The difference between data and metadata

Jt Oakley 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 successful.

I am writing to make an open government request for all the
information to which I am entitled under the Freedom of Information Act 2000.

Title of request within scope.

::

Please send me recorded information, which includes information
held on computers, in emails and in printed or handwritten
documents as well as images, video and audio recordings.

If this request is too wide or unclear, and you require a
clarification, I would be grateful if you could contact me as I
understand that under the Act, you are required to advise and
assist requesters.(Section 16 / Regulation 9).

If my request is denied in whole or in part, I ask that you justify
all deletions by reference to specific exemptions of the act. I
will also expect you to release all non-exempt material. I reserve
the right to appeal your decision to withhold any information or to
charge excessive fees.

If any of this information is already in the public domain, please
can you direct me to it, with page references and URLs if
necessary.

Please confirm or deny whether the requested information is held ( section (Section 1(1)(a) and consider whether information should be provided under section 1(1)(b), or whether it is subject to an exemption in Part II of the Act.

If the release of any of this information is prohibited on the
grounds of breach of confidence, I ask that you supply me with
copies of the confidentiality agreement and remind you that
information should not be treated as confidential if such an
agreement has not been signed.

I would like the above information to be provided to me as
electronic copies, via WDTK. The information should be immediately readable - and, as a freedom of Information request, not put in a PDF or any closed form, which some readers may not be able to access.

I understand that you are required to respond to my request within
the 20 working days after you receive this letter. I would be
grateful if you could confirm in writing that you have received
this request.

::::::::

Please consider the ICO's Decision on the provision original documents on file, rather than newly written letters of response.
https://ico.org.uk/media/action-weve-tak...

Nb This request does not require a letter, drafted by the external affairs department after the date of request, or any other written input by reputational defence employees, purporting to be the response to a FOIA request.

===

Please supply data held on record describing the difference between data and metadata.

It appears that there is confusion as to the difference between the two - and therefore it would be of public assistance to supply the information.

::

My own interpretation dovetails with this explanation:

https://techdifferences.com/difference-b...

I have been told by a public body that I am incorrect in assuming so.

If any light can be thrown on why I am wrong - according to the legal and in-house ICO interpretation - I would be grateful to know why.

I hope this will be an assistance to members of the public making future requests.

===

Yours faithfully,

JtOakley

AccessICOinformation, Information Commissioner's Office

Thank you for contacting the Information Commissioner’s Office. We confirm
that we have received your correspondence.

If you have made a request for information held by the ICO we will contact
you as soon as possible if we need any further information to enable us to
answer your request. If we don't need any further information we will
respond to you within our published, and statutory, service levels. For
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If you have raised a new information rights concern - we aim to send you
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If you are concerned about the way an organisation is handling your
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Yours sincerely

The Information Commissioner’s Office

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Information Commissioner's Office

11 July 2018

 

Case Reference Number IRQ0761677

 

Dear J T Oakley

 
We are now ready to respond to your request for information to the
Information Commissioner’s Office (ICO) which we received on 29 June.
 
We have considered your request under the Freedom of Information Act 2000.
 
Your request
 
“Please supply data held on record describing the difference between data
and metadata.”
 
Our response 
 
After searching all available systems and liaising with colleagues, I can
confirm that we do not hold any information within the scope of your
request.
 
That is to say, the ICO does not hold a document which describes the
difference between data and metadata.
 
***
 
By way of advice and assistance, we are aware of a number of documents,
accessible by other means, which mention or define data and metadata; but
these are either not produced by the ICO or are not directly relevant to
your request.
 
They are as follows:
 
The [1]General Data Protection Regulations (GDPR) defines personal data
as:
 
“any information relating to an identified or identifiable natural person
(‘data subject’); an identifiable natural person is one who can be
identified, directly or indirectly, in particular by reference to an
identifier such as a name, an identification number, location data, an
online identifier or to one or more factors specific to the physical,
physiological, genetic, mental, economic, cultural or social identity of
that natural person.”
 
The [2]Lord Chancellor's Code of Practice on the Management of Records
Issued under Section 46 of the Freedom of Information Act contains the
following definition of metadata:
 
“Information about the context within which records were created, their
structure and how they have been managed over time. Metadata can refer to
records within digital systems, for example event log data. It can also
refer to systems such as paper files that are controlled either from a
digital system or by a register or card index, for example the title and
location.”
 
 
The ICO’s [3]Guidance on Cloud Computing states that:
 
“‘metadata’ may also be personal data in certain circumstances.”
 
In terms of the practicalities of responding to subject access requests
(SARs) we would say that, as defined in the above quoted GDPR, any data
relating to an identifiable natural person should be considered within
scope of an information request. However, there is no requirement to
supply copies of metadata in response to a SAR if the metadata only
contains information which has already been provided to the requestor.
       
