Dear Rural Payments Agency,
Could you please provide me with the County Parish Holding Number, if any, for the variously named Spencer's Retreat Farm/Alexander Stables, Spencer's Lane, Berkswell, Solihull CV7 7BY.
The site keeps sheep, goats, pigs, poultry and ponies on approx. 2.02 ha. I believe the closest Grid Reference Number to the Postcode CV7 7BY is: SP 25778
Mrs S Cooper
20 April 2020
Our ref: RFI 5438
Dear Mrs Cooper,
Environmental Information Regulations – Information Request
We refer to your request for information dated 6 April 2020 which we have
dealt with under the Environmental Information Regulations 2004 (EIR).
Please accept our apologies for the delay in acknowledging your request.
You have requested the County Parish Holding number (CPH) for a particular
The RPA can confirm that the information you have requested is held
however, following careful consideration we regret to inform you that we
are unable to divulge the information as the exception to the duty to
disclose environmental information set out in Regulation 12(3) (Personal
Information) of the EIR applies.
Under EIR, if the information is the personal data of a person other than
the applicant, information should not be disclosed other than in specific
circumstances set out in Regulation 13 of EIR, none of which apply here.
The RPA considers any information which could identify a living
individual, to be personal data.
The General Data Protection Regulations (GDPR) and Data Protection Act
(DPA) 2018 defines personal data as follows:
‘personal data’ means any information relating to an identified or
identifiable natural person (‘data subject’); an identifiable natural
person 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 that natural person;’
As the information requested is the personal data of another party we
should consider whether disclosure would breach the data protection
principles at Article 5 of GDPR.
We consider that the first data protection principle (Article 5 1. (a) of
GDPR) would be breached if the requested information was disclosed. It
1. Personal data shall be:
(a) processed lawfully, fairly and in a transparent manner in relation to
the data subject (‘lawfulness, fairness and transparency’)
When considering whether disclosure of information is a breach of the
above principle (a), we should first consider whether disclosure is lawful
and then whether it is fair.
Article 6 1. (a) of GDPR states:
1. Processing shall be lawful only if and to the extent that:
(a) the data subject has given consent to the processing of his or her
personal data for one or more specific purposes;
We consider that, in the absence of consent from the data subject it would
not be lawful (or fair) to disclose the requested information and the only
condition in Article 6 which could have any relevance to disclosure, is
(f) 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 particular
where the data subject is a child.
In this context, the legitimate interests of a third party are held to be
the legitimate interests of the public at large rather than a particular
individual. Having considered the balance between the legitimate interests
of the public at large and the rights or legitimate interests of the data
subject we do not consider that the information should be released. This
* There is insufficient general public interest in the level of detail
you are requesting to be released to justify the disclosure; and
The data subject has not given permission to share their data with the
public at large and the data release would therefore be unfair and
incompatible with the purpose of which it was collected.
What you need to do
If you are not happy with the way we have handled your request, you can
ask for an internal review. These requests should be submitted in writing
within two months of the date of receipt of the response to your original
request and should be addressed to the Information Rights Team at the
Rural Payments Agency, North Gate House, 21-23 Valpy Street, Reading, RG1
1AF or alternatively email your request for a review to [email address]
If you are not content with the outcome of the internal review, you have
the right to apply directly to the Information Commissioner for a
decision. Please note that generally the Information Commissioner cannot
make a decision unless you have first exhausted RPA’s own complaints
procedure. The Information Commissioner can be contacted at:
Information Commissioner’s Office, Wycliffe House, Water Lane,
Wilmslow, Cheshire, SK9 5AF.
If you need further information
If you have any questions about this email, you can contact us by email
[Rural Payments Agency request email].
You can find more information on how we handle personal data in our
Personal Information Charter and RPA Privacy notices on GOV.UK
Information Rights Team
Rural Payments Agency | North Gate House | Reading | RG1 1AF
Tel: 03300 416502 | Fax: 03300 416574 | Email: [email address]
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