Dear Department of Health and Social Care,

On 21 July 2021 a meeting of the UK CMOs took place in which the shielding policy and the shielded persons list was discussed.

Please provide:
- the agenda and list of papers provided to this meeting;
- the attendee list for this meeting; and
- the minutes of this meeting which include any reference to the shielding policy, the shielded persons list and the potential use of prophylaxis for COVID-19

Please note that the exemption under section 40(2) of the Freedom of Information Act does not apply for any person above band 9, nor for any deputy director or higher.

Yours faithfully

Louise Bicknell

Dear Sirs,

Freedom of Information Request Reference FOI-1458915, FOI-1458916 and FOI- 1458833

Thank you for your response of 10 July 2023 in which you advise me that the DHSC holds information relevant to my three requests, however DHSC is refusing to provide this information as it believes that these requests are vexatious. Please can the DHSC treat this response as a request for internal review of this response.

The DHSC refusal is lengthy and provides many reasons to substantiate its decision that the three requests are vexatious. Given this, my response has to be complete and is therefore a detailed lengthy response. To aide review I have divided it into the following sections:

I. Main grounds for refusal of the three requests;
II. Previous substantially similar requests;
III. The number of my FOIA requests;
IV. The potential for my requests to cause a disproportionate or unjustified level of disruption, irritation and distress, meaning that DHSC has had to take staff members who were in the Antivirals and Therapeutics Taskforce off other work to answer my persistent queries which is detrimental to Department work, divided by:
A. The three requests subject to this response which are stated by DHSC to be vexatious; and
B. Current FOIAs outstanding with DHSC at at the date of its response;
V. Further points made by the DHSC on the public interest;
VI. Impact of the Independent Inquiry on this request;
VII. DHSC conclusion; and
VIII. My Conclusion.

To avoid duplication the information below includes reference to whether advice and assistance was provided by DHSC where relevant.

I should point out that since the time of the DHSC response of 10 July the outstanding FOIAs have all been responded to by the DHSC and one is considered closed. This detail is referenced in IV. B below.

I. THE MAIN GROUNDS ON WHICH THIS REFUSAL IS MADE IS ON THE BASIS THAT THESE THREE REQUESTS (WHICH DHSC HAS LINKED TOGETHER) ARE SUBSTANTIALLY SIMILAR TO PREVIOUS REQUESTS. AS I EXPLAIN BELOW, THAT IS CLEARLY NOT THE CASE.

Please note that the requests the DHSC are treating together in its response are three specific stand alone requests asking for:
1. details of the revised process for checking responses to Parliamentary Questions and the six original answers that were approved (four of which were subsequently stated in Parliament to have been incorrectly simplified before publication);
2. details of which senior individuals from the UKHSA and the Antivirals and Therapeutics Taskforce attended or received the results of the Expert Working Group meeting of 19 May 2022; and
3. the agenda and minutes of the UK CMO’s meeting of July 2021 where they discussed the shielding policy.

I will deal with each in turn:

1. In respect of the request for details of the revised process for checking responses to Parliamentary Questions and the six original answers that were approved (four of which were subsequently stated in Parliament to have been incorrectly simplified before publication).

I have made two previous requests that can be said to be connected to this request.

The first was on 7 October 2022. I asked for the procedure document(s) and other related documents so that I could understand the way that the DHSC prepares the written answers to written parliamentary questions. This was answered on 4 November 2022 and two templates, a flow chart and a guidance document were provided.

The second was on 15 March 2023. I asked for the detail of the backing papers for six written parliamentary answers that were published on the Parliamentary website between 25 May 2022 and 4 July 2022. These represented a sample of four that had all been the subject of correction and a further two that still appeared misleading. Some of this information was provided by the DHSC in its first response on 26 May 2023, but only following the intervention of the Information Commissioner’s Office. On 4 July 2023, I wrote to the DHSC asking for internal review of the decision not to provide the answer to the question on the form “is this PQ controversial (and why/why not?)” for each of the six parliamentary answers.

Since DHSC’s response of 10 July the DHSC’s independent internal reviewer concluded on 23 August that “After careful consideration, I have concluded that the response you received to your FOI request was not compliant with the requirements of the FOIA.”

