Background information from "What Price Privacy?" report

The request was refused by Information Commissioner's Office.

William Thackeray

Dear Information Commissioner’s Office,

I refer to your 2006 reports "What Price Privacy?" and "What Price Privacy Now?".

Please provide:

1) Concerning prosecutions brought by the Information Commissioner (WPP, Annex A): the name of the publication and the type of data concerned (e.g. medical records, voicemails).

2) The document 'Blagger Training Manual' (WPP, Annex B), in full.

3) Concerning the table on page 9 of "What Price Privacy Now?": For each 'positively identified' transaction, the name of the journalist, the name of the publication and the type of data concerned (e.g. medical records, voicemails).

4) Documentation from Operation Motormouth, including internal and external communications (e.g. with the Police and the CPS). I wish to exclude from this request the personal data which was illegally obtained.

The clear public interest in the release of this information is documented in the WPP reports themselves and in 19 July 2011's House of Commons Home Affairs Committee report, "Unauthorised tapping into or hacking of mobile communications".

Please provide the information to me in electronic format at this email address.

Many thanks.

Yours faithfully,

William Thackeray

Information Commissioner's Office

Link: [1]File-List

21 July 2011

Case Reference Number IRQ0405586

Dear Mr Thackeray

Thank you for your email of 20 July 2011 in which you have made a request
for information to the ICO.

Your request has been passed to the Internal Compliance Team, and is being
dealt with in accordance with the Freedom of Information Act 2000 under
the reference number shown above.  We will therefore respond to your
request by 17 August 2011 which is 20 working days from the day after we
received your request.

If you wish to add further information to your request case please reply
to this email, being careful not to amend the information in the
‘subject’ field. This will ensure that the information is added
directly to your case. However, please be aware that this is an automated
process; the information will not be read by a member of our staff until
your case is allocated to a request handler.

Yours sincerely

Helen Ward

Lead Internal Compliance Officer

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Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF
Tel: 0303 123 1113 Fax: 01625 524 510 Web: www.ico.gov.uk

References

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1. file:///tmp/rad2852D_files/filelist.xml

Information Commissioner's Office

Link: [1]File-List

26th July 2011

Case Reference Number IRQ0405586

Dear Mr Thackeray

I am writing further to our email dated 21 July 2011 in which we
acknowledged your request for information to the Information
CommissionerÂ’s Office (ICO).

In order to administer your request we require some further information
from you.  In relation to question 4 of your email you have asked for;

“Documentation from Operation Motormouth, including internal and
external communications (e.g. with the Police and the CPS). I wish to
exclude from this request the personal data which was illegally
obtained.”

Firstly to clarify the ICO does not hold any recorded information in
regard to “Operation Motormouth”.  The ICO does however hold
information relating to “Operation Motorman” and we assume that it
is this matter which you are referring to.  As this part of your
request is very broad we would be grateful if you could specify exactly
what information you are seeking.

In addition in regard to question 1 of your email which states
“Concerning prosecutions brought by the Information Commissioner (WPP,
Annex A): the name of the publication and the type of data concerned (e.g.
medical records, voicemails)” as I understand it appears that there
may be some confusion regarding the individuals/organisations listed on
the Annex.  These individuals/organisations are not journalists but
rather are those whom the ICO has previously sought to prosecute for
offences under the Data Protection Act 1998, therefore as you will
appreciate there is not a “name of the publication”.  In light
of this clarification we would be grateful if you could confirm whether
you wish to proceed with this part of your request.

We would be grateful for your response to this email as soon as
possible.   When replying please be careful not to amend the
information in the ‘subject’ field as this will ensure that your
email is added directly to your case.

Yours sincerely

Joanne Crowley

Lead Internal Compliance Officer

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Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF
Tel: 0303 123 1113 Fax: 01625 524 510 Web: www.ico.gov.uk

References

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William Thackeray

Dear Joanne,

Thank you for your email.

Concerning your queries:

- Yes, I meant Operation Motorman. Apologies for the typo. You ask me to specify which information I'm seeking - it would be helpful if you could describe what information is available. Essentially I'm looking for the 'case file' or similar - presumably the important documents in the case are collected together in some way?

