this may be a question of sustaining faith in a demo-cratic society. Authorities that act openly and keep citizens well informed are better equipped for dealing with the situations that can arise in times of severe stress or strife.

The relationship between the public, the authorities and the media is stud-ied and research has shown that the more openness and better relations that exist when dealing with a crisis, the more credibility is gained. The concept of information preparedness can be seen as a refl ection of the importance of information when serious events are unfolding. Such preparedness requires technical resources as well as human skills and endurance.

The concept of information preparedness relates to how well those respon-sible for the dissemination of information are prepared to meet the demands for information and communication in the event of a serious crisis or emergen-cy. It is a question of the extent to which an organisation understands, and can satisfy, the needs for communication with the media and general public before, during and after a period of serious stress, for example, and of the adequacy and sustainability of the technical resources that are available for information purposes.

The general defi nition of information preparedness is:• A public agency’s capability for informing the media and citizens

in times of accidents, disasters, crises and war.The main characteristics of a crisis are that it is unexpected, connected with

risks or threats, creates uncertainty and insecurity, there is very little time and there is great pressure to act. Pressure from the media and the public is enor-mous.

The importance of readiness and speed when starting up an information organisation in a crisis, in order to avoid dealing with an information vacuum is also critical. Most research and experience shows that information in a crisis makes up about70-80% of crisis management. Information forms the basis for decisions, and if a management does not have access to correct, fast and rele-vant information, it cannot make correct, fast or relevant decisions. All of these activities are aimed at gaining the public’s trust in how crises are handled.

Building trust in crisis management is based on four areas; • competence when dealing with a crisis; • total openness with all information, not just the good news but

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also what doesn’t go so well; • fairness, • treating everybody equally; • and empathy.

Research shows very clearly that how the receiver sees you handling a crisis is very important.

Managing Defence Information

Defence information must be managed as a corporate asset within a struc-tured framework. The current environment is characterised by information overload on the one hand and lack of access to, or knowledge of, relevant in-formation sources on the other. Both hinder individual and group productivity, the operational capability of the Armed Forces, exploitation of MOD’s corpo-rate knowledge base and the ability to plan and use resources effectively.

A systematic and structured approach to information management, includ-ing research and analytical processes, will enable information assets to be used far more productively than has been possible in the past. It will also assist in dealing with litigation action and provide improved support to the achieve-ment of MoD objectives,

There must be a strategic assumption that all defence information is share-able within an appropriate security framework. The key to delivering this objec-tive is to develop a better understanding of where decisions need to be made and of the supporting processes and information needs.

Underpinning much of this line of action will be the building blocks of data defi nition and data management that, pragmatically and systematically applied, enable information management.

MoD must provide a range of information access and exchange services that support greater joined-up working between the constituent parts of MoD, between MOD and the rest of Government and with external stakeholders. Traditionally, the constituent parts of MoD have developed local systems hosted on closed networks, leading to information belonging to one group not being readily accessible to other groups within MOD or to external parties. Greater information accessibility within a better-connected environment can be achieved by various means, including:

• of fundamental importance, establishing a Defence-wide infor-mation infrastructure and set of common computing services, including intranets, that together improve internal connectivity and hence enable electronic delivery of information and internal processes, facilitating increased sharing of information and col-laborative working throughout Defence;

• providing points of access or gateways to partners, service families,

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Other Government Departments, Parliament, the media, research organisations, the general public and others, via for example the PRIU Government Portal, to enable secure and legitimate access to a range of information content and transaction processing serv-ices and thus dramatically improving connectivity between MOD and the outside world;

The move to greater joined-up information must be accompanied by consid-eration of potential increased risk to operational and business processes.

MOD must ensure that it has access to appropriately skilled, competent, and well-motivated staff if it is to be able to implement The MoD Information Strategy as well as to conduct the need-driven change programmes that should form part of the impetus towards transforming working practices.

This objective may well present the most signifi cant implementation chal-lenges, as it will require change in deep-rooted organisational and personal competencies and cultures and affect the way that individuals and groups think and work; from the very highest levels of the Department downwards.

Related to developing and sustaining changes to attitudes and culture is the issue of “knowledge”, which is an attribute of people which enables them to make expert and effective judgments on the basis of the information presented to them.

In order to exploit its information assets more fully, MOD must put in place an effective governance regime comprising management processes, structures, roles, responsibilities, and control mechanisms to take forward the planning and management of the constituent parts, as well as the totality, of the Information Strategy. The governance framework must be capable of allowing information requirements to be captured; enabling investment priorities to be determined based on better quality planning information, so that the right de-cisions are made concerning the investments in information capabilities; and providing support for the procurement of information capabilities in a timely, cost-effective, coherent and controlled manner, without being overly specifi ed. It must allow the resource needs of the Strategy to be identifi ed and prioritised. It must also allow the impact of the Strategy on MoD to be monitored and measured using meaningful performance indicators so that areas for improve-ment can be identifi ed and acted upon.

There also needs to be a clear hierarchy of accountability for local infor-mation strategies and plans. These information plans will cascade down to functional unit or team level, with information plans likely for every signifi cant operation, setting out amongst other things, the information management ar-rangements to be followed within command levels and with other agencies.

Overall responsibility for the new information governance framework will rest with Director (Information & Public Affairs) D(IPA) Information, although

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its operation will be delegated as appropriate. In common with other public sector bodies, MOD must meet Information

Age Government targets for electronic service delivery as a means of improving the quality and availability of services to the public and to business. In MOD’s case, this will additionally apply to services provided to the wider defence com-munity, including service families and ex-Service and MOD personnel, together with other Defence related Departments and organisations.

In this, as with all of the other Lines of Development, it should be remem-bered that the focus is on information in the round, and not just on the technology aspects. Records, libraries, documents, research, archives, and all information processes and resources must be deployed in achieving our objec-tives.

