Freedom of information (FOI) disclosure log

23378

Date Sent: June 17, 2026

Conclusion: Released In Full

Description: 1. Does the Council use publicly available information (for example, social media platforms such as Facebook, LinkedIn, or other online sources) to support debt recovery or tracing activity? 2. If yes: a) For what purposes is this information used? (e.g. confirming address, identifying employment, tracing absconders) b) Is this use formally documented within any policy, procedure, or guidance? 3. Please provide copies of, or links to, any relevant documents, including: - Debt recovery policies - Investigation or enforcement policies - Social media or “open source intelligence (OSINT)” guidance - RIPA-related guidance (if applicable) 4. Does the Council define or refer to “open source intelligence” (OSINT), “social media”, or “publicly available information” within its policies or guidance? 5. What controls are in place to ensure that information obtained from publicly available sources is: a) Accurate and up to date b) Verified before being used to take enforcement action (e.g. Attachment of Earnings) 6. Is information obtained from social media or publicly available sources ever used as the sole basis for decision-making or enforcement action? 7. Does the Council have any requirement for staff to: - Record when social media or online sources have been used - Record what verification steps have been undertaken 8. Has the Council provided any training, guidance, or instructions to staff on the use of social media or open-source intelligence in debt recovery or investigation activity? 9. Does the Council’s privacy notice (or fair processing information) explicitly state that it may obtain information from publicly available sources, including social media? 10. If yes, please provide a copy or link to the relevant privacy notice. 11. Does the Council use credit reference agencies or external tracing tools alongside publicly available information to confirm debtor details?

Attachments: FOI_Response FOI 513.docx

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