Financial Liabilities of Possible Incinerator Project Outcomes

Cos Ttofa made this Freedom of Information request to Gloucestershire County Council

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 partially successful.

Dear Gloucestershire County Council,

Please provide a summary of each possible outcome with regard to the Javelin Park incinerator planning application and the related financial liability that would be borne by GCC.

Outcomes should include, but not be limited to: Successful appeal by UBB, Unsuccessful appeal by UBB, termination of the contract by GCC, termination of the contract by UBB.

Financial liability provided should be as accurate as possible and include, as relevant, any specific contractual provision, any related Council budgetary provision, forecasts or estimates.

Yours faithfully,

Cos Ttofa

Freedom of Information questions/information requests, Gloucestershire County Council

Dear Mr Ttofa

 

Request for Information (Reference 13/FOI/6414)

 

Thank you for your request for information for the financial liabilities
of possible incinerator project outcomes, received on

23 June 2013. Your request is being considered and you will receive a
response as soon as possible, and within the statutory timescale of 20
working days as defined by the Freedom of Information Act (FoIA) 2000;
that date is 19 July 2013.

 

Gloucestershire County Council is committed to the principles of FoIA and
will, wherever possible, provide all information requested unless
constrained by another statute or by an exemption within the FoIA. Please
note some information you have requested may not be provided to you; this
will only be information that can be withheld by law, and the reason will
be explained to you when we send out any information that can be released.

 

We may need to contact you if the request needs to be clarified; this is
to ensure we provide you with the information you require.

 

If the information you have requested is held by another public authority,
we will transfer the request to them. If you have any objections to this,
please contact us as soon as possible so we know not to transfer the
request, and we will provide you with the relevant contact details
instead.

 

Yours sincerely

 

 

Information Management Service

 

Gloucestershire County Council

Shire Hall

Westgate Street

Gloucester

GL1 2TG

 

Tel: 01452 425317

Email: [1][Gloucestershire County Council request email]

 

Go to [2]www.gloucestershire.gov.uk to find information on any County
Council service. It couldn’t be easier to find information instantly and
in some cases apply for services online.

 

For Freedom of Information (FOI) requests please email
[3][Gloucestershire County Council request email]

 

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Freedom of Information questions/information requests, Gloucestershire County Council

2 Attachments

Dear Mr Ttofa

 

Information request under Environmental Information Regulations ref
13/FOI/6414

 

I am writing in response to your request for information: “Please provide
a summary of each possible outcome with regard to the Javelin Park
incinerator planning application and the related financial liability that
would be borne by GCC. Outcomes should include, but not be limited to:
Successful appeal by UBB, Unsuccessful appeal by UBB, termination of the
contract by GCC, termination of the contract by UBB. Financial liability
provided should be as accurate as possible and include, as relevant, any
specific contractual provision, any related Council budgetary provision,
forecasts or estimates.”

 

We have considered your application for information under the
Environmental Information Regulations (EIRs) and in so far as any
information within the documentation is not considered environmental
information, the information has been considered under the Freedom of
Information Act (FoIA).

 

Figures for the financial  liability that would be borne by GCC will not
be known until one of the scenarios provided for in the Schedules becomes
a reality. To this extent the Council does not hold the information
requested.

 

Where the Authority holds the information requested, it is contained
within Schedules 17 and 26 of the contract between Urbaser Balfour Beatty
and Gloucestershire County Council. To aid understanding of schedules 17
and 26, please find enclosed a copy of the full redacted contract. This is
in two parts: project agreement and schedules.

 

Information relating to your request was also contained within Annex 4 of
the report presented to Cabinet on 12^th September for a decision to award
the contract for the treatment of residual waste. Annex 4 contained exempt
information and was considered in closed session and is therefore withheld
due to its commercial sensitivity.