The DHSC will understand that following the written correction by the Minister of State on 17 April 2023 to the 13 parliamentary answers provided over the course of four weeks, the reason given for the correction was that:

“in simplifying the technical language, the responses to these PQs incorrectly indicated that testing was ongoing. During June, the UK Health Security Agency carried out isolation and characterisation of the BA.4 Omicron variant in preparation for testing it against various compounds, which could potentially have included Evusheld. However, in PQ responses, these activities were incorrectly interpreted as testing and the language was simplified.” … “The department takes its responsibility for parliamentary accountability very seriously and has reviewed and amended the process for checking responses to Parliamentary Questions to ensure future accuracy.“

I am therefore asking for this information to try to understand:
• how the DHSC procedures/guidance document(s) that I was provided with in November 2022 had been changed; and
• what actual correction was made to the original approved answers.

Therefore, as DHSC has told Parliament that it had revised its processes after the date of my earlier request, it cannot be vexatious for me to ask to see this revised document, as it did not exist previously. Nor can it be vexatious for me to ask to see the original approved answer from the DHSC’s systems.

2. details of which senior individuals from the UKHSA and the Antivirals and Therapeutics Taskforce attended or received the results of the Expert Working Group meeting of 19 May 2022

I have never asked the DHSC for this information before, therefore how can it be vexatious to ask for it for the first time?

3. details of the agenda and minutes of the UK CMO’s meeting of July 2021 where they discussed the shielding policy

I have made one request that is directly related to this. On 4 December 2022 I requested the background paper to the Sajid Javid letter emailed to all people who were advised to shield on 27 September 2021 to understand what had led to the suspension of shielding for vulnerable people. On 31 March 2023 this was provided after an internal review found that the DHSC’s original response was only partially compliant. It was in this document that the reference to the UK CMO meeting of 21 July 2021 (para 23) was found. Given that at that time there were no prophlyaxis, antivirals or nMABs available, l wanted to understand why the UK CMOs decided that they did not need to maintain the shielded persons list and shielding at that time. So, as I mention below, do Blood Cancer UK.

II. PREVIOUS SUBSTANTIALLY SIMILAR REQUESTS

DHSC state that the number of previous requests that I have made are substantially similar. The DHSC are aware from correspondence that a large number of immunocompromised people and their families continue to shield. I am a member of the Forgotten Lives Facebook group with over 2,100 members (who use social media) a large number of whom report that they are in the same position.

It is important for this large group of people who remain at higher risk of hospitalisation or death from COVID (NICE in February 2023 estimated this to be 1.2 million) to understand the decision making around their situation. Especially the approach to prophylactic treatments like Evusheld when this was being made available elsewhere in the world.

All FOIAs that I have made have had the clear, genuine purpose of understanding the events around the DHSC’s advice to Government on shielding and the use of prophylaxis. Obviously as information was obtained through answers being provided, and sometimes through what has been omitted, further questions inevitably arose, as has been the case here. This also happened as time passed and other information became available from elsewhere. The focus of these questions was inevitably to find out about the extensive work of the Antivirals and Therapeutics Taskforce, its related meetings and their structure.

At the beginning of my information gathering work there was limited information in the public domain about the structure of the decision making around prophylaxis. The sheer number of bodies involved in decision making, the complexity of the changing structures and their role was bewildering. Here is the list that I compiled as I read various papers found on the DHSC website (which I tried to search extensively, but also found confusing), in parliamentary answers and that were referred to in papers provided accompanying FOIA responses. To an outsider the numerous bodies involved, with DHSC advising that there was no overview chart explaining their roles being available, appeared to be very confusing:

Antivirals Taskforce Operations Board
Antivirals Taskforce Programme Board
Therapeutics Taskforce Operations Board
Therapeutics Taskforce Programme Board
Antivirals and Therapeutics Taskforce Programme Board
Antivirals and Therapeutics Taskforce Strategy Board
UK COVID-19 Therapeutics Advisory Panel
Prophylaxis Oversight Group
RAPID C-19
UK National Expert Policy Working Group
COVID-19 tixagevimab/cilgavimab (Evusheld) pre-exposure prophylaxis National Expert Group
Therapeutics Clinical Review Panel
Antivirals and Therapeutics Taskforce
Antivirals and Therapeutics Taskforce Engagement Board
COVID-19 nMABs Access and Policy National Expert Group – Evusheld
COVID-19 Neutralising Monoclonal Antibodies (nMABs) and Antivirals Access Independent Advisory Group

The best advice and assistance that DHSC could have provided for all concerned would have been an organisation structure chart for these bodies which they failed to do, despite my request for this.

