 Welcome, everybody, and this is a slightly cold and miserable Wednesday afternoon. My name is Mark Critch. I'm chief executive of my society. And I've got great pleasure in introducing the new policy paper produced by my colleagues, Rebecca Rumble and Alex Parsons, looking at how we can reform freedom of information in the UK and to suggest a number of improvements to strengthen access to information in the UK. And over the next 30 minutes or so, also joined by two great speakers, Jim Killock from the Open Rights Group, who is, over many years, has taken such great interest in access to information, privacy rights, and so on, and has got some really important contributions to the discussion and also Peter Gagan from Open Democracy. Open Democracy have been real champions of freedom of information over the past few years. And as I'm sure Peter will elaborate on, are right in the middle of a beginning of a court case, really, to bring the cabinet office to bear on greater access and the provision of the Cleaning House, which is caused quite a lot of kerfuffle, shall we say, around how journalists and others and campaigners are treated in regards to the Freedom of Information Act. So my society, as you might know, has been around for the past 18 years or so. I've been chief executive for the past six years. And we really help people be active citizens. We help people understand their rights and actually make use of those rights. And our services are used in the UK in over 40 countries around the world. And we work with campaigners and individual citizens, journalists, civil society to really make use of the technology resources we have, but also the wonderful research and data that the team produces as well. Everything we do is open source and available for reuse. And we encourage you to, if you haven't already seen the report, to visit research.mysociety.org where you can see all of the great reports and policy papers that we've put together over the past few years. What we're going to talk about today is obviously Freedom of Information. And the reason we are so interested in Freedom of Information, not least because we run whatdotheyknow.com, which as many of you, I'm sure, are aware, is a wonderful repository of over 700,000 requests made to over 38,000 public bodies over the past 13 years. And it's really testament to the variety of information that people want to understand from government and public sector bodies and the depth of your information and data and your real answers to real questions that people have existed. And this is a core part of why the Freedom of Information Act is so important. And I guess the question for me is why are we putting this report out now? Why is it important to draw attention to how we might improve Freedom of Information? And I think two things really. One is it's really to make the statement Freedom of Information is unequivocally a good thing. I think we don't say this often enough. There's a lot of many, many different opinions on FOI and how it's used, but the access to information and the rights it grants to ordinary citizens is really, really critical. And it's especially critical because when those rights are abused, it can lead to cronyism and slipping standards in public life. And especially at those times when there's a closing of civic space, it's especially important to both celebrate the rights as they exist, but look at ways that can be reformed and extended and expanded upon. And the report that Beck and Alex are going to introduce really goes into some, as with all my society research, some really practical and actionable advice for actions that can be taken really today that would improve the act and improve people's access to it. So over the next half hour, Beck and Alex will take 10 minutes or so. They're going to talk about the report itself. Hopefully you've all had a chance to look at it. It is available online, as I said at researchmysociety.org. Then Jim Killock will go first. I believe Jim's in the room already. And then Peter Gagan will go next. And again, if you have questions, please do put them in the chat and we'll make sure if they can't get answered on this call, we'll make sure they're followed up afterwards as well. So really excited over the next 25 minutes. I'm going to hand over to Beck, who can take it from there and present the report. Thank you very much. Mark, so as Mark said, there is quite a lot going on, I think, at the moment with FOI in the UK. But there has been, I think, a concern over the last few years that FOI maybe isn't being nurtured to the extent it should be. We think there are some really pressing issues. These are not exhaustive. We know there are many other areas that need attention. But these are the ones that we felt were really relevant right now and that can have some practical impact. So we know there's millions of FOI requests to be made every year. But as a digital and as a data organization, we think that there should be data on those requests. It's utterly absurd, in my opinion, that you can't actually say with any authority this is how many FOI requests were made last year. It's impossible to tell something so basic for such a basic right. So we really believe that there is a huge data gap in terms of understanding how FOI is actually operating. What statistics there are do actually show increasing delays, which is bad. This is not something that should be allowed to slip just because people aren't really monitoring it. And obviously, there was a review a few years ago, FOI survived, but it didn't get nurtured anymore. The recommendations on enhancing or improving the regime have not been implemented. The other thing we're really concerned about is that FOI is an increasingly marginalized proportion of the ICO's work. The regulator, understandably, because it is responsible for data protection as well, is increasingly pivoting to focus on data protection at a global level. And we feel