21 Bloomsbury
London WC1B 3HF
Benjamin Dean
By email to:
xxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxxxxx.xxx
Our ref: FOI-2017-0083
16 January 2018
Dear Mr Dean,
Thank you for your emails of 14 December 2017 in which you requested:
“The second term of PEDL147 expired on 30/09/17.
Please confirm if PEDL147 is extant. If PEDL147 is extant please provide a copy of the Deed of
Variation or correspondence that has either extended its second term or moved it into its third term
based on a Retention Area Work Plan.”
We have considered your request under the Freedom of Information Act 2000
(
FOIA) and, where relevant, the Environmental Information Regulations 2004 (
EIRs).
PEDL 147 is extant. Please find attached the Deed of Variation and the
correspondence in respect of the Deed of Variation.
Section 40(2) and Regulation 13(1) You will note some information including the names and contact details of some of
the individuals and all signatures has been redacted. The redacted information is
being withheld under Section 40(2) FOIA and 13(1) EIR. Section 40(2) provides that
personal data is exempt from disclosure where disclosure would result in a
contravention of one or more of the data protection principles or would contravene
Section 10 of the Data Protection Act 1998 (“DPA”) which prohibits processing likely
to cause damage or distress to a data subject. The data protection principles
includes that any processing of personal data must be fair and lawful and must
Oil and Gas Authority is a limited company registered in England and Wales with registered number 09666504 and VAT registered number 249433979. Our registered
office is at 21 Bloomsbury Street, London, United Kingdom, WC1B 3HF.
For information about how we process data and monitor communications please see our Data Protection Statement and for terms of use please see our Terms and
Conditions, both available on our website.
comply with one of the conditions either in schedule 2 or 3 of the DPA. The
provisions of Section 13 EIR mirror those of Section 40(2) FOIA.
The OGA considers that disclosure of the names, signatures and contact details of
the individuals would breach the principles of fairness and lawfulness. The
individuals concerned do not have public facing roles and are acting in good faith in
the discharge of their employment duties. In some cases those involved in the
correspondence are acting as public servants. Given that the individuals are
discharging their employment duties, and in some cases acting as public servants,
the OGA considers that they have and are entitled to an expectation of privacy. In
any event, the relevant individuals have not consented to their personal data being
disclosed.
The OGA further considers that disclosure of the names of the individuals would, or
would be likely to result in them suffering from undue harassment over and above
the level normally expected to be tolerated by a public servant or those acting in an
employment capacity on behalf of a private company. The OGA considers that
disclosure of the names, signature and contact details of the individuals would
breach the data protection principles of fairness and lawfulness. In light of this this is
being withheld under Section 40(2) FOIA and 13(1) EIR.
This concludes the OGA’s consideration of your request.
Appeals procedure
If you are unhappy with the way the OGA has handled your request, you may
request an internal review. A request for an internal review should be made within 40
working days of the date of receipt of the response to your request and should be
addressed to:
FOI Manager
Oil and Gas Authority
21 Bloomsbury Street
London
WC1B 3HF
Email:
xxxxxxxxxxx@xxxxxxxxxxx.xx.xx Please quote the reference number above in any future communications with regard
to this request.
If you are unhappy with the outcome of the internal review, you may contact the
Information Commissioner a
t www.ico.org.uk or at Information Commissioner’s
Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
Oil and Gas Authority is a limited company registered in England and Wales with registered number 09666504 and VAT registered number 249433979. Our registered
office is at 21 Bloomsbury Street, London, United Kingdom, WC1B 3HF.
For information about how we process data and monitor communications please see our Data Protection Statement and for terms of use please see our Terms and
Conditions, both available on our website.
Yours sincerely,
FOI Officer
Oil and Gas Authority is a limited company registered in England and Wales with registered number 09666504 and VAT registered number 249433979. Our registered
office is at 21 Bloomsbury Street, London, United Kingdom, WC1B 3HF.
For information about how we process data and monitor communications please see our Data Protection Statement and for terms of use please see our Terms and
Conditions, both available on our website.