SUMMARIES OF SELECTED CASES analyse working hours in primary and lower secondary schools and in general upper secondary schools for the purpose of preparing for the forthcoming collective bargaining negotiations. Around the time at which the collective bargaining negotiations started, the working group discontinued its work because according to the Ministry of Finance it was no longer relevant. The Ministry of Finance also stated that the working group’s documents had remained internal within the meaning of the Access to Public Administration Files Act since they were not part of the authorities’ subsequent preparations for the collective bargaining negotiations. After investigating the case, the Ombudsman concluded that based on the information from the Ministry of Finance, there were no legal grounds for criticising the refusal of access to the documents. However, the case caused the Ombudsman to make some general statements about ‘creative thinking’ in regard to the provisions on access to internal documents of the Access to Public Administration Files Act. 2013-13. Inclusion of considerations of validity in decision to deny increased access to public records Three journalists complained independently of each other to the Ombudsman because the Agency for the Modernisation of Public Administration had denied them access to the public procurement database. Since the journalists had requested access to a database, and since no data extracts etc. from the database existed, the Ombudsman agreed with the Agency that the journalists were not entitled to access pursuant to the Access to Public Administration Files Act. However, the Ombudsman did point out that to the extent the public procurement database contained environmental information, the question of access must be considered pursuant to the Environmental Information Act, which – unlike the Access to Public Administration Files Act – also applies to environmental information contained in a database. While processing the case, the Agency had also considered giving increased access to the public procurement database but had not found grounds to do so. The grounds given by the Agency for denying increased access was that it would not be possible to guarantee the validity of the information. 125

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