To try and understand the sequence of events that took place in the decision making in respect of prophylaxis inevitably led to asking questions about these meetings, about which I believe I now have a better understanding. These bodies had changed over time and there was a certain laxity in the use of their titles as some in the list above were subsequently identified as duplicates. Trying to understand these changing structures and when (and where) decisions would be made, without these structures being clear on the DHSC website meant that, sadly, it was inevitable that numerous questions would be asked in seeking to understand these.

I followed all of DHSC’s helpful suggested advice and assistance refinements where they fitted with the course that my inquiry was taking. Obviously, as my inquiries changed over time, some of the suggested follow ups were not necessary. I agree that the DHSC did provide me with links to further resources, many of which I had already found (e.g. the RAPID C-19 and NICE information) but I had considered that the information on the website begged questions rather than provided the answers.

Because of the time it has taken to obtain answers, sometimes having to ask the Information Commissioner’s Office to chase for these, it was inevitable that the emphasis of questions forming part of my inquiry would change overtime.

III. THE NUMBER OF MY FOIA REQUESTS

I do not propose to descend into a blow by blow review of each request and the grounds the DHSC provided for refusal. I have reviewed each response provided in detail and, where refused for what do not appear well founded reasons, I have asked for internal review. The reasons have been challenged by me, as the legislation permits. I have not done so for all refusals from the DHSC, so do not consider that I have raised internal review requests for no good reason.

Of the 16 requests where internal review had been concluded at the date of the DHSC’s response of 10 July 2023, the DHSC independent reviewer had originally found that 5 were partially complaint, 6 were complaint and, for the 5 that were amalgamated together and were referred to the ICO, the DHSC has now agreed that the refusal on costs grounds on 3 of these was unfounded. 2 remain with the ICO for review. Further detail on these is provided at IV. (B) below.

Since the date of the DHSC’s response, as mentioned above, its independent reviewer has found a further refusal to provide information was not compliant with the requirements of the FOIA.

My figures differ from those used by the DHSC, as the DHSC amalgamate initial requests together for some number illustrations and not for others.

In respect of this refusal to provide the information for the current requests under consideration, the number of my FOIA requests per se does not mean that these three requests are themselves vexatious.

IV. THE POTENTIAL FOR MY REQUESTS TO CAUSE A DISPROPORTIONATE OR UNJUSTIFIED LEVEL OF DISRUPTION, IRRITATION AND DISTRESS, MEANING THAT DHSC HAS HAD TO TAKE STAFF MEMBERS WHO WERE IN THE ANTIVIRALS AND THERAPEUTICS TASKFORCE OFF OTHER WORK TO ANSWER MY PERSISTENT QUERIES WHICH IS DETRIMENTAL TO DEPARTMENT WORK

DHSC states that these three requests have the potential to cause a disproportionate or unjustified level of disruption, irritation or distress.

I am at a loss to understand how the three highly specific requests detailed above, which are not duplicative in anyway, can be seen as substantially similar to the others that I have made from 11 June 2022 to 12 June 2023 and therefore cause the DHSC a disproportionate or unjustified level of disruption, irritation or distress. Indeed as I set out at A below, I consider that responding to these should be relatively straightforward.

I am somewhat confused by DHSC’s statement that it would have to expend a disproportionate amount of time and resources to meet its statutory requirements on my requests and will have to take key staff members off other work, that is detrimental to other key departmental work, to answer my persistent queries.

I am not asking DHSC in this request, or any other requests that were still outstanding at the date of its response, for any information about these bodies that would be burdensome. For clarity I set out below in respect of the three requests that are stated to be vexatious in this request for internal review (A) (and also for the remaining 4 outstanding requests at 10 July (B)) why I believe this not to be the case:

A. THE THREE REQUESTS SUBJECT TO THIS RESPONSE WHICH ARE STATED BY DHSC TO BE VEXATIOUS

1. In respect of the request for details of the revised process for checking responses to Parliamentary Questions and the six original answers that were approved (four of which were subsequently stated in Parliament to have been incorrectly simplified before publication).

The revised process for checking responses to Parliamentary Questions - This, I anticipate, would be the new standard DHSC departmental document, which should be readily to hand. So I would anticipate this would be an updated version of the “Written PQs” document that DHSC provided to me on 4 November 2022 which states that “this guidance should be read alongside the cabinet office guidance” “The answers that ministers give are published and read widely and our performance as a Department in answering questions accurately and on time is crucial to our reputation and credibility”.

