Signatories to petitions

The request was successful.

Dear Bristol City Council,

I would like you to supply to me the 'IP Address' (unique identifier of the computer signing the petition) that you log for each signatory to:

http://epetitions.bristol.gov.uk/epetiti...

The IP address is not personally identifiable without corresponding information from their internet provider, so I do not believe falls under the DPA.

Yours faithfully,

Tom Hodder

Freedom of Information, Bristol City Council

Thank you for your request for Information made under the Freedom of Information Act.

Your request will now be dealt with and a response will be sent within 20 working days, starting from the next working day after your request is received.

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Dear BCC Freedom of Information,

You are outside of the time limit laid down by law. Please either provide me with the information requested or an acceptable reason for your delay.

Yours sincerely,

Tom Hodder

Freedom of Information, Bristol City Council

Dear Mr Hodder,

Thank you for your request which is detailed below. I apologise for the
delay in responding.

I would like you to supply to me the 'IP Address' (unique
identifier of the computer signing the petition) that you log for
each signatory to:


http://epetitions.bristol.gov.uk/epetiti...


There appears to be conflicting opinions with regard to whether an IP
Address is considered to be "personal data". As you will be aware the
definition of personal data is " data which relates to a living
individual who can be identified - (a) from those data, or (b) from
those data and other information which is in the possession of, or is
likely to come into the possession of any data controller Data
Protection Act S1(1).

It is very likely that as a data controller, we hold other information
relating to the individuals who have completed the e-petitions in
question and if we chose to combine this information it may be possible
to identify them. And, it is well known that there is publicly available
information that when combined with an IP address, may form a set of
data that could constitute personal data, and this may allow you to
identify them.

I understand that this may not be the case where the IP address is
dynamic and not fixed but we have no way of knowing which type of IP
address it is.

Therefore, Bristol City Council considers IP addresses to be "personal
data" and the disclosure of this information would contravene the data
protection principles, namely the first principle, as e-petition users
are advised:
"Only your name and area will appear on the website. The other details
you give us are needed by the Council to validate your support. This is
the same information required for a paper petition. Your details will
only be used by the council and the principal petitioner for any
petitions that you sign. Your details will not be used for any purposes
other than ePetitions, unless you have expressly given permission
otherwise."
To then release their personal data, or data that could be added to
other data to create personal data, would be misleading those
individuals and therefore would breach the first data protection
principle, for this reason the information is exempt from disclosure
under S40(2).

This response should answer your request in full, however if you are
not satisfied with this response or wish to lodge an appeal against any
exemptions that may have been applied, you can do so by writing to the
Data Protection Officer at Bristol City Council Legal Services, The
Council House, College Green, Bristol, BS99 7PH or [Bristol City Council request email].
Details of the complaints procedure can be found at
http://www.bristol.gov.uk/complaints.

If, after you have exhausted the council’s complaints procedure, you
are still not satisfied with the response you have received you have the
right to complain to the Information Commissioner, details of your right
to complain can be found at http://www.ico.gov.uk/complaints.aspx

Copyright notice
The provision of information by Bristol City Council under this scheme
does not imply a right to reproduce or commercially exploit such
information without the Council's express prior written permission.
Reproduction or commercial exploitation of materials supplied under
this scheme without the express permission of Bristol City Council may
be an infringement of copyright.
The Council is unable to grant permission to reproduce or re-use any
material accessed through this scheme that is the property of third
parties. Permission to reproduce or re-use such material must be
obtained from the copyright holders.

Yours Sincerely
For Head of Legal Services
Stephen McNamara

______________________________________________________________________
'Do it online' with our growing range of online services - http://www.bristol.gov.uk/services

Sign-up for our email bulletin giving news, have-your-say and event information at: http://www.bristol.gov.uk/newsdirect

View webcasts of Council meetings at http://www.bristol.gov.uk/webcast

Bristol is the UK's first Cycling City. Visit www.betterbybike.info to join thousands of others getting around by bike.

Dear Stephen,

Arguably, your publishing of name/area, coupled with a quick search on 192.com or a telephone directory would reveal far more about an individual than an anonymous IP address, but that is a battle for another day.