In moving towards the strategic outcome, the MoD must continue to balance the benefi ts to be achieved from greater joined-up working with the inherent risk of operational information or activities being compromised as a result of connecting systems into a larger and more diverse community of interests. Provision will need to be made to judge and mitigate risks and for operational continuity, reversionary modes of working and resilience.

The MOD must ensure that it has the means of monitoring threats to its information, and of detecting and responding quickly and effectively to inci-dents, including deliberate electronic attacks when they occur. These systems and procedures must address the full spectrum of Departmental activity, must be fl exible and responsive to changes in the threat, and must take account of MOD’s national and international obligations.

In so doing, business and operationally driven balances must be struck be-tween exploiting the opportunities of the information, especially in the front-line, and protecting information and sustaining processes that rely on informa-tion. Judgements on the balance between sharing information, protection of information and maintaining robust services will have a profound impact on how the strategy is realised.

Strategies rapidly become obsolete unless constantly reviewed and adjusted as part of a permanent strategic management process. Director (Information & Public Affairs) D(IPA) will maintain the currency of the Defence Information Strategy, involving stakeholders formally through Secretary of Defence, other existing and emerging groups, as needed. The work on Information Governance will consider the intimate relationship between this strategy and wider Departmental strategic planning and management processes. It is essen-tial that The Defence Information Strategy, and its on-going implementation and maintenance processes, are integrated fully into the wider corporate plan-ning processes; to inform and be informed by, the operational and business imperatives of the day and to ensure that managers and planners at all levels are aware of how information can support and enhance the delivery of Defence

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outputs. Implementation of The Defence Information Strategy will not be cost neu-

tral. There will be some need to invest in order to exploit the information and co-evolution opportunities and to meet the objectives

At the very least existing programmes, whether Short Term Plan (STP) or Equipment Programme (EP) funded, will need to be adjusted to achieve the greater level of coherence needed to make progress along the lines of action. Some programmes and capabilities will need to be managed centrally, requir-ing the re-brigading of STP, EP resources and a consequential impact on fi nan-cial delegations.

As the implementation of this strategy proceeds and a coherent picture of Defence’s overall information assets and priorities for investment develops, increasingly quantitative assessments for the costs and benefi ts should be pos-sible and details of performance relative to best practice become available.

There is clear scope for improvements in the effi ciency of current invest-ments, especially in areas of duplicated infrastructure and increasingly in terms of application coherence, as the developing understanding of processes reveals commonality amongst organisations and business units. Transparency of the resources expended on information related capability through MoD is essential to developing the coherent picture.

Experience suggests that in the long term money can be saved. Using information in better ways reduces reliance on capital investment and is an increasingly important factor in the commercial sector as the use of ebusiness techniques spreads. Commercial experience of just-in-time instead of just-in-case logistics is a well known example, and the exponential growth of more powerful and cheaper information capabilities is widening the scope to apply this type of benefi t beyond logistics into more administrative processes, as seen in the Banking Sector.

In the operational context, the benefi ts of timely and accurate information are well known and historically proven. However, the necessary cultural and organizational changes needed to realise the benefi ts should not be

The revolution in Information Technology is transforming all areas that af-fect our lives. Defence is no exception, and the new technologies make the effective exploitation of information - long recognised as a key component of military effectiveness – even more important.

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Annexe 1

Policies, guidelines, responsibilities and functions of the Directorate of Information and Public Affairs (DIPA).

1. Assumptions : It has been assumed that the Ministry of Defence (MoD) consists of both military and non-military components (MoD Components), the military components consists of a Unifi ed Chain of Command (UCC) under a General Offi ce Commanding (GOC), that operational activities are undertaken jointly and concurrently under a Joint Forces (JF) command structure. In the case where such structures may not be in place, appropriate amendments will be made dependent on existing structures and future exigencies.

2. Statement of MoD Principles for News Media Coverage of MoD Operations 2.1. It is MoD policy to make available timely and accurate information

so that the public, the Parliament, and the news media may as-sess and understand the facts about national security and defence strategy. Requests for information from organizations and private citizens shall be answered quickly. In carrying out that MoD policy, the following principles of information shall apply: 2.1.1. Information shall be made fully and readily available, con-

sistent with statutory requirements, unless its release is precluded by national security constraints or valid statu-tory mandates or exceptions.

2.1.2. A free fl ow of general and military information shall be made available, without censorship or propaganda, to the men and women of the Armed Forces and their depend-ents.

2.1.3. Information will not be classifi ed or otherwise withheld to protect the Government from criticism or embarrass-ment.

2.1.4. Information shall be withheld when disclosure would adversely affect national security, threaten the safety or privacy of Government personnel or their families, vio-late the privacy of the citizens of Sri Lanka, or be contrary to law.

2.1.5. The Ministry of Defence’s obligation to provide the pub-lic with information on MoD major programs may require detailed Public Affairs (PA) planning and coordination in the Ministry of Defence and with the other Government

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Agencies. Such activity is to expedite the fl ow of informa-tion to the public; propaganda has no place in MoD pub-lic affairs programs.

2.1.6. Open and independent reporting shall be the principal means of coverage of military operations.

2.1.7. Media pools (limited number of news media who rep-resent a larger number of news media organizations for news gatherings and sharing of material during a speci-fi ed activity), are not to serve as the standard means of covering military operations. However, they sometimes may provide the only means of early access to a military operation. In this case, media pools should be as large as possible and disbanded at the earliest opportunity (in 24 to 36 hours, when possible). The arrival of early-access media pools shall not cancel the principle of independ-ent coverage for journalists already in the area.

2.1.8. Even under conditions of open coverage, pools may be applicable for specifi c events, such as those at extremely remote locations or where space is limited.