The four original answers that were approved should be readily available in the background audit trail of the parliamentary answer documents. Indeed, given that the Minister for State issued the correction to written parliamentary answers on 17 April 2023 stating that this mistake had happened and the changing of the text was the reason, this should be readily accessible in a file that members of the DHSC’s staff who prepared Mr Quince’s and Lord Markham’s written correction must have compiled. The same should be true for the two other answers, here I am asking whether they had also been mistakenly corrected before being published

I do not understand how retrieving these pieces of information would need to involve any members of this Taskforce now on other duties, or involve any detriment to the work of the department.

No advice and assistance has been provided by DHSC in respect of this FOIA.

2. details of which senior individuals from the UKHSA and the Antivirals and Therapeutics Taskforce attended or received the results of the Expert Working Group meeting of 19 May 2022;

Again this should be a simple matter of looking at the actual minutes and paperwork (probably one email) on file for this meeting. The only disclosure of who attended the Expert Working Group meeting made to date by the DHSC that I have seen on the ”whatdotheyknow” site are the names of two very senior NHS individuals. One the chair of the Expert Working Group, Professor Anthony Kessel (Clinical Director, National Clinical Policy, NHS England and NHS Improvement) and the other Professor James Palmer (National Medical Director, Specialised Commissioning, NHS England and Improvement). Given the seniority of these people I am not convinced that junior staff would have attended this meeting. I am not asking for the names of all attendees at this meeting, nor all recipients of the results of testing. I am solely asking which members of the UKHSA and the Antivirals and Therapeutics Taskforce, of deputy director status or more senior, attended or received the results of the meeting.

Again, I do not understand how retrieving this specific information would need to involve any members of this Taskforce now on other duties or be detrimental to the work of the department.

No advice and assistance has been provided by DHSC in respect of this FOIA.

3. details of the agenda and minutes of the UK CMO’s meeting of July 2021 where they discussed the shielding policy.

These papers relate not solely to Evusheld, but to understanding the thought processes that lead to shielding advice being moved from mandatory to advisory.

The items requested under the first two bullets should be straight forward to provide – the agendas, the list of papers accompanying and the attendee list. I restricted my request under the third bullet to the minutes of the meeting which include any reference to the shielding policy, the shielded persons list and the potential use of prophylaxis for COVID-19, to enable this to be easily reviewed, given the time that has transpired since the meeting.

For the immunocompromised the “COVID-19; guidance for people whose immune system means they are at higher risk. Updated 14 March 2023” guidance issued by the DHSC is still in effect. This advice is to continue shielding, albeit by another name. The guidance still clearly says “You are advised to try to avoid contact with people who have symptoms of COVID-19 or other respiratory infections. … If you have visitors to your home, consider ventilating your rooms by opening windows and doors to let fresh air in. … Consider asking visitors to your home to take additional precautions, such as keeping their distance. … you may wish to ask visitors to take a lateral flow device (LFD) test before visiting. You might also consider asking them to wear a face covering and you may want to wear a face covering yourself. … when out and about, you may want to try to keep your distance from others…”

Blood Cancer UK in September 2021 said “We’re disappointed shielding has ended, because it sends the wrong message at a time when the infection rate is high and because people with blood cancer need the Government’s support to help them keep safe over the winter. We will continue to make this case.”

Again, I do not understand how retrieving the agenda and this set of minutes would need to involve any members of this Taskforce now on other duties or be detrimental to the work of the department.

No advice and assistance has been provided by DHSC in respect of this FOIA.

B. CURRENT FOIAS OUTSTANDING WITH THE DHSC AS AT THE DATE OF ITS RESPONSE

In respect of my other current FOIAs that are outstanding with the DHSC, which I list below, I cannot see how these key staff members need to be involved, nor that there can be any detrimental effect on key departmental work in providing, what appears to be, straightforward information.

I list those outstanding below:
1. Meeting of the Antivirals and Therapeutics Taskforce Strategy Board on 19 January 2023
2. Meeting of the Antivirals and Therapeutics Taskforce Programme Board 2 February 2023

Both of the above are with the Information Commissioner, but now only in relation to the appropriateness of the withholding of names of the attendees at these important recent meetings. Given the change in course of the focus of my inquiries over the time, I have advised the Information Commissioner’s Office that I am not pursuing any arguments on the public interest aspect of the application of section 35(1)(a) exemption recently cited by the DHSC to replace the initial refusal ground of costs which was upheld at internal review, then subsequently withdrawn by DHSC at the Information Commissioner’s Office level.

