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

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.

Accepted manuscript on May 5, 2026, to the 25th IFIP International Conference on Electronic Government (EGOV 2026)