Advice on pseudonyms

Dear Sir or Madam

Request for information under the Freedom of Information (Scotland)
Act 2002

I'm interested in the differences in official guidance between FOIA
and FOISA with regard to pseudonyms, especially given that they
have the same legal wording - Sections 8(1)(b) from each Act
follow:

FOIA - "8 Request for information
(1) In this Act any reference to a "request for information" is a
reference to such a request which -
(b) states the name of the applicant and an address for
correspondence"

FOISA - "8 Requesting information
(1) Any reference in this Act to "requesting" information is a
reference to making a request which -
(b) states the name of the applicant and an address for
correspondence"

My questions below relate to the article on pseudonyms in your
newsletter of December 2005, section entitled "Revised guidance on
requests made using a pseudonym"
<<http://www.itspublicknowledge.info/web/F...>>

Q1) "As a result of legal advice, the Commissioner has changed his
guidance on how public authorities should deal with requests made
under a pseudonym. Although the Commissioner previously advised
that an applicant could use a pseudonym, updated guidance makes it
clear that for an application to be valid, the actual name of the
applicant must be used. The Commissioner will not investigate cases
where a pseudonym has been used."

Please provide a copy of the legal advice referred to above that
resulted in a change to the SIC's guidance on the use of pseudonyms
or aliases in (A) requests for information made under Section 1 of
FOISA, and (B) in applications for investigation of cases by the
SIC (Section 47).

Q2) "Applicants who have made a request under a pseudonym may wish
to contact the Commissioner for advice on how to proceed."

Please provide examples of any specific advice given by the SIC to
applicants who had made requests under a pseudonym in response to
the above newsletter article, or to the changed guidance FAQs,
redacting any personal information where necessary.

Q3) I would be very grateful if you could also provide a copy of
the document referred to as "INV4366" in your "Investigation and
Enforcement Procedures" document (relating to applications made
under Section 47(1) by solicitors on behalf of unnamed clients).

Thanking you in advance

Yours faithfully,

Alex Skene

Dear Margaret,

Just to clarify, it is just the advice I'm looking for, not the
details of who asked for it.

I'll reply separately regarding the undeliverable messages.

Thanks again for your help,

Alex Skene