that FOI is very much a kind of poor brother in that relationship. And the other thing as well over the last year, I think everyone has become a little bit more aware of the devolved nature of the UK and just how different and how much opportunity there is for policy to diverge in the devolved nations. And we feel that that's something that hasn't really been looked at or considered very much and that maybe we should actually be looking at now. So we have some broad recommendations as part of this report. Obviously, all of this loads and loads of detail in the actual reports itself, which you have access to. But roughly, we think establishing an ongoing data collection and publication program on how FOI works in the UK is absolutely crucial. How can we possibly know if this law is working well and it's doing what it's supposed to do if we have no data on it? We believe that for FOI to thrive and have a proper champion, that it should actually be carved out of the Information Commissioners Office and established as an independent FOI or access to Information Commissioner. And that that person should be responsible to parliament rather than as part of a ministerial portfolio because we believe FOI is a crucial constitutional issue. We think that we need to improve and expand the operation and coverage of FOI. And we also want to champion innovation and divergence in the devolved nations. So I'll pass it over to Alex. Sorry, I lost my unmute button. So our first recommendation is again, it's a problem of data collection. So at the UK in the moment, there are two sources of information about FOI statistics. What are official sources? There have been periodic surveys done but sort of ongoing statistics are only two current levels. So the Cabinet Office collects information from the central government. They collect about 76 different statistics sort of saying about if different exemptions are used, how many requests were received, how many were sent by the statutory deadline. The Office of the Scottish Information Commissioner collects data across the public sector in Scotland. And so that covers it from about 500 authorities. Ed and covers many more statistics in part because they separate FOI and environmental information requests and statistics, which is very useful. The trouble is as well, that's quite good in Scotland given an overview of most of the requests going on there. In terms of FOI requests in the UK as a whole, very few of them are covered by all of this. So there are thousands and thousands and thousands more authorities subject to FOI and the majority of FOI sent in the UK go to these. This is especially triple local authorities where we know lots of information requests go to local authorities, but despite there are periodic slap shots, people do that essentially by FOI in the authorities themselves, but there is no ongoing publication and especially no ongoing monitoring of compliance on a systematic level. The review in 2015 recommended that there should be more data collection and it sort of recommended that they should be published and they should be brought together by a central body. In the end, the Code of Practice change made it so that it suggested that it be good for authorities to publish more data, but this, they really recommend the Code of Practice doesn't track legal obligations such to meet the statute of deadlines. So if lots of authorities did publish this data, it wouldn't be quite enough. At the same time as without a central collection, even publishing this data would still not get the benefits of releasing it. So a little bit of extra work to collect information into a central collection unlocks most of the value of producing the information in the first place. So based on this, we sort of think that the mirror in the 2015 recommendations that the ICO or the UK regulator should hold a central repository of data about FY request in the UK. We discussed a bit more of the ports about fresh holds for inclusion, but we think that limiting to bodies of a reasonable size would make the problem manageable at the same time as unlocking most the benefit of it. But this raises a broader question of funding and the resourcing of the regulator. I do back. So this idea about separating the information and data protection regime of the ICO and creating a dedicated independent FY champion we think is quite interesting. There is no necessity for the two roles to be combined. It's quite regular in a lot of other countries, but nor is it universal. And we think one of the key reasons is because it has become less useful over time to have those two roles combined. So as you can see in terms of funding, there has been a funding squeeze for FY anyway. If you look at the graph, from 2005 down to 2020, the budget allocated to the ICO for FY regulation has gone down significantly. When you compare that to the Scottish Information Commissioner, obviously the ICO funding is higher because it is a larger organization and it deals with a lot more authorities, but it's not substantially so. It's worth noting that all it would take is an extra two million to get that line back up to where we were in terms of funding in 2005. And in terms of public sector spending, two million is kind of a drop in the ocean. So the budget squeeze on FY, we believe is not good for good quality regulation. The other thing is that changing the status to an officer of parliament with funding allocated by parliament would be less politicized. This has been recommended previously. And again, as we say, we believe this is a constitutional watchdog kind of regulation. This is not just comparable to Scotland, it's happening in other places as well. There are similar arrangements in Canada and we think this is much more effective at keeping FY properly kind of overseen. The other budget squeeze and the marginalization of FY within the ICO is becoming extreme as well. I mean, this is, I think the graph says it all