John O'Sullivan
Date
21 July 2023
request-992390-
xxxxxxxx@xxxxxxxxxxxxxx.xxx
Post Office
100 Wood Street,
London, EC2V 7ER
Classification:
Public
Dear John O'Sullivan,
Freedom of Information Request – FOI2023/00351
We are writing in response to your email received by Post Office Limited (“
Post
Office”) on 20 June, which has been dealt with under the terms of the Freedom of
Information Act 2000 (“
FOIA”).
In your email you have requested the information shown in bold below:
“
“All required evidence and information supplied on time, with
confirmation from Sir Wyn Williams and team that Post Office’s
performance supported and enabled the Inquiry to finish in line with
expectations.”Can you please say who owned this Metric and was able to
confirm it had been met in order to allow Bonus Payments to be made to
POL Executive?”
We can confirm that Post Office does hold the information you have requested. To
provide context, Post Office considers that the ‘ownership’ of all bonus-related
metrics in the 2021-22 Annual Report and Accounts (“
ARA”) sits with the
Remuneration Committee, rather than any individual, as it is the Remuneration
Committee that is accountable for these metrics.
Whilst we do hold some information that associates individual names with the ARA
inquiry metric, it is the position of Post Office that these individuals were providing a
purely administrative function, such as tracking and monitoring progress through
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committee stages and submitting papers for review by the Remuneration
Committee. Those individuals did not exercise any direct control over the metric, nor
did they hold any decision-making responsibility for its implementation. This control
sat solely with the Remuneration Committee.
We have, therefore, decided that the names of these individuals should be withheld
under sections 40(2) and 40(3A) of the FOIA as the information constitutes personal
data relating to other persons. These sections exempt personal information from
disclosure if that information relates to someone other than the applicant, and if
disclosure of that information would breach any of the data protection principles in
Article 5(1) of the UK General Data Protection Regulation (GDPR).
As these individuals did not have any level of control over the metric due to their
contextually purely administrative role, we consider that disclosure of this
information would be highly misleading. Identifying these individuals with
ownership of the metric, would incorrectly and unfairly imply a level of
responsibility that was not held and would breach the first data protection principle,
which provides that personal data must be processed lawfully, fairly, and in a
transparent manner.
If you are dissatisfied with the handling of this response, you do have a right to
request an internal review. You can do this by writing to the address above within
40 working days of receipt of this response stating your reasons for your internal
review request or alternatively, by emailing
xxxxxxxxxxx.xxxxxx@xxxxxxxxxx.xx.xx. If, having requested an internal review by Post Office, you are still not satisfied with
our response you also have a right of appeal to the Information Commissioner at:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
Telephone: 0303 123 1113
https://ico.org.uk
Yours sincerely,
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postoffice.co.uk
Classification: Public
Information Rights Team
xxxxxxxxxxx.xxxxxx@xxxxxxxxxx.xx.xx
https://corporate.postoffice.co.uk/en/governance/access-to-information/access-to-
information/
Post Office Limited is committed to protecting your privacy, information about
how we do this can be found on our website at www.postoffice.co.uk/privacy
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postoffice.co.uk
Classification: Public