Nid ydym yn gwybod a yw'r ymateb mwyaf diweddar i'r cais hwn yn cynnwys gwybodaeth neuai peidio - os chi ywAlly Tibbitt mewngofnodwch a gadael i bawb wybod.

Current and historical Registers of Interest data

Ally Tibbitt made this Rhyddid Gwybodaeth request to Greenwich Borough Council as part of a batch sent to 415 authorities

This request has been closed to new correspondence from the public body. Contact us if you think it ought be re-opened.

We're waiting for Ally Tibbitt to read recent responses and update the status.

Dear Greenwich Borough Council,

Please treat this email as a Freedom of Information request.

I would like to receive a copy of the complete current local authority Register of Interest for all elected politicians in a machine-readable spreadsheet format such as a CSV file, including any additional information that may not be published on your website.

If you hold records relating to historical registers of interest for current and former elected politicians I would be grateful if you could also supply them.

I would also like to receive a copy of the complete current local authority Gifts and Hospitality Registers for all elected politicians in a machine-readable spreadsheet format, including any data that may not be published on your website.

If you hold historical records of gifts or hospitality received for current and former elected politicians I would be grateful if you could also supply them.

Lastly, if you hold a separate register of interests that records those declared at meetings, please also supply that register in a machine-readable spreadsheet format. Again, if you hold historical records of declarations that may not be published on your website, please supply details.

I would prefer not to receive the requested information in pdf format files.

If the requested information is published as open data, please could you supply the location where this data can be found.

I look forward to hearing from you in due course.

Yours faithfully,

Ally Tibbitt

foi, Greenwich Borough Council

Dear Ms Tibbitt

 

Freedom of Information request:  FOI-37625

 

Thank you for your request dated 25 February 2020

 

Your request will be answered by 24 March 2020

 

If you have any queries about this request, please contact me, quoting the
reference number above.

 

Yours sincerely,

 

Jackie Jago

Head of Corporate Services

Corporate Services

Directorate of Communities & Environment

Royal Borough of Greenwich

 

' 020 8921 5044

*   3^rd Floor, The Woolwich Centre, 35 Wellington Street, London, SE18
6HQ

8 www.royalgreenwich.gov.uk

 

ü Please consider the environment before printing this email

 

 

dangos adrannau a ddyfynnir

foi, Greenwich Borough Council

Dear Ms Tibbitt

 

Freedom of Information request:  FOI-37625

Please accept our apologies for the delay in providing a response to your
Freedom of Information request.  This is due to urgent operational
responses in dealing with Covid-19 priorities.  We apologise for any
inconvenience this may cause, we do remain committed to responding to your
request and will respond as soon as we are able to do so.  

 

Yours sincerely,

 

David White

Information & Systems Manager

Directorate of Communities and Environment

Royal Borough of Greenwich

 

' 020 8921 3943

*   The Woolwich Centre, Wellington Street, Woolwich, London, SE18 6HQ

8 [1]www.royalgreenwich.gov.uk

 

ü Please consider the environment before printing this email

 

 

From: foi
Sent: 25 February 2020 14:58
To: 'Ally Tibbitt' <[FOI #649751 email]>
Cc: foi <[Greenwich Borough Council request email]>
Subject: FOI-37625: Freedom of Information request - Current and
historical Registers of Interest data

 

Dear Ms Tibbitt

 

Freedom of Information request:  FOI-37625

 

Thank you for your request dated 25 February 2020

 

Your request will be answered by 24 March 2020

 

If you have any queries about this request, please contact me, quoting the
reference number above.

 

Yours sincerely,

 

Jackie Jago

Head of Corporate Services

Corporate Services

Directorate of Communities & Environment

Royal Borough of Greenwich

 

' 020 8921 5044

*   3^rd Floor, The Woolwich Centre, 35 Wellington Street, London, SE18
6HQ

8 www.royalgreenwich.gov.uk

 

ü Please consider the environment before printing this email

 

 

dangos adrannau a ddyfynnir

foi, Greenwich Borough Council

Dear Ms Tibbitt

 

Freedom of Information request:  FOI-37625

 

Thank you for your request dated 25 February 2020

 

Our response is as follows:

 

I would like to receive a copy of the complete current local authority
Register of Interest for all elected politicians in a machine-readable
spreadsheet format such as a CSV file, including any additional
information that may not be published on your website.

 

Section 21(1) of the FOIA says that information which is reasonably
accessible to the applicant otherwise than under section 1 is exempt
information.

 

            The Register of Interests for each of the current Councillors
can be found on the individual Councillor pages on the website.  See link
below.

