John Dimitroulopoulos Sent via email only: email@example.com
13 February 2020
Reference: FOI 2020/013
Dear John Dimitroulopoulos
Re: Freedom of Information Request
Thank you for your recent information request received via email on 18th January 2020. Your
request has been considered under the Freedom of Information (FOI) Act 2000 (the Act).
In your email you requested the following information:
I would like to request the following information about your single honours law course (please
exclude any data on joint honours law courses from your reply).
1. The number of students who enrolled in 2019.
394 undergraduate students enrolled in to the first year of Law and were still current on the 1st
2. A complete, anonymised list of the A-level results achieved by each of the students who
enrolled in 2019. Please break this down by student (e.g. Candidate 1 got A*AA,
Candidate 2 got AAA, etc.) 3. A complete, anonymised list of the IB total points achieved
by each of the students who enrolled in 2019. Please break this down by student (e.g.
Candidate 1 got 35 points out of 45, Candidate 2 got 38 points out of 45, etc.)
I can confirm that we do hold information that falls within questions 2 and 3 of your request.
However, access has been refused to the information on the following grounds:
Please note that section 40(2) exemption has been applied to the information held because we do
not consider it possible to disclose an anonymised list in the form requested as it would be possible
for each student to identify themselves in the list and possibly other students in their cohort.
Students applying for the course would have no expectation that qualifications on admission to the
course would be disclosed and published on an external website. This is not set out in the
information provided to students on application, on registration or in City’s main privacy notice for
students at www.city.ac.uk/about/governance/legal/data-protection.
Section 40(2) states that information is exempt from disclosure if it were to contravene any of the
data protection principles to disclose it, in accordance with Article 5(1) of the General Data
Protection Regulations (GDPR) i.e. that personal data shall be: (a) processed lawfully, fairly and in
a transparent manner in relation to individuals. Section 40(2) also states that if disclosure of the
information were to contravene Article 21 of the GDPR (general processing: right to object to
processing) then it shall also be exempt from disclosure. In line with advice published by the ICO
regarding anonymisation, in particular the risks of jigsaw identification, City considers that
disclosure of the information you have requested would be in contravention Article 5(1)(a) of the
GDPR relating to the principles of processing personal data.
In addition to the privacy concerns City considers that the commercial interests exemption Section
43(2) also applies. A list of the qualifications of each student on admission to any City course,
including the City’s single hours law course, would provide other higher education institutions with
information on City’s admissions strategy and policy that they could use to their advantage and to
the detriment of City’s commercial interests. Higher education institutions also need to be sensitive
to competition law and the sharing of information that could be useful to other higher education
institutions and in time restrict the competitiveness of the sector for future students.
City recognises that there is a public interest in the disclosure of information which facilitates the
accountability and transparency of public bodies for decisions taken by them. However, there is
also a public interest in City being able to work within competitive markets where results in a
financial or resource benefit is put to the wider public interest. Having undertaken the balancing
exercise, City has concluded that the public interest in maintaining the exemption outweighs the
public interest in disclosing the requested information having regard to the effect that the disclosure
would not be in the public interest.
We would like to take this opportunity to inform you, the University has a formal complaints and
internal review process. If you are dissatisfied with the manner your request for information has
been managed, please do so in writing, describe the original request, explain your grounds for
dissatisfaction and include an address for correspondence to the Information Compliance Team
Information Compliance Team Leader
City, University of London
London EC1V 0HB
020 7040 4000
If after contacting City, University of London you are still dissatisfied with the outcome, you have a
right of appeal to the Information Commissioner Office (ICO):
Information Commissioner's Office
Information Compliance Team
City, University of London
London EC1V 0HB T:
+44 (0)20 7040 4000 www.city.ac.uk