Elizabeth Denham's speaking engagements

The request was partially successful.

Dear Information Commissioner’s Office,

Please provide:

- a list of all speaking engagements that Ms Denham has completed since her arrival as IC to date in the UK and the date of which they have taken place and who for.

-a list of all speaking engagements listed in Ms Denham's diary as taking place in April 2018, May 2018 and June 2018

-a list of all speaking engagements which were originally supposed to be carried out in 2017 and 2018 by Ms Denham but have subsequently had attendance by her private office at the ICO cancelled/postponed or a representative from the ICO sent in Ms Denham's place.

- of those speaking engagements the date they were booked, the date of the event and the date of which they were cancelled/postponed or a representative arranged to attend instead of Ms Denham

-all correspondence in relation to the cancellation/postponement or replacements sent.

-where possible provide the policy in which accepting speaking engagements is documented

Yours faithfully,

Joanne

AccessICOinformation, Information Commissioner's Office

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

26 January 2018

 

Case Reference Number IRQ0721962

 

Dear Ms Gemini

Request for Information
 
Thank you for your message which we received on 22 January, in which you
have made a request for information held by the Information Commissioner's
Office (ICO). 
 
Your request has been passed to the ICO’s Information Access Team, and is
being dealt with in accordance with the Freedom of Information Act 2000
under the reference number shown above. 
 
As you are probably aware the FOIA provides individuals with the right of
access recorded information held by public authorities. It is important to
note that a release under FOIA is applicant blind and therefore
effectively a release to the wider world.
 
We will respond to your FOIA request promptly, and no later than 19
February which is 20 working days from the day after we received your
request.
 
Should you wish to reply to this email please be careful not to amend the
information in the ‘subject’ field. This will ensure that your reply is
added directly to your case.
 
Yours sincerely
 
 
 
 

Danny Langley
Lead Information Access Officer
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire SK9 5AF
T. 01625 545784  F. 01625 524510  [1]ico.org.uk  [2]twitter.com/iconews
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Information Commissioner's Office

8 Attachments

19 February 2018

 

Case Reference Number IRQ0721962

 

Dear Ms Gemini

Request for Information
 
Further to our acknowledgement of 26 January we can now respond to your
request for information of 22 January.
 
We have dealt with your request in accordance with your ‘right to know’
under section 1(1) of the Freedom of Information Act 2000 (FOIA).
 
Request
 
In your email you asked:
 
“Please provide:
- a list of all speaking engagements that Ms Denham has completed since
her arrival as IC to date in the UK and the date of which they have taken
place and who for.
-a list of all speaking engagements listed in Ms Denham's diary as taking
place in April 2018, May 2018 and June 2018
-a list of all speaking engagements which were originally supposed to be
carried out in 2017 and 2018 by Ms Denham but have subsequently had
attendance by her private office at the ICO cancelled/postponed or a
representative from the ICO sent in Ms Denham's place.
- of those speaking engagements the date they were booked, the date of the
event and the date of which they were cancelled/postponed or a
representative arranged to attend instead of Ms Denham
-all correspondence in relation to the cancellation/postponement or
replacements sent.
-where possible provide the policy in which accepting speaking engagements
is documented.”
 
Our response
 
list of all speaking engagements that Ms Denham has completed since her
arrival as IC to date in the UK and the date of which they have taken
place and who for.
 
Please find attached a PDF file (Disclosure 1) containing the list of
speaking engagements, with dates and the name of the organiser where this
information is held, that the Commissioner has undertaken since her
appointment in July 2016.
 
-a list of all speaking engagements listed in Ms Denham's diary as taking
place in April 2018, May 2018 and June 2018
 
I can confirm we hold this information. At the time of receipt of your
request the Commissioner was scheduled to speak at three specific events
in this timeframe. Because details of the Commissioner’s speaking events –
and the speeches she delivers – are published by the ICO on our website,
the information we hold is exempt under section 22 of the FOIA. I have
expanded on the use of this exemption in this instance and the associated
public interest test in more detail below and have provided a link to the
webpage the information will be published in in due course.
 
-a list of all speaking engagements which were originally supposed to be
carried out in 2017 and 2018 by Ms Denham but have subsequently had
attendance by her private office at the ICO cancelled/postponed or a
representative from the ICO sent in Ms Denham's place.
 
Events at which the Commissioner is no longer attending are removed from
her diary. There is therefore limited information held at the time we
received your request regarding speaking engagements that the Commissioner
had originally arranged to undertake and which were subsequently
cancelled, postponed or had a substitute speaker sent in her stead.
 
We do however hold information regarding two events that fall within the
scope of this part of your request, which we are able to disclose to you
in the second PDF attachment (Disclosure 2).
 
- of those speaking engagements the date they were booked, the date of the
event and the date of which they were cancelled/postponed or a
representative arranged to attend instead of Ms Denham 
 
-all correspondence in relation to the cancellation/postponement or
replacements sent.
 
