Thank you for contacting the Office of the Registrar of Consultant
Lobbyists.  Your email is important to us so we will respond as soon as
possible.

In the meantime you may wish to click [1]here to visit our website for
further information including access to the latest guidance.

Many thanks,
 
Office of the Registrar of Consultant Lobbyists

1 Horse Guards Road (Room 3.26)
London, SW1A 2HQ
t: 020 7271 8827
e: [2][Registrar of Consultant Lobbyists request email]
w: [3]registrarofconsultantlobbyists.org.uk

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Office of the Registrar of Consultant Lobbyists
1 Horse Guards Road (Room 3.26)
London, SW1A 2HQ
t: 020 7271 8827
e: [4][Registrar of Consultant Lobbyists request email]
w: [5]registrarofconsultantlobbyists.org.uk

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Dear Mr Dolan,

Thank you for your request for information, received by the Office on 14
January 2019.  This request is being treated under the terms of the
Freedom of Information Act 2000 (‘the FoI Act’). Your request was as
follows:

"Please could you provide me with all documents and correspondences
relating to the Registrar's investigation into the Institute of Economic
Affairs."

The information you have requested is exempt under section 31(1)(a) and
also (g) (in relation to section 31(2)(a)) of the FoI Act. The relevant
parts of section 31 exempt information if its disclosure would prejudice
the prevention or detection of crime, or the exercise by any public
authority of its functions for the purpose of ascertaining whether any
person has failed to comply with the law.

All information we hold relating to the Institute of Economic Affairs
concerns an investigation by the Registrar as to whether that organisation
had complied with the requirements of the Transparency of Lobbying [etc]
Act 2014 as regards registration of consultant lobbying activity: a
failure to comply being an offence under that Act. The information
contains details about the investigation that would assist the avoidance
of detection by anyone prospectively seeking to avoid complying with the
statutory requirements.

The information also contains details provided in confidence by a number
of individuals during the investigation. Disclosure of this information
would make it easier to hide deliberate non-compliance with the
legislation and/or make it less likely that individuals would provide full
information to the Registrar during an investigation. In either case it
would reduce the effectiveness of the Registrar in detecting instances of
non-compliance with the law.

The exemption in section 31 is a qualified exemption and the Registrar has
considered whether the balance of the public interest favours releasing or
withholding this information. There is a general public interest in
disclosure of information and the Registrar recognises the general
principle that openness in a public body may increase public trust in and
engagement with that body. The Registrar also recognises a more specific
public interest in assuring the public that effective arrangements are in
place for the prevention and detection of the offence of unregistered
consultant lobbying.

The Registrar has weighed these public interests against a strong public
interest in the practical effectiveness of the processes employed to
prevent and detect unregistered consultant lobbying. It is contrary to
this public interest to disclose information that would facilitate
non-compliance or hinder its detection. Taking into account all the
circumstances of this case, the Registrar has concluded that the balance
of the public interest favours withholding this information.

If you have any questions about the content of this reply, please contact
me direct, using the contact details below. If you are not content with
this response, you may make a complaint to the Information Commissioner.
Details of how to do so are set out on the website of the Information
Commissioner’s Office: [1]https://ico.org.uk/make-a-complaint/
Yours sincerely,
Tony Bellringer
Head of Office
Office of the Registrar of Consultant Lobbyists
1 Horse Guards Road (Room 3.26)
London, SW1A 2HQ
t: 020 7271 8827
e: [2][Registrar of Consultant Lobbyists request email]
w: [3]registrarofconsultantlobbyists.org.uk

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