Thank you for contacting the Information Commissioner’s Office. We confirm
that we have received your correspondence.

If you have made a request for information held by the ICO we will contact
you as soon as possible if we need any further information to enable us to
answer your request. If we don't need any further information we will
respond to you within our published, and statutory, service levels. For
more information please visit:

[1]https://ico.org.uk/about-the-ico/our-inf...

If you have raised a new information rights concern - we aim to send you
an initial response and case reference number within 30 days.

If you are concerned about the way an organisation is handling your
personal information, we will not usually look into it unless you have
raised it with the organisation first. For more information please see our
webpage ‘raising a concern with an organisation’ (go to our homepage and
follow the link ‘for the public’). You can also call the number below.

If you have requested advice - we aim to respond within 14 days. 

If your correspondence relates to an existing case - we will add it to
your case and consider it on allocation to a case officer.

Copied correspondence - we do not respond to correspondence that has been
copied to us.

For more information about our services, please see our webpage ‘Service
standards and what to expect' (go to our homepage and follow the links for
‘Report a concern’ and ‘Service standards and what to expect'). You can
also call the number below.

For information about what we do with personal data see our [2]privacy
notice.

If there is anything you would like to discuss with us, please call our
helpline on 0303 123 1113.

Yours sincerely

The Information Commissioner’s Office

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References

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4. http://www.twitter.com/ICOnews

25 January 2022

Our reference: IC-151664-D5Q4 

Dear Joseph Lloyd,

Thank you for your recent request for information. We received your
request on 14 January 2022. Your request will be allocated to an
Information Access Officer who will contact you under the reference number
above in due course.
Under statutory timeframes our response to your freedom of information
request is due by 11 February 2022. Like many other organisations our work
has been disrupted by the pandemic. We continue to experience high demand
for our services while operating at reduced capacity. We are working as
hard as we can to respond to all of the requests we receive within the
statutory time period, but unfortunately it is not always possible for us
to do so.
If you have any queries about this information request you may email us,
quoting our reference number in the subject line. Please note that
Information Access Officers are only able to address information requests
to ICO; they are unable to assist with complaints to ICO, or to provide
general advice about the legislation we oversee, as this work is done by
other ICO departments.  
Our privacy notice explains what we do with the personal data you provide
to us when you make an information request: 
https://ico.org.uk/global/privacy-notice...
Thank you for your interest in the work of the Information Commissioner's
Office.
Yours sincerely,
Information Access Team
Information Commissioner’s Office 
 

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire SK9 5AF
T. 0303 123 1113 [1]ico.org.uk [2]twitter.com/iconews
Please consider the environment before printing this email

Please be aware we are often asked for copies of the correspondence we
exchange with third parties. We are subject to all of the laws we deal
with, including the data protection laws and the Freedom of Information
Act 2000. You can read about these on our website ([3]www.ico.org.uk).
Please say whether you consider any of the information you send us is
confidential. You should also say why. We will withhold information where
there is a good reason to do so.
For information about what we do with personal data see our privacy notice
at [4]www.ico.org.uk/privacy-notice
 

References

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1. https://ico.org.uk/
2. https://twitter.com/iconews
3. https://www.ico.org.uk/
4. https://www.ico.org.uk/privacy-notice

11 February 2022 

Case Reference: IC-151664-D5Q4 

Dear J Lloyd

Thank you for your request for information of 14 January.

I can confirm that the ICO does hold information within scope of your
request.

This information includes briefings on international strategy and
international regulatory activity, sections of which are exempt pursuant
to s.27 of the FOIA.

Section 27 applies to information held in connection with ‘international
relations’, and states:

“(1) Information is exempt information if its disclosure under this Act
would, or would be likely to, prejudice —

(a) relations between the United Kingdom and any other State,

(b) relations between the United Kingdom and any international
organisation or international court,

(c) the interests of the United Kingdom abroad, or

(d) the promotion or protection by the United Kingdom of its interests
abroad.”

The requested information includes assessments of ICO’s prioritised
interests in its bi-lateral and multilateral relationships with other
states as well as international organisations and we find that disclosure
of the information you have requested would be likely to cause disruption
within those relationships and impact our ability to effectively carry out
our international engagement and collaboration functions in support of our
domestic regulatory role.  