here. Obviously because of changes in regulation on the data protection side of things, you know, the ICO budget for data protection work has increased significantly, whereas obviously as we've seen the FY budget has decreased. This now represents, I think, 8% of the ICO budget now, which is devoted to freedom of information. We don't believe that's healthy. We don't believe that that makes for a good quality regulator to be overseeing and championing this piece of legislation. Relative position, oh, sorry. Alex, can you skip it back, please? Yeah, the relative position is inappropriate at this point, we think. Institutionally, FY is going to continue to be increasingly marginalized. Data protection is huge. It's not going to go away. The use of personal data is going to increase. And therefore the attention that any commissioner and any regulatory body that combines the two will pay to it, will increase as well. Creating a new information commissioner is a good opportunity to move that to parliamentary oversight. And it will give sole oversight on access to information issues. It'll also de-politicize it, we would hope. We don't believe it's healthy for a regulator, beholden, to a minister to be regulating the government itself. We've obviously, and again in the report, we go into it in greater detail about the arguments for or against where the ICO should sit and where responsibility should lie. But we believe that it's far better and there will be far clearer oversight if it was responsible to parliament. At the moment, we're recruiting a new information commissioner. And the fact that the job description and the person specification barely mentioned freedom of information. It was completely tailored towards getting a very kind of international data protection expert in really shows how little F for Y is considered to now be a part of that job. So we think that this will make it far, far more robust over to Alex. Thank you. So the first section of this is when we were looking at how the Scottish law works compared to the UK law, there's actually a number of areas we think that are quite the problems that have been sort of articulated in the UK having to be something solved in advance in Scotland because it sort of worked as a because they were starting with the UK law and then revised on top of that. Several practical issues have been resolved in terms of things that lead to these problems now 15 years later, sort of fixed at the start. So in there is much more clarity around time scales in Scotland. And when a big issue with freedom of information is delays, this is it makes a big difference just in terms of how appeals work. So for instance, the internal review processes in the statute, not the code of practice giving them a bit more force. There is an exemption that says if authority is going to publish something anyway they don't have to give it to you. In Scotland, they sort of recognized that this was sort of a loophole and there is a time that it has to be published within three months. And the most interesting is there is a growing problem of administrative silence in responses in the UK. And this is when an authority just won't respond. And because no one responds you can't engage the normal appeal process. In Scotland, this is sort of, if there isn't a response in the statute deadline this is taken to be refused. And so it can be appealed to the next level. And so this has gone to a bit more detail in the report. What this means is it reduces the amount of time an authority can really drag out responses. So it is just a nice little practical tweak that solves some of the problems requests have been having. But there are also philosophical differences in how Scotland works in terms of slightly stronger tests for like prejudice tests which sort of require there to be an actual harm. So in Scotland the language is it's supreme prejudice rather than just prejudice. And so that sort of makes it easier for appeals against refusals to give information where the harm is hypothetical rather than really demonstratable. And it's a bit hard to work out exactly what the relationship between this but generally speaking the Scottish system does result in more successful appeals through the regulator. So of appeals fully withheld in the ICO that's more than 50% from the Scottish Information Commission that's about 34%. Now there is more partially withheld but this still in general works out in the request as favor between the two systems. So if we're looking for examples of how to improve things in the request as favor look at the system nearby where there is absolutely good indications that this is already the case is an excellent thing for reformers working side the wider UK system to learn from. And our fourth point is as we said at start looking a bit more about how divergence and especially Wales can be used to further access to information. And one of the things we sort of especially concerned about in this area is the private operation of public services. So both the UK and Scottish government have the ability to say that private bodies who do public services are subject to FOI but the government has to explicitly say this. In the UK this power hasn't been used much to talk whereas in Scotland private prisons set selection of private special schools and social housing providers have been covered under FOI. The UK is equivalent of things haven't been done and it often actually actively been argued against. So what we would sort of point out is for Wales which since 2017 has had the ability to diverge on the FOI is they don't necessarily have to go the full way of Scotland has and create an independent commission special independent law. These powers to add private bodies may be incredibly relevant to them and it would be a way of a little mini divergence that helped makes Welsh public services more accessible to FOI without creating a large divergence in the law. So I think these kinds of ways