The speaking engagement at the ACA seminar and symposium was booked on 31
October, the date of the event is provided in the attached PDF entitled
‘Disclosure 3’, and the Commissioner’s attendance was cancelled on 28
November. The attached PDF entitled ‘Disclosure 4’ contains a copy of our
outgoing email to the organisers of the event cancelling the attendance of
the Commissioner. This is the only correspondence we hold regarding this
cancellation.
 
The speaking engagement at the IRMS conference was booked on 9 March 2017,
the date of the event is provided in the attached PDF entitled ‘Disclosure
5’ and a replacement speaker was offered on 5 January 2018. Please find
attached a copy of our outgoing correspondence with the organisers of this
conference regarding the cancellation (‘Disclosure 6’) and a small amount
of internal correspondence confirming the availability of a replacement
speaker (‘Disclosure 7’). 
 
Further information we hold that falls within the scope of this part of
your request is a small amount of incoming correspondence from IRMS. We
received this email with an expectation of confidence from the organiser
and do not have consent to disclose it further. It is therefore withheld
under section 44 of the FOIA, more information regarding which I have
provided below.
 
You will see redactions have also been made to the personal information of
a junior member of ICO staff pursuant to the provisions of section 40(2)
of the FOIA. This exempts information which is the personal data of a
person other than the requestor and where disclosure would breach the data
protection principles.
 
-where possible provide the policy in which accepting speaking engagements
is documented
 
Please find attached our Engagement and Speaker request procedure
(‘Disclosure 8’). Also falling within the scope of this part of your
request is our speaking engagements policy. This is available on our
website at the link below. Because we have published this information, it
is technically withheld under section 21 of the FOIA as it is “reasonably
accessible by other means”.
 
https://ico.org.uk/media/about-the-ico/d...
 
FOIA section 22
 
The information regarding the Commissioner’s future speaking engagements
is exempt from disclosure as it is being held for future publication.
Details regarding the Commissioner’s speaking events are routinely
published on the ICO website, and the information held within the scope of
the relevant part of your request will be published in the near future.
 
Section 22 of the Act states that information is exempt from disclosure in
response to an information request if:
 
 “(a) the information is held by the public authority with a view to its
publication, by the authority or any other person, at some future date
(whether determined or not),
(b) the information was already held with a view to such publication at
the time when the request for information was made, and
(c) it is reasonable in all the circumstances that the information should
be withheld from disclosure until the date referred to in paragraph (a).”
 
In this case we find that the exemption at section 22 of the FOIA applies
to the information we hold regarding the Commissioner’s future speaking
engagements.
 
The exemption at section 22 is qualified by the public interest test,
meaning that the information should be disclosed if the public interest in
the maintenance of the exemption does not outweigh the public interest in
disclosure.
 
In this case the public interest factors in disclosing the information
are:
 
•       Providing transparency in relation to the Information
Commissioner’s diary commitments.
 
The factors in withholding the information are:
 

* The ICO has a history of publishing this information on a regular
basis and has committed to publishing the relevant speeches and
organiser information into the public domain
* Earlier disclosure is not necessary to satisfy any pressing public
interest at the present time.

 
Having considered the public interest arguments, we have decided to
withhold this information in reference to section 22 of FOIA. The page on
our website where the information will be published in due course is:
[1]https://ico.org.uk/about-the-ico/who-we-...
 
FOIA Section 44
 
The correspondence received by IRMS was provided with an expectation of
confidence and solely for the purposes of our arranging a speaking event
for the Information Commissioner. This is therefore being withheld under
the provisions of Section 44 of the FOIA which places prohibitions on
disclosure. 
 
Section 44(1)(a) of the FOIA states;
 
‘(1) Information is exempt information if its disclosure (otherwise than
under this Act) by the public authority holding it -
(a) is prohibited by or under any enactment’
 
The enactment in question is the Data Protection Act 1998 (DPA) and
specifically section 59 of that Act. Section 59 states that neither the
Commissioner nor her staff shall disclose;
 
“any information which:
 
a.     has been obtained by, or furnished to, the Commissioner under or
for the purposes of the information Acts.
b.     relates to an identified or identifiable individual or business,
and
c.      is not at the time of disclosure, and has not been available to
the public from other sources, unless the disclosure is made with lawful
authority.”
 
This prevents us from disclosing the information which has been provided
to us with an expectation of confidence and where we have no consent to
disclose further.
 
Review Procedure
 
I hope this provides you with useful information. However, if you are
dissatisfied with this response and wish to request a review of our
decision or make a complaint about how your request has been handled you
should write to the Information Access Team at the address below or e-mail
[2][ICO request email].
 
Your request for internal 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.
 
If having exhausted the review process you are not content that your
request or review 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 legislation. To make such an application, please write
to our Customer Contact Team at the address given or visit our website if
you wish to make a complaint under the Freedom of Information Act.
 
A copy of our review procedure can be accessed from our website.
[3]here.
 
Yours sincerely
 
 

Danny Langley
Senior Information Access Officer
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire SK9 5AF
T. 01625 545784  F. 01625 524510  [4]ico.org.uk  [5]twitter.com/iconews
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