2.1.9. Journalists in a operational zone shall be credentialed by the military and shall be required to abide by a clear set of military security ground rules that protect the Armed Forces and their operations. Violation of the ground rules may result in suspension of credentials and expul-sion from the combat zone of the journalist involved. News organizations shall make their best efforts to assign experienced journalists to operational areas and to make them familiar with military operations.

2.1.10. Journalists shall be provided access to all major military units. Special operations restrictions may limit access in some cases.

2.1.11. Military PA offi cers should act as liaisons, but should not interfere with the reporting process.

2.1.12. Under conditions of open coverage, fi eld commanders should be instructed to permit journalists to ride on mili-tary vehicles and aircraft when possible. The military shall be responsible for the transportation of pools.

2.1.13. Consistent with its capabilities, the military shall sup-ply PA offi cers with facilities to enable timely, secure, compatible transmission of pool material and shall make those facilities available, when possible, for fi ling inde-

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pendent coverage. If Government facilities are unavail-able, journalists, as always, shall fi le by any other means available. The military shall not ban communications systems operated by news organizations, but electromag-netic operational security in battlefi eld situations may require limited restrictions on the use of such systems.

2.1.14. Those principles in paragraphs above, shall apply as well to the operations of the standing MoD National Media Pool system.

3. OPERATIONAL POLICIES

3.1. It is MoD policy that commanders and heads of the MoD Components involved in joint, combined, and unilateral military operations shall plan for, resource, and conduct public affairs ac-tivities to support such missions.

3.2. In implementing the MoD Principles of Information, the combat-ant commanders shall grant the news media, both civilian and military, access to unclassifi ed joint, combined, and unilateral op-erations, consistent with operations security and prevailing public affairs guidelines (PAG). Concern over the personal safety of jour-nalists shall not be a factor in deciding the degree of access.

4. RESPONSIBILITIES AND FUNCTIONS of DIPA

4.1. The Director (Information & Public Affairs) D(IPA)is the princi-pal staff assistant and advisor to the Secretary and the Additional Secretary of Defence for Ministry of Defence news media relations, public information, internal information, community relations, public affairs and visual information training, and audiovisual mat-ters and shall:4.1.1. Develop policies, plans, and programs in support of MoD

objectives and operations.4.1.2. Ensure a free fl ow of news and information to the news

media, the general public, the internal audiences of the Ministry of Defence, and the other applicable fora, lim-ited only by national security constraints and valid statu-tory mandates or exemptions. Sections 2 and 3 delineate principles that guide the Department regarding public access to information and media coverage of MoD activi-ties.

4.1.3. Ensure Defence WEB (http://www.defenseweb.gov.lk) is operated and maintained as the offi cial primary point of

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access to MoD information on the Internet in accordance with Web Site Administration Policies and Procedures established by the Director

4.1.4. Act as the sole spokesperson and release authority for MoD information and audiovisual materials to news me-dia representatives; evaluate news media requests for MoD support and cooperation; and determine applicable levels of MoD participation.

4.1.5. Establish and exercise procedures for the administra-tive management, activation, and direction of the MoD National Media Pool.

4.1.6. Oversee and coordinate, as necessary, the activities of the MoD National Media Pool for potential use in military contingency operations and other activities.

4.1.7. Monitor, evaluate, and develop systems, standards, and procedures for the administration and management of MoD-approved policies, plans, and programs relating to Public Affairs.

4.1.8. Issue public affairs guidance to the MoD Components.4.1.9. Participate with the relevant authorities in planning, pro-

gramming, and budgeting activities, as required.4.1.10. Promote coordination, cooperation, and mutual under-

standing among the MoD Components and with the other agencies, and the civilian community.

4.1.11. Serve on boards, committees, and other groups, and represent the Secretary of Defence outside of the Department in matters relating to Public Affairs.

4.1.12. Prepare speeches, public statements, parliamentary tes-timony, articles for publication, and other materials for public release by the Secretary of Defence, and other selected MoD and government offi cials, as required.

4.1.13. Serve as offi cial point of contact for public and media activities by the Secretary of Defence; develop short- and long-range plans to communicate policies and programs; and support the execution of such plans, including ad-vance programming and event coordination with other Agencies of Government and with private, public and media organizations.

4.1.14. Receive, analyze, and reply to inquiries on MoD policies, programs, or activities that are received from the general public, either directly or from the other Government

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Agencies. Prepare, and provide to the referring offi ce, replies to inquiries from the general public that are for-warded from other government agencies including but not limited to the President’s Offi ce, the Parliament, the Prime Minister’s Offi ce and the Offi ce of the Cabinet of Ministers.

4.1.15. Evaluate, coordinate, approve and provide policy guid-ance regarding:

4.1.15.1. Requests for MoD support and cooperation in pro-grams involving relations with the public, national associations, and non-governmental organizations. Such programs include, but are not limited to, those involving MoD participation in national and international events held in the Sri Lankan terri-tory, and other events receiving national media coverage.

4.1.15.2. Requests by news media representatives or other non-MoD personnel for travel in military carriers for public affairs purposes,

4.1.15.3. All proposed public affairs guidance, plans, and an-nexes.

4.1.16. Provide MoD assistance to non-Government and enter-tainment-oriented motion picture, television, and video productions.

4.1.17. Evaluate and coordinate the MoD responses to requests for speakers received by the Department and, as re-quired, assist in scheduling, programming, and drafting speeches for the participation of qualifi ed personnel.

4.1.18. Develop, coordinate and oversee the implementation of public affairs policy and plans for MoD participation in activities supporting Sri Lanka’s. international public information programs, in coordination with appropriate MoD offi cials.