 You need to click on View to access the Register.

 

            [1]CMIS > Councillors
[2]https://www.royalgreenwich.gov.uk/info/2...

 

 

If you hold records relating to historical registers of interest for
current and former elected politicians I would be grateful if you could
also supply them.

 

Section 40(2) of the FOIA provides that information is exempt from
disclosure if it is the personal data of an individual other than the
requester and where one of the conditions listed in section 40(3A)(3B) or
40(4A) is satisfied.

 

In relation to your request the relevant condition is contained in section
40(3A)(a). This applies where the disclosure of the information to any
member of the public would contravene any of the principles relating to
the processing of personal data (‘the DP principles’), as set out in
Article 5 of the General Data Protection Regulation (‘GDPR’).

 

Firstly the Council has considered the requested information constitutes
personal data as defined by The Data Protection Act 2018 (DPA)  as amended
by Schedule 19 Paragraph 58(3)DPA 2018(DPA).

 

Secondly, the Council considers that disclosure of the withheld
information will breach one of the data protection principles. 

 

Is the information personal data?

 

Section 3(2) of the DPA defines personal data as: “any information
relating to an identified or identifiable living individual”.

 

The two main elements of personal data are that the information must
relate to a living person and that the person must be identifiable. An
identifiable living individual is one who can be identified, directly or
indirectly, in particular by reference to an identifier such as a name, an
identification number, location data, an online identifier or to one or
more factors specific to the physical, physiological, genetic, mental,
economic, cultural or social identity of the individual.

Information will relate to a person if it is about them, linked to them,
has biographical significance for them, is used to inform decisions
affecting them or has them as its main focus.

 

The requested information relates to current and former elected
politicians, which includes their names.

 

The requested information identifies the individuals concerned and
identifies them in relation to their roles as current or former
politicians. The information therefore falls within the definition of
‘personal data’ in section 3(2) of the DPA.

 

The second element of the test is to determine whether disclosure would
contravene any of the data protection principles.

 

The most relevant DPA principle in this case is principle (a).

 

Would disclosure contravene principle (a)?

 

Article 5(1)(a) of the General Data Protection Regulation 2018 (GDPR)
states that: “Personal data shall be processed lawfully, fairly and in a
transparent manner in relation to the data subject/s.

 

This means that the information can only be disclosed if to do so would be
lawful, fair and transparent.

 

Article 6(1) of the GDPR specifies the requirements for lawful processing
by providing that “processing shall be lawful only if and to the extent
that at least one of the” lawful bases for processing listed in the
Article applies.

 

The Council considers that the lawful basis most applicable is basis
6(1)(f) which states: “processing is necessary for the purposes of the
legitimate interests pursued by the controller or by a third party except
where such interests are overridden by the interests or fundamental rights
and freedoms of the data subject which require protection of personal
data,

 

 

In considering the application of Article 6(1)(f) of the GDPR in the
context of a request for information under freedom of information, it is
necessary to consider the following three-part test: - i) Legitimate
interest test: Whether a legitimate interest is being pursued in the
request for information; ii) Necessity test: Whether disclosure of the
information is necessary to meet the legitimate interest in question; iii)
Balancing test: Whether the above interests override the legitimate
interest(s) or fundamental rights and freedoms of the data subject.

 

The Council has considered that the test of ‘necessity’ under stage (ii)
must be met before the balancing test under stage (iii) is applied.

 

In considering any legitimate interest(s) in the disclosure of the
requested information. The Council recognises that such interest(s) can
include broad general principles of accountability and transparency for
their own sake, as well as case specific interests.

 

 

The council recognised that there is a legitimate interest in the
information being disclosed in order to create greater accountability and
transparency.

 

Is disclosure necessary?

 

  The council considers that a disclosure of the information is not
necessary in this instance. Sufficient information has already been
disclosed to meet the legitimate interests in creating transparency and
accountability. (which is contained in the link).

 

The Council’s view is there is no need for the requested information of
the individuals to be disclosed in order to meet the legitimate interests
it as identified.

 

The central legitimate interest relates to creating transparency and the
Council has provided all of the other requested information which is
contained in the link referred to above.

 

 

The Council accepts that the information which the council has already
disclosed provides a clear and transparent record of the councillors’
interests.

 

This additional disclosure of this information would add no additional
value to the requester other than allowing the public to identify the
names of the politicians.

 

From the point of view of creating public transparency and accountability,
the essential information has already been disclosed

 

. The Council has therefore decided that it was not necessary for this
information to be disclosed.