 

Information relevant to budget provision, forecast or estimates is already
within the public domain. The waste management budget (which includes
current waste disposal costs) for the financial year 2013/2014 is £25.072
million. This includes the council’s share of the estimated cost of the
planning appeal of £346,185, with a further £100,000 contingency, all
within budget.

 

Where we have taken the decision to either redact or withhold the
information, we have used the following exceptions and exemptions:

 

·          Environmental Information Regulations:

o   Regulation 12 (3) and regulation 13 of the EIRs and Section 40 of the
FoIA* - the information is the personal data of a person other than the
applicant

o   Regulation 12 (5) (e) - the confidentiality of commercial or
industrial information where such confidentiality is provided by law to
protect a legitimate economic interest

o   Regulation 12 (5) ( c) intellectual property rights

 

·         Freedom of Information Act

o   section 42 – information whose release is likely to prejudice the
commercial interests of any person

o   section 41 – confidential information

 

All are considered in more detail below.

With respect to exceptions and exemptions listed above, the matters which
were considered in applying the public interest test were as follows:

 

For release

 

·          Promoting public debate;

·          Further the understanding of issues;

·          Allowing individuals to understand decisions;

·          Promoting accountability and transparency in terms of decision
making;

·          Promoting accountability and transparency in terms of spending;

·          Impact of making information public; and

·          Information affecting public health and safety.

 

Against Release

 

·         Disclosing it could affect the commercial or economic interest
of the contractor;

·         The likelihood of commercial damage being caused to the
contractor through a disclosure of information it considers confidential;

·         The possibility that in disclosing this information the level of
service to the community may be impaired,

·         The possibility that the cost for obtaining services may
increase through decreased competition for the contract thereby creating
detriment to the best interest of the community; and

·         impact on subsequent contracts which the Council may wish to
enter into.

Consideration of request for information under the Environmental
Information Regulations 2004

Use of regulation 12(5)(e):

In order to come within the terms of the exception it must be shown that:

(1)  The information in question is “commercial or industrial”.

The council is satisfied that the sections of the contract to which the
exception has been applied contain commercial or industrial information.
The requested information contains information on the planning and
development of a residual waste management solution for Gloucestershire.

(2)  The information is subject to confidentiality provided by law, being
information which is confidential under either common law, contract or a
statutory bar.

a)    Common law confidentiality

In order to be subject to common law confidentiality the information must
(a) have the necessary quality of confidence and (b) be imparted in
circumstances importing an obligation of confidence.

In order to ascertain whether the information has the necessary quality of
confidence it can be helpful to ask a number of questions in order to
ascertain if the information has the necessary quality of confidence.
These include whether:

• the information is trivial, and whether

• the information is available from other sources

i) Is the information trivial?

It has been determined that this information is not trivial. In this case
the contract involves a major procurement of residual waste management
services by the council. It includes information which could potentially
be used by the contractors’ competitors to their own advantage. Elements
within the information would disclose a package of information brought
together using the skills and experience of the contractor over time,
which would be advantageous to other businesses in the area of waste
management.

ii) Is the information already available by other means/has it passed into
the public domain?

There is some information about the contract and solution in the public
domain and available via these links: 

 

[1]http://www.gloucestershire.gov.uk/articl...

 

[2]http://www.recycleforgloucestershire.com...

 

 

[3]http://www.ubbgloucestershire.co.uk/

However, the information withheld encompasses aspects that are unique to
the contractor and as such are not available by other means and have not
been passed into the public domain.

b)    Contractual obligation of confidence

The contract contains a number of provisions whereby both parties have
agreed to keep certain information confidential where this is necessary to
protect the interests of both parties.  The major provisions of the
contract have yet to be implemented and so the information remains
confidential at this time.

c)    Confidentiality under the Public Contracts Regulations 2006

There is an inherent duty of confidentiality when information is submitted
to councils in procurement exercises. The Public Contracts Regulations
2006 and their precursor required that where a contractor submits
information as part of a procurement process the council should accede to
reasonable requests from the contractor that information passed to the
council as part of the procurement process is treated as confidential.

