Information Rights Reports

Helen Cross 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 partially successful.

Dear Information Commissioner’s Office,

Please provide me with the following information:

1) A copy of the Information Rights report presented to the Management Board meeting of 22 April 2013 under agenda item 9.

2) A copy of the Information Rights report presented to the Management Board meeting of 21 January 2013 under agenda item 11.

3) A copy of the Information Rights report, Risk Management report and Risk Register presented to the Management Board meeting of 29 October 2012 under agenda item 13.

Yours faithfully,

Helen Cross

Information Commissioner's Office

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2nd May 2013

 

Reference: IRQ0495944

 

Dear Ms Cross,

Request for Information
 
Thank you for your correspondence dated 30 April 2013.  
 
Your request is being dealt with in accordance with the Freedom of
Information Act 2000.  We will respond promptly, and no later than 30 May
2013 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 the information
is added directly to your case. However, please be aware that this is an
automated process; the information will not be read by a member of our
staff until your case is allocated to a request handler.
 

Yours sincerely

Hannah Burling
Lead Information Governance Officer

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Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF
Tel: 0303 123 1113 Fax: 01625 524 510 Web: www.ico.org.uk

Dear Information Commissioner’s Office,

Your response to this request is now overdue. Please could you let me know when you expect to be able to provide a response.

Yours faithfully,

Helen Cross

Information Commissioner's Office

2 Attachments

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30 May 2013

 

Case Reference Number IRQ0495944

 

Dear Ms Cross
 
I am writing further to our 2 May acknowledgement of your 30 April request
for information. As you know, this is being dealt with as a request for
information under the Freedom of Information Act 2000 (FOIA). We are now
in a position to provide our response.
 
You requested:
 
“1) A copy of the Information Rights report presented to the
Management Board meeting of 22 April 2013 under agenda item 9.

2) A copy of the Information Rights report presented to the
Management Board meeting of 21 January 2013 under agenda item 11.

3) A copy of the Information Rights report, Risk Management report
and Risk Register presented to the Management Board meeting of 29
October 2012 under agenda item 13.”
 
We hold the information you have requested. To clarify one element before
we go further, the latter part of request 3 is made up of a cover sheet
for the risk register and the risk register itself. These fall under
agenda item 14, not 13 as stated in your request. This is probably because
there was an error in drafting the ICO website content which refers to
this matter. The website is being updated to reflect the actual position.
 
Copies of the risk register and cover note, as presented at the Management
Board meeting in October 2012 are attached.
 
Information withheld
 
The Information Rights reports requested in parts 1, 2 and 3 of your
request are being withheld. These elements of your request are being
refused under the provisions of section 36 of FOIA (Prejudice to the
effective conduct of public affairs). Information to which this exemption
applies is exempt information if, in the reasonable opinion of a qualified
person, disclosure of this information under this Act would otherwise
prejudice, or would be likely to prejudice the effective conduct of public
affairs. 

For the purposes of FOIA, the Qualified Person in respect of section 36
within the ICO is the Information Commissioner and we sought his opinion
with regard to the information you have requested.
 
Section 36
 
It is the opinion of the Information Commissioner, that disclosure of the
information rights reports would be likely to inhibit the free and frank
provision of advice and would be likely to inhibit the free and frank
exchange of views for the purposes of deliberation, and therefore that the
information is exempt from disclosure under the provisions of sections
36(2)(b)(i) and (ii) of FOIA. Additionally, it is considered more
generally that disclosure would be likely to inhibit the effective conduct
of public affairs – in this case the ICO’s ability to do its job
effectively, and therefore is also exempt under the provisions of section
36(2)(c). In all cases, it is considered that the balance of public
interest favours non-disclosure. I will provide more details on the
application of this exemption, below.
 
Section 36(2) provides that –
 
“Information to which this section applies is exempt information if, in
the reasonable opinion of a qualified person, disclosure of the
information under this Act- 
 
b) would, or would be likely to, inhibit-
 
 

 1. the free and frank provision of advice, or

 
 

 2. the free and frank exchange of views for the purposes of deliberation,
or

 
c) would otherwise prejudice, or would be likely otherwise to prejudice,
the effective conduct of public affairs.
 