Let me rephrase my request, hoping it will meet with your requirements. Can you supply me with the number of *unique* IP addresses and non unique IP addresses that have signed the petition in question?

For reference, my definition of non unique is an IP address that has signed the petition more than once.

I am now not asking you to reveal actual IP addresses, just an aggregate number.

Yours sincerely,

Tom Hodder

Dear Stephen,

Can I trust you received this email and are acting on it? I have no received no followup.

Yours faithfully,

Tom Hodder

Freedom of Information, Bristol City Council

Dear Mr Hodder,

Thank you for your email. I can confirm that your refined request received
on 12.11.10 has been sent to the relevant department to be dealt with.
The deadline to respond to your request is 20 working days from the date
the request was received.

Yours Sincerely,
For Head of Legal services
Stephen McNamara
>>> Tom Hodder <[FOI #49203 email]> 19/11/2010
07:56 >>>
Dear Stephen,

Can I trust you received this email and are acting on it? I have no
received no followup.

Yours faithfully,

Tom Hodder

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Freedom of Information, Bristol City Council

Mr Hodder,

In response to your request for "Can you supply me with the number of
*unique* IP addresses and non unique IP addresses that have signed the
petition in question?"

The information is as follows:

Unique IP addresses: 793
Multiple IP addresses: 108 (77% of these had 2 signatures, 99% had less
than 10 signatures)
We would like to add some contextual information to our response to your
FOI request received on 12th November 2010:

* The E-petition system shows paper and online signatories. These
figures can be accessed by hovering the pointer over the signatures
count under Live Petitions . It is the lead petitioner's
responsibility to ensure their is no duplication.
* There were 793 unique IP addresses and 108 non-unique (repeated) IP
addresses and these need to be considered against the figure of the
total online signatories.
* There are number of reasons why e-petitions show multiple signatories
per IP address and we wanted to highlight these:

* Some businesses have one IP address and people sign an e-petition
at work
* Educational establishments have one IP address and students can
sign an e-petition at university or college
* Public internet terminals e.g. in libraries have been used for
people to sign the e-petition
* Several members of a household who share an IP address can
support the petition.

* Of course, there will be an element of individuals who have signed the
petition multiple times. Collecting the IP address helps the council
look at the patterns for multiple completions and check for fraud.
* The e-petitions system insists on an signatory having a unique email
address, so in many respects has more 'checks and balances' than paper
petitions. Of course, it is possible for individuals to set-up
multiple accounts / aliases and we are mindful of this.

This response should answer your request in full, however if you are not
satisfied with this response or wish to lodge an appeal against any
exemptions that may have been applied, you can do so by writing to the
Data Protection Officer at Bristol City Council Legal Services, The
Council House, College Green, Bristol, BS99 7PH or [Bristol City Council request email].
Details of the complaints procedure can be found at
[1]http://www.bristol.gov.uk/complaints.

If, after you have exhausted the council’s complaints procedure, you are
still not satisfied with the response you have received you have the right
to complain to the Information Commissioner, details of your right to
complain can be found at [2]http://www.ico.gov.uk/complaints.aspx

Copyright notice

The provision of information by Bristol City Council under this scheme
does not imply a right to reproduce or commercially exploit such
information without the Council's express prior written permission.

Reproduction or commercial exploitation of materials supplied under this
scheme without the express permission of Bristol City Council may be an
infringement of copyright.

The Council is unable to grant permission to reproduce or re-use any
material accessed through this scheme that is the property of third
parties. Permission to reproduce or re-use such material must be obtained
from the copyright holders.

Yours Sincerely
For Head of Legal Services
Stephen McNamara

>>> Tom Hodder <[FOI #49203 email]> 12/11/10 09:13
>>>
Dear Stephen,

Arguably, your publishing of name/area, coupled with a quick search
on 192.com or a telephone directory would reveal far more about an
individual than an anonymous IP address, but that is a battle for
another day.

Let me rephrase my request, hoping it will meet with your
requirements. Can you supply me with the number of *unique* IP
addresses and non unique IP addresses that have signed the petition
in question?

For reference, my definition of non unique is an IP address that
has signed the petition more than once.

I am now not asking you to reveal actual IP addresses, just an
aggregate number.

Yours sincerely,

Tom Hodder

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