(3) Such confidentiality is provided to protect “a legitimate economic
interest”;

The contract contains information provided by the contractor as to when
and how it intends to carry out the contract and provide waste management
services. Some of this information is proprietary in nature and provides a
detailed overview of the way the contractor approaches such contracts. The
contractor states that disclosure would provide information on its methods
of business which would be of advantage to its direct competitors, thereby
negating its ability to develop a commercial advantage when tendering for
other contracts. The council therefore accepts that the legitimate
economic interests of the contractor would be adversely affected by the
disclosure of this information.

There is an agreement that the confidential information contained in the
contract would be confidential to both parties (in that each party agreed
to hold the information in confidence and could not therefore disclose it
as each would owe the other a duty of confidence to protect their
respective economic interests). Therefore, the council is able to consider
its own economic interests in addition to those of the contractor. The
council feels that confidentiality is required in order to protect its
position as purchaser. Disclosing this information would affect its
ability to negotiate best value and to enable it to effectively procure
services in the future.

(3)  The disclosure of the information would adversely affect such
confidentiality.

Some of the information which has been withheld contains detailed
technical information on the equipment and systems used by the contractor
which could be studied and adopted by competitors of the suppliers of the
equipment.

Disclosure would be likely to disadvantage the contractor’s ability to
tender for other public or private commercial contracts if competitors to
the manufacturers of the equipment use this information for their own
benefits.

Many elements of the technical information include details on commercially
sensitive systems and processes developed by third parties – e.g. they may
be the trade secrets of third parties.

Freedom of Information.

Section 42 of the FOIA provides that information is exempt if release of
the information is likely to prejudice the commercial interests of any
person, which can include the Council itself. As detailed above in
relation to EIR, disclosure of some of the information which has been
withheld would adversely affect the contractor’s position in the market by
disclosing technical detail and commercially sensitive processes.  This is
a qualified exemption – the public interest test is set out below.

In addition, under section 41 of the FOIA information is exempt if it is
provided to the Council by a third party and disclosure would give rise to
an actionable breach of confidence. Some of the information which has been
withheld is exempt under this section because it is caught by the
confidentiality provisions of the contract between the Council and UBB. 
It is information which has been provided by UBB as part of the
procurement process and then incorporated into the contract.

Public interest test

For disclosure:

Increased public access to environmental information and the dissemination
of such information contribute to a greater awareness of environmental
matters, a free exchange of views, more effective participation by the
public in environmental decision-making and, eventually, to a better
environment.

Local communities should be given the opportunity to participate fully in
the process of drawing up plans and to be consulted on proposals for
development. Consultation on issues and priorities for disposing of
residual waste in Gloucestershire has taken place.

Waste management is a core function of local authorities, and has the
capacity to affect all of the community. It can affect the community in a
number of ways in addition to the general effects of ensuring household
and commercial waste is dealt with appropriately. This can include
environmental concerns.

As such the council has taken into account the fact that there will be a
great deal of public interest in the disclosure of information which
throws light on whether the council has ensured that adequate safeguards
to protect the environment have been established as part of the proposed
solution.

Disclosure of this information could help improve transparency and
accountability about council decisions and the spending of public funds,
while disclosing information about the systems being employed by the
contractor (on behalf of the council), could promote discussion about
possible detrimental effects upon the environment.

Against disclosure:

Confidentiality is required in order to protect the council’s position as
purchaser. It is argued that disclosing this information would affect the
council’s ability to negotiate best value in the future.

There is a strong public interest in confidences being maintained.

There is a significant likelihood of commercial damage being caused to the
contractor through a disclosure of information it considers confidential.

There is a possibility that in disclosing this information the level of
service to the community may be impaired.

There is a possibility that the cost of obtaining services may increase
through decreased competition for contracts, thereby creating detriment to
the best interests of the community.