of looking at FOI a slightly different way that in different parts of the UK there are different experiments going on is a useful way of exploring what's possible but then after the fact and trying to learn how we can spread those good practices around. I think Bec may be struggling to unmute here. Sorry, my unmute button has disappeared. Quickly to sum up. I mean, we know FOI reform is a long game and it's really difficult to get any government of the day to agree to more scrutiny. So I mean, this is something that we want to be a kind of catalyst for ongoing conversation amongst civil society, amongst campaigners, amongst lobbyists and it's something that we really want to kind of embed in our conversations over the next few years. Coming up to when parties are starting to think about constructing their manifestos around the next election. These are things that we think should be on the agenda for the future. As much as I would love things to change tomorrow we know that that's not gonna be the case. So we absolutely want to kind of create a kind of collaborative conversation that's ongoing with anyone that's interested in working on these issues going forward. And obviously in the meantime, we do run what they know as most of you know we're trying to maximize public access to information as much as we can. So we're improving that service all the time putting in-depth advice on that, how to craft internal reviews and appeals. We've got the pro service that is very, very useful for researchers and journalists who are using FOI to craft more kind of investigative or academic pieces that require a little bit longer to write up before they get published. And we are gathering what FOI statistics we can which are available on our many side there. So thank you very, very much for that. And I'm really excited to hear what other people think about the report and for Jim and Peter's thoughts. That's great, thanks, Bec and Alex. So we'll move straight on to Jim, if Jim is available. So Jim Kelly from the Open Mates Group. So it's an opportunity Jim to give a reflection on the report and any particular questions you want to dig into from the chat but I'll hand straight over to you for the next six, seven minutes. Thank you very much. I'm really pleased to read this report. That's the first thing to say. It's really timely. Obviously FOI is under a great deal of stress at the moment. And it's also very clear with a government that frankly seems to have gone somewhat rogue in certain parts of these matters. You need an FOI at that point. You need the transparency. That's becoming really plain, I think. But at the same time, it's harder to exercise than ever before for very practical reasons that Open Democracy and others have demonstrated. So I'm really, really glad to see this work. On the question of the ICO and its independence, one thing I would say is I think that question applies equally to data protection because one of the biggest problems is actually holding the government to account for what it wants to do with personal data. And the ICO is essentially, it seems to me to have vacated the field both on privacy and on freedom of information. I mean, the ICO should be saying the government is not doing its job. It is overstepping the market. It's breaking the law. It's not saying these things. And again, I don't know if anybody from the ICO is at this meeting, but really we should be hearing their thoughts about this report as well. I think it's very clear from the report that the FOI part of the job is declining. I agree about the concerns around the recruitment process. Although I'd add that the recruitment process seems to be biased towards appointing somebody to help dismantle data protection. So it doesn't really feel like, you know, we're going to get any kind of ICO that's going to do its job. And that's really concerning, right? So it seems to me that independence question applies to both on the Wales and Scotland points. I think, again, you know, Labour have committed to improving FOI and extending FOI to the private delivery companies for the state sector. Well, it can do that already in Wales. So it shouldn't be waiting to get power at Westminster. The Welsh institutions should pick that up because if that works in Wales, it's a way to demonstrate why it's a good idea at the UK level. And that's where, in lots and lots of other fields, it's actually working for open rights group in terms of the data privacy we work, we do in Scotland and seeing better policies on digital identity, more accountability for the police over what they do with biometrics and other technologies. These are things that could be replicated in Wales and Scotland. And that eventually creates pressure at the UK level. In terms of the other point I would just make quickly is that the point about oppositions really being the parties that are going to learn and implement these changes, I think is critical. So this is the right time to build up that head of steam and to MPs to understand and to learn about what they need done. But it is going to be some kind of change of government, whether that's a coalition or whether that's the Labour Party or some other party taking over. It is unlikely to be the government of the day who, you know, in this particular case are very resistant to freedom of information and transparency in any case it would seem. But I think parliamentarians are going to learn those lessons and we need to make it really concrete in terms of what is needed and what those changes look like. So again, this report seems to be extremely timely. I note also in the report, there's a bit of talk about more work being needed to be done on exactly how the exemptions are working in practice, what kind of information gets denied and so on. I think that would be good to see somebody pick that up as well. So all of those sort of points, I think, are the really key ones. For Open Rights Group, I think we'd be really