Information to which this exemption applies is exempt information if, in
the reasonable opinion of the qualified person, disclosure of this
information under this Act would otherwise prejudice, or would be likely
to prejudice the effective conduct of public affairs. 

However, this exemption is not absolute. When considering whether to apply
it in response to a request for information, there is a ‘public interest
test.’ That is, we must consider whether the public interest favours
withholding or disclosing the information.

In this case the public interest factors in disclosing the information
within the scope of the request are:
 
 

* disclosure would increase transparency about matters of potential
public interest relating to information rights, and the engagement of
the ICO, and could assist public debate about such matters prior to
their implementation;
* disclosure would show the level and scope of engagement of the ICO,
both reactive and proactive, in matters of public interest.

 
The factors in withholding the information are –
 
 

* disclosure would lead to a profound chilling effect. ICO contributors
would be reluctant to put thoughts on paper, which would make our
internal communication and deliberative processes less effective;
* if the reports were routinely to be considered eligible for
publication or disclosure under FOIA, the authors would be
considerably more circumspect in the way they drafted their
contributions. The reports need to be candid and honest in order to
adequately fulfil their objective in keeping the Management Board
properly informed, which is essential to the running of the ICO; and
* parties external to the ICO would be less willing to engage with the
ICO fully and frankly if their contributions were likely to be
published via any commentary presented within the Information Rights
reports. This could lead to a reduction in information and
intelligence available to the ICO, or a reluctance for bodies to
approach, or engage with, the ICO on matters where the ICO should be
directly involved under its remit as regulator of the information
acts.
 

It is also necessary to consider the prejudice or harm that disclosure may
cause, and its likelihood. It is important to remember that a disclosure
under FOIA is to the world at large rather than to the requester and this
is an important factor when looking at the prejudice or harm that could be
caused by the release of this information. It is possible that disclosure
of the withheld information could be used to disrupt, influence or
otherwise prejudice ongoing discussions and negotiations which the ICO is
engaged in with external parties, including government and trans-national
bodies.
 
Having considered all of these factors we have taken the decision that the
public interest in withholding the redacted information outweighs the
public interest in disclosing this information. I am sorry, therefore,
that in this instance we are unable to provide you with that information
but I hope that this response is nevertheless of some help to you, and our
reasoning is clear.

If you are dissatisfied with the response you have received 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 Governance
Department at the address below or e-mail
[1][email address]
 
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 the First Contact Team, at the address below or visit the ‘Complaints’
section of our website to make a Freedom of Information Act or
Environmental Information Regulations complaint online.
 
A copy of our review procedure is available [2]here.
 
Yours sincerely
 
Steven Dickinson                 Lead Information Governance Officer
 
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire SK9 5AF.
T. 01625 545676 F. 01625 524510 [3]www.ico.org.uk
 
 
 
 
 
 

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Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF
Tel: 0303 123 1113 Fax: 01625 524 510 Web: www.ico.org.uk

References

Visible links
1. mailto:[email address]
2. http://www.ico.gov.uk/about_us/~/media/d...
3. http://www.ico.org.uk/

Information Commissioner's Office

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31 May 2013

 

Case Reference Number IRQ0495944

 

Dear Ms Cross

thank you for your message, received 00:07 on 31 May.

Our response to your request was sent to you on 30 May, at 17:02.
Technical difficulties external to the ICO have delayed delivery of
emails.

Yours sincerely

Steven Dickinson                 Lead Information Governance Officer
 
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire SK9 5AF.
T. 01625 545676 F. 01625 524510 [1]www.ico.org.uk
 
 

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Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF
Tel: 0303 123 1113 Fax: 01625 524 510 Web: www.ico.org.uk

References

Visible links
1. http://www.ico.org.uk/

P. John left an annotation ()

How unfortunate.

Information Rights Reports withheld on the basis that the public whose rights are so reported do not have the right to read the reports, by the organisation that claims to be an "independent authority set up to uphold information rights".

:o|

Ganesh Sittampalam left an annotation ()

The headers of the email dated 30th May suggest that the delay occurred somewhere before or at gateway-201.energis.gsi.gov.uk, which I think is a standard outgoing gateway for the government as a whole.