This is why we find that the exemption at section 27 1 (a) and (b) applies
in this instance.

Additionally, the requested information includes an overview of our
regulatory activity pipeline which contains details of active and
anticipated investigations where regulatory action is being considered.
This information is exempt pursuant to section 31(1)(g) of the FOIA.

The exemption at section 31(1)(g) of the FOIA refers to circumstances
where the disclosure of information “would, or would be likely to,
prejudice – … the exercise by any public authority of its functions for
any of the purposes specified in subsection (2).”

 In this case the relevant purposes contained in subsection 31(2) are
31(2)(a) and 31(2)(c) which state –

 “(a) the purpose of ascertaining whether any person has failed to comply
with the law” and

 “(c) the purpose of ascertaining whether circumstances which would
justify regulatory action in pursuance of any enactment exist or may arise
…”   

Revealing details of live investigations would be likely to prejudice the
outcome of those investigations as it would reveal information about lines
of enquiry, priorities and investigatory strategy which could provide
opportunities for law breakers to negatively impact upon the course of the
ICO’s investigations and to evade regulatory action.

Additionally parties under investigation would be likely to be discouraged
from the assisting the ICO by fully and frankly responding to the ICO’s
enquiries should details of those investigations be disclosed prematurely.
This would also be likely to discourage other organisations from full
cooperation with the ICO’s investigations in future.

Both exemptions under section 27 and 31 are not absolute and I will now
perform a Public Interest Test (PIT) for each to decide whether the
exemptions fall away or are maintained.

Section 10(3) of the Freedom of Information Act 2000 (FOIA) enables an
authority to extend the 20 working day limit up to a ‘reasonable’ time in
any case where it requires more time to determine whether or not the
balance of the public interest lies in maintaining an exemption.

The FOIA does not define what might constitute a ‘reasonable’ extension of
time. However, the ICO’s view is that an authority should normally take no
more than an additional 20 working days to consider the public interest,
meaning that the total time spent dealing with the request should not
exceed 40 working days. We will therefore respond to you by 11 March 2022
unless we are in a position to respond earlier. Should we not be in a
position to respond by that date we will provide a further update. 

Yours sincerely,

Hannah Silk 
Senior Information Access Officer 
Information Commissioner's Office

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire SK9 5AF
T. 0330 313 1688 [1]ico.org.uk [2]twitter.com/iconews
Please consider the environment before printing this email.
For information about what we do with personal data see our privacy notice
at [3]www.ico.org.uk/privacy-notice.

References

Visible links
1. https://ico.org.uk/
2. https://twitter.com/iconews
3. https://www.ico.org.uk/privacy-notice

11 March 2022

Our reference: IC-151664-D5Q4
Dear J Lloyd,

I write concerning your request for information which we received on 14
January. On 11 February we wrote to you advising that we would be
extending the statutory deadline for our response by 20 working days to 11
March in line with s.10(3) of the FOIA, in order to further consider the
public interest test in respect of qualified exemptions which we
determined were applicable to part of the information in scope.

Unfortunately, while we have made every effort to respond within this
timeframe, we are not yet in a position to respond to your request and so
will be extending the deadline by a further two weeks to 25 March.

Please accept our apologies for this, as this is not up to the level of
service we intend to provide, however extensive work has gone in to
handling this request and under the circumstances we do require more time.

To provide some explanation, within the scope of your request are twenty
four briefing documents provided to the Commissioner by senior members of
staff across the ICO covering high level and detailed overviews of the
ICO’s work in each area, which has required extensive internal
consultations on the suitability for the material for disclosure.

Sections of this information have engaged several qualified exemptions
including s.27 and s.31 as explained previously, and some have required
consideration under s.36, which requires a decision by the ICO’s Qualified
Person, which is the Commissioner.

Given that he is new in the role and is exceptionally busy familiarising
himself with all aspects of the ICO’s work and travelling around the UK
meeting staff, stakeholders and the media, this has taken longer that we
would usually expect.

