On 4 February 2025, the Netherlands Food and Consumer Product Safety Authority (NVWA) decided not to disclose documents in response to a Woo request regarding the internal review of the Covenant on Unstunned Slaughter according to Religious Rites. This decision raises questions about the transparency and accessibility of information of public interest.
The Woo request, submitted on 23 December 2024, concerned the NVWA's internal evaluation mentioned in Deloitte's report of 15 November 2021. The NVWA indicated that one document was found, namely a report of the internal evaluation, but decided not to make it public.
The NVWA bases its decision on section 5.1(2), opening words and (i) of the Woo. This states that information need not be disclosed if it harms the proper functioning of the government. The NVWA argues that disclosure could make employees reluctant to give honest input in future similar evaluations. This, they say, would compromise the quality of future investigations and the provision of information to the people's representatives. Simply slapping away the names has apparently not been considered.
While it is understandable that internal evaluations may contain confidential elements, this decision gives the impression that essential information on the supervision of unstunned slaughter is being withheld. The NVWA indicates that supervisors have raised personal and moral objections to unstunned slaughter, but without disclosure it remains unclear how these objections have been incorporated into the evaluation and whether any policy adjustments have been proposed.
In addition, the NVWA's refusal is at odds with the objectives of the Open Government Act, which is precisely designed to promote transparency and public scrutiny. By completely shielding the review, it hinders the debate on animal welfare and religious slaughter practices. This is worrisome, as this discussion is of great social importance and policy decisions on it have a broad impact.
The NVWA's decision not to make the internal review public raises questions about the level of transparency within government. While protection of internal opinion formation is a legitimate interest, it must be balanced against society's right of access to information. Partial disclosure, shielding sensitive personal data, could have been a balanced solution. The NVWA should be more accountable for how it monitors the balance between confidentiality and disclosure, especially in issues that receive so much public and political attention.