Ganesh - WhatDoTheyKnow volunteer

Dear Information Commissioner’s Office,

Thank you for providing one of the documents that I requested, and for your further message explaining the delay in the delivery of that response. I am writing to request an internal review of ICO's handling of my FOI request 'Information Rights Reports'.

You stated that it is the opinion of the Information Commissioner, that disclosure of the information rights reports would be likely to inhibit the free and frank provision of advice and would be likely to inhibit the free and frank exchange of views for the purposes of deliberation, and therefore that the information is exempt from disclosure under the provisions of sections 36(2)(b)(i) and (ii) of FOIA.

You also stated that, more generally, disclosure would be likely to inhibit the effective conduct of public affairs – in this case the ICO’s ability to do its job effectively, and therefore is also exempt under the provisions of section 36(2)(c).

Upon deciding that these exemptions were engaged, you performed a public interest test and concluded that the public interest favoured this information being withheld.

I am requesting an internal review because I believe that you have failed to consider all the relevant factors in favour of disclosure and instead have relied on generic arguments in favour of transparency. I believe that you have given insufficient weight to the factors in favour of disclosure that you did identify and have given too much weight to the factors that you state are in favour of withholding the information. I further believe that some of the factors that you have identified in favour of withholding the information do not apply to the information that I requested.

You stated that: “if the reports were routinely to be considered eligible for publication or disclosure under FOIA, the authors would be considerably more circumspect in the way they drafted their contributions. “

Information Rights committee reports are covered by the ICO’s Freedom of Information Publication Scheme and have been proactively in the past. A number are available to read on the ICO website including:

* May 2011: http://www.ico.org.uk/about_us/boards_co...
* July 2011: http://www.ico.org.uk/about_us/boards_co...
* November 2011: http://www.ico.org.uk/about_us/boards_co...
* January 2012: http://www.ico.org.uk/about_us/boards_co...

In respect of more recent reports, the Commissioner’s website states only that “at the time of the meeting the document was not for publication.” There is nothing to suggest that these reports will not be published at a later date, or that more timely proactive publication of subsequent reports will not resume.

It is clear that these reports have in fact been routinely considered eligible for publication or disclosure under FOIA in the past. It is reasonable to contend that the authors of the reports, who are all employees of the public body charged with upholding information rights, would be aware of the past publication of the reports and that they will already anticipate that these reports may be published in future, given that these documents continue to form part of the ICO publication scheme.

You further argued that if this information were to be published, then: “the authors would be considerably more circumspect in the way they drafted their contributions. The reports need to be candid and honest in order to adequately fulfil their objective in keeping the Management Board properly informed, which is essential to the running of the ICO.” and “disclosure would lead to a profound chilling effect. ICO contributors would be reluctant to put thoughts on paper, which would make our internal communication and deliberative processes less effective”.

I believe that there is no evidence that ICO employees were any less “candid” or “honest” then otherwise might have been the case during the period when these reports were proactively published in a timely manner. Civil servants and other public officials charged with giving advice are expected to be impartial and robust in discharging their responsibilities and should not be deterred from expressing their views by the possibility of future disclosure.

Given the above, the ICO was wrong to argue that withholding the latest reports would or would be likely to result in a future lack of candour from employees or that the knowledge that they might be published would or would be likely to cause a “chilling effect.”

Given the inclusion of these documents within your publication scheme and the prior proactive publication of this information, I would also like you to consider whether the blanket use of the s36 exemption to apply to all information is warranted in this case. I believe that the reports may contain fairly generic information such as subheadings and the names of the ICO staff members who are taking responsibility for looking at particular issues. The reports may also contain summaries of information already in the public domain such as recent tribunal judgements and Government reports as well as statistical information about the ICO’s activities. This is sort of information is routinely made available by the ICO and as such, it is hard to envisage any potential prejudice arising from the release of this kind of information.

With regards to the public interest arguments advanced by the Commissioner in favour of disclosure, I would ask that the following additional factors also be considered:
* The strong public interest in ensuring citizens are confident that decisions made by the ICO are taken on the basis of the best available information and that the Management Board are being made aware of all the issues relating to information rights that the Commissioner faces.

* Disclosure of Information Rights Reports would better enable individuals to understand decisions made by the ICO affecting their lives and assisting individuals in challenging those decisions where appropriate.

* Open policy making may lead to increased trust and engagement between members of the public and other stakeholders and the ICO.