We are however at advanced stages with this work and do anticipate being
able to respond within the next two weeks.

Yours sincerely,

Hannah Silk
Senior Information Access Officer
Information Commissioner’s Office 
0330 313 1688

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire SK9 5AF
T. 0303 123 1113 [1]ico.org.uk [2]twitter.com/iconews
Please consider the environment before printing this email
Please be aware we are often asked for copies of the correspondence we
exchange with third parties. We are subject to all of the laws we deal
with, including the data protection laws and the Freedom of Information
Act 2000. You can read about these on our website ([3]www.ico.org.uk).
Please say whether you consider any of the information you send us is
confidential. You should also say why. We will withhold information where
there is a good reason to do so.
For information about what we do with personal data see our privacy notice
at [4]www.ico.org.uk/privacy-notice

References

Visible links
1. https://ico.org.uk/
2. https://twitter.com/iconews
3. https://www.ico.org.uk/
4. https://www.ico.org.uk/privacy-notice

16 March 2022

Our reference: IC-151664-D5Q4
Dear J Lloyd,

Please find attached our response to your FOI request. I will send some
additional emails with additional attachments, due to size. I will
indicate when I have sent the final email which comprises this response. 

Yours sincerely,

Hannah Silk
Senior Information Access Officer
Information Commissioner’s Office 
0330 313 1688

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire SK9 5AF
T. 0303 123 1113 [1]ico.org.uk [2]twitter.com/iconews
Please consider the environment before printing this email
Please be aware we are often asked for copies of the correspondence we
exchange with third parties. We are subject to all of the laws we deal
with, including the data protection laws and the Freedom of Information
Act 2000. You can read about these on our website ([3]www.ico.org.uk).
Please say whether you consider any of the information you send us is
confidential. You should also say why. We will withhold information where
there is a good reason to do so.
For information about what we do with personal data see our privacy notice
at [4]www.ico.org.uk/privacy-notice

References

Visible links
1. https://ico.org.uk/
2. https://twitter.com/iconews
3. https://www.ico.org.uk/
4. https://www.ico.org.uk/privacy-notice

16 March 2022

Our reference: IC-151664-D5Q4
Dear J Lloyd,

Further documents attached which accompany our response.

Yours sincerely,

Hannah Silk
Senior Information Access Officer
Information Commissioner’s Office 
0330 313 1688

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire SK9 5AF
T. 0303 123 1113 [1]ico.org.uk [2]twitter.com/iconews
Please consider the environment before printing this email
Please be aware we are often asked for copies of the correspondence we
exchange with third parties. We are subject to all of the laws we deal
with, including the data protection laws and the Freedom of Information
Act 2000. You can read about these on our website ([3]www.ico.org.uk).
Please say whether you consider any of the information you send us is
confidential. You should also say why. We will withhold information where
there is a good reason to do so.
For information about what we do with personal data see our privacy notice
at [4]www.ico.org.uk/privacy-notice

References

Visible links
1. https://ico.org.uk/
2. https://twitter.com/iconews
3. https://www.ico.org.uk/
4. https://www.ico.org.uk/privacy-notice

16 March 2022

Our reference: IC-151664-D5Q4
Dear J Lloyd,

Final documents which accompany our response attached. 

Yours sincerely,

Hannah Silk
Senior Information Access Officer
Information Commissioner’s Office 
0330 313 1688

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire SK9 5AF
T. 0303 123 1113 [1]ico.org.uk [2]twitter.com/iconews
Please consider the environment before printing this email
Please be aware we are often asked for copies of the correspondence we
exchange with third parties. We are subject to all of the laws we deal
with, including the data protection laws and the Freedom of Information
Act 2000. You can read about these on our website ([3]www.ico.org.uk).
Please say whether you consider any of the information you send us is
confidential. You should also say why. We will withhold information where
there is a good reason to do so.
For information about what we do with personal data see our privacy notice
at [4]www.ico.org.uk/privacy-notice

References

Visible links
1. https://ico.org.uk/
2. https://twitter.com/iconews
3. https://www.ico.org.uk/
4. https://www.ico.org.uk/privacy-notice