- Re prosecutions brought by the Information Commissioner. I understand that the individuals/organisations are not necessarily journalists, but it was my understanding that they were included in the report because they had some connection with journalism. So I'd be grateful if you could provide the name of the publication with which they were connected. For example, if a private investigator was hired by a newspaper to get personal data, did so illegally and was prosecuted by the Information Commissioner, I'd like to know the name of the newspaper. If there is no connection with journalism in a specific case then I accept that this information does not exist and cannot be provided by the ICO.

Thank you for your assistance with this matter.

Yours faithfully,

William Thackeray

new casework,

Thank you for emailing the Information Commissioner's Office (ICO). This
is an automatic acknowledgement to tell you we have received your email
safely. Please do not reply to this email.

If your email was about a new complaint or request for advice it will be
considered by our Customer Contact Department. One of our case officers
will be in touch as soon as possible.

If your email was about an ongoing case we are dealing with it will be
allocated to the person handling your case.

If your email was about a case you have already submitted, but is yet to
be allocated to one of our case officers your email will be added to your
original correspondence and will be considered when your case is
allocated.

If you require any further assistance please contact our Helpline on 0303
123 1133 or 01625 545745 if you prefer to use a national rate number.

Thank you for contacting the Information Commissioner's Office

Yours sincerely

ICO Customer Contact Department

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Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF
Tel: 0303 123 1113 Fax: 01625 524 510 Web: www.ico.gov.uk

William Thackeray

Re Operation Motorman: plus communications connected with the case, please (as in my original request).

Yours faithfully,

William Thackeray

Information Commissioner's Office

Link: [1]File-List

1st August 2011

Case Reference Number IRQ0405586

Dear Mr Thackeray

Thank you for your two emails of 26 July 2011 in which you have provided
further information in regard to the information which you are seeking.

As you will be aware the Freedom of Information Act 2000 (the FOIA) states
that where a public authority reasonably requires further information in
order to identify and locate the information requested and has informed
the applicant of that requirement, the authority is not obliged to comply
unless it is supplied with that further information. 

Now that we have received further information from you regarding the
information which you are seeking we will respond to your request as soon
possible and within 20 working days from receipt of your recent emails,
which is by 23 August 2011.

Yours sincerely

Joanne Crowley

Lead Internal Compliance Officer

show quoted sections

Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF
Tel: 0303 123 1113 Fax: 01625 524 510 Web: www.ico.gov.uk

References

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Information Commissioner's Office

1 Attachment

Link: [1]File-List

19th August 2011

Case Reference Number IRQ0405586

Dear Mr Thackeray

We are writing further to our email dated 1 August 2011 regarding your
request for information to the Information CommissionerÂ’s Office
(ICO).

As you have asked several questions relating to What price privacy and
What price privacy now, for your ease of reference we will deal with each
one in turn.

“1) Concerning prosecutions brought by the Information Commissioner
(WPP, Annex A): the name of the publication and the type of data concerned
(e.g. medical records, voicemails).”

In regard to this part of your request in our email to you of 26 July 2011
we explained that those listed in Annex A of What Price Privacy were not
journalists.  In your email of 26 July 2011 you explained that you had
assumed Annex A was included in the report because those identified had
some connection with journalism and you asked for the name of the
publication which these entries were connected with.

Firstly to clarify the ICO only keeps prosecution files for six years. 
Unfortunately therefore we no longer hold any further information in
regard to the prosecutions listed which took place prior to 2005.  We
do not hold therefore whether any of these entries were working for a
“publication”.

In regard to the seven entries which are listed from 2005 and 2006, I can
confirm that none of these were connected with journalism therefore there
is no “publication”. 

For your information the purpose of Annex A was to highlight the low
penalties issued for a section 55 offence.  As you will have seen in
the “Foreword” of What Price Privacy the previous Information
Commissioner, Mr Thomas, was calling for custodial sentences to be
introduced.

“2) The document 'Blagger Training Manual' (WPP, Annex B), in
full.”
We are unable to provide you with a full copy of the information which you
have requested as this information would be exempt under section 44 of the
Freedom of Information Act 2000 (FOIA) which places prohibitions on
disclosure. 