Conclusion

 

Having carefully balanced these considerations, the Council has concluded
that the public interest in maintaining the exceptions and exemptions
outweighs the public interest in disclosure.

 

Table 1: List of documents

 

Document Document Description Supplied Redacted With held
  Project Agreement/contract   X  
Schedule 1 Definitions   X  
Schedule 2 Output Specification   X  
Schedule 3 Service Delivery Plans     X
Schedule 4 Payment Mechanism     X
Schedule 5 Ancillary Documents and Finance X    
Agreements
Schedule 6 Contractor Warranted Data   X  
Schedule 7 Site Information     X
Schedule 8 Key Dates   X  
Schedule 9 Review Procedure   X  
Schedule 10 Required Insurances   X  
Schedule 11 Tests X    
Schedule 12 Independent Certifier Deed of   X  
Appointment
Schedule 13 Not Used      
Schedule 14 Gloucestershire Waste Law List     X
Schedule 15 Best Value and Continuous Improvement   X  
Schedule 16 Refinancing   X  
Schedule 17 Compensation on Termination   X  
Schedule 18 Liaison Procedure X    
Schedule 19 Revision of Base Case and Custody   X  
Schedule 20 Employment and Pensions X    
Schedule 21 Change Protocol   X  
Schedule 22 Dispute Resolution Procedure   X  
Schedule 23 Commercially Sensitive Information   X  
Schedule 24 Direct Agreement   X  
Schedule 25 Form of Collateral Warranty   X  
Schedule 26 Planning   X  
Schedule 27 Approach to Permit Risk   X  
Schedule 28 Relevant Discharge Terms X    
Schedule 29 Basic Design Proposal   X  
Schedule 30 Outline Substitute Waste Plan X    
Schedule 31 Waste Acceptance Protocol     X
Schedule 32 WCA Composition Protection     X
Schedule 33 Power Offtake Arrangements     X

 

Further detail regarding information that is withheld or redacted is
summarised in Table 2.

 

Table 2: Reasons for redactions/withholding information

 

Document Document Description Legislation applicable Reason
to redaction/withheld
document

 
  Project Regulation 12 (5) (e) - The information
Agreement/contract confidentiality of redacted includes a
commercial or range of commercially
industrial information sensitive information
to protect economic such as:
interest
·         financial
information,

·         negotiated
positions,

·         details of
tax structures.

 

All of these details
are commercial
negotiated positions,
bespoke to the
Gloucestershire
residual waste
project and release
would be likely to
cause commercial harm
to both the council
and the contractor in
future procurements
as set out above.
Schedule 1 Definitions   The information
redacted includes a
range of commercially
sensitive information
such as:

·         financial
information

·         negotiated
positions

·         details of
tax structures.

 

All of these details
are commercial
negotiated positions,
bespoke to the
Gloucestershire
residual waste
project and release
would be likely to
cause commercial harm
to both the council
and the contractor in
future procurements
as set out above.
Schedule 2 Output Specification Regulation 12 (5) (e) - The information
confidentiality of redacted includes a
commercial or range of commercially
industrial information sensitive negotiated
to protect economic positions that are
interest bespoke to the
Gloucestershire
residual waste
project and release
would be likely to
cause commercial harm
to both the council
and the contractor in
future procurements
as set out above.
Schedule 3 Service Delivery Plans Regulation 12 (5) (e) - The information with
confidentiality of held consists of the
commercial or details of how the
industrial information contractor will
to protect economic deliver the service.
interest These documents have
been heavily
negotiated and are
clear commercial
positions bespoke to
the Gloucestershire
residual waste
project. Release
would be likely to
cause commercial harm
to both the council
and the contractor in
future procurements
as set out above.
Schedule 4 Payment Mechanism Regulation 12 (5) (e) - The information with
confidentiality of held is used to
commercial or determine the cost to
industrial information the Authority of the
to protect economic contract and how the
interest finances of the
contract are managed.
This document has
been heavily
negotiated and has
clear commercial
positions bespoke to
the Gloucestershire
residual waste
project. Release
would be likely to
cause commercial harm
to both the council
and the contractor in
future procurements
as set out above.
Schedule 5 Ancillary Documents and N/A - released
Finance Agreements
Schedule 6 Contractor Warranted Regulation 12 (5) (e) - The information
Data confidentiality of redacted includes
commercial or financial information
industrial information about shareholders,
to protect economic it is bespoke to the
interest Gloucestershire
residual waste
project and release
would be likely to
cause commercial harm
to both the council
and the contractor in
future procurements
as set out above.

