Brexit mapping exercise on North-South cooperation in context of Good Friday Agreement

The request was refused by Department for Exiting the European Union.

Dear Department for Exiting the European Union,

FREEDOM OF INFORMATION ACT REQUEST

In the section dealing with Ireland and Northern Ireland, the Joint Report of the UK and the EU Brexit negotiators published on 8 December 2017 states that "[t]he Parties have carried out a mapping exercise, which shows that North-South cooperation relies to a significant extent on a common European legal and policy framework." See paragraph 47 of this document:

https://ec.europa.eu/commission/sites/be...

I am writing to request disclosure of all documents which you hold relating to this mapping exercise. Please note the following:

1. I am not clear to what extent the mapping exercise was a joint exercise or whether the EU and UK negotiators have effectively conducted their own assessments and then "compared notes". If the latter, then my request relates to the documents which the UK government prepared to inform its assessment of the dependency of North-South cooperation on the EU legal and policy framework. If it was a joint exercise which can only be disclosed with the consent of the EU negotiator, I would be grateful if you would request that consent without delay (referring to the reasons outlined at points 2 and 3 below as to why I believe that disclosure should not be refused).

2. You appear to have refused a number of other FOI requests for Brexit-related documentation on the grounds that disclosure could prejudice the outcome of the negotiations. In this case, however, the report referred to above indicates that the mapping exercise is something that negotiators on both sides are aware of and upon which they have reached a common understanding. Against that background, it is difficult to see how its disclosure could conceivably prejudice the negotiations. If you are minded to refuse disclosure on these grounds, please explain why you disagree with my assessment of the likely impact of disclosure on the negotiations.

3. You also appear to have refused a number of requests for Brexit-related documentation (including my own previous request for details of the timetable and scope of consultations on Brexit) on the grounds that the relevant information is intended for later publication. If you are minded to do so in this case, please state when it will be published and why you consider that the public interest favours withholding the information until that later date. In particular, your response should explain why you believe that the public interest in withholding the information outweighs the following factors - which in my view strongly favour disclosure in this case:

(a) The impact of Brexit on the border between Northern Ireland and the Republic of Ireland is a matter of significant public interest and debate, raising complex issues which are frequently poorly explained in the media and in some cases presented in a highly misleading manner; disclosure of the requested information could reasonably be expected to inform and enhance the level of debate; and

(b) As a result of the handling of recent requests for disclosure of sectoral analyses/impact assessments, an impression has arisen that the government has not prepared as thoroughly as many had expected in the light of Ministerial statements. This undermines public confidence in the Brexit process; disclosure of the requested information could reasonably be expected to help restore public confidence, at least with regard to the thoroughness and professionalism of the government's approach to the impact of Brexit on Northern Ireland the the Republic of Ireland.

As regards both 2 and 3, merely stating that you have conducted a balancing exercise and have concluded that information should be withheld is not sufficient; you need to explain what factors you considered, what weight you gave to them and why you decided in favour of non-disclosure. If you do not include this information, I will appeal and if necessary complain to the ICO, as I did in relation to my previous request.

Yours faithfully,

Jonathan Rush

DEXEU Freedom of Information Team Mailbox, Department for Exiting the European Union

Dear Jonathan Rush,
Thank you for your FOI request, reference DEX000949. We will now respond
in line with the Freedom of Information Act.
Kind regards, 
DExEU FOI Team

Freedom of Information Team

9 Downing Street | London | SW1A 2AG
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DEXEU Freedom of Information Team Mailbox, Department for Exiting the European Union

1 Attachment

Dear Jonathan Rush,
Thank you for your FOI request, reference DEX000949. Please find our
attached extension.
Kind regards, 
DExEU FOI Team

Freedom of Information Team

9 Downing Street | London | SW1A 2AG
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Dear DEXEU Freedom of Information Team Mailbox,

Thank you for your letter of 18 January 2018 regarding your proposed extension to the time for answering my FOI request (reference DEX 000949 relating to the Brexit mapping exercise on North-South cooperation in the context of the Good Friday agreement). I can appreciate that you might need more time because of staff being away over the Christmas/New Year period, but that is not the reason you have given for your extension. You have instead suggested that certain exemptions may apply and that further time is needed to consider this. I find it difficult to see how these exemptions are applicable in this case given that:

