Shadows of Transparency: Signaling Transparency-Impeding Behavior Using Public Data

2026-06-12

AI Summary

This study addresses a critical gap in freedom of information (FOI) research, which has predominantly emphasized legal compliance while neglecting systematic evaluation of governments’ actual transparency practices. Drawing on an archive of 15,277 Dutch FOI requests, complemented by a literature review and expert interviews, the project introduces the first operationalizable and quantifiable typology of organizational behaviors that impede transparency, structured into six distinct patterns. The resulting data-driven indicator framework demonstrates strong interpretability and practical utility, as validated by researchers, journalists, and civil servants. It enables meaningful cross-institutional and longitudinal comparisons of disclosure practices and supports evidence-based prioritization for oversight and improvements in transparency governance.

Abstract

Freedom of Information (FOI) laws aim to increase government transparency, yet existing assessments focus mainly on legal compliance and procedural outcomes, leaving organizational behavior underexamined. As FOI processes are increasingly mediated through digital information systems, public response data offer traces of how organizations handle requests and disclosures in practice. This paper develops and evaluates a pattern-based approach that uses such data to signal transparency-impeding behavior across government agencies and over time. Drawing on prior literature, we identify nine recurring behavioral patterns that undermine transparency. Using a dataset of 15,277 Dutch FOI dossiers comprising 139,449 documents, we operationalize and evaluate measurable indicators for six of these patterns, demonstrating that they enable systematic comparison of disclosure practices across agencies and over time. Expert interviews with researchers, journalists, and civil servants confirm the interpretability and practical usefulness of the indicators for investigative prioritization, comparative research, and transparency oversight.

Problem

• transparency-impeding behavior
• Freedom of Information
• organizational behavior
• public data
• government transparency

Innovation

• transparency-impeding behavior
• pattern-based approach
• Freedom of Information
• public data analytics
• government accountability