* The expectation that the arguments relating to a debate taking place within the ICO will be disclosable will in fact improve the quality of the arguments put forward by ICO staff.

* Far from inhibiting the frank provision of advice, as the ICO has suggested there will be circumstances where the prospect of disclosure will enhance the quality of advice.

* Disclosure of information about the ICO’s policy making will result in improved responses to new ICO policy initiatives and the work of the ICO may be improved as a result.

* More open policy making can result in better policy formulation. A wider range of views and opinions, including expert knowledge, may be canvassed.

* The release of Information Rights Reports will bring to light threats to the security of personal information (including medical and financial records) and better enable individuals to take steps to protect themselves, whilst being reassured that the ICO is taking these issues seriously.

A full history of my FOI request and all correspondence is available on the Internet at this address:
http://www.whatdotheyknow.com/request/in...

Yours faithfully,

Helen Cross

Information Commissioner's Office

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5 June 2013

 

Case Reference Number RCC0499936

 

Dear Ms Cross

Thank you for your correspondence dated 2 June 2013.
 
This correspondence will now be treated as a request for an internal
review of the response we provided to your recent request for information
under the Freedom of Information Act 2000.
 
We will aim to respond by 28 June which is 20 working days from the day
after we received your recent correspondence. This is in accordance with
our internal review procedures which were provided with our response.
 
Yours sincerely

Steven Dickinson                 Lead Information Governance Officer
 
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire SK9 5AF.
T. 01625 545676 F. 01625 524510 [1]www.ico.org.uk
 

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Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF
Tel: 0303 123 1113 Fax: 01625 524 510 Web: www.ico.org.uk

References

Visible links
1. http://www.ico.org.uk/

Information Commissioner's Office

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25 June 2013

 

Case Reference Number RCC0499936

Internal Review

In our 5 June acknowledgement of your request for an internal review, we
indicated our intention to respond by 28 June, this being 20 working days
from our receipt of your request for an internal review. Unfortunately, it
appears unlikely that we will be able to meet this timescale and our
response will be delayed.

The ICO’s guidance on the conduct of internal reviews indicates that,
while there is no statutory time for compliance in the case of FOI
requests, where an internal review is offered, a public authority should
“ensure the review takes no longer than 20 working days in most cases, or
40 in exceptional circumstances” see:

[1]http://www.ico.org.uk/for_organisations/...

(page 51 refers).

While we make every effort to comply with this 20 working day timescale,
there are occasionally exceptional circumstances which mean this timescale
cannot be met. We consider that exceptional circumstances apply in the
present case and, unfortunately, this means we will be unable to provide
our response by 28 June. We hope to be able to provide our response
shortly, however, and in any event within the 40 working days provided for
in our guidance.

Please accept our apologies for any inconvenience this may cause.

Yours sincerely
 
 
Steven Dickinson                 Lead Information Governance Officer
 
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire SK9 5AF.
T. 01625 545676 F. 01625 524510 [2]www.ico.org.uk
 
 
 

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Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF
Tel: 0303 123 1113 Fax: 01625 524 510 Web: www.ico.org.uk

References

Visible links
1. http://www.ico.org.uk/for_organisations/...
2. http://www.ico.org.uk/

Information Commissioner's Office

1 Attachment

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18 July 2013

 

Case Reference Number RCC0499936

 

Dear Ms Cross

 
Thank you for your email dated 2 June 2013 in which you sought an internal
review of our refusal to provide copies of the Information Rights Reports
submitted to Management Board dated 22 April 2013, 21 January 2013 and 29
October 2012. I am sorry for the delay in responding to you with the
outcome of my review.
 
In summary, I have found that a considerable amount of the information
should have been disclosed but with a number of redactions. For the
reasons explained below, section 36(2)(b)(i) has been found to apply to
some information within the reports. I have also concluded that a small
amount of information should have been withheld under section 30(1)(a)(ii)
because it relates to live investigations being carried out by the ICO.
Where the exemptions in sections 30 and 36 apply the public interest
favours maintaining the exemptions. Finally I have concluded that the
section 40(2) exemption applies to some information which provides details
of individuals prosecuted or given a caution for offences under the Data
Protection Act 1998 (DPA).
 