 

The Council has decided that disclosure is not necessary to meet the
legitimate interest in disclosure. As disclosure is not necessary, there
is no lawful basis for this processing and it is unlawful and does not
meet the requirements of principle (a). For the reasons et out above the
information is withheld in accordance with section 40(2).

 

 

I would also like to receive a copy of the complete current local
authority Gifts and Hospitality Registers for all elected politicians in a
machine-readable spreadsheet format, including any data that may not be
published on your website.

 

Section 21(1) of the FOIA says that information which is reasonably
accessible to the applicant otherwise than under section 1 is exempt
information.

 

           The Gifts and hospitality information is contained in the
Registers of Interests –
[3]https://www.royalgreenwich.gov.uk/info/2...

 

If you hold historical records of gifts or hospitality received for
current and former elected politicians I would be grateful if you could
also supply them.

 

Section 40(2) of the FOIA provides that information is exempt from
disclosure if it is the personal data of an individual other than the
requester and where one of the conditions listed in section 40(3A)(3B) or
40(4A) is satisfied.

 

In relation to your request the relevant condition is contained in section
40(3A)(a). This applies where the disclosure of the information to any
member of the public would contravene any of the principles relating to
the processing of personal data (‘the DP principles’), as set out in
Article 5 of the General Data Protection Regulation (‘GDPR’).

 

Firstly the Council has considered the requested information constitutes
personal data as defined by The Data Protection Act 2018 (DPA)  as amended
by Schedule 19 Paragraph 58(3)DPA 2018(DPA).

 

Secondly, the Council considers that disclosure of the withheld
information will breach one of the data protection principles. 

 

Is the information personal data?

 

Section 3(2) of the DPA defines personal data as: “any information
relating to an identified or identifiable living individual”.

 

The two main elements of personal data are that the information must
relate to a living person and that the person must be identifiable. An
identifiable living individual is one who can be identified, directly or
indirectly, in particular by reference to an identifier such as a name, an
identification number, location data, an online identifier or to one or
more factors specific to the physical, physiological, genetic, mental,
economic, cultural or social identity of the individual.

Information will relate to a person if it is about them, linked to them,
has biographical significance for them, is used to inform decisions
affecting them or has them as its main focus.

 

The requested information relates to current and former elected
politicians, which includes their names.

 

The requested information identifies the individuals concerned and
identifies them in relation to their roles as current or former
politicians. The information therefore falls within the definition of
‘personal data’ in section 3(2) of the DPA.

 

The second element of the test is to determine whether disclosure would
contravene any of the data protection principles.

 

The most relevant DPA principle in this case is principle (a).

 

Would disclosure contravene principle (a)?

 

Article 5(1)(a) of the General Data Protection Regulation 2018 (GDPR)
states that: “Personal data shall be processed lawfully, fairly and in a
transparent manner in relation to the data subject/s.

 

This means that the information can only be disclosed if to do so would be
lawful, fair and transparent.

 

Article 6(1) of the GDPR specifies the requirements for lawful processing
by providing that “processing shall be lawful only if and to the extent
that at least one of the” lawful bases for processing listed in the
Article applies.

 

The Council considers that the lawful basis most applicable is basis
6(1)(f) which states: “processing is necessary for the purposes of the
legitimate interests pursued by the controller or by a third party except
where such interests are overridden by the interests or fundamental rights
and freedoms of the data subject which require protection of personal
data,

 

 

In considering the application of Article 6(1)(f) of the GDPR in the
context of a request for information under freedom of information, it is
necessary to consider the following three-part test: - i) Legitimate
interest test: Whether a legitimate interest is being pursued in the
request for information; ii) Necessity test: Whether disclosure of the
information is necessary to meet the legitimate interest in question; iii)
Balancing test: Whether the above interests override the legitimate
interest(s) or fundamental rights and freedoms of the data subject.

 

The Council has considered that the test of ‘necessity’ under stage (ii)
must be met before the balancing test under stage (iii) is applied.

 

In considering any legitimate interest(s) in the disclosure of the
requested information. The Council recognises that such interest(s) can
include broad general principles of accountability and transparency for
their own sake, as well as case specific interests.

 

 

The council recognised that there is a legitimate interest in the
information being disclosed in order to create greater accountability and
transparency.

 

Is disclosure necessary?

 

  The council considers that a disclosure of the information is not
necessary in this instance. Sufficient information has already been
disclosed to meet the legitimate interests in creating transparency and
accountability. (which is contained in the link).