4.1.19. Perform such other functions as the Secretary of Defence may prescribe.

5. RELATIONSHIPS

5.1. In the performance of assigned functions and responsibilities, the D(IPA) shall: 5.1.1. Report directly to the Secretary of Defence.5.1.2. Exercise authority, direction, and control over the Joint

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Forces Information Service5.1.3. Coordinate and exchange information with other MoD

and Joint Forces (JF) offi cials, the Heads of the MoD Components, and State Departments and Agencies hav-ing collateral or related functions.

5.1.4. Use existing facilities and services of the Ministry of Defence and other Agencies, when possible, to avoid du-plication and achieve maximum effi ciency and economy.

5.1.5. Maintain liaison with, and provide assistance to, rep-resentatives of the news media, non-Government and entertainment-oriented industry, and members of the public seeking information on the responsibilities and functions in sections above.

5.2. Other JF offi cials and the Heads of the MoD Components shall co-ordinate with the D(IPA) on all matters related to the authorities, responsibilities and functions assigned in this Directive.

6. AUTHORITIES

6.1. The D(IPA) is hereby delegated authority to: 6.1.1. Issue MoD Instructions, Publications, and one-time

directive-type memoranda, which carry out policies ap-proved by the Secretary of Defence in assigned fi elds of responsibility. MoD Instructions that have operational implications shall be coordinated with the General Offi ce Commanding (GOC).

6.1.2. Obtain reports, information, advice, and assistance, con-sistent with the MoD policy as necessary.

6.1.3. Communicate directly with the Heads of the MoD Components. The channel of communications with the Combatant Commands on public affairs matters shall be between the D(IPA) and the Commanders of the Combatant Commands. Communications that have op-erational implications shall be coordinated with the GOC. Joint Staff communications that have public affairs policy or guidance implications shall be coordinated with the D(IPA).

6.1.4. Communicate with the other State Departments and Agencies, the representatives of the Legislative Branch, the news media, the non-Government and entertain-ment-oriented industry, and the members of the public.

6.1.5. Establish arrangements for MoD participation in those

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non-MoD Government programs for which the D(IPA) has been assigned primary staff cognizance.

6.1.6. Act as the sole agent at the Seat of Government for the release of offi cial MoD information for dissemination through any form of public information media. This may be delegated to MoD Components, as appropriate.

6.1.7. Establish accreditation criteria similar to the UK Green Book and serve as the approving and issuing authority for credentials for newsgathering media representatives travelling with coverage of offi cial MoD activities.

6.1.8. Approve participation of MoD Components in public ex-hibitions, demonstrations, and ceremonies of national or international signifi cance.

6.1.9. Portions of the authorities listed in this section may be delegated to MoD Components as appropriate to that Agency or Service.

6.2. Director (Information and Public Affairs) shall: 6.2.1. Retain primary responsibility for the consistent imple-

mentation of MoD information policy in this 6.2.2. Determine who shall serve as the initial source of infor-

mation about joint, combined, and unilateral operations and decide whether to delegate public affairs release au-thority to combatant command level.

6.2.3. Review, coordinate, approve, and disseminate PAG, pub-lic affairs plans, and public affairs annexes

6.2.4. Establish and exercise procedures for the administra-tive management, activation, and direction of the MoD National Media Pool; and direct the deployment of the MoD National Media Pool when ordered by the Secretary of Defence.

6.2.5. Coordinate public affairs matters within the Ministry of Defence and with other State Departments and Agencies outside the Ministry of Defence.

6.2.6. Provide policy guidance for the employment of joint combat camera teams (COMCAM) (see below for de-tailed policy on COMCAM) and the distribution of their products. The audiovisual products of combat camera teams shall be appropriately classifi ed at the source and may be cleared for public release in accordance with MoD Directive on Camera Assets

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6.2.7. Provide representation to the JF Crisis Coordination Centre and establish, as necessary, a crisis and/or war-time public affairs cell at the Ministry to provide continu-ous public affairs planning, to gather and disseminate information, and to evaluate public affairs support of the operational mission.

6.2.8. Conduct periodic news briefi ngs on issues and events about ongoing joint, combined, and unilateral opera-tions.

6.2.9. Support Unifi ed Combatant Command plans for the command information mission, including the deploy-ment of broadcast facilities from the Army Radio and Television Service (ARTS), and distribution of print media. The on-scene commander shall determine when these services should begin, but services will be provided at the earliest practicable opportunity.

6.2.10. Conduct joint public affairs training at appropriate Defence Training Schools for entry- and advanced-level military and civilian public affairs personnel of all grades.

6.2.11. In coordination with the Defence Training Schools, the General Offi cer Commanding, the Military Departments, and the Unifi ed Combatant Commands, develop, teach, and maintain public affairs policy.

6.2.12. Activate the MoD National Media Pool. 6.3. The Chief of Staffs of three Armed Forces shall:

6.3.0.1. Coordinate closely with the combatant command-ers to determine the resources (personnel and equipment) needed to conduct successful public affairs activities in joint or single-Service environ-ments. Ensure the prompt and sustained availabil-ity of Active and Reserve component public affairs resources needed to support any assigned mission. Ensure that a fully capable public affairs structure, made up of Active and Reserve component assets, exists to support short-notice deployments.

6.3.0.2. Organize, train, fund, and equip public affairs per-sonnel and units to conduct public affairs activities in support of combatant commanders conducting operations. Personnel and units needed to sup-port the earliest stages of any operation should be immediately available for deployment to assist the

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supported commander in chief in addressing news media information requirements.

6.3.0.3. Conduct Service-unique public affairs programs required to support joint and unilateral operations. Included are command information programs that serve deployed military personnel and the military forces and families at home station, as well as com-munity relations programs designed to meet exist-ing MoD policies and Directives.