Please find enclosed copies of the three reports with the redactions
marked as appropriate. Due to the large file sizes, these will be sent as
three separate emails. Redactions under sections 30(1)(a)(ii) and 40(2)
have been marked (s30) or (s40) respectively, in the adjacent margin. All
other redactions can be assumed to have been applied in respect of the
exemption at section 36(2)(b)(i).
 
Section 36(2)(b)(i)
 
As you know the ICO initially refused to disclose any of the reports on
the basis that, in the Commissioner’s opinion (in his capacity as the
qualified person), the section 36 exemptions applied.  I have considered
all of the points in your request for an internal review together with the
content of the withheld information and associated paperwork detailing how
the request was initially handled.
 
In my view some important information was not provided to the Commissioner
when he reached his initial opinion regarding section 36. In view of this
I have provided a revised submission to the Commissioner and he has
reviewed his opinion. He has now concluded that significant elements of
the reports can be disclosed. However, he is also satisfied that there are
some elements which are exempt under section 36(2)(b)(i).
 
In the Commissioner’s opinion, some information within the reports which
details the content of discussions between the ICO and its external
stakeholders would be likely to harm the free and frank provision of
advice if it were disclosed. He is satisfied that, if details of
discussions which were particularly free and frank, about a sensitive
issue and/or took place in a particularly sensitive context were
disclosed, external stakeholders would be less forthcoming or willing to
co-operate with the ICO in future. Stakeholders engage with the ICO about
information rights issues on a regular basis. This often involves
providing substantial amounts of detail about proposed activities that are
in the early stages of development and where there are commercial
sensitivities involved. Those stakeholders are unlikely to continue to
provide such information if the details and substance of the advice being
sought were disclosed.  This, in turn, would be likely to reduce the free,
frank and full advice that we were able to provide regarding information
rights issues.
 
Where the Commissioner has concluded that the section 36(2)(b)(i)
exemption applies I have also considered the public interest test. In your
request for an internal review you suggested that insufficient weight had
been given to some public interest arguments in favour of disclosure.
Having reviewed the information that the Commissioner has now found to be
exempt I consider that the following arguments you mentioned are relevant:
 
 

* Open policy making leading to increased trust and engagement between
members of the public, other stakeholders and the ICO.

 
 

* Disclosure of Information Rights Reports would better enable
individuals to understand decisions made by the ICO affecting their
lives and assisting individuals in challenging those decisions where
appropriate.

 
 

* More open policy making can result in better policy formulation. A
wider range of views and opinions, including expert knowledge, may be
canvassed.

 
I accept that these arguments are relevant and should be given weight. The
withheld sections of the reports would provide the public with detailed
information about a wide range of proposals and initiatives that affect
them and about which the ICO’s input and advice has been sought. It would
reassure the public that the ICO is being consulted in appropriate
circumstances and that it is providing advice to ensure compliance with
information rights legislation.
 
On the other hand, there is a significant public interest in ensuring that
the ICO is able to maintain relationships and trusts with external
stakeholders so that they are willing to share sensitive information in
order to inform the advice that we provide. Stakeholders need to continue
to share sensitive information with the ICO so that we can provide advice
about information rights legislation and any action they may need to take
to ensure that their activities or proposals are compliant. This in turn
protects personal data and the public’s information rights.
 
Whilst there may be some instances in which we could compel the provision
of information this will not always be the case and, in any event, it is
more efficient and effective to maintain positive relationships and
voluntary co-operation.
 
In this instance I am satisfied that if the information falling within
section 36(2)(b)(i) were disclosed the harm to the free and frank
provision of advice would be extensive and severe. In these circumstances
my view is that the public interest in favour of maintaining the exemption
outweighs the public interest in disclosure.
 
Section 30(1)(c)
 
The October 2012 report contains a small amount of information held for
the purposes of criminal proceedings that the Commissioner has the power
to conduct. I have reviewed the content and discussed the matter with the
head of our enforcement department and I am satisfied that disclosure at
the time of the request would have been likely to harm the ongoing
criminal proceedings. The information contains details of the nature of
the alleged offences, descriptions of evidence and free and frank comments
about how the case is likely to proceed.
 
