FOI 2026/1863

I am writing to request information under the Freedom of Information Act 2000 regarding the Integrated Care Board’s (ICB) implementation, governance, and oversight of Freedom to Speak Up (FTSU) arrangements, following the transition of responsibilities on 1st July 2026.

Specifically, please provide the following information:

1. Strategy and Implementation Plans

·         Copies of any specific strategy, transition plan, or policy document approved by the Board regarding how the ICB will execute its new system-level oversight responsibilities for FTSU.

2. Local Guardian Arrangements and Mapping

·         A list of all Freedom to Speak Up Guardians directly employed or commissioned by the ICB to cover the ICB’s own staff and those within NHS Trusts in your nominated operating area.

·         Confirmation of how the ICB is ensuring that primary care providers (GP practices, dental practices, community pharmacies, and optometry providers) within your Integrated Care System (ICS) footprint have access to a designated FTSU Guardian (e.g., via a centralized hub, a commissioned service, or individual practice arrangements).

3. Governance and Board-Level Accountability

·         The name and job title of the Executive Director and the Non-Executive Director (NED) who have been given formal board-level accountability for FTSU within the ICB.

·         Copies of the section of minutes, papers, or briefing notes from any ICB Board or Committee meetings held between 1st January 2026 and the date of this response where the dissolution of the National Guardian’s Office or the ICB’s new FTSU responsibilities were discussed. N/A

4. Budget and Resourcing

The total financial budget allocated by the ICB for FTSU arrangements (including Guardian salaries, ring-fenced time, and training) for the 2026/27 financial year.

If any of this information is already in the public domain, please provide the specific URLs to the exact documents. If the cost limit under Section 12 of the FOI Act is likely to be exceeded, please contact me to discuss how the request might be refined, prioritizing items 2 and 3.

1. NHS GM does not hold the information requested.
2. NHS GM does not have any full-time Freedom to Speak up Guardians, but operates with voluntary (fully-trained) Guardians. NHS Greater Manchester can confirm that it holds the names of these Guardians, however we consider this to be exempt under section 40(2) of the Freedom of Information Act 2000 as the disclosure of this information may lead to the identification of those Guardians. A formal refusal notice is below.

As part of new arrangements, the ICB will not be picking up or managing any cases from primary care or NHS trusts. Case management is the responsibility of individual organisations and the ICB’s role will be limited to signposting, guidance and system learning. As independent contractors, practices are not mandated to adopt a standardised FTSU model. Targeted communication, guidance and signposting from the ICB will be essential to support practices and reduce variability. FTSU concerns received via primary care are signposted to NHSE now under new arrangements.

Refusal Notice – Section 40(2) Freedom of Information Act 2000

Section 40(2) of the Freedom of Information Act 2000 states:

“Any information to which a request for information relates is also exempt information if –

• it constitutes personal data which does not fall within subsection (1), and

(b) the first, second or third condition below is satisfied.

(3A) The first condition is that the disclosure of the information to a member of the public otherwise than under this Act –

• would contravene any of the data protection principles [as set out in (i) Article 5(1) of the GDPR and (ii) section 34(1) of the Data Protection Act 2018]…”

Article 4 of the GDPR states:

• “‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
• “‘processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction…”

The information that you have requested constitutes personal data as it relates to identifiable natural persons. Furthermore, those persons could be identified from the information that you have requested.

Article 6 of the GDPR states:

1. Processing shall be lawful only if and to the extent that at least one of the following applies:

• the data subject has given consent to the processing of his or her personal data for one of more specific purposes;
• processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
• processing is necessary for compliance with a legal obligation to which the controller is subject;
• processing is necessary in order to protect the vital interests of the data subject or of another natural person;
• processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
• processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

We believe that the disclosure would lead to the identification of the individuals concerned and as a result, we are refusing these values under section 40(2) of the Freedom of Information Act 2000.

This exemption is not subject to the public interest test.

3. Colin Scales, Acting Chief Executive and Sue Bailey, Non-Executive Director are the executive and non-executive leads for FTSU respectively. Please see the board report attached.
4. There is no formal budget for the delivery of Freedom to Speak Up arrangements, however all Guardians have 2 hours ring fenced time (per week).