Request to Un-redact IFA names from Payment to Supplier files

Mae'r ymateb i'r cais hwn yn hwyr iawn. Yn ôl y gyfraith, ym mhob amgylchiad, dylai Dudley Council fod wedi ymateb erbyn hyn. (manylion). Gallwch gwyno drwy yn gofyn am adolygiad mewnol.

Dear Dudley Council,

Your payments to suppliers files for the months of Aug, Sep & Oct 2019 contain several (552) redacted entries for IFA names. Kindly request you to please un-redact them, as they do not constitute personal sensitive information.

Thank you,
Yours faithfully,
nikhil prabhu

Information Governance, Dudley Council

Dear Nikhil.

We understand IFA to relate to Independent Financial Advisors. Is this the case in your email below as we do not believe that these are used by Dudley MBC?

If not, I would be grateful if you can define what you mean by an IFA and provide an example of an entry for an IFA name that has been redacted so we can investigate further.

Regards

M J Guy

(Information Governance Officer - Dudley MBC)

dangos adrannau a ddyfynnir

Dear Information Governance,

Thank you for your response. My apologies, by IFA - I was referring to "Independent Fostering Agencies".

If it would help one of the dates is 25-09-2019, net amount=571;
with the narrative ---> RESIDENTIAL CARE PAYMENTS JC3ACA INDEPENDANT FOSTERING AGENCIES 325060771 153003 Revenue General Fund incl HRA

Yours sincerely,
nikhil prabhu

Information Governance, Dudley Council

1 Atodiad

  • Attachment

    Picture Device Independent Bitmap 1.jpg

    10K Download

Dear Nikhil Prabhu,
 
Freedom Of Information Act 2000 - Information Request 22849
 
Your request for information received on 04/03/2020 has now been
considered and the information requested is enclosed.
 
Your Request
Your payments to suppliers files for the months of Aug, Sep & Oct 2019
contain several (552) redacted entries for IFA names. Kindly request you
to please un-redact them, as they do not constitute personal sensitive
information.
 
Our Response
The information you refer to has been withheld because it has been deemed
not suitable for disclosure under the General Data Protection Regulation
and Data Protection Act 2018.
 
In coming to this conclusion the council has considered the Information
Commissioner’s definition of personal data and, more specifically, the
view that personal data includes information relating to a natural person
who can be indirectly identified from the information in combination with
other information.
 
The Information Commissioner’s guidance specifically highlights the
following:

* It is important to be aware that information you hold may indirectly
identify an individual and therefore could constitute personal data.
* Even if you may need additional information to be able to identify
someone, they may still be identifiable.
* That additional information may be information you already hold, or it
may be information that you need to obtain from another source.
* In some circumstances there may be a slight hypothetical possibility
that someone might be able to reconstruct the data in such a way that
identifies the individual. However, this is not necessarily sufficient
to make the individual identifiable in terms of GDPR. You must
consider all the factors at stake.
* When considering whether individuals can be identified, you may have
to assess the means that could be used by an interested and
sufficiently determined person.
* You have a continuing obligation to consider whether the likelihood of
identification has changed over time (for example as a result of
technological developments).

The council has considered other factors in this circumstance including,
for example, the possibility of individuals utilising
names/supplier/finance codes etc to contact the council as bogus service
providers in an attempt to locate a child. To mitigate against this risk
the council has decided not to publish details of Independent Foster
Agencies.
 
The council takes the view that safeguarding and the interests of the
child are paramount and, as a consequence, is not prepared to place this
information into the public domain.
 
If you are unhappy with the service you have received in relation to your
request and wish to make a comment or complaint, or request a review of
the decision, you should write to the Freedom of Information Officer at
Dudley MBC, The Council House, Dudley, West Midlands, DY1 1HF, telephone
0300 555 2345, e-mail [1][Dudley Metropolitan Borough Council request email]   . 
 
Please remember to quote the reference number above in any future
communications.
 
If you are not content with the outcome of your complaint, you may apply
directly to the Information Commissioner for a decision. Generally, the
ICO cannot make a decision unless you have exhausted the complaints
procedure provided by Dudley MBC.
 
The Information Commissioner may be contacted at:
 
Information Commissioner's Office
 
Wycliffe House
Water Lane
Wilmslow 
Cheshire 
SK9 5AF
Telephone:   01625 545 700
[2]www.ico.org.uk
 
Most of the information that we provide in response to Freedom of
Information Act 2000 requests will be subject to copyright protection.  In
most cases the copyright will be owned by Dudley MBC. The copyright in
other information may be owned by another person or organisation, as
indicated in the information itself. You are free to use any information
supplied for your own use, including for non-commercial research purposes.
The information may also be used for the purposes of news reporting.
However, any other type of re-use, for example, by publishing the
information or issuing copies to the public will require the permission of
the copyright owner.
 
For information where the copyright is owned by the Council details of the
conditions on re-use can be found on our website at [3]www.dudley.gov.uk.
 
For information where the copyright is owned by another person or
organisation, you must apply to the copyright owner to obtain their
permission.
 