6.3.0.4. Ensure that public affairs personnel are properly trained, qualifi ed, and able to function in joint, combined, and unilateral operational environ-ments.

6.3.0.5. Provide public affairs training at Service schools and encourage programs that improve understand-ing and cooperation between the military and the news media.

6.3.0.6. Provide news media training for public affairs per-sonnel, commanders, and key staff who would be involved in media relations activities.

6.3.0.7. Support planning and provide resources for con-tingency and operations of ARTS.

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6.3.1. The General Offi cer Commanding (GOC) shall: 6.3.1.0.1. Promulgate joint public affairs doctrine.6.3.1.0.2. Ensure that existing operational public affairs plans

comply with published joint public affairs doctrine and guidance.

6.3.1.0.3. Establish a General Offi cer Commanding (GOC) Public Affairs Response Cell within the National Military Command Centre during times of crisis and confl ict to provide public affairs support to the Offi ce of the Director (Information & Public Affairs) D(IPA).

6.3.1.0.4. Support the Ministry of Defence in explaining mis-sion aspects of joint and unilateral operations by making available senior offi cers with expertise on matters of interest to the news media and the pub-lic.

6.3.1.0.5. Plan for the employment of combat camera assets in crisis situations, planned operations, and exer-cises

6.3.1.0.6. Plan for the employment of Reserve component public affairs assets to support the unique public information and command information require-ments of mobilized Reserve component units.

6.3.2. The Commanders of the Unifi ed Combatant Commands shall:

6.3.2.0.1. Include in operation plans an annex that establish-es responsive public affairs organizations and struc-tures; and provides dedicated personnel, facilities, equipment, transportation, and communications assets to the public affairs mission. Since resources should ideally be in place before the beginning of operations, deployment plans shall assign a high priority for the movement of public affairs assets. To ensure that adequate public affairs support is available to meet news media requirements, there shall be a high priority assigned for the movement of public affairs assets by air and ground transpor-tation.

6.3.2.0.2. Plan to support news media from the earliest plan-ning and pre-deployment stages of any operation. Commanders shall ensure that reporters are grant-

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ed all possible access to all unclassifi ed activities, including combat operations. The personal safety of correspondents is not a reason for excluding them from such situations. The goal is to treat the news media as members of units, allowing them to accompany the organizations during the conduct of their missions.

6.3.2.0.3. Besides the planning required as above, develop operational public affairs policy and guidance in accordance with MoD Instruction which recom-mends the policy approach (active or passive), proposes news statements, and provides responses to anticipated news media questions.

6.3.2.0.4. Prepare for and assist in the deployment and op-eration of the MoD National Media Pool.

6.3.2.0.5. Conduct a full range of public affairs activities consistent with current Public Affairs Guidelines (PAG), public affairs release authority, and opera-tions security requirements.

6.3.2.0.6. As appropriate, establish, resource, and operate Joint Information Bureaus (JIBs) to serve as focal points of interface between the joint forces and the news media.

6.3.2.0.7. Assist news media in gaining access to the full spec-trum of military units and personnel conducting joint and unilateral operations, subject to special operations restrictions. Access includes command-ers, staffs, offi cers, and enlisted personnel directly involved with combat and sustainment operations.

6.3.2.0.8. As needed, support on a 24-hour basis other information requirements identifi ed by D(IPA) Provide daily JIB, CIB, or APIC situation reports to D(IPA) during current operations as circumstances require, apprising D(IPA) immediately of major op-erational developments, incidents, or other news-worthy events.

6.3.2.0.9. Prepare plans to conduct command information programs using, as appropriate, component assets and resources. Plan to employ the capabilities of ARTS and other internal news media products that convey information to deployed forces, to those

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remaining at the home station, and to all family members.

6.3.2.0.10. Ensure that ground rules for releasing information are applied equally to military reporters assigned command information tasks and to civilian report-ers.

6.3.2.0.11. Provide public affairs resources (personnel, equip-ment, transportation, and communications) to the supported combatant commander as identifi ed in approved contingency or operations plans. Be prepared to reinforce the supported combatant commander to meet unplanned resource require-ments.

6.3.2.0.12. Designate an offi cer as the combat camera repre-sentative to plan for the employment of combat camera assets.

6.3.2.0.13. In accordance with reference above, plan for the employment of combat camera assets in crisis situ-ations, planned operations, and exercises. Provide the Joint Combat Camera Centre appropriate com-bat camera documentary products for release to the news media through D(IPA).

6.3.2.0.14. Ensure that public affairs personnel and units are properly prepared to support the assigned opera-tional mission.

6.3.2.0.15. Support the public affairs requirements of Reserve component units mobilized and deployed in a theatre of operations. Unlike active duty forces, which generally deploy from major installations, Reserve component units come from communi-ties throughout the country. Reserve component personnel leave civilian jobs behind, and Reserve component family members are generally not ac-customed to long-term deployments. Support from family members, community leaders, and former employers is vital to unit and individual morale and to recruiting and retention efforts following demo-bilization. Commanders must ensure that Reserve component family members and hometown news media are provided a continuous fl ow of informa-tion to dispel rumours and anxieties, sustain public awareness, and increase understanding of Reserve

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component units and their missions in the theatre of operations.

7. Combat Camera (COMCAM).

7.1. The acquisition and utilization of still and motion imagery in support of combat, information, humanitarian, special force, in-telligence, reconnaissance, engineering, legal, public affairs, and other operations involving the Military Services.

7.2. COMCAM Forces. 7.2.1. Military personnel trained and employed to acquire,

process, and transmit classifi ed and unclassifi ed still and motion imagery in support of air, sea, and ground mili-tary operations.

7.3. COMCAM Imagery. 7.3.1. Still and motion images of military operations, equip-

ment, and people acquired by COMCAM Forces, regard-less of the medium in which the images are acquired, transmitted, or displayed.