Section 44(1)(a) states;

“(1) Information is exempt information if its disclosure (otherwise
than under this Act) by the public authority holding it -

(a) is prohibited by or under any enactment”

The enactment in question is the Data Protection Act 1998 (DPA) and
specifically Section 59 of the DPA. Section 59 (as amended by the FOIA)
states that neither the Commissioner nor his staff shall disclose;

“any information which:

(a) has been obtained by, or furnished to, the Commissioner under or
for the purposes of the information Acts.

(b) relates to an identified or identifiable individual business, and

(c) is not at the time of disclosure, and has not been available to
the public from other sources,

unless the disclosure is made with lawful authority.”

This prevents us from disclosing the information which has been collected
in the course of our investigations unless we have lawful authority to do
so.    

We do not have lawful authority on the basis that this information was
obtained during our investigations. 

“3) Concerning the table on page 9 of "What Price Privacy Now?": For
each 'positively identified' transaction, the name of the journalist, the
name of the publication and the type of data concerned (e.g. medical
records, voicemails).”

In regard to the names of journalists this information would be exempt
under section 40(2) of the FOIA by virtue of section 40(3)(a)(i), which
allows a public authority to withhold information from a response to a
request under the FOIA when the information requested is personal data
relating to someone other than the requestor, and its disclosure would
contravene one of the Data Protection principles.

In the case of Operation Motorman the personal data we hold has been used
and retained in connection with the Information CommissionerÂ’s
regulatory functions under the Data Protection Act 1998 (DPA), and
specifically the need to retain the evidence of criminal offences being
committed under the DPA, notably section 55, which relates to the unlawful
obtaining of personal data.

We take the view that it is reasonable to assume that those individuals
whose details were recorded in connection with Operation Motorman could
not have anticipated or expected their details to be made public in
providing a response to a freedom of information request. We believe this
is the case whether they have been the subject of an enquiry, a journalist
or an ‘information getter’. Therefore, we consider that such a
disclosure of the journalistÂ’s names would be unfair and in breach of
the first Data Protection principle which states that “Personal data
shall be processed fairly and lawfully”.

As you may be aware the ICO has previously released in response to two
requests from the whatdotheyknow website, redacted copies of the
spreadsheets which the ICO had created from the Operation Motorman ledger
information which we hold.  The information which was released includes
the names of the publications in relation to the transactions and the type
of information which was being sought.  A copy of the information which
we released is publically available from the whatdotheyknow website via
the following links;

[2]http://www.whatdotheyknow.com/request/op...
[3]http://www.whatdotheyknow.com/request/th...

To clarify we have not provided you with the information in this email as
this information would be exempt under Section 21 of the FOIA as it is
reasonably accessible to you from the internet.

“4) Documentation from Operation Motormouth, including internal and
external communications (e.g. with the Police and the CPS). I wish to
exclude from this request the personal data which was illegally
obtained.”

In our email of 26 July 2011 we asked for clarification in regard to the
information which you are seeking.  In your first email of 26 July 2011
you explained that you were seeking a “case file or similar” then
in your second email of 26 July 2011 you said “plus communications
connected with the case”.

We can confirm that the ICO does hold the following categories of
information in relation to Operation Motorman; information obtained from
third parties (individuals and other organisations), internal
communications and legal advice.

This information is however exempt by virtue of section 30 and section 44
of the FOIA.

Section 30(2) concerns investigations and proceedings conducted by public
authorities and states;

“Information held by a public authority is exempt information if –

(a) it was obtained or recorded by the authority for the purposes of its
functions relating to -

(i) investigations falling within subsection (1)(a) or (b)”

The investigations outlined in section 30(1)(a)

“(a) any investigation which the public authority has a duty to
conduct with a view to it being ascertained -

(i) whether a person should be charged with an offence, or

(ii) whether a person charged with an offence is guilty of it,

(b) any investigation which is conducted by the authority and in the
circumstances may lead to a decision by the authority to institute
criminal proceedings which the authority has power to conduct”

These purposes apply when the Information Commissioner has determined
whether a criminal offence has been committed under the Data Protection
Act 1998 (the DPA), and whether to take action.

This exemption is a “class based exemption” which means that it is
not necessary to identify some harm or prejudice that may arise as a
result of the disclosure.  However, this exemption is not absolute. 
When considering whether to apply it in response to a request for
information, there is a ‘public interest test’.  That is, we
must consider whether the public interest favours withholding or
disclosing the information.   

