How can a community protect sensitive data without restricting access to information to which people are rightfully entitled? How can it ensure that oral inquiries are not overlooked, that requests are answered in a timely manner, and that appointments are held when in-person meetings may be unsafe?

These topics were the focus of an online seminar organised by the All-Ukrainian Association of Local Governments ‘Association of Amalgamated Territorial Communities’ and the Office of the Ukrainian Parliament Commissioner for Human Rights. Over 900 representatives of local governments in communities joined the event.

The participants discussed the findings of the 2026 monitoring exercise on the protection of information rights, analysed common mistakes, and examined practical scenarios. The key message of the seminar was that security may require restrictions on access to specific information, but war itself does not nullify the right to access information nor does it render any information classified.

Requests and enquiries are different procedures

One common mistake is to decide how to handle a letter based solely on its subject line. The content of the message is what matters.

If a person asks for a dangerous section of road to be repaired, this is a complaint: the authority has to consider the matter and decide what action to take. If they ask for a repair estimate or details of funds spent, this is a request for public information: it concerns information that is already available and on record.

A single letter may contain both types of inquiries. For example, an applicant may request that a road be repaired and that information be provided on the planned expenditure. In such a case, each part should be considered in line with the relevant procedure and within the prescribed timeframe. As Vira Svyrydova, a representative of the Commissioner’s Office, explained, when registering a document, one should look not only at the heading but also at the body of the document.

Public information is data recorded on any medium that a public authority has created or received in the course of its duties. This may include paper documents, electronic records, and data in document management systems. If a public authority holds such information, the default position is that it is open to the public, unless the law provides grounds for restriction.

The applicant does not need to explain why they need the information, nor do they need to know the exact title of the document, the date of its adoption or the local authority’s internal record-keeping system. It is sufficient to describe the information in such a way that the authority can identify it; for its part, the authority has to assist in locating the document. It is not appropriate to request a passport, tax identification number, or other additional documents unless required by law. A query may be made orally, including by telephone: it is incorrect to insist that all queries and requests be submitted in writing only.

Deadlines: keep track, notify, do not confuse

As a general rule, requests for public information are processed within five working days. If the request involves a large volume of data or a search through a significant number of documents, the time limit may be extended to 20 working days. This is the overall processing time, not an additional 20 days following the initial five; the requester needs to be notified of the extension and the reasons for it no later than five working days after the request is received. A response of no later than 48 hours is required for requests for information necessary to protect human life or liberty, the state of the environment, the quality of foodstuffs, as well as accidents, disasters, and other emergencies that threaten people’s safety.

Requests that do not require further examination are processed without delay, but no later than 15 days. The general time limit is up to one month. If this is insufficient, the head of the department may extend the consideration period, notifying the applicant; the total time limit cannot exceed 45 days.

A written request that does not comply with the formal requirements should not simply be left unprocessed. It has to be returned to the applicant within ten calendar days at the latest, with an explanation of exactly what is missing. For applications submitted by email, a qualified electronic signature cannot be automatically required. A properly drafted application has to be registered; in the case of an oral application, the person should be given a registration number so that they can understand whether and when to expect a reply.

If a single application contains several questions, the reply has to set out the position on each one. For example, if a person asks to be invited to the hearing of their application, it is not permissible to reply only to the main question and ignore the request to participate. If it is not possible to invite them for security reasons, this has to be explained.

A refusal should be founded on an assessment of specific harm

Restrictions on access to information have to be lawful and relate specifically to that information whose disclosure poses a real risk. Before refusing a request, the authority in charge has to apply a three-part test: it has to identify the legitimate interest that could be harmed by disclosure; assess whether the harm would be substantial; and weigh this harm against the public interest in the information. A reasoned refusal has to explain this analysis, rather than merely referring to martial law or listing the legal grounds.

If only part of a document needs to be restricted, the rest of the information should be provided. The mere fact that a document contains some classified information does not mean that the entire document can be kept from the public. The Office of the Commissioner’s representatives also cautioned against automatically classifying information as confidential: not all information about a natural or legal person has such status, and details of the exercise of official powers by public officials cannot be concealed simply because they relate to a specific individual.