7.4. Joint-Interest Imagery. 7.4.1. Imagery that depicts subjects of known or probable in-

terest to the Offi ce of the Secretary of Defence (OSD), the General Offi ce Commanding (GOC), or more than one MoD Component. All COMCAM imagery shot in the joint environment is assumed to be joint-interest im-agery. Other imagery, both from COMCAM sources and other-than-COMCAM sources (such as Public Affairs (PA) and photojournalists), that depicts subjects of known or probable interest to the OSD, the (GOC), or more than one MoD Component, is also joint-interest imagery.

7.5. POLICY 7.5.1. It is MoD policy that:

7.5.1.1. COMCAM is an essential battlefi eld information resource that supports strategic, tactical, and op-erational mission objectives. It is a deployable force multiplier that provides Commanders with combat trained documentation teams that are primary sup-pliers of operational imagery to support battlefi eld information superiority.

7.5.1.2. The mission of COMCAM is to provide the OSD, the GOC, the Military Departments, the Combatant Commands, and the Joint Task Forces (JTF) with

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a directed imagery capability in support of opera-tional and planning requirements during wartime operations, crises, contingencies, and joint exer-cises. The COMCAM mission can support, but is independent from unique imagery operations and systems designed to meet specifi c visual informa-tion (VI) mission requirements, such as is the case with Intelligence, Operational Test and Evaluation, and certain other MoD functions.

7.5.1.3. COMCAM Forces shall be tasked, deployed, and employed as an integral part of operations to en-sure documentation of the entire scope of military activities during wartime operations, crises, contin-gencies, joint exercises and other events involving the MoD Components having signifi cant national interest.

7.5.1.4. COMCAM imagery shall be forwarded immedi-ately to a central MoD reception and distribution point as a shared resource to simultaneously sup-port the operational and planning requirements of OSD, GOC, the Military Departments, and the Combatant Commands. Those requirements include situational awareness, information opera-tions, mission assessment, legal documentation, and PA.

7.5.1.5. Except when it would delay forwarding, review of unclassifi ed COMCAM imagery for possible public release shall be accomplished in theatre, at the lowest practical level.

7.5.1.6. The MoD Joint Combat Camera Centre (JCCC) shall serve as the central MoD reception and distri-bution point for COMCAM imagery. The JCCC shall distribute COMCAM and other joint-interest image-ry to the OSD, the GOC, the Military Departments, the Combatant Commands, the Defence Agencies, and the other MoD Components.

7.6. D(IPA) RESPONSIBILITIES 7.6.1. The Director (Information & Public Affairs) D(IPA):

7.6.1.1. Serve as the OSD Principal Staff Assistant for the Joint COMCAM Program.

7.6.1.2. Provide and monitor the implementation of MoD

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COMCAM policy and issue supplemental guidance and instruction, as required, to ensure program ef-fectiveness.

7.6.1.3. Conduct management oversight of the Joint COMCAM Program.

7.6.1.4. Operate and maintain the JCCC as the MoD central reception and distribution point for classifi ed and unclassifi ed COMCAM and other joint-interest im-agery.

7.6.1.5. Establish and coordinate communication require-ments with the Combatant Commands to transmit COMCAM imagery to the JCCC.

7.6.1.6. Recommend to the Commanders of the Combatant Commands to deploy and employ COMCAM Forces to document events likely to yield high value imagery for public affairs and other applications.

7.6.1.7. Provide technical training for COMCAM personnel. 7.6.1.8. Distribute information to assist those who plan for

and use COMCAM imagery. 7.6.1.9. Chair the JCCPG to provide contingency, deliber-

ate, and exercise planning support, and to establish procedural and technical interoperability standards for COMCAM Forces, equipment, and systems.

7.6.1.10. Operate a central MoD VI records centre to retain, preserve, catalogue, and make COMCAM-gener-ated record material accessible.

7.6.1.11. Provide a primary and alternate COMCAM repre-sentative to the National Military Command Centre (NMCC) and the OSD Crisis Coordination Centre when necessary to facilitate COMCAM integration into operations.

7.6.1.12. Coordinate with the GOC and the Combatant Commands in the development of joint COMCAM doctrine.

7.7. The General Offi ce Commanding (GOC)shall: 7.7.1. Identify and include in all applicable implementing or-

ders COMCAM objectives, priorities, and tasking in sup-port of the OSD, the GOC, the Combatant Commands, and the Military Departments during wartime operations, worldwide crises contingencies, joint exercises, and other worldwide crises contingencies, joint exercises, and other

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events involving the MoD Components having signifi cant national interest.

7.7.2. Plan for and coordinate the deployment of COMCAM Forces with the Combatant Commands and the Military Departments.

7.7.3. Promulgate joint COMCAM doctrine. 7.7.4. Establish a position on the Joint Staff to coordinate inte-

gration of COMCAM Forces into operations and identify imagery requirements for the Joint Staff. The incumbent shall be the GOC representative on the JCCPG.

7.7.5. Request joint COMCAM representation to GOC response cell in the NMCC during crises to coordinate imagery mission requirements and direct imagery distribution.

7.8. The Commanders of the Combatant Commands shall: 7.8.1. Plan for, task, deploy, and employ COMCAM Forces dur-

ing wartime operations, crises, contingencies, joint exer-cises, and other events involving the MoD Components having signifi cant national interest. In all applicable crisis action and deliberate plans, include a COMCAM Concept of Operations and initial imagery requirements.

7.8.2. Expeditiously provide classifi ed and unclassifi ed COMCAM imagery to the JCCC for immediate distribu-tion.

7.8.3. Assist COMCAM Forces in coordinating facilities, trans-portation, and communications, and provide other logis-tical support to sustain deployed personnel.