1. As noted in my original request dated 18 December 2017, there are compelling reasons why it is in the public interest for the mapping exercise to be disclosed - and the sooner that disclosure takes place, the better in terms of informing the public debate;

2. As also noted in my original request, negotiators on both sides in the Brexit talks are aware of the information; in view of this, it is not evident to me how disclosure of the information would prejudice the UK's position in the negotiations (as implied by your reference to the section 27 exemption). If that is your view, I trust you will explain how and why such prejudice could realistically occur; and

3. As regards section 35, I recognise that there may sometimes be an interest in preventing disclosure so as to permit full and frank discussion of policy options. However, the mapping exercise would seem to be a description of current arrangements, rather than information which outlines different policy options which the government may or may not wish to pursue after Brexit. As such, I fail to see how it can properly be characterised as information on the formulation or development of government policy. I am not seeking disclosure of discussions between civil servants and/or Ministers relating to the mapping exercise which might reveal their views about what the post-Brexit arrangements might be; I am simply requesting information amounting to the mapping exercise itself (which, on the face of it, would seem to relate to the pre-Brexit position).

In the light of all the above, I am disappointed that you have decided to extend the time period for responding to my request.

If your eventual answer is to refuse disclosure, I consider that I should be permitted to appeal directly to the ICO without having to seek an internal review (which, based on my own past experience, is likely to take over 3 months). I consider that such a step would be justified given that (a) you have extended time; (b) an appeal to the ICO is likely to take further time to resolve (probably several months at least); and (c) my contention is that the information should be disclosed as soon as possible, so as to better inform public debate on the ongoing Brexit negotiations (so if I am right that it should be disclosed, it should not be open to DEXEU to engineer a situation whereby the public benefit of my request is effectively undermined by the passage of time). I trust that you will consider this request should you take a decision to refuse disclosure.

Yours sincerely,

Jonathan Rush

Dear DEXEU Freedom of Information Team Mailbox,

Further to my request dated 18 December 2017, which you still considering under Ref DEX 000949, I am writing to let you know that I have now requested the same information from the EU Article 50 Taskforce. For details, see: https://www.asktheeu.org/en/request/brex...

Details of my request to you dated 18 December 2017 under FOI can be found here:
https://www.whatdotheyknow.com/request/b...

Yours sincerely,

Jonathan Rush

DEXEU Freedom of Information Team Mailbox, Department for Exiting the European Union

1 Attachment

Dear Jonathan Rush,
Thank you for your FOI request, reference DEX000949. Please find our
attached response.
Kind regards, 
DExEU FOI Team

Freedom of Information Team

9 Downing Street | London | SW1A 2AG
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Dear Department for Exiting the European Union,

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

I am writing to request an internal review of Department for Exiting the European Union's handling of my FOI request 'Brexit mapping exercise on North-South cooperation in context of Good Friday Agreement'.

You have refused my request based on sections 27 and 35 of FOIA. I am seeking an internal review primarily because I do not consider that either of these sections is applicable to my request.

As regards section 27, I could accept that this exemption might be engaged if disclosure of the information would give the EU negotiators knowledge of material relating to the UK position which they would not otherwise have. However, paragraph 47 of the Joint Report of the UK and the EU Brexit negotiators published on 8 December 2017 states that "[t]he Parties have carried out a mapping exercise, which shows that North-South cooperation relies to a significant extent on a common European legal and policy framework." It is therefore clear that the negotiators on both sides in the Brexit talks are already aware of the contents of the mapping exercise; as such, it is difficult to see how any prejudice to the UK position could occur.

As regards section 35, I recognise that there may sometimes be an interest in preventing disclosure so as to permit full and frank discussion of policy options. However, the mapping exercise would seem to be a description of current arrangements, rather than information which outlines different policy options which the government may or may not wish to pursue after Brexit. As such, it cannot properly be characterised as information on the formulation or development of government policy. Please note that I am not seeking disclosure of discussions between civil servants and/or Ministers relating to the mapping exercise which might reveal their views about what the post-Brexit arrangements might be; I am simply requesting information amounting to the mapping exercise itself (which, on the face of it, would seem to relate only to the pre-Brexit position).