Martial law provides for a specific exception with regard to the prior publication of draft acts by local governments. However, this exception does not abolish the other obligations to publish information as specified by law.

Telephone, website, and in-person office hours have to work in practice

The monitoring exercise, presented by Oleksii Kabanov, UNDP Expert on Access to Public Information, covered 200 public authorities. Between June and August 2026, monitors examined oral and written enquiries and appeals, the operation of in-person reception services, and the publication of information. The problems identified included incomplete telephone numbers, contact details scattered across different sections of the website, unanswered calls, calls being passed between staff members, and refusals to accept oral requests or appeals.

This is not merely a matter of convenience. If a person cannot get through on the phone, does not know where to send a letter, or is unsure whether their appeal has been registered, the right exists only formally. The seminar also provided counterexamples: communities organised a hotline for protective shelters, allocated responsibilities amongst staff, or suggested that applicants try again the following day if a video consultation was interrupted during an alert.

In-person appointments have not been cancelled during the period of martial law. If it is unsafe to meet people in person, the community can adapt the format: conducting appointments via video link or organising remote outreach meetings where possible. This is particularly important for military personnel, internally displaced persons, and residents who have left the community but wish to resolve issues related to their community. The consultation schedule and booking procedure should be clearly published on the website.

A website is not an archive of random updates

The law requires information to be published systematically and promptly. In practice, this means that the community regularly checks that contact details, timetables, information on services, procedures for submitting requests and appeals, decisions by authorities, and the agendas for open meetings are up to date. If official materials are posted on several websites and the information is updated inconsistently, it is difficult for people to determine which source to trust.

The system for recording public information requires special attention. As Oleksandr Yurchenko explained, this is not merely a register of council decisions: the system has to reflect the documents held by the authority and their key details. It can be made public in the form of an up-to-date file. Open data is another format for access: it needs to be structured and suitable for automated processing, rather than simply consisting of scans or text posted on the website. If technical resources are lacking, the seminar advised starting with priority datasets and gradually expanding the open data portal.

Information that is important for the community’s daily life should also be published: how to access administrative services, where to find a protective shelter, and how to obtain humanitarian or social assistance. Information on threats to life, health or property, and on the measures taken, needs to be published without delay.

Electronic petitions and the petitioner’s involvement

An electronic petition is a specific form of collective appeal. According to Nataliia Shorobura, it has to be published within two working days of being submitted. The threshold number of signatures required for consideration is determined by the community’s charter. If a petition has gathered the required number of signatures, it must be considered no later than ten working days after publication. If the threshold is not met, the petition is still treated as a citizens’ appeal and a response is provided.

While an application or complaint is under review, the applicant may request access to the relevant materials or to participate in the review process. Such requests should not be overlooked amongst the main issues: a date and method of participation needs to be specified, and if this is not possible, the applicant needs to be informed of this with an explanation. This is one of the areas where, according to the speakers, authorities often lack a clear internal procedure.

Things communities should do now

The Commissioner’s Office announced that, in the first and second quarters of 2027, it plans to monitor the publication of information – in particular that required under Article 15 of the Law “On Access to Public Information” – and open data. Community leaders were encouraged not to place all responsibility on a single specialist, but to organise the process and oversee it. The Commissioner’s Office and UNDP are ready to provide training and consultations for communities; the report on the results of the 2026 monitoring exercise and recommendations on the right to make enquiries are available on the Commissioner’s website.

Yuliia Derkachenko presented data for the period from 1 January to 1 October 2026: the Commissioner received 133,156 enquiries, of which 23,560 concerned violations of information rights. The problems mentioned included untimely or incomplete responses, unfounded refusals, and inaccessible communication channels.

For communities, the practical takeaway from the seminar is to review the entire process of a person’s enquiry: from the initial call or letter through to registration, the determination of the procedure, the timeframe, and the provision of a full response. It is also important to ensure that websites and communication channels really do help people to obtain information, and that any restrictions on access are justified by a specific threat. This is precisely the kind of organisational approach that can simultaneously protect security and ensure people are not left without a response.