 

Schedule 7 Site Information Regulation 12 (5) (e) The information has
- confidentiality of been with held as it
commercial or has commercial
industrial information implications for the
to protect economic council, the
interest information redacted
includes a range of
commercially sensitive
negotiated positions
that are bespoke to
the Gloucestershire
residual waste project
and release would be
likely to cause
commercial harm to
both the council and
the contractor in
future procurements as
set out above.
Schedule 8 Key Dates Regulation 12 (5) (e) The information
- confidentiality of redacted is
commercial or commercially sensitive
industrial information information that
to protect economic includes mechanisms
interest and triggers for other
contractual procedures
and are negotiated
positions that are
bespoke to the
Gloucestershire
residual waste
project. Release would
be likely to cause
commercial harm to
both the council and
the contractor in
future procurements as
set out above..
Schedule 9 Review Procedure Regulation 12 (5) (e) The information
- confidentiality of redacted is
commercial or commercially sensitive
industrial information information that is
to protect economic directly linked to the
interest cost of the solution
and is bespoke to the
Gloucestershire
residual waste
project. Release would
be likely to cause
commercial harm to
both the council and
the contractor in
future procurements as
set out above.
Schedule 10 Required Insurances Regulation 12 (5) (e) The information
- confidentiality of redacted includes a
commercial or range of commercially
industrial information sensitive negotiated
to protect economic positions that are
interest bespoke to the
Gloucestershire
residual waste project
and release would be
likely to cause
commercial harm to
both the council and
the contractor in
future procurements as
set out above.
Schedule 11 Tests N/A - released
Schedule 12 Independent Certifier Regulation 12 (5) (e) The information
Deed of Appointment - confidentiality of redacted includes a
commercial or range of commercially
industrial information sensitive negotiated
to protect economic positions and figures
interest that are bespoke to
the Gloucestershire
And residual waste project
and release would be
Regulation 12 (3) - likely to cause
the information is the commercial harm to
personal data of a both the council and
person other than the the contractor in
applicant future procurements as
set out above. In
addition, there is
personal information
within the schedule
that has been
redacted.
Schedule 13 Not Used
Schedule 14 Gloucestershire Waste Regulation 12 (5) (e) The information has
Law List - confidentiality of been with held as it
commercial or has commercial
industrial information implications for the
to protect economic council and the
interest Contractor that is
directly liked to the
cost of the solution.
This contains
negotiated positions
that are bespoke to
the Gloucestershire
residual waste project
and release would be
likely to cause
commercial harm to
both the council and
the contractor in
future procurements as
set out above.
Schedule 15 Best Value and Regulation 12 (5) (e) The information
Continuous Improvement - confidentiality of redacted includes a
commercial or range of commercially
industrial information sensitive negotiated
to protect economic positions that are
interest bespoke to the
Gloucestershire
residual waste project
and release would be
likely to cause
commercial harm to
both the council and
the contractor in
future procurements as
set out above.