In this case the public interest factors in disclosing the information
within the scope of the request are –

o increased transparency in the way in which the ICO conducts its
investigations

The factors in withholding the information are –

o the public interest in not prejudicing ongoing investigations into a
possible criminal offences
o the public interest in maintenance of independence of the judicial and
prosecution processes
o the public interest in maintaining the ICOÂ’s ability to discuss
and formulate views in relation to possible proceedings
o the public interest in not prejudicing any prosecution which may arise
out of the investigations.

Having considered all of these factors we have taken the decision that the
public interest in withholding the information outweighs the public
interest in disclosing it.  I am sorry, therefore, that in this
instance we are unable to provide you with the information from the
investigation that you have requested. 

As explained above Section 44(1)(a) of the FOIA places prohibitions on
disclosures and states;

“(1) Information is exempt information if its disclosure (otherwise
than under this Act) by the public authority holding it -

(a) is prohibited by or under any enactment”

The enactment in question is the Data Protection Act 1998 (DPA) and
specifically Section 59 of the DPA. Section 59 (as amended by the FOIA)
states that neither the Commissioner nor his staff shall disclose;

“any information which:

(a) has been obtained by, or furnished to, the Commissioner under or
for the purposes of the information Acts.

(b) relates to an identified or identifiable individual business, and

(c) is not at the time of disclosure, and has not been available to
the public from other sources,

unless the disclosure is made with lawful authority.”

This prevents us from disclosing the information which has been collected
in the course of our investigations unless we have lawful authority to do
so.    

We do not have lawful authority on the basis that much of the information
which we hold in regard to “Operation Motorman” was obtained
during our investigations. 

As you may be aware there is some information which is already in the
public domain such as the ICOÂ’s involvement in various parliamentary
committees in relation to What Price Privacy and Operation Motorman. 
For your information the current Information Commissioner provided
evidence to a select committee in September 2009;

[4]http://www.parliament.the-stationery-off...

The previous Information Commissioner, Mr Thomas, provided evidence to the
Culture Media and Sport Committee for their “Self regulation of the
press” report in March 2007;

[5]http://www.publications.parliament.uk/pa...

If you are dissatisfied with the response you have received and wish to
request a review of our decision or make a complaint about how your
request has been handled you should write to the Internal Compliance
Department at the address below or e-mail
[6][email address]

Your request for internal review should be submitted to us within 40
working days of receipt by you of this response. Any such request
received after this time will only be considered at the discretion of the
Commissioner.

If having exhausted the review process you are not content that your
request or review has been dealt with correctly, you have a further right
of appeal to this office in our capacity as the statutory complaint
handler under the legislation.  To make such an application, please
write to the First Contact Team, at the address below or visit the
‘Complaints’ section of our website to make a Freedom of
Information Act or Environmental Information Regulations complaint online.

 

A copy of our review procedure is attached.

Yours sincerely

Joanne Crowley

Lead Internal Compliance Officer

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Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF
Tel: 0303 123 1113 Fax: 01625 524 510 Web: www.ico.gov.uk

References

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2. http://www.whatdotheyknow.com/request/op...
3. http://www.whatdotheyknow.com/request/th...
4. http://www.parliament.the-stationery-off...
5. http://www.publications.parliament.uk/pa...
6. mailto:[email address]

William Thackeray

Dear Information Commissioner’s Office,

Please pass this on to the person who conducts Freedom of Information reviews.

I am writing to request an internal review of Information Commissioner’s Office's handling of my FOI request 'Background information from "What Price Privacy?" report'.

I wish to challenge the following exemptions which have been applied:

A) Section 44 with reference to DPA section 59.

Under DPA 59(2)(c)(i), the release of this information is lawful in that it is necessary for the discharge of the ICO's functions under FOIA.

Under DPA 59(2)(e), disclosure is lawful because it is in the public interest. I note that part of the "blaggers' manual" has already been disclosed by the ICO in its report; unless the ICO wishes to argue that it or its employees were guilty of an offence under DPA s59(3) in the disclosure of that information, the ICO has clearly already accepted that disclosure is lawful.

B) FOIA section 40(3)(a)(1) - personal information.

