Existence of information about the purpose of Wealth Screening

Madeline Bowles made this Freedom of Information request to Information Commissioner's Office

This request has been closed to new correspondence from the public body. Contact us if you think it ought be re-opened.

The request was refused by Information Commissioner's Office.

Dear Information Commissioner’s Office,

In your letter to universities sent in October 2018 you stated that "Wealth screening is a separate and distinct activity that requires its own lawful basis for processing." This was in a paragraph about fundraising.

I am aware of the content of the letter to universities and also of the content of the document produced for the February 2017 conference.

This request is specifically about the manner by which ICO has come to the conclusion that wealth screening is "a separate and distinct activity" from fundraising; it is not about the alleged intrusiveness of the activity.

The request simply asks whether or not ICO holds any information e.g. internal documentation, emails, records of meetings etc. or any other documentation, which were used to form the opinion that "Wealth Screening is a separate and distinct activity" from fundraising.

Yours faithfully,

Madeline Bowles

AccessICOinformation, Information Commissioner's Office

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

20 December 2018

 

Case Reference Number IRQ0806376

 

Dear M Bowles

Thank you for your recent request for information. We received your
request on 6 December.
 
We have considered your request under the Freedom of Information Act 2000.
 
Your request

In your email you asked:
 
‘In your letter to universities sent in October 2018 you stated that
"Wealth screening is a separate and distinct activity that requires its
own lawful basis for processing." This was in a paragraph about
fundraising. I am aware of the content of the letter to universities and
also of the content of the document produced for the February 2017
conference. This request is specifically about the manner by which ICO has
come to the conclusion that wealth screening is "a separate and distinct
activity" from fundraising; it is not about the alleged intrusiveness of
the activity. The request simply asks whether or not ICO holds any
information e.g. internal documentation, emails, records of meetings etc.
or any other documentation, which were used to form the opinion that
"Wealth Screening is a separate and distinct activity" from fundraising.’
 
Our response 
 
A request was made to the ICO on 29 October 2018, in which you were named
an associate (request reference IRQ0798121), details as below:
 
‘I understand that you wrote to a number of universities in October 2018
about what you call wealth screening. This request concerns the factual
basis for some of the assertions you have made in the letter to
universities. 1. You state on page 1: "Wealth screening raises privacy
concerns because it is the kind of processing that individuals are
unlikely to expect as a result of providing their personal data to a
university..." Please provide details of the evidence that ICO has used to
come to this conclusion. Has it carried out research amongst donors and /
or alumni of universities to ask whether this is the case? 2. You also
state "Even when individuals make a charitable donation, they would not
reasonably expect the organisation to profile their wealth to see whether
they are likely to increase their donations or leave a legacy donation."
In response to a request I made to you on 17 Feb 2017 after you made a
similar assertion in a conference paper, you said that you had "no
specific evidence base" for making this claim. Please explain whether or
not the ICO has carried out any research to support this assertion since
that time, and if not, please explain on what basis ICO continues to make
this unsubstantiated claim, especially in the light of a) the Daily Mail
articles which gave rise to your letter which substantially raised public
awareness of wealth screening and 2) the delivery of privacy notices by a
number of universities explaining this in some detail in response to which
there has been a vanishingly small rate of objection. 3. On page 3 you say
"Wealth screening is a separate and distinct activity that requires its
own lawful basis for processing." If ICO believes wealth screening is so
different from fundraising that it is a separate and distinct activity,
please explain what purpose ICO believes wealth screening serves if it is
not fundraising.’
 
A response was provided to this request on 20 November which advised that
no information was held.
 
Therefore in regard to your recent request of 6 December, we are refusing
your request under section 14(2) FOIA, which says that a public authority
does not have to comply with a request which is identical, or
substantially similar to a previous request submitted by the same
individual, unless a reasonable period has elapsed between compliance with
the previous request and the making of the current request.
 
We have decided to take this approach after considering our guidance on
dealing with repeated FOIA requests.  
 
[1]https://ico.org.uk/media/for-organisatio...
 
It’s important to note that section 14(2) does not require consideration
of the public interest when it is applied to a request.
 
It is our view that the scope of your 6 December 2018 request does not
significantly differ from that of your earlier request of the 29 October
2018 and is another attempt to obtain information that we have already
advised is not held.
 
A reasonable amount of time has not lapsed since our response to
IRQ0798121. Furthermore you will appreciate that considering similar
repeated requests is not an effective use of our resource. 
 
This concludes our response and we hope that it makes our position clear.
 
Next steps
 
If you would like me to clarify anything about the way your request has
been handled please contact me.
 
You can ask us to review the way we have handled your request. Please see
our review procedure [2]here.
 
Following our internal review, if you remain dissatisfied with the way we
have handled your request, there is a statutory complaints process and you
can report your concern to the regulator. I have included information
about how to do this separately.
 
Yours sincerely,

Sarah Whelan
Senior Information Access Officer
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire SK9 5AF
T. 0330 414 6322  F. 01625 524510  [3]ico.org.uk  [4]twitter.com/iconews
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