To the extent that you continue to take the view that sections 27 and 35 are applicable, I consider that you have not given adequate weight to the public interest in releasing the information. In particular, as a result of the handling of recent requests for disclosure of sectoral analyses/impact assessments, an impression has arisen that the government has not prepared for Brexit as thoroughly as many had expected in the light of Ministerial statements. There is ample evidence of this impression from publicly available commentary on the government's handling of Parliament's request for disclosure of the sectoral analyses/impact assessments. Such an impression undermines public confidence in the Brexit process. Disclosure of the requested information, on the other hand, could reasonably be expected to help restore public confidence, at least with regard to the thoroughness and professionalism of the government's approach to the impact of Brexit on Northern Ireland the the Republic of Ireland. In my view this consideration far outweighs any possible prejudice of the kind envisaged by section 27 or any prejudice to the policy formulation or decision-making process as envisaged by section 35.

All the substantive points made above were apparent from my original request and my message dated 18 January 2018, yet you have not addressed any of them in your letter of refusal. Instead, you have provided what appears to be a boilerplate response, citing sections 27 and 35 without in any way explaining how they actually relate to the specific information I have requested. This further supports my contention that you have not properly considered either the applicability of those sections, nor have you carried out a proper balancing exercise in relation to the public interest test.

In my message dated 18 January, I also asked you if - given the significant delay in responding to my request - you would be willing to allow me to appeal directly to the ICO if you refused my request. Again, you have not addressed this point in your response. If you are willing to do that, then we can dispense with the need for you to carry out an internal review. It is my intention to appeal to the ICO unless you agree to disclose the mapping exercise.

If you are not willing to agree to this, I trust that you will respond promptly to my request for an internal review, particularly given that there has already been substantial delay in responding to my initial request. My previous experience of requesting an internal review is that you took over 3 months to respond, which is completely unacceptable. In this case, given the existing delay, I would ask you to expedite my request for an internal review so that it can be completed well within the 20 working days stipulated in the ICO's guidance.

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

Yours faithfully,

Jonathan Rush

Dear DEXEU Freedom of Information Team Mailbox,

On 15 February 2018, I requested an internal review of your refusal of my request for disclosure of the Brexit mapping exercise on North-South cooperation in the context of the Good Friday Agreement (your reference DEX 000949).

I asked you to respond within 20 working days, in accordance with ICO guidance. You have failed to do so (the 20 working days expired on 15 March) and have not provided any explanation for this delay. You have not even acknowledged my request for an internal review.

Unless I receive the results of your internal review by Friday 30 March, I will make a complaint to the ICO.

Yours sincerely,

Jonathan Rush

Jonathan Rush left an annotation ()

I have now complained to the ICO. You can read the complaint here (submitted on 9.4.2018):
https://www.dropbox.com/s/39o021t7p2hxc6...

Dear DEXEU Freedom of Information Team Mailbox,

With reference to my FOI request (DEX 000949), please note that - having not received any response from you to my request for an internal review - I have now complained to the Information Commissioner's Office. Given the significance of the information requested, I have asked them to expedite their handling of the complaint.

Yours sincerely,

Jonathan Rush

Jonathan Rush left an annotation ()

The ICO has responded to my complaint by insisting that DEXEU must be given the chance to conduct its internal review. This is disappointing because DEXEU have had plenty of time to do that already - so giving them one more chance just adds to the delay in the handling of my request. The good news is that if they fail to respond within 10 working days, the ICO has said it will launch an investigation into my complaint.

Dear Department for Exiting the European Union,

I refer to my FOI request reference DEX000949. Following my recent complaint to the ICO, I understand you have been sent a letter dated 16 April 2018 from the ICO requesting that you complete your internal review of my request within 10 working days. Please confirm that you have received the ICO's letter, whether you intend to carry out an internal review and if so, when you expect to complete it.