DHSC states that I have failed to refine my requests in line with advice given and therefore built a pattern (in the opinion of DHSC) of rejecting advice and assistance and taking an unreasonably entrenched position.

The request initially comprised five different requests for information relating to different bodies. All five were initially refused by DHSC on cost grounds with advice being given by DHSC to reduce the timeframe and number of the requests. I challenged this as I considered that the cost estimates were not accurate or realistic. Following the Information Commissioner’s Office becoming involved the DHSC responded stating that for two of the requests no meetings had taken place in the period I requested and for another only one had occurred, thus indicating that the cost estimates provided were not based on any firm foundation, as they could not have been informed by a proper review of what meetings had actually taken place.

Providing these names should not be detrimental to the work of the department. Indeed, DHSC on 30 August provided a further response providing the minutes with some of the attendees named that I am currently reviewing.

3. Preparation of the COVID-19 Response: Living with COVID-19 by HMG in respect of prophylaxis treatments.

This refers to “the government’s plan for removing the remaining legal restrictions while protecting people most vulnerable to COVID-19 and maintaining resilience”. This was published in February 2022. Here, following advice and assistance provided in DHSC’s helpful response I refined the request in April 2023 to avoid the commercial sensitivity that the DHSC advised would be a hurdle. I am purely asking for “any paper prepared and advice provided on the use of prophylaxis treatments (excluding vaccines) that was considered by HMG … when preparing this plan.”

DHSC provided a partial response on 25 July 2023 following the intervention of the Information Commissioner’s Office, and on 24 August DHSC sent a full and final response including some information from a “Quad briefing” which I am currently reviewing.

Again, how providing this information could have been detrimental to the work of the department, given how restrictive the requested information was, is open to question.

4. Preparation of Parliamentary answers on Evusheld.

At the time of the DHSC response on 10 July 2023, this was with the DHSC as a request for internal review. All information, except the answer to the question “what is the policy context” for six parliamentary answers, was provided. This was withheld on the sole basis of the application of section 35(1)(d) as it relates to the operation of a ministerial private office and the public interest in DHSC’s view favoured it being withheld. I challenged both the basis for this refusal plus the application of the public interest test.

No advice or assistance was provided by DHSC to enable me to refine this request.

As mentioned above, the independent internal review concluded on 23 August that “After careful consideration, I have concluded that the response you received to your FOI request was not compliant with the requirements of the FOIA. The information that was previously withheld under Section 35(1)(d) of the FOIA should have been released.” This was then provided.

This information would have been readily available on the parliamentary answers system and as the other answers to the questions on the form had already been provided this should not have been difficult to provide, nor involve detriment to the work of the department or involved the time of key staff members.

V. FURTHER POINTS MADE BY THE DHSC ON THE PUBLIC INTEREST

I am comforted that the DHSC recognises that there may be a public interest in the information surrounding the Antivirals and Therapeutics Taskforce and decisions relating to the procurement of Evusheld.

DHSC state that the closure of the Taskforce evidences the diminishing public interest in this information, as no further policy decisions are expected to be made by DHSC in relation to Evusheld. NICE has now conducted its appraisal of Evusheld, following its established processes, and concluded that this treatment is not to be made available through the NHS based on current evidence showing a lack of efficacy. Since NICE has now published this guidance DHSC believes that the public interest has been diminished even further and it would be a waste of taxpayer funds to continue to answer these requests.

As evidenced by the details I provide below, I submit that there was and continues to be public interest in the events and decisions surrounding the procurement of Evusheld as well as in the accuracy of written parliamentary answers.

The first sentence in the DHSC’s statement does not make sense, the fact that a Taskforce is closed does not mean that public interest in the subject matter for which it was responsible for ceases.

Decisions are expected on the successor to Evusheld once the clinical trials are completed. Why the earlier decisions were made, and how accurately parliamentary questions were answered in respect of the decision making by the DHSC, remain matters of concern and of public interest to those affected. Indeed many such people to my knowledge were deeply troubled by the decisions made on Evusheld by the DHSC and the length of time taken to make them. Particularly given that almost all other developed nations had taken the opposite approach to the provision of Evusheld.

