TI Ireland’s National Integrity Index (NII) on Local Authorities is composed of a set of 30 indicators, assessing the systems and practices of Ireland’s 31 local authorities to promote and ensure transparency, accountability and ethics.
Each local authority received one point for fulfilling the criteria outlined in our methodology, and zero points otherwise. The sum of points received is then converted to a percentage (points out of 30), rounded to the nearest whole number, and then used as the respective local authority’s score.
The Indicator Reference Sheet (provided on the NII webpage), explains the significance, justification for including each indicator, as well as the marking scheme and the source of the information (e.g. council websites, emails to councils, phone calls to councils, and freedom of information requests).
DEVELOPMENT OF THE METHODOLOGY
TI Ireland developed the project based on similar research carried out by TI National Chapters in other European countries (examples include Austria, Portugal, Slovakia and Ukraine). In adapting the indicators to the local context and to ensure they covered the issues relevant to local government in Ireland, TI Ireland consulted with the Standards in Public Office Commission, the Local Government Audit Service, the Office of the Information Commissioner, two academic institutions, a former Director of Services in a local authority and a former County Manager in a local authority. Additionally, in anticipation of this updated index, TI Ireland held four regional workshops around the country during 2019. All elected councillors in the country, along with senior officials from all councils were invited. The location of each workshop was chosen to maximise accessibility, and regions were defined based on the Central Statistics Office guidelines. The aim of these consultations was to receive feedback and input from a broad sample of stakeholders, namely academia, central government, local government, as well as rural and urban experience.
With the exception of the FOI requests lodged with local authorities, TI Ireland informed the authority that it was undertaking research on local government in Ireland. Local authorities were also informed that the workshops were being held around the country to discuss this update to the NII and receive feedback on our methodology. In addition, local authorities were emailed several weeks before publication to share their preliminary results. When forwarding the results with councils, TI Ireland requested that feedback by received back within eight business days.
STRUCTURE OF THE METHODOLOGY
Given the varying environments, sizes and contexts across the 31 authorities, TI Ireland understands the complexity in assessing local authorities. This methodology is based on a binary system of indicators, all of which TI Ireland expects local authorities should and can fulfil, regardless of budget, location, or number of staff. Additionally, during our engagement with local authority staff this year, several expressed their satisfaction with the methodology and noted that these expectations were reasonable.
A number of possible indicators were considered when developing the methodology, with multiple indicators removed that were considered too demanding for smaller authorities. The National Oversight and Audit Commission’s (NOAC) performance indicators for local government were considered. Some loosely relate to accountability but given that they are intended to measure management rather than transparency, accountability and ethics, they are not directly relevant to this research. Much of the data published by NOAC is not appropriate for comparative purposes. Some of this data was instead used for regression analysis with the study’s final data.
It was not feasible to address every corruption and ethics-related risk in the list of indicators. Where additional risks arise, they could be included in future editions of the index.
DATA COLLECTION
Data was collected for the 2019 edition of the NII between July and November 2019. TI Ireland took every reasonable step to obtain the data for each respective indicator. However, if there were obstacles to obtaining data or a local authority was not forthcoming with information, no points were awarded to those authorities. Likewise, an authority might maintain that certain information is published on its website. If TI Ireland’s team of researchers cannot find this information after an exhaustive search, then a typical citizen is unlikely to find this information, and hence no points can be awarded.
Similarly, when calling and emailing local authorities, TI Ireland called and/or emailed each local authority initially and, if not reaching them on the first attempt, provided at least two follow-up calls and/or emails. Voicemails or messages were left with the officials’ colleagues when calling, and follow-up emails were sent when no voicemail response was received. If there was no response from the authority after the third attempt, questions were not pursued further, and no points were given. A citizen should not have to call or email his or her local authority four times in order to obtain public information.
As part of this research, TI Ireland sent a five-part questionnaire by email to each local authority. The questions contained in the email were as follows:
- What steps does x County Council take to inform individuals (lobbyists and designated officials) of their obligations under the Regulation of Lobbying Act?
- Does the Council take any steps to prevent employees from taking on positions in the private sector that would conflict with their role in the local authority, both during and following employment with the local authority (i.e. Section 10 of the LGA Code of Conduct for Employees)? If so, could the Council share example(s)?
- Would it be possible to share any procedures the Council has in place to investigate alleged contraventions of Part 15 of the Local Government Act 2001 by councillors and “relevant employees”?
- Would it be possible to share any disciplinary procedures applicable for instances when an employee breaches the LGA’s Code of Conduct?
- Would it be possible to share any risk management or alert plan, addressing corruption and fraud risks, that the Council has in place, including when it was drafted?
FOI requests were also sent to each local authority. The questions included were as follows:
- With regard to Section 174 (8)(a) of the Local Government Act, 2001, could the Council share records on the number of “matters brought to attention under subsection (7)”, the number of corresponding investigations carried out (Section 174 (8)(a)(i)) and the number of corresponding reports prepared (Section 174 (8)(b)(i)) separately for 2018, 2017 and 2016? Only numbers, no details, are requested.
- Could the Council share an organisational chart, indicating the reporting structure of the internal audit unit? Alternatively, we ultimately would like to know – does the internal audit unit (or contracted company, if outsourced) report directly to a Head of Finance or Director of Service (as opposed to the Chief Executive and Audit Committee)?
- Can the council confirm that it has available for inspection by the public, as per guidance in the Department of Public Expenditure and Reform’s Model Publication Scheme for FOI Bodies, and as applies to ministers and secretary generals; diaries relating to the professional activities of the Chief Executive, and if so, can the council share these documents?