In Information Tribunal case 'Thackeray v ICO & General Medical Council', the Tribunal concluded that where there had been improper behaviour on the part of the data subject, release of their personal information was justified, in that the data subject would at the time they performed the improper behaviour have had the expectation that if the improper behaviour came to light then the public authority would not keep it confidential. The personal information of those convicted of offences under FOIA should therefore be released. The personal information of other individuals (such as those persons whose phones were hacked) could be redacted.

C) Section 30(2) - investigations

There is a public interest in the release of this information.

A full history of my FOI request and all correspondence is available on the Internet at this address:
http://www.whatdotheyknow.com/request/ba...

Yours faithfully,

William Thackeray

Information Commissioner's Office

Link: [1]File-List

19th August 2011

Case Reference Number RCC0411458

Dear Mr Thackeray

Thank you for your email of todayÂ’s date regarding our response to
your request for information.

This correspondence will now be treated as a request for review of your
recent request for information under the Freedom of Information Act 2000.

We will respond by 19 September 2011 which is 20 working days from the
date we received your recent correspondence.  This is in accordance
with our internal review procedures.

Yours sincerely

Joanne Crowley

Lead Internal Compliance Officer

show quoted sections

Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF
Tel: 0303 123 1113 Fax: 01625 524 510 Web: www.ico.gov.uk

References

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Information Commissioner's Office

Link: [1]File-List

19th September 2011

 

Case Reference Number RCC0411458

 

 

Dear Mr Thackeray

 

Your email of 19 August has been passed to me so that I can conduct the
internal review you have asked for, concerning the ICOÂ’s handling of your
FOI request for background information from the “What Price Privacy”
report.

 

I have read all the relevant material, including your request, the ICOÂ’s
initial response and your request for an internal review.  I have also
considered the nature of the withheld information, how the ICO comes to
hold it and the purposes for which it might be used.

 

For the reasons given below, I am upholding the ICOÂ’s original decision,
made by Joanne Crowley, with one exception.  The exception concerns the
full Blagger Training Manual which in my view is exempt and should not be
disclosed, but for different reasons.

 

IÂ’ll deal with the specific points raised by you in your email of 19
August by way of challenge to the initial response as I address each
element of the request.

 

“1)    Concerning prosecutions brought by the Information Commissioner
(WPP, Annex A): the name of the publication and the type of data concerned
(e.g. medical records, voicemails).”

 

You havenÂ’t challenged the explanation given by Joanne Crowley to this
aspect of your request.  On this basis, and given what you said in your
clarifying email of 26 July, it seems to me that this has now been dealt
with.  We’ve explained the situation, but not withheld anything or
applied any exemptions to relevant information.

 

“2)    The document “Blagger Training Manual” (WPP Annex B), in
full.”

 

I have concluded that it was not correct to exempt this information on the
basis that disclosure is prohibited by section 59 of the Data Protection
Act 1998.  This is because section 59 (1) (b) does not apply: the
document itself does not relate to an identified or identifiable
individual or business.  It is only the manner in which it was obtained
that relates to an identifiable individual or business in that it was
seized from such by the ICO.

 

However, having carefully examined the information, I am satisfied that it
is exempt because it is held having been obtained for the purpose of a
criminal investigation which the ICO has power to conduct.  Section
30(2)(a)(i) and (ii) of the Freedom of Information Act 2000 apply to the
information.  Section 30(1) also applies because it was obtained in the
course of a specific investigation.

 

I am also firmly of the view that disclosure would at least be likely to
prejudice the prevention of crime, because the manual describes techniques
for unlawfully obtaining personal information, which is an offence under
section 55(1)(a) of the Data Protection Act 1998.  However, information
which is exempt under section 30, because it has been held for the
purposes of a criminal investigation, cannot also be exempt under section
31 on crime prevention grounds.  Nevertheless, crime prevention is a very
clear and decisive public interest reason which favours maintaining the
exemption. It is very much in the public interest that any future
investigations into such activity are should not be hampered by the fact
that this information has been disclosed.

 

There is also a public interest in disclosure in that by revealing some of
the techniques used by blaggers, members of the public might be more aware
of what the look out for to avoid being drawn into revealing information
about themselves.  However, the public interest is better served by not
disclosing the information which would assist in the perpetration of
criminal activity and hamper future investigations.