This is illustrated by the newspapers reporting Dame Kate Bingham’s statements from the last week of July 2023 at the Buxton Literary Festival, as detailed below:

“Dame Kate revealed ministers made an “outrageous” decision forcing up to 500,000 vulnerable people to ‘shield’ when the Omicron variant of Covid was raging in late 2021 – in order to save money. She revealed that Britain was the only leading country not to spend on the treatment (Evusheld), which could have allowed those with severe health conditions to live their lives rather than stay at home. … Dame Kate said that the government changed its mind and decided not to order any of the ‘highly effective’ treatment … She added: ‘Then they (the government) said its cheaper to allow (vulnerable people) to shield at home than it is to give them antibodies. I thought it was completely outrageous.”

The All Party Parliamentary Group on Vulnerable Groups to Pandemics (APPG) continues its work for the immunocompromised. The numerous affected charities continue to raise these matters with the DHSC. Questions on the treatment of the vulnerable continue to be raised in Parliament. Oxford University Science Museum currently has an exhibition called “Coming together through COVID” which has a dedicated section on the treatment of the clinically vulnerable to COVID. In addition, the public interest in the veracity of answers to parliamentary questions can never diminish.

VI. IMPACT OF THE INDEPENDENT INQUIRY ON THIS REQUEST

The DHSC appears to state that because it is cooperating fully with the independent public inquiry, at which the work of the Taskforce is expected to be scrutinised, which will lead to documents being published in due course that this is a reason to not provide this requested information at this stage in response to these three requests.

The public inquiry and its extensive broad lines of inquiry that “befit an inquiry into an event of this magnitude” are welcomed. The Inquiry Chair recognises that there are many still suffering from the decisions made in the pandemic. Those still suffering, it will be submitted in module 4, will be the immunocompromised and their families.

I am unaware that the fact of giving information to a public inquiry is an exemption from the provision of information under the Freedom of Information Act. If anything, the preparing of such paperwork, with the consequent indexing of such documents into a database, should make them easier to locate and less onerous to provide.

VII. DHSC CONCLUSION

The DHSC concludes stating again that these requests are a burden and that the motivation behind these three requests is personal and does not benefit the public as a whole. Obviously for all the reasons stated above I totally disagree.

I refer to the public statements below, which are a small sample of many that demonstrate the genuine public interest in the matters that I am investigating and the wider public benefit from these outstanding requests.

Bob Blackman MP, co-chair of the APPG on Vulnerable Groups to Pandemics said in February this year that:

“The Government have disenfranchised a whole group of vulnerable people and put them outside of the NHS provision for protection against Covid-19. I am disappointed that this has not yet been rectified for situations of serious national health crises. Addressing this disparity and inequality of protective provision is long overdue.

Our constituents have also been vocal in raising this issue with us, their representatives. The effects of the threat of infection and its consequences are serious for them and also for their families. We need a minister steering through proper policies to acknowledge these failings and make sure a plan is in place.”

Lord Mendelsohn the other co-chair of the APPG said, again in February this year:
“The terrible toll of Covid-19 on the immunocompromised and the immunosuppressed is a tragic indictment of this Government’s failures. There remains a vulnerable group of half a million people who cannot “live with” Covid but do live with the fear of its extreme consequences for them.

These families have been subjected to one bad decision after the other which has caused real harm including loss of life and loss of quality of life, as well as significant economic impact. We need urgent answers on how this group can be protected from the life threatening effects of Covid-19. Taking ministerial responsibility for vulnerable groups will show that the Government has learnt its lesson and will take the protection of this group seriously.”

The APPG website concludes that “Policies to protect and support this community need oversight and accountability at the highest level, and the system that prevents treatments being made available quickly needs to be clarified. The Government should ensure that the voices of the vulnerable are heard, their lives are valued, and that they receive equality of healthcare provision.”

VIII. MY CONCLUSION

To conclude, every request that I have made has had a serious purpose, to understand the decisions made by the DHSC. Without having the transparency in respect of this information, the DHSC may (potentially incorrectly) be seen as having adversely affected the lives of many thousands of people. I am seeking to understand why these decisions were made and to place this information in the public domain for the benefit of all inquirers.

The DHSC appears to me to have mischaracterised the past history of my requests to bolster an argument that my motivation is somehow improper or unduly burdensome. They use this to refuse these three requests as vexatious out of hand, giving undue weight to these past (perfectly proper) requests and referring to my taking an unreasonably entrenched position, rather than considering what information is actually being requested in the requests which are subject to this internal review request. None of these requests arise from a failure by me to follow any advice and assistance given on refinement of any questions.

From the standpoint of the immunocompromised and their families the requests are not disproportionate, manifestly unreasonable, inappropriate or improper.

I look forward to receiving the outcome of the independent internal review.

Yours faithfully

Louise Bicknell

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