Data protection register entry for Disciple Media Limited ZA147341

The request was successful.

Dear Information Commissioner’s Office,

On the issue of whether Disciple Media Limited were correctly registered on 1st February 2018 at the launch of the "Matt Hancock app" under the Freedom of information act please could you provide:

Dates and times and details of requests to update registry entry ZA147341 and specifically when you were notified of change of address.

Also any correspondence by letter or email between yourselves and disciple media Limited

Please note that according to companies house their change of address took place on 7th July 2016
https://beta.companieshouse.gov.uk/compa...

Also I'm aware that their registration lapsed on 28th October 2017 and was renewed and backdated until then on 1st February 2018

Yours faithfully,

Jack Pottinger

AccessICOinformation, Information Commissioner's Office

Thank you for contacting the Information Commissioner’s Office. We confirm
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The Information Commissioner’s Office

 

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Information Commissioner's Office

1 Attachment

9 March 2018

 

Case Reference Number IRQ0725485

 

Dear Mr Pottinger

Information request

I write in response to your email of 9 February 2018 in which you
submitted a request for information to the Information Commissioner’s
Office (ICO). Your request has been dealt with in accordance with the
Freedom of Information Act 2000 (FOIA).
 
Your request

“Freedom of Information request - Data protection register entry for
Disciple Media Limited ZA147341 
 
Dear Information Commissioner’s Office, On the issue of whether Disciple
Media Limited were correctly registered on 1st February 2018 at the launch
of the "Matt Hancock app" under the Freedom of information act please
could you provide: 
 

* Dates and times and details of requests to update registry entry
ZA147341 and specifically when you were notified of change of address.
* Also any correspondence by letter or email between yourselves and
disciple media Limited  

Please note that according to companies house their change of address took
place on 7th July 2016
https://beta.companieshouse.gov.uk/compa... Also
I'm aware that their registration lapsed on 28th October 2017 and was
renewed and backdated until then on 1st February 2018”
 
Our response

I can confirm we hold information that falls in the scope of your request.

Please find attached the information we hold that falls in scope of your
request attached.

The name and contact details of a Disciple Media Limited employee have
been redacted from the information provided. This information is exempt
from disclosure to you under section 40(2) of the FOIA, by virtue of
section 40(3)(a)(i), as disclosure of this third party personal data would
be ‘unfair’, and therefore in breach of the first data protection
principle under the DPA.

The only other information that has been redacted is the security number
of Disciple Media where this appears in the information provided. By way
of explanation the ICO provides data controllers with a unique number for
identification purposes. This number is used to verify that the individual
contacting the ICO is indeed the individual responsible for the data
controller’s registration, and therefore that the request for any
amendment to the register is genuine.
 
This information has been withheld in line with section 31 of the FOIA.
Section 31 is a prejudice based exemption and therefore can only be used
where disclosure would, or would be likely to prejudice one of the
activities listed in subsection (1) or (2).
 
The exemption at section 31(1)(a) of the FOIA refers to circumstances
where the disclosure of information “would, or would be likely to,
prejudice-… (a) the prevention or detection of crime”. As stated in our
[1]guidance, this covers “all aspects of the prevention and detection of
crime” and can be used to “withhold information that would make anyone,
including the public authority itself, more vulnerable to crime for
example, by disclosing its own security procedures, such as alarm codes”.
 
In this case prejudice would be likely to occur as disclosure of the
security number would leave the public register susceptible to malicious
or mischievous tampering and could be used in conjunction with other
information to obtain or alter details from the data controller’s
registration fraudulently and unlawfully. Disclosure here would be likely
to undermine the ICO’s system of security checks and could lead to further
requests for other data controllers’ security numbers, increasing their
vulnerability to fraudulent and unlawful activity.
 
As you may be aware the exemption at section 31 of the FOIA is not
absolute and is subject to the public interest test. I have therefore gone
on to consider whether the public interest arguments lie in favour of
disclosure or in favour of maintaining the exemption.

In this case the public interest factors in disclosing the information are
– 
 

* The general principles of transparency and openness.

The factors in withholding the information are –
 

* There is a strong public interest in the ICO maintaining a secure and
efficient method of identifying data controllers for the purpose of
maintaining the register of data controllers as required under the
DPA.

* The public interest in the ICO having in place appropriate measures to
ensure that the public register it maintains is accurate and not
susceptible to malicious or mischievous tampering.

* The public interest in assuring individuals and organisations in
correspondence with the ICO that the information they provide is
managed responsibly and efforts are taken to ensure its security.

 
Additionally we note that disclosure of the security number adds nothing
of value to the information contained in the correspondence itself. Having
considered all of these factors we have taken the decision that the public
interest in withholding the security number outweighs the public interest
in disclosing this information.

This concludes our response to your request. I hope the information
provided is helpful.

Review Procedure

If you are not satisfied that your request for information has been dealt
with correctly, please write to the Information Access Team at the address
below, reply directly to this email (with the reference number contained
within the square brackets left intact), or email us at
[2][ICO request email], quoting the reference number
IRQ0725485.

Your request for a review should be submitted to us within 40 working days
of receipt by you of this response.  Any such request received after this
time will only be considered at the discretion of the Commissioner.

Ultimately if you are not satisfied that your request for information has
been dealt with correctly you have a further right of appeal to this
office in our capacity as the statutory complaint handler under the
relevant legislation.  To make such an application, please write to our
Customer Contact Team at the address below, or visit the ‘Report a
Concern’ section of our website.
 
A copy of our review procedure is available here
[3]https://ico.org.uk/media/about-the-ico/p...
 
Yours sincerely

Ian Goddard
Senior Information Access Officer
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire SK9 5AF
T. 01625 545823  F. 01625 524510  [4]ico.org.uk  [5]twitter.com/iconews
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References

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2. mailto:[ICO request email]
3. https://ico.org.uk/media/about-the-ico/p...
4. http://ico.org.uk/
5. https://twitter.com/iconews