 

The Council’s view is there is no need for the requested information of
the individuals to be disclosed in order to meet the legitimate interests
it as identified.

 

The central legitimate interest relates to creating transparency and the
Council has provided all of the other requested information which is
contained in the link referred to above.

 

 

The Council accepts that the information which the council has already
disclosed provides a clear and transparent record of the councillors’
interests.

 

This additional disclosure of this information would add no additional
value to the requester other than allowing the public to identify the
names of the politicians.

 

From the point of view of creating public transparency and accountability,
the essential information has already been disclosed

 

. The Council has therefore decided that it was not necessary for this
information to be disclosed.

 

The Council has decided that disclosure is not necessary to meet the
legitimate interest in disclosure. As disclosure is not necessary, there
is no lawful basis for this processing and it is unlawful and does not
meet the requirements of principle (a). For the reasons et out above the
information is withheld in accordance with section 40(2).

 

 

 

Lastly, if you hold a separate register of interests that records those
declared at meetings, please also supply that register in a
machine-readable spreadsheet format. Again, if you hold historical records
of declarations that may not be published on your website, please supply
details. 

 

Section 21(1) of the FOIA says that information which is reasonably
accessible to the applicant otherwise than under section 1 is exempt
information.

 

            This information is also on the website.  See above link under
“Meeting Declarations” 
[4]https://www.royalgreenwich.gov.uk/info/2...

 

 

 

 

 

If you have any queries about this correspondence, please contact me,
quoting the reference number above.

 

If you are not satisfied with our response to your request, you can ask
for an Internal Review.  Internal review requests must be submitted within
two months of the date of receipt of the response to your original
request.  If you wish to do this, please contact us in writing, setting
out why you are dissatisfied.

 

If you are not satisfied with the outcome of the Internal Review, you may
apply directly to the Information Commissioner (ICO) for a decision. 
Generally, the ICO cannot make a decision unless you have exhausted the
Internal Review procedure provided by the Council. You can contact the ICO
by emailing [5][email address], or by post at Customer Contact,
Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow,
SK9 5AF.

 

Yours sincerely,

 

David White

Information & Systems Manager

Directorate of Communities and Environment

Royal Borough of Greenwich

 

' 020 8921 3943

*   The Woolwich Centre, Wellington Street, Woolwich, London, SE18 6HQ

8 [6]www.royalgreenwich.gov.uk

 

ü Please consider the environment before printing this email

 

 

From: foi
Sent: 31 March 2020 10:09
To: 'Ally Tibbitt' <[FOI #649751 email]>
Cc: foi <[Greenwich Borough Council request email]>
Subject: FOI-37625: Freedom of Information request - Current and
historical Registers of Interest data

 

Dear Ms Tibbitt

 

Freedom of Information request:  FOI-37625

Please accept our apologies for the delay in providing a response to your
Freedom of Information request.  This is due to urgent operational
responses in dealing with Covid-19 priorities.  We apologise for any
inconvenience this may cause, we do remain committed to responding to your
request and will respond as soon as we are able to do so.  

 

Yours sincerely,

 

David White

Information & Systems Manager

Directorate of Communities and Environment

Royal Borough of Greenwich

 

' 020 8921 3943

*   The Woolwich Centre, Wellington Street, Woolwich, London, SE18 6HQ

8 [7]www.royalgreenwich.gov.uk

 

ü Please consider the environment before printing this email

 

 

From: foi
Sent: 25 February 2020 14:58
To: 'Ally Tibbitt' <[8][FOI #649751 email]>
Cc: foi <[9][Greenwich Borough Council request email]>
Subject: FOI-37625: Freedom of Information request - Current and
historical Registers of Interest data

 

Dear Ms Tibbitt

 

Freedom of Information request:  FOI-37625

 

Thank you for your request dated 25 February 2020

 

Your request will be answered by 24 March 2020

 

If you have any queries about this request, please contact me, quoting the
reference number above.

 

Yours sincerely,

 

Jackie Jago

Head of Corporate Services

Corporate Services

Directorate of Communities & Environment

Royal Borough of Greenwich

 

' 020 8921 5044

*   3^rd Floor, The Woolwich Centre, 35 Wellington Street, London, SE18
6HQ

8 www.royalgreenwich.gov.uk

 

ü Please consider the environment before printing this email

 

 

dangos adrannau a ddyfynnir

Nid ydym yn gwybod a yw'r ymateb mwyaf diweddar i'r cais hwn yn cynnwys gwybodaeth neuai peidio - os chi ywAlly Tibbitt mewngofnodwch a gadael i bawb wybod.