interested in working on the devolved institutions to see some progress on information rights in Wales and Scotland, partly because we have presence in Scotland already and partly as you pointed out very clearly, these opportunities exist today. This is something we actually can make happen. So thank you very much for letting me talk. That's fantastic, Jim, thank you. And I guess just in building on that, as Beck mentioned already, it's both playing the long game and as much as kind of getting the ideas on the table so that when opportunities to make significant changes do become available, the right ideas are there. But it's also about playing the short game as well and you're making sure we really celebrate the great uses of freedom of information and how it can be so useful in kind of day-to-day campaigning and transparency and how it leads to better government and better decision-making and continually make that case ultimately. So with that in mind, I'll ask Peter Gagan from Open Democracy who many people know is really a leading light in running lots of campaigns around freedom of information and I'll hand over to Peter. Thank you very much Mark and thanks a million for inviting me along. It's great to be here with my side, you've done so much work around FY over the years and what do they know pro is I would be lost without it so a quick big up for that, it's really, really great stuff. So thanks for that and I'd be lost at times without it. And I think what this report did for me is I think it's just reiterated again just the importance of FY and freedom of information and the whole principles of access for information. And I feel like we're in a particular moment and lots of speakers already today have touched upon it but we have had, we've got this green, it's a lobbying scandal. We've got the Prime Minister today facing loads of questions about the refurbishment of the flat. The whole issue of transparency and property in public life I think is live in a way it probably hasn't been for a very long time. And one of the points I've been making recently is that we're gonna have a lot more talk about lobbying laws and lobbying regulations soon. If we had a really functioning FY regime, I think a lot of those questions would slip off the agenda. And it's one of the arguments I've been making behind the scenes to people like Dave, Tory MPs and others saying, look, this is one reason you could care about this. You can kind of sidestep these really difficult naughty issues around who counts as a lobbyist, who doesn't. I'm not saying don't go there, but if we had a really functioning FY regime, a lot of those issues would be a lot better than there at the moment. And I think that's a big thing and as we've got a first year tribunal case with the Cabinet Office starting tomorrow as well around this clearinghouse as was mentioned earlier, which again, it's around how FY has been dealt with in government. And we've kind of seen this over and over, like our recent report on the open box we brought out, Art of Darkness, looked at a lot of this as well and found really, what you're looking at is the very departments that are supposed to be at the heart of FY, particularly the Cabinet Office, are the worst when it comes to FY responses, are the worst when it comes to, I think when it's FY, the Cabinet Office, I'm sure is familiar with this kind of endless extensions and a huge failure at the centre of it. So I think this report really kind of speaks to a lot of the problems we have and a lot of the big issues. And I think the idea of having the ideas to hand, I think is a really good one. I just want to pick up a couple of themes that I think are really interesting from it. So almost, you know, that kind of speak to some of the things we've been looking at too. One is around this idea of stonewalling or what you call in the report, the minister of silence. You know, this is where the refusal is not issued at all by a public authority. It's basically ignoring the FY response, which leaves the requester in limbo or where do they go? And this is increased. The number of ICO rulings about a minister of silence have increased 70% since 2016. And the problem with this is that it basically resets the clock to the start. And actually the ICO gives the local authority or whoever it is, the public body, 35 calendar days response, which is more than the original 20 working days for an FY. And I think what the reports suggests about, like that an FY, if an FY request is not answered in 20 working days, it should be considered refused. And then the requester can engage in the appeals process. And this is something that a lot of, even seasoned FY users are not aware of. I have had this conversation with so many journalists over the last six months, where they would get in touch going, my FY is not even been acknowledged. What do I do? Because it's something that even, kind of well burst FY users are struggling with. So I think, and we're seeing such an increase in it. Even just anecdotally myself, I'm seeing this more and more, I'm having to chase local authorities, public bodies just to say that they've received us. So I think, and I also think the recommendation that FY legislation has to include an explicit time limit for internal reviews is a very good thing too. Because what we're also seeing is internal reviews, barely half of internal reviews have been done within 20 days. So again, it's adding more and more time into this. And often it feels like it's an attempt to try and stop the clock and stall the release of information. So I think they're very good practical ways. I think they're both things that really practically, they would really help. And it's interesting as well, like we did recently at Open The Box, we went and did a big analysis of ICO judgments and comments about various government departments. And at one stage, at one stage, the cabinet office, the ICO complaints to the cabinet office that