7.8.4. Plan to employ COMCAM Forces during the initial phases of an operation to ensure comprehensive mission docu-mentation. Ensure that COMCAM Forces have full mis-sion access, as is reasonably and tactically feasible, during each phase of the operation.

7.8.5. Identify a COMCAM staff position to plan for the em-ployment of COMCAM Forces. The COMCAM staff posi-tion shall have the primary responsibility to integrate COMCAM Forces in theatre, establish mission priorities, and coordinate imagery requirements for the supported staff. The incumbent shall be the Combatant Command representative on the JCCPG.

7.8.6. Ensure that tasking orders and requests for forces iden-tify the operational controlling authority for COMCAM Forces in advance of deployment and provide an in-thea-

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tre point of contact for initial coordination. 7.8.7. Establish a Joint COMCAM Management Team (JCMT) in

JTFs, when appropriate, to prioritize COMCAM imagery missions and direct documentation and imagery distribu-tion efforts. The JCMT shall receive guidance from the Combatant Command or the supported JTF Commander.

7.8.8. Assign operational control for the theatre Weapons Systems Video (WSV) COMCAM team to the JTF. The WSV team shall normally be co-located with the Commander, Air Force Forces or the Joint Force Air Component Commander.

7.8.9. Ensure COMCAM imagery is reviewed for protection of classifi ed information and transmitted in accordance with applicable security regulations and local instructions.

7.8.10. Ensure that unclassifi ed COMCAM imagery is reviewed by a PA representative and designated either cleared or not cleared for distribution to sources external to the Department of Defence. Authority to clear imagery for release may be delegated to the JTF or Component Command PA representative to expedite the movement of imagery.

7.8.11. Coordinate with the JCCC and publish specifi c guidelines for imagery distribution, clearance, and security classifi ca-tion requirements.

7.8.12. Include within the Operations Plan the communication requirements necessary for the transmission of COMCAM imagery to the JCCC.

7.8.13. Ensure COMCAM Forces participating in joint exercises receive training based on criteria from the Mission-Essential Task Listing.

7.9. The Secretary of Defence shall provide the strategic telecommuni-cations technology and services required to ensure the availability, reliability, and security of COMCAM imagery commensurate with its intended use.

7.10. The Chief of Staff’s of the Military Departments shall: 7.10.1. Organize, train, and equip COMCAM personnel and

units to provide highly responsive imagery acquisition, processing and transmission capabilities in support of operational and planning requirements during wartime operations, crises, contingencies, and joint exercises. COMCAM resources shall be force sized to support the

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Joint Strategic Capabilities Plan force structure. 7.10.2. Ensure that personnel and the units tasked in support

of joint or combined COMCAM missions are properly trained to effectively function in a joint or combined op-erational environment.

7.10.3. Establish readily deployable and adaptive COMCAM force packages that may operate within JTF component com-mands and /or be integrated into a JTF headquarters staff.

7.10.4. Coordinate with the Combatant Commands and the GOC through the JCCPG to ensure that COMCAM personnel, equipment, doctrine, and training are interoperable and complementary.

7.10.5. Provide COMCAM or VI personnel to supplement the imagery capabilities of the JCCC and the Combatant Commands for extended operational periods.

7.10.6. Designate a qualifi ed offi cer to be a member of the JCCPG.

7.11. The Chief of Staff of the Army shall: 7.11.1. As the Network Infrastructure Services Agency for the

Ministry of Defence, provide information technology services to the JCCC.

7.11.2. As the VI service centre, provide visual information sup-port to the JCCC.

7.11.3. Ensure availability of static line and free fall jump-quali-fi ed COMCAM personnel to support operational require-ments.

7.12. The Chief of Staff of the Navy shall7.12.1. Ensure the availability of COMCAM personnel with ship-

board and underway experience. 7.12.2. Ensure the availability of aircrew and diver-qualifi ed

COMCAM personnel with appropriate equipment to sup-port operational requirements.

7.12.3. Ensure the availability of Special Forces (Navy) COMCAM personnel to support operational requirements.

7.12.4. Appoint an offi cer from the Special Forces (Navy) to serve as a member of the JCCPG.

7.13. The Chief of Staff of the Air Force shall: 7.13.1. Ensure availability of aircrew qualifi ed COMCAM person-

nel to support operational requirements.

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7.13.2. Ensure availability of COMCAM personnel qualifi ed and equipped to centrally manage, process, and distribute both classifi ed and unclassifi ed WSV collected from each of the Military Services, to support level-level operational requirements. Equipment and management process shall meet interoperability requirements and reporting timelines of joint-automated systems supporting the joint targeting cycle, as identifi ed by the Joint Staff and joint doctrine.

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Annexe B

Code of Practice on Access to MoD Information

MOD has a responsibility to respond positively to any request for informa-tion. In general, information should be released in the most cost effective man-ner. Answers must be open, honest and unambiguous. They must not deceive or mislead. Information should only be withheld where the Code allows it and advice to Ministers should identify any information why it is not possible to publish and explain the reasons why.

It is never acceptable to say, as has been done regularly in the past, that it is not our practice to release a particular type of information. No categories of information are automatically excluded from disclosure.

Categories of information that may be exempted from release when it is in the public interest are listed in Part II of the Code (reproduced at ANNEX B). Each request must be treated individually and judged on its own merits. There should not be the assumption that if information has been exempt in the past it will continue to be so. The emphasis must always be on allowing as much information as possible to pass into the public domain.

