Principles for the publication of Welsh public sector board and audit committee meetings

The devolved public sector in Wales and its boards are subject to various legal duties according to company and charity law and other legislation. Most, if not all, devolved Welsh public bodies are subject to the Freedom of Information Act 2000 and the Public Bodies (Admission to Meetings) Act 1960. 

Board meetings take different forms, some are held in public and others in private while some have a mix of both. These principles are intended to cover all types of board and audit committee meetings. 

Where access to board information and meetings is not specified by law, the following guidance sets out the principles and standards which have been agreed by the Public Leaders Forum on 4 December 2024.

Principle 1

The publication of information about board and audit committee meetings enables a public body to be transparent about its ways of working and its decision making which leads to greater accountability. 

Sharing information proactively leads to greater understanding of how a board or committee grapples with and resolves issues. When done in an open, accessible way it can lead to greater engagement with the community it serves so that there is confidence in how the public body carries out its work and greater trust in the organisation.

Principle 2

These principles are intended to apply to board and audit committee meetings. It will be for each board to consider whether they should apply to meetings of other sub-groups of the board.

Principle 3

Information should be shared with the public unless there are reasons why the information shouldn’t be in the public domain or where publicity would be prejudicial to the public interest by reason of the confidential nature of the business. For example, information about security, commercially sensitive data or information which would be excluded under Freedom of Information requests should not be publicly available. Care should also be taken with the inclusion of personal data.

Principle 4

Publication can take the form of minutes or summaries of meetings. It is up to each board and committee to decide which will be most appropriate. Considerations when taking this decision should include not stifling debate at meetings, becoming risk averse and leading to unintended consequences including business being held through informal discussion rather than through a formal meeting. Unless set out by legislation, it is for each board and committee to decide whether to publish papers which have been circulated ahead of the meeting.

Principle 5

Unless set out by legislation, both summaries and minutes can be produced where the board or committee think this is the most practical approach. It may be helpful to do this where full details of speakers or discussions are needed to be kept for internal record and for the effective running of the organisation.

Principle 6

The audience for the minutes or summary should be considered. Accessibility to the general public should be paramount. Text should be engaging and informative. Minutes or summaries should be set out in plain English or Welsh, with acronyms spelled out the first time they are used and jargon minimised.

Principle 7

Minutes or summaries should present a coherent picture of decision making. They should set out what was the item under discussion and what was the outcome of the discussion. Where decisions have been difficult to reach, this should not prevent transparency. Being open with the public about difficult decisions can help manage public expectations.

Principle 8

Minutes or summaries should make it clear what actions arise from the discussion and how they have been taken forward including what was the outcome of the actions.

Principle 9

Unless there is a specific reason to name an individual or their role, the approach should be to summarise discussion and points made without attributing who made each particular point. Including individuals’ names in published meeting minutes or summaries must comply with UK GDPR, as their name and their work title are their personal data. Individuals must be informed before the meeting takes place. 

Consideration should be given to using job titles rather than names (although, it should also be remembered job titles are also personal data where they apply to a specific person), particularly in the case of people who are not senior or where publishing their names could result in security concerns. Individuals who are quoted should have the opportunity of confirming the accuracy of the record as they recall it before minutes are published.

Principle 10

Minutes or summaries should be put in the public domain as soon as they have been agreed by the board or committee. There is a balance to be struck between waiting for the next meeting and putting making the information publicly available while it is topical. 

Consideration should be given to agreeing text for publication in between meetings if there is a long gap (3 months or more) between meetings. It should be clear how long the minutes or summary will remain publicly available (there should be some form of time limit).

Further information

For further information on the data protection implications of publishing minutes and summaries or the implications for reports by internal audit, please contact AuditAssuranceandCounterFraud2@gov.wales