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FOI Request: Organisational Structure for Commissioning and Procurement Teams

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Dear City of London Corporation,

Please could you provide the current/latest organisational structure for the Commissioning and Procurement teams, including the names, job titles and contact details of all mid and senior management.

Yours faithfully,

Sam John

COL-EB-InformationOfficer, City of London Corporation

Dear Sam John,


The City of London (CoL) acknowledges receipt of your request for information of 22 December 2020.

Public authorities are required to respond to requests within the statutory timescale of 20 working days beginning from the first working day after they receive a request. The Act does not always require public authorities to disclose the information which they hold.

The FOIA applies to the CoL as a local authority, police authority and port health authority. The CoL is the local and police authority for the "Square Mile", ie the historic City of London, and not for London as a whole. Please see the following page containing a link to a map (City of London - Interactive Mapping), which shows the local authority area covered by the CoL:

The CoL does have some functions, including Port Health Authority functions, which extend beyond the City boundary. For further information please see: www.cityoflondon.gov.uk.

Yours sincerely,

Information Officer
Comptroller & City Solicitor's Department
City of London
Tel: 020-7332 1243

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CityProc – Policy & Compliance, City of London Corporation

2 Attachments

Dear Sam John,




Following your request for information of 22 December and our
acknowledgement of 22 December, the City of London (CoL) responds as


Please could you provide the current/latest organisational structure for
the Commissioning and Procurement teams, including the names, job titles
and contact details of all mid and senior management.


Please see the attached organisational structure for the Commissioning and
Procurement teams. City Procurement is the central procurement team for
the City of London Corporation and is part of the Chamberlain’s
department. Due to the specialised nature of their work, the department
for Community & Children’s Services department retains a specialised
Commissioning Team which works closely with City Procurement.


Community & Children’s Services contact details:
Simon Cribbens

Assistant Director of Partnerships & Commissioning

Email: [1][email address]  
Phone: 0207 606 3030


City Procurement contact details:

Peter Kane

Email: [2][email address]
Phone: 0207 606 3030


In regard to the names and contact details for mid-level managers, in
accordance with section 17 of the FOIA, this response acts as a refusal
notice as follows:


Exemption – Section 21


In so far as the names of staff and contact information are already in the
public domain on the CoL website ([3]www.cityoflondon.gov.uk) the FOIA
section 21 exemption is applied (information accessible to the applicant
by other means). This is an absolute exemption, ie it is not subject to
the public interest test.


The CoL’s full organisation (including names of senior managers) can be
found on our website under Organisational Structure:

 In accordance with The Local Government Transparency Code, this
information is updated annually.


Departmental contact details are also available on our website -


Exemption – S40(2) – Personal Information


With regard to the names of staff below that of senior level managers, and
direct email addresses of all staff (personalised work contact
information), where these do not already appear on the CoL website, the
CoL applies the section 40(2) exemption (personal information) to
disclosure under the FOIA.


The CoL applies the exemption because it considers that a breach of the
data protection principles under the Data Protection Act 2018 (DPA) would
occur as a result of disclosure. In this instance, we consider that
Section 8 would be breached by disclosure, ie the principle of fair and
lawful processing. There is no general expectation by staff, other than
senior managers, that their names, place of work and work contact details
should be automatically disclosed following FOI requests. It is one of the
reasons why our website gives only a few named contacts (being mainly
limited to departmental managers), and why, usually, generic rather than
individual email contact addresses are provided on our website.


The CoL considers that where someone works, and who is their employer, is
personal information, just as such employment details would be considered
in the private sector. The Information Tribunal has upheld this view,
stating that "to release the name of an individual’s employer would be to
release significant personal data" (Appeal decision EA/2007/0058), and
hence could be a breach of the DPA. Such disclosure would inevitably take
place were the CoL to release the names of its entire staff.


A public authority also has to consider a disclosure under the FOIA as a
disclosure to the world. Again, we note the Information Tribunal’s
statement that “Disclosure under [the] FOIA is effectively an unlimited
disclosure to the public as a whole” (Appeal reference EA/2006/0011 &
0013), which statement is also referred to by the Information
Commissioner, for example in the Information Commissioner’s Decision
Notice FS 50294078. Disclosure of names and personalised contact details
would therefore represent a comprehensive overriding of the DPA.


We consider that it is necessary to pay due respect to the privacy of
employees in the public sector. We do not consider that, because a body
receives public funding to a greater or lesser degree, its employees
automatically forfeit their rights to privacy. We also do not consider
that the information that a particular named individual is a public sector
employee of a particular named public authority is information which in
itself would constitute information of general public interest. On the
contrary, in relation to the vast majority of public sector employees,
such information is manifestly of no general public interest, and
disclosure would therefore not pass the public interest test.


It is also the case that there is always going to be some level of staff
turnover, with employees either leaving the organisation or moving to a
different role or department. Therefore it is far more practical to simply
disclose generic information for service areas as these are less likely to
change as often, if at all. Ultimately, it is in any case the top
management which holds responsibility in an organisation for corporate
decisions, and these names are not withheld.


Please see also the further arguments in support of non-disclosure, by the
Information Commissioner in Decision Notice FS50184497, which, as
mentioned, stated that the Commissioner could see no public interest
arguments in support of wholesale disclosure of names and direct contact


Finally, we note that the website of the information Commissioner's Office
(ICO) shows an extremely limited disclosure of employee names, to a degree
which implies a very high threshold for the unlimited publication of such
information in relation to a public authority which falls within the scope
of the FOIA.


In conclusion, with regard to this exemption, the CoL does not see any
legitimate interests in the public routinely having access to this
information, and considers that disclosure would not pay due respect to
the rights and freedoms of the data subjects, ie in this instance the
members of staff. The CoL does not consider that there are any conditions
under Section 8 of the DPA (which Schedule concerns conditions under
Principle 1 for processing personal information) which would permit


Despite the application of these exemptions, we hope this response is


If you wish to make a complaint about the way the CoL has managed your
enquiry, please make your complaint in writing to email address:
[6][email address]. For a link to the CoL’s FOI complaints
procedure, please visit the following page:
[7]www.cityoflondon.gov.uk/Feedback, at the end of which is located the
FOI complaints procedure. If, having used the CoL’s FOI Complaints
Procedure, you are still dissatisfied, you may request the Information
Commissioner to investigate. Please contact: Information Commissioner,
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Telephone:
(01625) 545700.  Website: [8]http://www.ico.org.uk/.

The FOIA applies to the CoL as a local authority, police authority and
port health authority. Subject to any other statutory provisions requiring
the CoL to disclose information, release of information outside the scope
of the Act is subject to the discretion of the CoL.

The CoL holds the copyright in this communication.   The supply of this
information does not give a right to re-use in a way that would infringe
that copyright, for example, by making copies, publishing and issuing
copies to the public or to any other person. Brief extracts of any of the
material may be reproduced under the fair dealing provisions of the
Copyright, Designs and Patents Act 1988 (sections 29 and 30) for the
purposes of research for non-commercial purposes, private study,
criticism, review and news reporting, subject to an acknowledgement of the
copyright owner.

Yours sincerely,


Supplier Performance Officer

City Procurement

Chamberlain’s Department

City of London

Tel: 020 7606 3030

Email: [9][email address]


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We don't know whether the most recent response to this request contains information or not – if you are Sam John please sign in and let everyone know.