 

Schedule 16 Refinancing Regulation 12 (5) (e) - The information redacted
confidentiality of includes a range of
commercial or commercially sensitive
industrial information negotiated positions,
to protect economic figures and confidential
interest information about the
contractor’s investment
strategy which are all
bespoke to the
Gloucestershire residual
waste project and release
would be likely to cause
commercial harm to both
the council and the
contractor in future
procurements as set out
above..
Schedule 17 Compensation on Regulation 12 (5) (e) - The information redacted
Termination confidentiality of includes a range of
commercial or commercially sensitive
industrial information negotiated positions and
to protect economic figures and confidential
interest information about the
contractor’s investment
strategy which are all
bespoke to the
Gloucestershire residual
waste project and release
would be likely to cause
commercial harm to both
the council and the
contractor in future
procurements as set out
above.
Schedule 18 Liaison Procedure N/A - released
Schedule 19 Revision of Base Regulation 12 (5) (e) - The information redacted
Case and Custody confidentiality of includes a range of
commercial or commercially sensitive
industrial information negotiated positions,
to protect economic procedures and figures
interest which are all bespoke to
the Gloucestershire
residual waste project
and release would be
likely to cause
commercial harm to both
the council and the
contractor in future
procurements as set out
above.
Schedule 20 Employment and N/A -  released
Pensions
Schedule 21 Change Protocol Regulation 12 (5) (e) - The information redacted
confidentiality of includes a range of
commercial or commercially sensitive
industrial information negotiated positions, and
to protect economic figures which are all
interest bespoke to the
Gloucestershire residual
waste project and release
would be likely to cause
commercial harm to both
the council and the
contractor in future
procurements as set out
above.
Schedule 22 Dispute Resolution Regulation 12 (5) (e) - The information redacted
Procedure confidentiality of includes a range of
commercial or commercially sensitive
industrial information negotiated positions,
to protect economic which are all bespoke to
interest the Gloucestershire
residual waste project
and release would be
likely to cause
commercial harm to both
the council and the
contractor in future
procurements as set out
above.
Schedule 23 Commercially Regulation 12 (5) (e) - The information redacted
Sensitive confidentiality of highlights areas of
Information commercial or commercial sensitivity
industrial information and key negotiated
to protect economic points. Release would be
interest likely to cause
commercial harm to both
the council and the
contractor in future
procurements as set out
above.
Schedule 24 Direct Agreement Regulation 12 (5) (e) - The information redacted
confidentiality of includes a range of
commercial or commercially sensitive
industrial information negotiated positions,
to protect economic which are all bespoke to
interest the Gloucestershire
residual waste project
and release would be
likely to cause
commercial harm to both
the council and the
contractor in future
procurements as set out
above.
Schedule 25 Form of Collateral Regulation 12 (5) (e) - The information redacted
Warranty confidentiality of includes a range of
commercial or commercially sensitive
industrial information negotiated positions,
to protect economic which are all bespoke to
interest the Gloucestershire
residual waste project
and release would be
likely to cause
commercial harm to both
the council and the
contractor in future
procurements as set out
above.

 

