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Animal Experimentation at Cardiff University

Dr Adrian Stallwood made this Freedom of Information request to Cardiff University

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Dr Adrian Stallwood

Dear Cardiff University,

I write to request information concerning animal experimentation undertaken by the University of Cardiff, under the Freedom of Information Act 2000.

I would be grateful if you would provide me with the following information:

1. For the years 2010 - 2012, the minutes, reports and correspondence of any Ethical Review Committee or sub-committee at University or any other level (including but not limited to departmental committees), where these relate to animal experimentation, in addition to any guidance issued by these committees at any time if it is currently in use.

2. For the years 2010 - 2012, the number of animals used in regulated procedures under the Animals (Scientific Procedures) Act 1986, broken down by species.

3. For the years 2010 - 2012, the number of mice who were bred and killed before undergoing any licensed procedures, and the proportion of these that were genetically altered. If this figure is not centrally recorded, an estimated percentage from the main users of mice would be an acceptable alternative.

Information that identifies individuals who are or were involved in animal experimentation can be redacted if you believe this to be appropriate. If you require any clarification in order to comply with this request, please contact me at the earliest opportunity. I look forward to receiving the information requested within 20 working days.

Yours faithfully
Dr Adrian Stallwood

Yours faithfully,

Dr Adrian Stallwood

InfoRequest, Cardiff University

Dear Dr Stallwood

I acknowledge receipt of your Freedom of Information request below
received by this office on 15th January 2013  in which you requested
information regarding animal experimentation.  This has been allocated
reference FOI2013-009 which should be quoted in all correspondence.

Your query will now be dealt with under the Freedom of Information Act
2000 and we will respond to your request within 20 working days starting
the day after receipt. Therefore you can expect to receive a response no
later than 12th February 2013.

In some circumstances we may not be able to meet this deadline and if this
is likely to be the case we will contact you as soon as possible and give
you a revised date for response.

Kind regards
Information Governance Team
Governance and Compliance Division
Cardiff University
McKenzie House
30-36 Newport Road
Cardiff
CF24 0DE

Fax 029 20874478
Tel 029 20879351

Freedom of Information request - Animal Experimentation at Cardiff
University

Dr Adrian Stallwood   to: FOI requests at Cardiff 14/01/2013 19:32
University

From: Dr Adrian Stallwood <[FOI #145573 email]>
To: FOI requests at Cardiff University <[Cardiff University request email]>

     Dear Cardiff University,
   
    I write to request information concerning animal experimentation
    undertaken by the University of Cardiff, under the Freedom of
    Information Act 2000.
   
    I would be grateful if you would provide me with the following
    information:
   
    1. For the years 2010 - 2012, the minutes, reports and
    correspondence of any Ethical Review Committee or sub-committee at
    University or any other level (including but not limited to
    departmental committees), where these relate to animal
    experimentation, in addition to any guidance issued by these
    committees at any time if it is currently in use.
   
    2. For the years 2010 - 2012, the number of animals used in
    regulated procedures under the Animals (Scientific Procedures) Act
    1986, broken down by species.
   
    3. For the years 2010 - 2012, the number of mice who were bred and
    killed before undergoing any licensed procedures, and the
    proportion of these that were genetically altered. If this figure
    is not centrally recorded, an estimated percentage from the main
    users of mice would be an acceptable alternative.
   
    Information that identifies individuals who are or were involved in
    animal experimentation can be redacted if you believe this to be
    appropriate. If you require any clarification in order to comply
    with this request, please contact me at the earliest opportunity. I
    look forward to receiving the information requested within 20
    working days.
   
    Yours faithfully
    Dr Adrian Stallwood
   
    Yours faithfully,
   
    Dr Adrian Stallwood
   
    -------------------------------------------------------------------
   
    Please use this email address for all replies to this request:
    [FOI #145573 email]
   
    Is [Cardiff University request email] the wrong address for Freedom of
    Information requests to Cardiff University? If so, please contact
    us using this form:
    [1]http://www.whatdotheyknow.com/help/contact
   
    Disclaimer: This message and any reply that you make will be
    published on the internet. Our privacy and copyright policies:
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    -------------------------------------------------------------------

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InfoRequest, Cardiff University

Dear Dr Stallwood

I am writing in response to your Freedom of Information request below
dated 14 January 2013 in which you requested information regarding animal
experimentation.

The University can confirm that information is held in relation to your
request however it is considered that the following exemptions apply to
significant elements of that information:

Section 38(1) Health and Safety - The University considers that some of
the location information contained within the information requested, if
released, is likely to endanger the health and safety of staff directly
involved in the research, their families and colleagues due to the
increased risk of
targeting by extremist animal rights groups.