 

I appreciate that the “What Price Privacy” report draws on the manual to
give brief examples of blagging techniques.  However, this represents
only a small amount of the Manual’s contents.  The fact that the
Commissioner considered that this should be included in his special report
to Parliament for illustrative purposes, to bring the issue to life, does
not negate the strong public interest in withholding the whole document.

 

“3)    Concerning the table on page 9 of “What Price Privacy
Now?”:  for each ‘positively identified’ transaction, the name of the
journalist, the name of the publication and the type of data concerned
(e.g. medical records, voicemails).”

 

The names of the journalists in conjunction with the type of data
concerned are clearly personal data as defined by the Data Protection
Act.  As it might indicate potential criminal activity, this might also
fall within the definition of sensitive personal data.  Where disclosure
of such information would breach the data protection principles, the
exemption under section 40(2) of the FOI Act applies, as indicated in
Joanne Crowley’s letter of 19 August.  I uphold her decision on that
aspect of your request for the same reasons that she has given.

 

Specifically, disclosure would be unfair to the journalists in question
and thereby in breach of the first data protection principle.  Whilst I
recognise there is a legitimate public interest in disclosure of their
names, I consider this to be outweighed by the prejudice that disclosure
would be likely to cause to the journalists in question.  In this
connection I have to bear in mind that the names of the journalists were
not provided to us voluntarily.  They only came into our possession as a
result of material we seized when exercising a search warrant.  Not all
the journalists whose names are held were necessarily involved in unlawful
activity.  We do not know with any certainty which ones were and which
ones were not and they have not had any opportunity to explain their
involvement.  The ICO has been consistent in adopting this stance having
previously received, and refused, FOI requests for the names of
journalists.  The only disclosures we have made have been in response to
court orders or in response to requests from individuals or their
employers for access to information about them.

 

Your point about improper behaviour does not therefore apply.  There has
been no finding of improper behaviour by these individuals.  None of them
has been convicted of offences under the DP Act.

 

“4)    Documentation from Operation Motormouth [sic], including
internal and external communications (e.g. with the Police and the CPS).”

 

Regarding the public interest test, you have commented that there is a
public interest in the release of this information.  I agree.  This has
been acknowledged, in that the response of 19 August said that there is a
public interest in increased transparency in the way in which the ICO
conducts its investigations.  However this is outweighed, very clearly in
my view, by the public interest factors in maintaining the exemption,
again as outlined in the letter of 19 August.  Even though much of the
information concerned is some years old, the issues remain live to some
extent, with ongoing Parliamentary scrutiny and police investigations into
related matters.  The information is not simply of historical interest. 
This heightens the public interest in maintaining the exemption in this
case.

 

The comments made regarding the statutory prohibition on disclosure by the
Commissioner and his staff of information obtained in the exercise of his
functions also applies to much of this information.  It is therefore
exempt under section 44 of the FOI Act.

 

In conclusion, therefore, I uphold the ICOÂ’s original decision that the
requested information should be withheld, although on a different ground
in respect of one item.

 

If you wish to appeal this refusal, you may do so by making a complaint to
the ICO under section 50 of the Act.  In that event, the matter will be
investigated by determined staff at the ICO who have had no previous
involvement with this request.       

 

How to complain

Information on how to complain is available on the ICO website at:

[2]http://www.ico.gov.uk/complaints/freedom...  

By post: If your supporting evidence is in hard copy, you can fill in the
Word version of our complaint form, print it out and post it to us with
your supporting evidence. A printable Freedom of Information Act
complaints form is available from the ICO website. Please send to:

First Contact Team
Information Commissioner's Office

Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF

By email: If all your supporting evidence is available electronically, you
can fill in our online complaint form. Important: information included in
the form, and any supporting evidence will be sent to us by email.

 

 

Yours sincerely

 

 

Graham Smith

Deputy Commissioner

 

 

show quoted sections

Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF
Tel: 0303 123 1113 Fax: 01625 524 510 Web: www.ico.gov.uk

References

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2. blocked::http://www.ico.gov.uk/complaints/freedom...
http://www.ico.gov.uk/complaints/freedom...

William Thackeray left an annotation ()

Referred to ICO.

Jonathan Mantle left an annotation ()

This is for my own reference and am doing it do have a permanent records of this request.