Yours faithfully,

Jonathan Rush

DEXEU Freedom of Information Team Mailbox, Department for Exiting the European Union

Dear Jonathan Rush, 
Thank you for your email regarding case DEX000949. I can confirm that we
have received your ICO complaint and that we aim to complete your internal
review by 30th March.
We would also like to take this opportunity to apologise for the delay.
Kind regards, 
DExEU FOI team

Freedom of Information Team

9 Downing Street | London | SW1A 2AG
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DEXEU Freedom of Information Team Mailbox, Department for Exiting the European Union

Dear Jonathan Rush, 
Apologies for the earlier mistake - we aim to complete your internal
review by 30th April.
Kind regards, 
DExEU FOI team

Freedom of Information Team

9 Downing Street | London | SW1A 2AG
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DEXEU Freedom of Information Team Mailbox, Department for Exiting the European Union

1 Attachment

Dear Jonathan Rush,
Please find attached our Internal Review response to FOI request ref:
DEX000949.
Kind regards,
FOI Team

Freedom of Information Team

9 Downing Street | London | SW1A 2AG
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DEXEU Freedom of Information Team Mailbox, Department for Exiting the European Union

1 Attachment

Dear Jonathan Rush,
Please find attached our Internal Review response to FOI request ref:
DEX000949.
Kind regards,
FOI Team

Freedom of Information Team

9 Downing Street | London | SW1A 2AG
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Jonathan Rush left an annotation ()

Following DEXEU's decision to uphold its refusal to disclose, I have written to the ICO today (30.4.2018) asking it to reactivate my complaint (which was on hold pending DEXEU's internal review). I have asked for the complaint to be expedited - without this, there is little prospect of the investigation being concluded before the Brexit negotiations are due to finish later this year.

DEXEU Freedom of Information Team Mailbox, Department for Exiting the European Union

1 Attachment

Dear Jonathan Rush
Please see attached some further information relating to your request for
information.
regards

Freedom of Information Team

9 Downing Street | London | SW1A 2AG
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Jonathan Rush left an annotation ()

Update 13.8.2018: Whilst DEXEU continues to insist that it intends to disclose the mapping exercise, it has yet to do so and my complaint to the ICO remains ongoing. Following the refusal of a similar request made to the European Commission, I have also complained to the European Ombudsman.

Jonathan Rush left an annotation ()

I asked the ICO for an update on progress including when a decision might be taken. I was told on 13.9.2018 that it hopes to produce a draft decision notice "within the next couple of weeks" but that further time would be needed after that for it to be signed off by other officials. This suggests that a decision in September is unlikely - October is possible, but that would be very late in the day. I am disappointed with the ICO's apparent lack of urgency, especially given the strong public interest in timely disclosure of this information to inform the public debate on the ongoing Brexit negotiations.

Jonathan Rush left an annotation ()

On 25.10.2018 the ICO upheld DEXEU's refusal to disclose the mapping exercise based on section 35 FOIA. The ICO acknowledges that there are "very compelling public interest arguments" in favour of disclosure, but concludes that there is a "a slightly stronger public interest in ensuring that the formulation and development of government policy on the operation of the border post-Brexit is unhindered by detailed disclosure at the crucial juncture indicated at the time of the request. The disclosure of the requested information would have a negative effect on discussions around this subject [.....][and] create a distraction to discussions."

I find this conclusion unconvincing and note that neither the ICO nor DEXEU has cited any credible, concrete examples of how disclosure would have harmed the discussions - especially as the requested information relates solely to the status quo (as opposed to any proposals for how the Irish border issue should be dealt with after Brexit). The mapping exercise was created to provide the necessary factual background to inform the government's deliberations on how to deal with border issues after Brexit - and as such, the ICO should have paid more attention to the following section of its own guidance (which is not referred to at all in its decision): "[s]ection 35(4) specifically acknowledges that there is particular public interest in the disclosure of any factual information used to provide an informed background to government decisions."

More generally, I am concerned by the ICO's readiness to accept DEXEU's view that the overall impact of disclosure would be negative rather than positive. At the very least, the ICO should be approaching such arguments with scepticism e.g. by insisting upon concrete examples of how disclosure would actually give rise to the prejudice claimed by government. It should also be open to arguments that disclosure could have a positive effect e.g. that transparency can expose government thinking to challenge and scrutiny from a wider range of external expert opinion, which may help government to develop a better policy response. Such arguments do not appear to have been considered here.

The upshot appears to be that section 35 is effectively being applied as if it were a blanket, unqualified exception (which it is not); after all, if even "very compelling public interest arguments" are not sufficient to secure disclosure, then what is the point of the public interest qualification in section 35?

I am considering whether to appeal - but am awaiting the outcome of my complaint to the European Ombudsman before doing so (this complaint relates to the refusal of the European Commission to release the mapping exercise). I will post an update once I had decided what to do. The ICO decision can be viewed here: https://www.dropbox.com/s/wa2rsczktpalwp...

