FOI release

Financial expenditure of the council

Case reference FOI2026/01195

Received 8 June 2026

Published 6 July 2026

Request

Please confirm the following:

1. Does the Council hold the itemised transaction-level expenditure data for the last three financial years in digital form, for example in an ERP system, finance system, purchase ledger, accounts payable system, procurement system, or similar database?

2. What system or systems are used to record, process and report Council expenditure?

3. Can the Council export transaction-level spend data from that system into CSV, Excel or another spreadsheet-compatible format?

4. If the answer to question 3 is no, please explain how the Council produces its published annual spending data and budget/spending classifications.

5. How were the costs aggregated and classified for the Council’s website, including the budget and spending summaries previously relied upon by Mr Mynett, if the underlying expenditure data is not held digitally in a structured form?

6. Is the section 12 estimate of 1,000 hours based only on locating, uploading and collating individual invoice/receipt documents, rather than exporting an existing digital ledger or report?

7. If the Council can publish itemised expenditure over £500, please explain why a similar export cannot be produced for expenditure below £500, even if personal data or sensitive descriptions need to be redacted.

Response

Thank you for your Freedom of Information request.

Please find the answers to your queries below:

Yes.

2. What system or systems are used to record, process and report Council expenditure?

Unit4 ERP.

3. Can the Council export transaction-level spend data from that system into CSV, Excel or another spreadsheet-compatible format?

Yes – the Council confirms that it does hold transaction-level expenditure data for the requested period within its Unit4 ERP system, and that data can, in principle, be exported into spreadsheet-compatible formats.

However, the Freedom of Information Act 2000 applies not only to whether information is held, but also to whether it can be provided within the appropriate cost limit prescribed under Section 12. Creating the reports that you have requested would be a process subject to significant system limitations and would place a substantial and possibly unreasonable burden on resource and your request is therefore exempt under section 12 of the Freedom of Information Act (where the cost of compliance exceeds the appropriate limit). The process involved in creating such custom-tailored reporting is explained in more detail below.

4. If the answer to question 3 is no, please explain how the Council produces its published annual spending data and budget/spending classifications.

N/A (since the answer to question 3 was ‘yes’ and was not ‘no’).

The information is held digitally in a structured format and the Council already publishes detailed expenditure data for transactions over £250, which exceeds statutory transparency requirements. This is produced using a bespoke report specifically designed for that purpose.

6. Is the section 12 estimate of 1,000 hours based only on locating, uploading and collating individual invoice/receipt documents, rather than exporting an existing digital ledger or report?

No, it is not based only on locating, uploading and collating individual invoice/receipt documents. However, it is not simply a case of exporting an existing digital ledger or report, as explained in more detail below:

Application of Section 12

Under Section 12(1) of the Freedom of Information Act 2000, a public authority is not obliged to comply with a request where it estimates that the cost of:

“locating, retrieving and extracting the information” would exceed the appropriate limit.

For local authorities, this limit is set at £450, equivalent to 18 hours of work at £25 per hour (Freedom of Information and Data Protection (Appropriate Limit and Fees) Regulations 2004).

Why the request exceeds the cost limit

Although the data is held digitally, it is not held in a single report or extract that can be readily produced for the full scope of your request.

There is no equivalent standard report available for:

all transactions; or,

transactions below £250/£500.

Producing such a dataset would require significant additional extraction and processing outside normal business reporting, which contributes to the cost estimate.

To provide all transaction-level spend, including payments below £500, for a three-year period, the Council would be required to:

Locate and run multiple system queries:

There is no single report available to extract the full dataset requested. Due to system constraints, reports must be run on a month-by-month basis, resulting in approximately 36 separate report executions.

Manage system limitations and performance impact:

These reports produce very large datasets and are known to significantly impact system performance, affecting other users of the finance system while the reports are being run.

Retrieve and extract the relevant data:

Each report output would need to be individually retrieved and processed. This includes checking completeness and ensuring that the correct parameters have been applied across all reporting periods.

Compile and consolidate outputs:

The outputs from each report would then need to be manually combined into a single, coherent dataset, as there is no automated process to merge the outputs into a disclosure-ready format.

The cumulative time required to undertake these activities—specifically locating, retrieving, and extracting the information from the system—would substantially exceed the 18-hour cost limit.

For clarity, this estimate relates only to activities permitted under Section 12. It does not include time required for reviewing, redacting, or validating the data, which cannot be counted toward the cost limit.

Regarding your request for advice and assistance on what transaction-level expenditure data can be provided within the cost limit – I can advise that we are able to provide a report showing details of all transactions under £250 made specifically using corporate purchasing cards, procurement cards and/or council credit cards for the period April 1^st 2025 and March 31^st 2026.

Please find said report attached herewith.

Please note that this report includes the following information:
· Transaction date
· Supplier/payee
· Transaction amount
· Department or service area
· Transaction description/reference

· A ‘summary’ tab which provides a breakdown of the number of transactions and sum of total spend by department and a broad insight into expenditure specifically via Amazon.

I trust this adequately explains the reasoning for the application of the Section 12 exemption.

If you are still not satisfied with the outcome of the internal review, you have the right to apply directly to the information Commissioner for a decision.

The Information Commissioner can be contacted at: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Telephone: 0303 123 1113
Website: https://ico.org.uk/

Yours sincerely,

FOI Team

Guildford Borough Council

Documents

FOI 1195 transactions under £250.xlsx (65.8 KB)

This is Guildford Council's response to a freedom of information (FOI) or environmental information regulations (EIR) request.

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