As per Section 10(3) of the Act, the University reasonably requires more
time to consider the Public Interest Test under the Section 38(1)
exemption. The University considers that a maximum of five more working
days will be sufficient to fully deliberate the Public Interest Test and
therefore you can expect to receive a full detailed response to your
request and any information not covered by exemptions, no later than 19
February 2012.

In the meantime if you have any further queries please do not hesitate to
get in touch.

Yours sincerely,

Matt Cooper
Information Governance Team
Governance and Compliance Division
Cardiff University
McKenzie House
30-36 Newport Road
Cardiff
CF24 0DE

Fax 029 20874478
Tel 029 20879351

InfoRequest, Cardiff University

23 Attachments

 Dear Dr Stallwood,

I am writing in response to your Freedom of Information request below
dated 14 January 2013 in which you requested information regarding animal
experimentation. As you will recall, the University required extra time in
order to consider the public interest in the application of exemption
Section 38 - Health and Safety. These deliberations are now complete and
our response to your questions are as follows:

1. For the years 2010 - 2012, the minutes, reports and correspondence of
any Ethical Review Committee or sub-committee at University or any other
level (including but not limited to departmental committees), where these
relate to animal experimentation, in addition to any guidance issued by
these committees at any time if it is currently in use.

The anonymised minutes of the Cardiff University Biological Standards
Committee are supplied as attachments below:

(See attached file: r_53 Oct 12.pdf)(See attached file: r_43 Mar
10.pdf)(See attached file: r_44 May 10.pdf)(See attached file: r_45 Oct
10.pdf)(See attached file: r_46 Dec 10.pdf)(See attached file: r_47 Mar
11.pdf)(See attached file: r_48 May 11.pdf)(See attached file: r_49 Oct
11.pdf)(See attached file: r_50 Jan 12.pdf)(See attached file: r_51
Mar12.pdf)(See attached file: r_52 May12.pdf)

This Committee encompasses a number of different functions, one of which
is “Ethical Review”, and the committee reports requested have been drawn
from this section of the Committee’s agenda to maintain pertinence with
the request.

(See attached file: r_BSC'12'06 Licensing Report Oct12.pdf)(See attached
file: BSC'09'27 Licensing report Mar10.pdf)(See attached file: BSC'09'49
Licensing report May10.pdf)(See attached file: BSC'10'03 Licensing report
Oct10.pdf)(See attached file: BSC'10'19 Licensing Report Dec10.pdf)(See
attached file: BSC'10'31 Licensing Report Mar11.pdf)(See attached file:
BSC'11'47 Licensing Report May12.pdf)(See attached file: r_BSC'10'41
Licensing Report May11.pdf)(See attached file: r_BSC'11'06 Licensing
Report Oct11.pdf)(See attached file: r_BSC'11'20 Licensing Report
Jan12.pdf)(See attached file: r_BSC'11'37 Licensing Report Mar12.pdf)

Information relating to locations of facilities in these minutes has been
withheld under the qualified exemption in section 38 of the Freedom of
Information Act 2000:

38. – (1)  Information is exempt information if its disclosure under
 this Act would, or would be likely to-

(a)  endanger the physical or mental health of any individual, or
(b)  endanger the safety of any individual….

Cardiff University has applied the exemption and determined that in all
the circumstances of the case the public interest in maintaining the
exclusion outweighs the public interest in releasing the information held.

In reaching this decision the University has considered the duty of care
owed to staff working in the facilities.  Their health and safety requires
the University to protect and maintain a safe environment which includes
the security of the sites at which they operate.  In particular
consideration has been given to the effects of disclosure concerning:

i. the welfare of employees working in those facilities (which present
particular security risks) and
ii. the University’s ability to comply with its statutory responsibilities
to staff within Health and Safety legislation and
iii. the University’s general duty of care in respect of its staff and
students

Disclosure of the information withheld under s38(1) relating to locations
would be likely to endanger the safety of licence holders and other staff
and students within proximity, as it is more than a remote possibility
that the information may be used to incite and target acts of violence
and/or harassment (s38(1)(b)). Indeed evidence of this is demonstrated by
the fact that previously when news stories about animal experiments have
appeared in the media, the University has received letters directed
against the staff and the wider university threatening physical violence
and destruction of property which have been passed to the police. Clearly,
identifying locations would allow direct targeting and would substantially
increase the risk of such attacks being carried out endangering the safety
of individuals.

In the context of this existing threat, Cardiff University takes the view
(of which the Commissioner himself is mindful, see ICO Decision Notice –
No: FS50108125 para 29) that for s38 to be engaged it is sufficient to
show that the publication of information might lead to an increased threat
to the health and safety of staff, the factor being always significant no
matter how small the risk.

In the circumstances the University has balanced the public interest in
disclosing the location of site specific information.  The output from
research is publicly available through research papers.  The public
interest in providing information from which specific facilities could be
located does not outweigh the factors the University has taken into
account as above.

