Trauma Related Grey Documents
Reference: 24-25068
Date response sent: 15/05/2024
Details of enquiry
I am currently looking into how trauma-informed care is conceptualised in the UK.
As part of my research, I am interested in evaluating trauma-related tools in a mental health care setting and have been used by colleagues to mitigate the issues around the implementation of trauma-informed care principles within the organisation. With the hopes that we address potential secondary traumatic stress that staff burnout can impact on the service.
I have copied in my “grey methods section” from my protocol so, it would help you understand the intentions of my study.
Response sent
Your request for information, as detailed in your email below, has been handled under the Freedom of Information Act 2000 (FOIA). We thank you for sharing with us the brief for your doctorate. Please find below our response:
We are sorry to be sending you what must be a disappointing response, but we cannot provide the information as requested, and you appear to have misunderstood what can be requested under FOIA.
We must therefore advise you that access to internal training documentation is not permitted (FOIA exemption under section 43 see below), and your participation in any observations or interviews with staff do not constitute requests for data held, as defined under FOIA. FOIA applies to recorded information that exists at the time of the request and that which can be provided within 18 hours of officer time, provided the data is already held by the Trust. Applicants may expect a response within 20 working days, which either provides the data requested, or provides details of the appropriate exemption if the data is withheld.
FOI does not require an authority to answer questions where this would involve the creation of new information such as the interviews and observations you intend to conduct. There is no obligation under FOIA to allow applicants to conduct interviews with staff, nor applicant participation in Trust activity such as joining observations from e-academy or any face-to-face training observation. This also excludes your aim of liaison with our HR department, or related mental health professionals, such as a clinical director, division lead or manager for appropriate resource guidance across the Trust.
FOI does not provide you with authority to select participants in our Trust to interview, who are from varying roles within mental health care settings such as frontline clinicians, policymakers, and administrators nor to interview mental health professionals such as psychologists, psychiatrists, social workers, and nurses. This also applies to your intended selection of diversity compliant staff who are employed as psychologists, psychiatrists, social workers, and nurses at the Trust.
Turning now to your request for all out Trauma related training materials, we are withholding our training documentation used to teach and train staff in trauma informed approaches under Section 43(2) of the Freedom of Information Act 2000 (Prejudice to commercial interests.) This is a qualified exemption, and we have conducted the public interest test, as set out below, to weigh up the arguments in favour of disclosure and in favour of withholding this information.
Engagement of Exemption from Disclosure under Section 43 of the Freedom of Information Act 2000
Section 43(1) Exemption from Disclosure if it constitutes a trade secret
Section 43 (2) Disclosure would prejudice commercial interests of the Trust
Arguments in favour of disclosure:
- Promoting accountability and transparency on details of the training package professional clinicians receive at the Trust on trauma informed approaches
- To assist the requester, and any other students, in writing up their theses about the UK approach to training in trauma care.
Arguments in favour of maintaining the exemption:
- Disclosure to the applicant would constitute a release into the unregulated public domain, and since these training materials were not written for a lay person in the public domain, but written by professionals psychotherapists for professional psythotherapists, they would present a clinical risk for unqualified persons or organisation trying to emulate the professional training which the Trust provides, at the risk of endangering patient safety.
- The requested training materials are the Trust’s own intellectual property and constitute a trade secret, which would cause actual harm to the commercial interests of the Trust, being the sole supplier of that specific training in the Trust. This would give unfair advantage to competition, and handicap the Trust’s future ability to successfully bid for such commercial activity.
- The training materials in question are current training materials, which are currently being delivered. This adds further weight to the argument to withhold from publication, though in time, and when they are no longer in use, this may diminish.
We have concluded that, on balance, the public interest in maintaining the exemption outweighs the public interest in disclosure.
As you can see from the above, your request for information is too wide-ranging as well as invalid under FOIA. Should you wish to reformulate and narrow your request, such as requesting specific clinical policies or procedures, or asking about the types of treatment we provide, then we would treat any reformulated request as a fresh request and deal with it accordingly.