Committee refuses to disclose evidence behind professional dog walker licensing
- Environment & Infrastructure has refused to disclose internal documents behind professional dog walker licensing decision
- No standalone study exists quantifying improvement in animal welfare outcomes from licensing professional dog walkers
- Committee withholds internal material under FOI exemption for policy advice, citing need to protect frank discussion
- 2025 public consultation showed support for controls on professional dog walking but was not regarded as representative
- Professional dog walking was specifically added to licensing framework through 2026 regulations, not included in original 2012 ordinance
Environment & Infrastructure has declined to release key internal documents that informed its decision to introduce licensing requirements for professional dog walkers, citing exemptions under the island's Freedom of Information Code.
The committee responded to a formal information request seeking evidence and documentation relied upon in developing the 2026 regulations, which brought professional dog walking within Guernsey's animal welfare licensing framework for the first time.
Whilst the committee provided links to published policy letters, consultation findings and legislation dating back to 2003, it confirmed it holds confidential internal material containing discussion, advice and policy recommendations which it is withholding under section 2.4 of the Code, relating to internal discussion and policy advice.
The committee stated it has not identified a standalone study quantifying any improvement in animal welfare outcomes attributable solely to the licensing of professional dog walkers, nor a standalone impact assessment, risk assessment or cost-benefit analysis relating specifically to the introduction of the licensing regime.
Instead, the licensing requirements were developed within the wider animal welfare framework and by reference to published information and internal consideration.
The committee justified withholding internal documents on the grounds that disclosure would be likely to harm the frankness and candour of internal discussion by inhibiting the ability of the committee and its officers to examine policy and implementation issues fully and candidly.
It acknowledged the public interest in transparency, particularly because the licensing requirements affect local operators, but concluded this interest is addressed to a substantial degree through published legislation, policy letters, consultation findings and other public information, and does not outweigh the anticipated harm to frank internal consideration.
The committee also declined to conduct exhaustive searches across current and archived records spanning several decades, invoking section 2.9 of the Code on the grounds that identifying every historical record that may have influenced the wider animal welfare framework would involve an unreasonable diversion of resources.
The response clarifies that professional dog walking was not expressly listed as a licensable activity in the original Animal Welfare (Guernsey) Ordinance, 2012. Instead, the 2026 regulations exercised delegated powers under section 26(3) of the 2012 ordinance to amend Schedule 2, inserting paragraph 10A to specifically bring walking a dog in the course of a business within the licensing arrangements.
The committee pointed to a public consultation undertaken by the States Veterinary Office in early 2025, which ran from 18 February to 18 March. The published summary recorded support among respondents for controls relevant to professional dog walking, including a limit on the number of dogs walked at one time.
However, the consultation report states that the responses were not regarded as definitive or representative of the views of the entire population but would help shape licensing conditions and requirements. The consultation material informed the development of the licensing conditions but is not presented as a standalone scientific study quantifying the effect of licensing on animal welfare outcomes.
The committee identified published records relevant to the request spanning more than two decades of animal welfare policy development. The Review of Animal Welfare Legislation proposals considered by the States in 2003 provided the early policy basis for the development of comprehensive and adaptable animal welfare legislation.
The Animal Welfare (Enabling Provisions) (Guernsey) Law, 2008 subsequently provided the enabling framework for detailed provisions to be made by ordinance. Further amendments and additions were considered by the States in 2011, before the Animal Welfare (Guernsey) Ordinance, 2012 substantially implemented the earlier States resolutions and established the principal animal welfare framework.
The Review of Animal Welfare Legislation: 2024 Update Policy Letter, dated 20 May 2024, provides a published account of that legislative history and the committee's proposals for further modernisation of the framework.
In relation to professional dog walking, the committee stated that matters considered include care, control and supervision, the management of dogs in groups, transport, operator competence, suitable equipment, first aid capability, inspection and risk-based regulation.
Across the relevant records, consideration was given to matters including animal welfare risk, proportionality, licensing conditions, fees, and the costs of administering and enforcing the scheme.
The committee also withheld any legal advice under section 2.5 of the Code, stating it is subject to legal professional privilege. The privilege belongs to the Law Officers of the Crown, not to the committee, and is not customarily waived.
The policy and legislative framework for animal welfare licensing developed over several stages, and the committee stated there is no single evidential dossier containing every record that informed that development.
Q&A
Q: Why was professional dog walker licensing introduced?
A: The licensing requirements were developed within the wider animal welfare framework following public consultation in 2025. However, the Committee has not identified a standalone study quantifying improvement in animal welfare outcomes from licensing professional dog walkers specifically.
Q: What documents has the Committee refused to disclose?
A: The Committee is withholding confidential internal material containing discussion, advice, recommendations and consideration of policy and implementation options, citing exemptions under section 2.4 of the Freedom of Information Code relating to internal discussion and policy advice.
Q: When was professional dog walking brought within the licensing framework?
A: Professional dog walking was not expressly listed as a licensable activity in the original 2012 Animal Welfare Ordinance. It was specifically brought within the licensing arrangements through the 2026 regulations, which exercised delegated powers to amend Schedule 2 of the 2012 ordinance.
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