Where individuals can be identified from information the University has
also applied the exemption under Section 40(2) of the Act entitled -
Personal Information. This exemption applies where to release such
information would breach any of the data protection principles. The
University considers that it would not be fair to disclose this personal
data to the public without the consent of the data subject. In the absence
of consent and in the presence of a clearly perceived threat to the data
subject, the University is unable to establish lawful grounds for
disclosure as to do so would be a breach of the first data protection
principle.

The documents disclosed are from the Committee dealing with ERP. It should
be noted that ERP is a process, and therefore the documents attached are
not exhaustive of all ethical review considerations and consultations
undertaken.

The University is not providing copies of correspondence relating to these
minutes, nor the relevant sub-committees as to locate and extract the
information held would, in conjunction with all the other searches
required to answer this whole request, exceed the appropriate limit of 18
hours as set out in the The Freedom of Information and Data Protection
(Appropriate Limit and Fees) Regulations 2004.  Accordingly the University
refuses the information contained within correspondence relating to these
minutes and the sub-committees under section 12 of the Freedom of
Information Act.

2. For the years 2010 - 2012, the number of animals used in regulated
procedures under the Animals (Scientific Procedures) Act 1986, broken down
by species.

3. For the years 2010 - 2012, the number of mice who were bred and killed
before undergoing any licensed procedures, and the proportion of these
that were genetically altered. If this figure is not centrally recorded,
an estimated percentage from the main users of mice would be an acceptable
alternative.

Any procedure carried out after an animal has been killed falls outside
the scope of the Animals (Scientific Procedures) Act and would not,
therefore, need licensed authority.

Whilst the numbers of mice used in licensed procedures are recorded and
disclosed at question 2 above, central records are not held of the number
of mice who were bred and killed before undergoing a licensed procedure,
or the proportion of mice that were genetically altered and it would not
be possible for the University to identify, extract and collate the
information within 18 hours.  Accordingly section 12(2) of the Freedom of
Information Act 2000 will apply as the time involved in searching for and
providing this information would exceed the appropriate time limit as set
out in the Freedom of Information and Data Protection (Appropriate Limit
and Fees) Regulations 2004.

I trust this information satisfies your enquiry.  The University has a
Freedom of Information Complaints Procedure should you feel dissatisfied
with this response or the way in which your request was handled.
Complaints must be made in writing within two months and must set out why
you believe the University has not met its obligations under the Freedom
of Information Act.  You may email your complaint to
[1][email address].uk where it will be forwarded to the Director of
Registry, Governance and Students Directorate who will be responsible for
overseeing the review.

If you are not happy with the outcome of such an internal review, you have
the right to apply directly to the Information Commissioner for a
decision.  The Information Commissioner can be contacted at the following
address: Information Commissioner's Office, Wycliffe House, Water Lane,
Wilmslow, Cheshire, SK9 5AF.

I would like to take this opportunity to thank you for your interest in
Cardiff University. If you require further assistance please feel free to
contact me.

Yours sincerely
Information Governance Team
Governance and Compliance Division
Cardiff University
McKenzie House
30-36 Newport Road
Cardiff
CF24 0DE

Fax 029 20874478
Tel 029 20879351

References

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Dr Adrian Stallwood

Dear InfoRequest,

Thanks for this. I'm happy with the redactions, and do not consider them overtly censorious.

I cannot however find the figures for animal usage in answer to my question 2, which you say you have disclosed. Have I missed something?

Yours sincerely,

Dr Adrian Stallwood

InfoRequest, Cardiff University

1 Attachment

Dear Dr Stallwood

The figures for Question 2 were set out in a table in our response and it
would appear this format has not appeared on your response.  I have
therefore attached an Excel spreadsheet with this information.

Kind Regards
Information Governance Team
Governance and Compliance Division
Cardiff University
McKenzie House
30-36 Newport Road
Cardiff
CF24 0DE

Fax 029 20874478
Tel 029 20879351

Re: FOI 2013-009 - Animal Experimentation

Dr Adrian Stallwood   to: InfoRequest 19/02/2013 21:11

From: Dr Adrian Stallwood <[FOI #145573 email]>
To: InfoRequest <[Cardiff University request email]>

     Dear InfoRequest,
   
    Thanks for this. I&#39;m happy with the redactions, and do not
    consider them overtly censorious.
   
    I cannot however find the figures for animal usage in answer to my
    question 2, which you say you have disclosed. Have I missed
    something?
   
    Yours sincerely,
   
    Dr Adrian Stallwood
   
   

show quoted sections

We don't know whether the most recent response to this request contains information or not – if you are Dr Adrian Stallwood please sign in and let everyone know.