1. Reasons For Confi dentiality

The following categories of information are exempt from the commitments to provide information in this Code. In those categories that refer to harm or prejudice, the presumption remains that information should be disclosed un-less the harm likely to arise from disclosure would outweigh the public interest in making the information available. References to harm or prejudice include both actual harm or prejudice and risk or reasonable expectation of harm or prejudice. In such cases, it should be considered whether any harm or preju-dice arising from disclosure is outweighed by the public interest in making information available. The exemptions will not be interpreted in a way that causes injustice to individuals.

1.1. Defence, Security and International Relations 1.1.1. Information whose disclosure would harm national secu-

rity or defence. 1.1.2. Information whose disclosure would harm the conduct

of international relations or affairs.1.1.3. Information received in confi dence from foreign govern-

ments, foreign courts or international organisations. 1.2. Internal discussion and advice Information whose disclosure

would harm the frankness and candour of internal discussion, including:

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1.2.1. Proceedings of Cabinet and Cabinet committees. 1.2.2. Internal opinion, advice, recommendation, consultation

and deliberation. 1.2.3. Projections and assumptions relating to internal policy

analysis; analysis of alternative policy options and infor-mation relating to rejected policy options.

1.2.4. Confi dential communications between Departments, public bodies and regulatory bodies.

1.3. Communications with the President’s Offi ce1.3.1. Information relating to confi dential communications

between Ministers and the President, or relating to confi -dential proceedings of the Cabinet of ministers

1.4. Law enforcement and legal proceedings. 1.4.1. Information whose disclosure could prejudice the ad-

ministration of justice (including fair trial), legal proceed-ings or the proceedings of any tribunal, public inquiry or formal investigations (whether actual or likely) or whose disclosure is, has been, or is likely to be addressed in the context of such proceedings.

1.4.2. Information whose disclosure could prejudice the en-forcement or proper administration of the law, including the prevention, investigation or detection of crime, or the apprehension or prosecution of offenders.

1.4.3. Information relating to legal proceedings or the pro-ceedings of any tribunal, public inquiry or other formal investigation which have been completed or terminated, or relating to investigations which have or might have resulted in proceedings

1.4.4. Information covered by legal professional privilege.1.4.5. Information whose disclosure would harm public safety

or public order, or would prejudice the security of any building or penal institution

1.4.6. Information whose disclosure could endanger the life or physical safety of any person, or identify the source of information or assistance given in confi dence for law en-forcement or security purposes

1.4.7. Information whose disclosure would increase the likeli-hood of damage to the environment, or rare or endan-gered species and their habitats.

1.5. Immigration and nationality Information relating to immigration,

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nationality, consular and entry clearance cases. However, infor-mation will be provided, though not through access to personal records, where there is no risk that disclosure would prejudice the effective administration of immigration controls or other statutory provisions.

1.6. Effective management of the economy and the collection of tax 1.6.1. Information whose disclosure would harm the ability of

the Government to manage the economy, prejudice the conduct of offi cial market operations, or could lead to improper gain or advantage.

1.6.2. Information whose disclosure would prejudice the assessment or collection of tax, duties or National Insurance contributions, or assist tax avoidance or eva-sion.

1.7. Effective management and operations of the public service 1.7.1. Information whose disclosure could lead to improper

gain or advantage or would prejudice: 1.7.1.1. the competitive position of a Department or other

public body or authority; 1.7.1.2. negotiations or the effective conduct of personnel

management, or commercial or contractual activi-ties;

1.7.1.3. the awarding of discretionary grants. 1.8. Information whose disclosure would harm the proper and effi -

cient conduct of the operations of a department or other public body or authority, or of any regulatory body.

1.9. Public employment, public appointments and honours 1.9.1. Personnel records (relating to public appointments as

well as employees of public authorities) including those relating to recruitment, promotion and security vetting.

1.9.2. Information, opinions and assessments given in confi -dence in relation to public employment and public ap-pointments made by Ministers

1.9.3. Information, opinions and assessments given in relation to recommendations for honours.

1.10. Voluminous or vexatious requests Requests for information which are vexatious or manifestly unreasonable or are formulated in too general a manner, or which (because of the amount of informa-tion to be processed or the need to retrieve information from fi les not in current use) would require unreasonable diversion of

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resources. 1.11. Publication and prematurity in relation to publication Information

which is or will soon be published, or whose disclosure, where the material relates to a planned or potential announcement or pub-lication, could cause harm (for example, of a physical or fi nancial nature).

1.12. Research, statistics and analysis 1.12.1. Information relating to incomplete analysis, research or

statistics where disclosure could be misleading or deprive the holder of priority of publication or commercial value.

1.12.2. Information held only for preparing statistics or carry-ing out research, or for surveillance for health and safety purposes (including food purposes), and which relates to individuals, companies or products which will not be identifi ed in reports of that research or surveillance, or in published statistics.

2. Privacy of an individual

2.1. Unwarranted disclosure to a third party of personal information about any person (including a deceased person) or any other disclosure, which would constitute or could facilitate an unwar-ranted invasion of privacy.

3. Third party’s commercial confi dences

3.1. Information including commercial confi dences, trade secrets or intellectual property whose unwarranted disclosure, which would constitute or could facilitate an unwarranted invasion of privacy.

4. Information given in confi dence

4.1. a. Information held in consequence of having been supplied in confi dence by a person who: 4.1.1. gave the information under a statutory guarantee that its

confi dentiality would be protected; or 4.1.2. was not under any legal obligation, whether actual or

implied, to supply it, and has not consented to its disclo-sure.

4.1.3. Information whose disclosure without consent of the supplier would prejudice the future supply of such infor-mation.

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5. Medical information

5.1 Information provided in confi dence if disclosure to the subject would harm their physical or mental health, or should only be made by a medical practitioner.

6. Statutory and other restrictions

6.1. Information whose disclosure is prohibited by or under any enact-ment, regulation, or international agreement.

6.2. Information whose release would constitute a breach of Parliamentary Privilege.

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