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FOI request (FOIR-771885233)
Citizen-facing online services
Requested Mon 08 December 2025
Responded Fri 19 December 2025I am a postgraduate student at the University of Strathclyde, conducting research for the MSc in Cyber Security (Graduate Apprenticeship) This research has received formal ethics approval from the Computer and Information Sciences department at the University of Strathclyde.
This request is made under the Freedom of Information Act 2000 and relates only to citizen-facing online services (for example, housing portals, council tax accounts, or benefits portals). It does not concern internal staff systems or administrative tools. The research does involve information on detailed technical configurations for public-facing web portals. Please provide the following information/documents:
1. A copy of (or extract from) your current policy that governs user authentication for citizen-facing online services.
2. The specific password rules that apply when citizens create an account or perform a password reset. Fore example, password character minimum and maximum limits, special character enforcement.
3. Whether MFA is offered or required for citizen-facing services, and, if so, what types are supported (e.g. SMS, email, or authenticator app).
4. A brief description or document outlining how password resets or account recovery are handled for public users (e.g. email verification, security questions, or other processes).
5. The date these policies were last reviewed or updated, and whether the policies align with any national or international guidance (e.g. NCSC, NIST SP 800-63, or ISO 27001).
Please also find attached a Participant Information Sheet titled “Participant Information Sheet” which explains in detail what data is being gathered, how it will be stored, how it will be processed, how it will be destroyed, and the process if any personal or sensitive information is received or found.
Response
Notice of Refusal
Disclosure of information relating to ICT systems, infrastructure and security constitutes a security risk as it would leave the Council's computer assets more vulnerable to a malicious hacking attack. This means that disclosure would:
• Make the Council more vulnerable to crime (Section 31)
• Risk harming the systems on which the day-to-day business of the Council relies (Section 43)
Section 31 (Law Enforcement) Section 31(1)(a) states that information is exempt if its disclosure is likely to prejudice the prevention or detection of crime. ICO guidance states that this can be used to protect information on a public authority's systems which would make it more vulnerable to crime.
This exemption can be used by a public authority that has no law enforcement function:
• To protect the work of one that does
• To withhold information that would make anyone, including the public authority itself, more vulnerable to crime
The crime in question would be a malicious attack on the Council's computer systems. Since the disclosure of the withheld information would make the Council's systems more vulnerable to such crime, the exemption is engaged.
The exemption is subject to the public interest test.
There is an overwhelming public interest in keeping the Council's computer systems secure which would be served by non-disclosure.
This outweighs the public interest in accountability and transparency that would be served by disclosure.
Section 43 (Commercial Interests) Section 43(2) states that information is exempt if its disclosure would, or would be likely to, prejudice the commercial interests of any person (including the public authority holding it). Disclosure of information relating to ICT systems, infrastructure and security puts the council at risk of a malicious hacking attack. This would compromise the Council's ability to provide its services and carry out 'business-as-usual' should our systems be compromised. Were our systems to be compromise, the cost of a system recovery would be detrimental to the Council's commercial interests.
The exemption is subject to the public interest test.
There is an overwhelming public interest in keeping the Council's computer systems secure which would be served by non-disclosure.
This outweighs the public interest in accountability and transparency that would be served by disclosure.
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Freedom of Information
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