Dear DEXEU Freedom of Information Team Mailbox,

I refer to my Freedom of Information Act request DEX000949 requesting disclosure of the Brexit mapping exercise referred to at paragraph 47 of the Joint Report of the EU and UK Brexit negotiators (dated 8 December 2017) . As you will be aware, this was the subject of a decision by the Information Commissioner dated 25 October in case FS50737561. Whilst the Commissioner upheld your decision to refuse disclosure, she indicated that timing was an important factor in her evaluation and that if the information were requested after the conclusion of Brexit negotiations, "the time factor...would not be of the same significance and the importance of being fully transparent would carry even greater weight." She also stated that the public interest in disclosure of the information was "very compelling."

In the light of these comments and the numerous existing commitments made by Ministers to publish the mapping exercise (as detailed below), I would invite you to confirm that you will disclose the mapping exercise without delay as soon as the relevant negotiations are concluded.

Commitments made to Parliament to publish the mapping exercise include:

1. Letter to Chair of the Exiting the EU Committee dated 24 April 2018 stating that the mapping exercise was expected to be published "soon."

2. Answer to Parliamentary question 141770 of 8 May 2018 from Nicky Morgan MP again stating that the government expected to publish the mapping exercise "soon" (answer dated 14 May 2018).

3. Letter to Helen Hayes MP dated 4 June 2018, again stating that government expected to publish the mapping exercise "soon."

I would suggest that most people would consider the word "soon" as referring to a period considerably shorter than the 6 months which have elapsed since the first of these commitments was made. In view of this, it is appropriate that the mapping exercise should be published without delay once the relevant negotiations have conclude and without my having to make a further request at that time.

Finally please note that I am considering an appeal against the Commissioner's decision; consequently, nothing in this email should be taken as an acceptance on my part that the Commissioner's decision to uphold your refusal to disclose is correct.

I look forward to hearing from you with the next seven days.

Yours sincerely,

Jonathan Rush

Dear DEXEU Freedom of Information Team Mailbox,

I wrote to you on 11 November 2018 asking you to disclose the Brexit mapping exercise which I requested in December 2017 (ref DEX00949) as soon as the relevant negotiations were concluded. Those negotiations have now concluded and the draft Withdrawal Agreement has been published. I cannot therefore see any reason why the mapping exercise should not now be released - particularly given that Ministers have made repeated commitments to publish the information, as detailed in my letter of 11 November.

I would also draw your attention to the conclusions of the European Ombudsman in her decision dated 9 November 2018 concerning the Brexit mapping exercise, where she noted that there was no "inherent confidentiality in the content" and stated that "[w]hen the elected representatives of EU and UK citizens vote on the outcome of these negotiations, this document is essential to the making of informed decisions in the public interest." See: https://www.ombudsman.europa.eu/en/decis...

As I am sure you are aware, Parliament is due to debate the Withdrawal Agreement next week. It cannot evaluate whether the proposed arrangements relating to Northern Ireland will avoid a hard border and preserve the peace process unless it can compare these with the government's assessment of the current arrangements (as set out in the mapping exercise).

I look forward to receiving your confirmation that the information will be published in good time for the Parliamentary debate.

Yours sincerely,

Jonathan Rush

DEXEU Freedom of Information Team Mailbox, Department for Exiting the European Union

1 Attachment

Dear Jonathan Rush
Please find attached a letter containing a link to published information.

Freedom of Information Team

9 Downing Street | London | SW1A 2AG
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FAO: J Millar, DEXEU Freedom of Information Team

Dear Ms Millar,

Thank you for your letter of 10 December 2018 drawing my attention to the publication of the technical explanatory note on the Brexit North-South cooperation mapping exercise. I very much welcome the publication of this information, although as I am sure you are aware, I consider that it is long overdue.

I note that the commentary explains that some of the 156 areas listed in the Annex are extensively underpinned by EU law, others less so and some not at all. Some examples of areas which fall into each of these 3 categories are provided, but this has not been done for all 156 areas.

In order to work out whether the Northern Ireland Protocol in the Withdrawal Agreement achieves its stated objective of preserving existing North-South cooperation, one would need to know which of the 156 areas was considered to be underpinned by EU law to a material extent (as it is in these areas that cooperation would be at risk of being undermined by Brexit). I assume that the government has this information, otherwise it would not have been able to form a view on which of the 156 areas needed to be covered by the Northern Ireland Protocol in the Withdrawal Agreement.