I have considered the public interest test and in my view the following
arguments in favour of disclosure are relevant:
 
 

* it would increase transparency and accountability in relation to the
ICO’s actions in this particular enforcement case;

 
 

* it would inform the public about the ICO’s decisions about the
allocation of its enforcement resources;

 
 

* it would further the public’s understanding of the process surrounding
such investigations and proceedings and provide an insight into the
work required to bring such a prosecution;

 
 

* it would reassure the public that the ICO is taking appropriate action
where there is evidence of a breach of the DPA.

 
The arguments in favour of maintaining the exemption are as follows:
 
 

* The ICO requires a safe space in which to conduct the criminal
proceedings and to make decisions about how to present and manage the
case.

 
 

* Those accused of committing offences have a right to a fair trial and
premature disclosure of details central to the prosecution is likely
to undermine this.

 
 

* There is a public interest in preserving the criminal court as the
sole forum for determining guilt.

 
Having reviewed the information and taken into account the fact that the
proceedings were ongoing at the time of the request I have concluded that
the public interest arguments in favour of maintaining the exemption
deserve significant weight. Furthermore, in the circumstances of this
case, they outweigh the arguments in favour of disclosure.
 
Section 40(2)
 
I have also concluded that it is necessary to withhold some information
from within the enforcement section of the reports under section 40(2).
This is on the basis that it is sensitive personal data of individuals
prosecuted under the DPA and disclosure would breach the first data
protection principle. This means that information must be processed fairly
and lawfully and not unless one of the conditions in schedule 2 is
satisfied. In the case of sensitive personal data a condition in schedule
3 must also be met.  
 
The ICO website includes press releases that provide a significant amount
of detail regarding prosecutions. However, the issue here is whether
disclosure of the same information in response to an FOI request would
breach the first data protection principle. Arguably the data subjects may
have an expectation that the information would be disclosed, particularly
given the relatively small amount of time between the date of the
prosecutions and the reports. I also recognise that it is unlikely that
the individuals are likely to suffer any further damage or distress given
that the information has already entered the public domain. Therefore it
may arguably be fair to disclose the information in these circumstances.
 
However, when processing sensitive personal data it is necessary to comply
with one of the conditions in schedule 3 of the DPA. Whilst there are
conditions that can be satisfied when the ICO issues the aforementioned
press releases this is not the case when considering disclosure in
response to a FOI request. When considering disclosures in response to FOI
requests the Commissioner’s view is that the only conditions that will be
relevant are condition 1 (the data subject has consented) or condition 5
(the information has been made public as a result of steps deliberately
taken by the data subject). In this case neither of these conditions is
satisfied and therefore disclosure would breach the first data protection
principle because none of the schedule 3 conditions has been met.
 
If you are dissatisfied with the outcome of the review you may make a
section 50 complaint to the ICO. 

How to complain

Information on how to complain is available on the ICO website at:
[1]http://www.ico.gov.uk/complaints/freedom...
By post: If your supporting evidence is in hard copy, you can fill in the
Word version of our complaint form, print it out and post it to us with
your supporting evidence. A printable Freedom of Information Act
complaints form is available from the ICO website. Please send to:
Case Reception Unit
First Contact Team
Information Commissioner's Office, Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF

By email: If all your supporting evidence is available electronically, you
can fill in our online complaint form. Important: information included in
the form, and any supporting evidence will be sent to us by email.

Yours sincerely
 
Jo Pedder
Group Manager – Policy Delivery 
 
 
 

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Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF
Tel: 0303 123 1113 Fax: 01625 524 510 Web: www.ico.org.uk

References

Visible links
1. http://www.ico.gov.uk/complaints/freedom...

Information Commissioner's Office

1 Attachment

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18 July 2013

 

Case Reference Number RCC0499936

 

Dear Ms Cross

document 2 of 3 attached

Yours sincerely
 
Jo Pedder
Group Manager – Policy Delivery
 

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Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF
Tel: 0303 123 1113 Fax: 01625 524 510 Web: www.ico.org.uk

Information Commissioner's Office

1 Attachment

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18 July 2013

 

Case Reference Number RCC0499936

 

Dear Ms Cross

document 3 of 3 attached

Yours sincerely
 
Jo Pedder
Group Manager – Policy Delivery

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Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF
Tel: 0303 123 1113 Fax: 01625 524 510 Web: www.ico.org.uk