Yours sincerely,
Mandy Fennell
Information Governance Monitoring Officer
Corporate Information Governance Team
Dudley Council
The Council House
Priory Road
Dudley
West Midlands
DY1 1HF
 
01384 81 4696
[4][email address]
[5]www.dudley.gov.uk
 
 
This Email and any attachments contains confidential information and is
intended solely for the individual to whom it is addressed. If this Email
has been misdirected, please notify the author as soon as possible. If
this email has a protective marking of OFFICIAL – SENSITIVE, PROTECT or
RESTRICTED in its title or contents, the information within must be
subject to appropriate safeguards to protect against unauthorised or
unlawful processing and against accidental loss or destruction or damage.
OFFICIAL – SENSITIVE, PROTECT and RESTRICTED information should only be
further shared where there is a legitimate need. If you are not the
intended recipient you must not disclose, distribute, copy, print or rely
on any of the information contained, and all copies must be deleted
immediately. Whilst we take reasonable steps to try to identify any
software viruses, any attachments to this e-mail may nevertheless contain
viruses which our anti- virus software has failed to identify. You should
therefore carry out your own anti-virus checks before opening any
documents. Dudley Metropolitan Borough Council will not accept any
liability for damage caused by computer viruses emanating from any
attachment or other document supplied with this e-mail.

Please consider the environment - do you need to print this e-mail?

References

Visible links
1. mailto:[Dudley Metropolitan Borough Council request email]
2. http://www.ico.org.uk/
3. http://www.dudley.gov.uk/
4. mailto:[email address]
5. http://www.dudley.gov.uk/

Dear Dudley Council,

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

I am writing to request an internal review of Dudley Council's handling of my FOI request 'Request to Un-redact IFA names from Payment to Supplier files'.

[ GIVE DETAILS ABOUT YOUR COMPLAINT HERE ]
We are not asking for "personal sensitive information". These are payments to IFA (agencies) which every other London Council has provided us. For eg. If it would help one of the dates is 25-09-2019, net amount=571; with the narrative ---> RESIDENTIAL CARE PAYMENTS JC3ACA INDEPENDANT FOSTERING AGENCIES 325060771 153003 Revenue General Fund incl HRA

We will be forced to take up this matter with the Regulator should these values not be Un-Redacted as required by law.

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

Yours faithfully,
nikhil prabhu

Dudley Triggers, Dudley Council

Dear Nikhil Prabhu,

Information Access Request - Information Request DMBCIR:22849
Description : Un-redact IFA names from Payment to Supplier files

I acknowledge your request for information received on 2020-03-04
11:33:00.

Your request is being considered and you will receive the information
requested within the statutory timescale of 20 working days (Freedom of
Information Act 2000/Environmental Information Regulations) or 1 month
from receipt (Data Protection access requests).

For your information, the Acts and Regulations define a number of
exemptions which may prevent release of the information you have
requested. There will be an assessment and if any of the exemption
categories apply then the information may not be released. In some
circumstances the decision to release information, or not, will be based
on a public interest test. You will be advised of any considerations,
subsequent decisions and your rights of appeal.

If the information you request contains reference to a third party then
they may be consulted prior to a decision being taken on whether or not to
release the information to you. You will be informed if this is the case,
including your rights of appeal.

Unless otherwise requested the information may be provided in electronic
format, paper copy, normal font size. If you require alternative formats,
e.g. language, audio, large print, etc. then please let me know.

There may be a fee payable for this information. This will be considered
and you will be informed if a fee is payable. In this event the fee must
be paid before the information is processed and released. The time limit
for responses is suspended until receipt of the payment.

If you have any queries or concerns then please contact the Information
Governance Officer at Dudley MBC, The Council House, Dudley, West
Midlands, DY1 1HF, telephone 0300 555 8283, e-mail
[Dudley Metropolitan Borough Council request email] .

Please remember to quote the reference number above in any future
communications.

Most of the information that we provide in response to Freedom of
Information/Environmental Information requests will be subject to
copyright protection. In most cases the copyright will be owned by Dudley
MBC. The copyright in other information may be owned by another person or
organisation, as indicated in the information itself. You are free to use
any information supplied for your own use, including for non-commercial
research purposes. The information may also be used for the purposes of
news reporting. However, any other type of re-use, for example, by
publishing the information or issuing copies to the public will require
the permission of the copyright owner.

For information where the copyright is owned by the Council details of the
conditions on re-use can be found on our website at www.dudley.gov.uk.

For information where the copyright is owned by another person or
organisation, you must apply to the copyright owner to obtain their
permission.

Yours sincerely,

The Information Governance Team
Council House
Priory Road
Dudley
West Midlands
DY1 1HF
[Dudley Metropolitan Borough Council request email]

Dear Dudley Triggers,

Way I request an update please?

Yours faithfully,
nikhil prabhu

Mail Delivery System,

2 Atodiad

This message was created automatically by mail delivery software.

A message that you sent could not be delivered to one or more of its
recipients. This is a permanent error. The following address(es) failed:

[email address]
host mailcluster.dudley.gov.uk [193.105.48.24]
SMTP error from remote mail server after RCPT TO:<[email address]>:
550 5.1.1 <[email address]>: Recipient address rejected:
User unknown in relay recipient table

Dear Dudley Council,

May I request an update at this point?
Of course being cognizant of the current situation.

Thank you,
Yours sincerely,
nikhil prabhu