there's no justifiable reason for it. It took eight months to conduct one internal review. And this is a huge problem because, it comes onto the second point, which I thought was really interesting in the report is the idea around the separation of powers. But it's the idea that we need a regulator with teeth to make this work. There's a carrot in the stick and the ICO does tend to use a hell of a lot of carrot and very little stick. And just publishing decisions against public bodies isn't enough. It's not sufficient. There needs to be action. The ICO has shown itself very, very, very unwilling for action. And people have talked about this already today. And looking through the report, I think some ICOs of graphics, seeing those kind of change in the ICO's budget and its focus, such a heavy focus now in data protection, I think is really striking. In the last annual report, there's just half a page about ICO, about the F-O-I in the ICO's annual report. So that gives you an indication of just how much kind of focus there is internally. And I think this idea, I think the comment that's made in reporting, the phrase used that the ICO's data protection and F-O-I portfolios are on divergent paths, which I think is a polite way of saying, there's a lot of focus on one aspect and not a lot of focus on the other. So I think, I do feel as if that is something that really does require attention, whether it's a separation of powers, I think there's a can be discussion around it, but I think there has to fundamentally be a regulator that works its focus on this issue. And I think we're not seeing that. And we're not seeing that from public statements from the ICO wider. I think under Elizabeth Denham, quite clearly saw itself as a data protection regulator. I don't even think first and foremost, I think almost solely. So I think even just starting that conversation, getting people aware of it, I think it's really important because if we're gonna see a culture change in F-O-I, which I think is what probably is the biggest problem is the culturally aspect of this. And the report does talk about changes in legislation, but I think most people would feel like, actually there's a lot good that we have in terms of legislation. The problem is how that legislation is enacted. And if we're gonna see a culture change, it has to come from a regulator. I think that's the thing where I think politicians other people who could be advocates for what for change need to kind of understand too. And just finally on the idea of expansion of F-O-I, I think the idea of bringing out F-O-I to include things like socially registered landlords, housing associations, the whole gamut of public sector work that's done by private companies. I think we can all agree on this. The ICO agrees on it, the labor part. We've been talking about this a lot. The way you can kind of contracting stuff, I think this is all really important. And unfortunately we're in a different place where the government is actually intentionally not included this new advanced research and invention agency was called ARIA in F-O-I. So we're kind of seeing rather than the expansion of F-O-I in some respects the retraction. And just to lend with like a kind of word of warning to even about the idea of expansion is that I guess I'm always a bit worried when it comes to this current administration, when it comes to asking for things like legislation to be opened up for examination, that that could be used as an opportunity to kind of close down things. So I think being strategic about what we want to see change legislatively is very important. And my sense is that there's actually a lot of things that exist that if they just were working properly and working well, we could really, you know, things would be a huge improvement. So I think that's the one thing as well in terms of thinking about how we move forward with some of this stuff. But overall, I just thought it was really important that I brought a lot out and I think there's a lot for all of us in the community to consider. That's great. Thank you so much, Peter. And you echo that very much. I mean, you know, the legislation is there and just putting the emphasis on actually making sure it's enacted in the right way and people are able to kind of make use of the rights we already have as a really critical component of the next few months and years. And that's certainly an area that my societies continue to commit to, to the expansion to the work we're doing with what do they know and what do they know pro, certainly making it easier to understand why rejections happen, what sort of responses might be appropriate in certain circumstances and really kind of helping oil the wheels of the FOI process to make it. You're better for requesters but also easier for public bodies to respond to as well. So thanks again, Jim and Peter. Thank you so much, Bec and Alex for a great introduction of the report. I hope you've had a chance to read a copy of the report yourself. Again, it is available on research.mysociety.org. Jim has posted it there in the chat as well. I know there were a lot of questions in the chat and we will be following up and there'll be a blog, blogs about some of the topics we've covered. Also we record the discussion. So there'll be a, we'll be sharing a copy of this recording as well. And this will be the first of many interventions I'm sure we'd like to make both as my society but you're supporting the great work that happens within the broader FOI community which is really represented here today. And just one last thing to start a quick shout out to Martin Rosenbaum who I noticed on Twitter is moving on from the BBC. He's been a tireless user and advocate of FOI in his work. So best of luck to him in future endeavors as well. Thank you all so much for coming. A little bit over time but I think that was well worth it, really good conversation or presentations and look forward to seeing you all soon.