In my view, neither Parliament nor members of the public can be expected to scrutinise the Withdrawal Agreement effectively without this information. Will DEXEU be publishing this information in time for Parliament to consider it ahead of any vote on the approval of the Withdrawal Agreement?

Yours sincerely,

Jonathan Rush

Jonathan Rush left an annotation ()

On 19 November 2018, I lodged an appeal against the Information Commissioner's decision in this case. The Commissioner responded to this on 18 December 2018 and I submitted my reply to that response on 1 January 2019. DExEU had until 8 January 2019 to apply to be joined as a party. It does not appear to have done so, although I understand that it could still be joined as a party by order of the Tribunal. I will post further updates here once there is any further news.

Jonathan Rush left an annotation ()

Update 9.4.2018: Earlier this year, the Tribunal joined the Cabinet Office to the proceedings as second respondent (Cabinet Office asked to be joined in place of DExEU because it has been taking the lead on Northern ireland and Brexit). At the end of March, Cabinet Office submitted its response to my grounds of appeal. I have now submitted my reply to that response - so the next stage should be for the Tribunal to consider the submissions and take a decision. At the time of writing, I hadn't been given any indication as to how long this is likely to take.

Jonathan Rush left an annotation ()

The Cabinet Office has released 2 of the key documents covered by my request, which you can access here:
https://www.parliament.uk/business/commi...

An FAQ on these documents (written by me) is available here: https://www.dropbox.com/s/yxm083afkzf2nt...

I have now decided to withdraw my appeal to the Information Tribunal. I will explain the reasons for this in a further annotation below.

Jonathan Rush left an annotation ()

REASONS FOR WITHDRAWING MY APPEAL

As noted above, I have now decided to withdraw my appeal to the Information Tribunal. I had some reservations about this because neither the government nor the Information Commissioner has admitted they were wrong to refuse my request in the first place (or in the IC’s case, to uphold the government’s refusal).

In particular, I remain concerned about the approach they have taken to section 35(4) of the Act, which in my view makes it clear that background information relating to policy development should generally be released unless there are particularly compelling reasons not to (the mapping exercise was clearly background information; it merely identified the areas of North-South cooperation that stood to be affected by Brexit and did not discuss policy options for the future).

That type of information is particularly valuable if released before decisions are taken on policy, so that the those wishing to comment on the options can do so from an informed position. However, the approach taken by both the government and the IC would mean that such information would normally only be released after the policy has been settled - which negates a key benefit of its disclosure. That is precisely what has happened in this case i.e. decisions have been taken on the issues relating to Northern Ireland without any formal public consultation and without the public being properly informed about what all those issues were in the first place. It is evident from the mapping table released by the Cabinet Office that the issues involved are many and complex - and that the majority of areas covered by the mapping exercise (96 out of 142 areas, or just under 70%) are either substantially or partially underpinned by EU legal or policy frameworks, which highlights the problems posed by Brexit. I was not the only person asking for it: throughout 2018, disclosure of the mapping exercise was requested on numerous occasions by MPs, including the House of Commons Select Committee on Exiting the EU, but to no avail.

I would have liked to obtain some clarity from the Tribunal on this point of principle about section 35(4), but there were several problems with this - which is why I have now withdrawn my appeal. First there was no guarantee the Tribunal would have been prepared to give a ruling given that the Cabinet Office had released the two main documents I was seeking. Second, even if the Tribunal had been prepared to go ahead, only decisions of the Upper Tribunal have value as binding precedents. So whatever the outcome at first instance, at least one of the parties would then need to appeal to the Upper Tribunal in order to get a decision which would have precedent value on the point of principle I was concerned about (relating to section 35(4) and the approach to background information on policy). Third, getting this far has involved spending hours preparing written submissions to the Tribunal and responding to points raised by the government and the IC - and a further appeal would involve yet more of the same (the Cabinet Office had indicated that if it lost, it would probably appeal). Fourth, there was some risk that I could be exposed on costs if I lost any appeal.

Richard Taylor left an annotation ()

The ICO also published a copy of their decision notice at:
https://ico.org.uk/media/action-weve-tak...