Schedule 26 Planning Regulation 12 (5) (e) - The information redacted
confidentiality of includes a range of
commercial or commercially sensitive
industrial information negotiated positions,
to protect economic which are all bespoke to
interest the Gloucestershire
residual waste project
and release would be
likely to cause
commercial harm to both
the council and the
contractor in future
procurements as set out
above. In addition, if
the information in Annex
1 of the Schedule is
released it could be
detrimental if the
contractor decides to go
forward with an appeal of
the planning decision.
Schedule 27 Approach to Permit Regulation 12 (5) (e) - The information redacted
Risk confidentiality of includes a range of
commercial or commercially sensitive
industrial information negotiated positions,
to protect economic which are all bespoke to
interest the Gloucestershire
residual waste project
and release would be
likely to cause
commercial harm to both
the council and the
contractor in future
procurements as set out
above.
Schedule 28 Relevant Discharge N/A -  released
Terms
Schedule 29 Basic Design Regulation 12 (5) (e) - The information redacted
Proposal confidentiality of includes a range of
commercial or commercially sensitive
industrial information negotiated positions,
to protect economic which are all bespoke to
interest the Gloucestershire
residual waste project
and release would be
likely to cause
commercial harm to both
the council and the
contractor in future
procurements as set out
above.
Schedule 30 Outline Substitute N/A - released
Waste Plan
Schedule 31 Waste Acceptance Regulation 12 (5) (e) - The information is with
Protocol confidentiality of held as it includes a
commercial or bespoke procedure
industrial information developed by the council
to protect economic and the contractor. It is
interest a commercially sensitive
document and the contents
And also reflect other
documents that are being
Regulation 12 (5) ( c) with held under this EIR
intellectual property request. Release would be
rights likely to cause
commercial harm to both
the council and the
contractor in future
procurements as set out
above.
Schedule 32 WCA Composition Regulation 12 (5) (e) - The information is with
Protection confidentiality of held as it includes a
commercial or bespoke procedure
industrial information developed by the council
to protect economic and the contractor. It is
interest a commercially sensitive
document which will be
And used for future
procurements and to
Regulation 12 (5) ( c) release this would
intellectual property undermine future
rights competitions run by the
council and/or the
contractor.
Schedule 33 Power Offtake Regulation 12 (5) (e) - The information is with
Arrangements confidentiality of held as it includes a
commercial or bespoke procedure
industrial information developed by the council
to protect economic and the contractor. It is
interest a commercially sensitive
document which will be
And used for future
procurements and to
Regulation 12 (5) ( c) release this would
intellectual property undermine future
rights competitions run by the
council and/or the
contractor.

 

 

In coming to that conclusion, the public interest in making the
information available against any prejudice to the public interest that
might arise from providing the information has been carefully weighed.

 

* Also, in considering your request and having come to the decision that
some of the information is personal data as defined by the Data Protection
Act 1998; it is information about someone else and, by law*, I’m unable to
give this to you.

If you feel that we have failed to comply with the regulations in relation
to this request, you may appeal against this decision by writing back
within 40 working days of the date of receipt of this letter, and sending
us any supporting evidence which you think supports your appeal. The full
procedure is on our website at

[4]http://www.gloucestershire.gov.uk/CHttpH....

 

We would like to hear your views on our service. If you’d like to tell us
how we did, you can complete our feedback form online at
[5]http://www.gloucestershire.gov.uk/foifee....

 

Yours sincerely

 

Information Management Service

 

Gloucestershire County Council

Shire Hall

Westgate Street

Gloucester

GL1 2TG

 

Go to [6]www.gloucestershire.gov.uk to find information on any County
Council service. It couldn’t be easier to find information instantly and
in some cases apply for services online.

 

For Freedom of Information (FOI) requests please email
[7][Gloucestershire County Council request email]

 

 

*As you are not the data subject, release of this information would
constitute a breach of principle 1 of the Data Protection Act. Principle 1
states that personal data shall be processed (used) fairly and lawfully
and, in particular, shall not be processed unless at least one of the
conditions in Schedule 2 is met; in this case none of the conditions in
Schedule 2 have been met.

 

This means that the section 40 exemption of the Freedom of Information Act
2000 (FoIA) is engaged; this email therefore acts as a refusal notice
under section 17 of the FoIA as some of the information you have requested
is exempt from disclosure.

 

 

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Think before you print - only print this email if absolutely necessary.

This email and any attachments are strictly confidential and intended for the addressee only.  
If you are not the named addressee you must not disclose, copy or take any action in 
reliance of this transmission and you should notify us as soon as possible.

This email and any attachments are believed to be free from viruses but it is your 
responsibility to carry out all necessary virus checks and Gloucestershire County Council 
accepts no liability in connection therewith. 

References

Visible links
1. http://www.gloucestershire.gov.uk/articl...
2. http://www.recycleforgloucestershire.com...
3. http://www.ubbgloucestershire.co.uk/
4. http://www.gloucestershire.gov.uk/CHttpH...
5. http://www.gloucestershire.gov.uk/foifee...
6. http://www.gloucestershire.gov.uk/
7. mailto:[Gloucestershire County Council request email]

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