Next steps
 
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 Access team
at the address below or email [4][ICO request email]
 
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 Customer Contact department, 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 [5]here.
 
For information about what we do with personal data see our [6]privacy
notice.
 
Yours sincerely,
 
 

Frederick Aspbury
Lead Information Access Officer
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire SK9 5AF
T. 0330 414 6397 F. 01625 524510  [7]ico.org.uk  [8]twitter.com/iconews
Please consider the environment before printing this email
For information about what we do with personal data see our [9]privacy
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References

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Dear Information Commissioner’s Office,
INTERNAL REVIEW

Thank you.

But I am somewhat surprised that the ICO has no employee guidance in the difference between metadata and data, since a recent complaint was turned down on the metadata alone.

- An established linked piece of data with the subject’s own telephone number.

Therefore it is important to know why a subject’s linked data is determined as metadata, rather than data.

==

If employees are not able to determine the difference between the two terms, how can they make valid Decisions between the two - without giving any explanation of the distinction ?

Surely they must have some reference in record, to determine metadata as different from data, as it would leave all ICO decisions - referencing the singular ‘data’ / or ‘metadata’ terms alone - as potentially incorrect?

==

In addition, I can see from my requests that the ICO initially only gives data in response to a SAR request.
Metadata is only produced within a SAR response - if the requester specifically mentions it.

And even though the requester might be legally due to receive it.

Because, if the requester specifies that the *metadata is missing ( *a term which requesters might be unaware) an entirely ADDITIONAl set of information is given to the requester.

Therefore I would ask you to find the recorded distinction between the two, which must lie on ICO records ( possibly guidance to those processing SAR requests) as this TWO-TIER SAR response system simply would not occur if the distinction is not understood by ICO employees.

Please therefore search for guidance to employees which enables this TWO-TIER SAR Request system.

==

PUBLIC INTEREST

I would state that it is in public interest to know why the ICO is excluding metadata from initial responses to SAR requests, even though they might be legally entitled to it.

Unless the requester makes it plain that they request the metadata, which, as you have indicated, can be part of the SAR response.

And to know how the ICO makes its distinction known to SAR caseworkers, who are processing requests by this two-tier system.

Logically guidance to caseworkers must exist to operate this TWO-TIER system.

Therefore please search again.

Yours faithfully,

Jt Oakley

AccessICOinformation, Information Commissioner's Office

Thank you for contacting the Information Commissioner’s Office. We confirm
that we have received your correspondence.

If you have made a request for information held by the ICO we will contact
you as soon as possible if we need any further information to enable us to
answer your request. If we don't need any further information we will
respond to you within our published, and statutory, service levels. For
more information please visit [1]http://ico.org.uk/about_us/how_we_comply

If you have raised a new information rights concern - we aim to send you
an initial response and case reference number within 30 days.

If you are concerned about the way an organisation is handling your
personal information, we will not usually look into it unless you have
raised it with the organisation first. For more information please see our
webpage ‘raising a concern with an organisation’ (go to our homepage and
follow the link ‘for the public’). You can also call the number below.

If you have requested advice - we aim to respond within 14 days. 

If your correspondence relates to an existing case - we will add it to
your case and consider it on allocation to a case officer.

Copied correspondence - we do not respond to correspondence that has been
copied to us.

For more information about our services, please see our webpage ‘Service
standards and what to expect' (go to our homepage and follow the links for
‘Report a concern’ and ‘Service standards and what to expect'). You can
also call the number below.

For information about what we do with personal data see our [2]privacy
notice.

If there is anything you would like to discuss with us, please call our
helpline on 0303 123 1113.

Yours sincerely

The Information Commissioner’s Office

Our newsletter

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Information Commissioner's Office

12 July 2018

 

Case Reference Number RCC0764882
(Review of IRQ0761677)

 

Dear J T Oakley

Thank you for your correspondence dated 11 July 2018.
 
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 8 August 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
 
 
 

Frederick Aspbury
Lead Information Access Officer
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire SK9 5AF
T. 0330 414 6397 F. 01625 524510  [1]ico.org.uk  [2]twitter.com/iconews
Please consider the environment before printing this email
For information about what we do with personal data see our [3]privacy
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Information Commissioner's Office

25th July 2018

 

Case Reference Number RCC0764882

 

Dear J T Oakley

Thank you for your email 2018, asking for a review of our response to your
information request to the Information Commissioner’s Office (ICO)
entitled “data and metadata” and handled under the reference number
IRQ0761677.
 
You request read:
 
“Please supply data held on record describing the difference between data
and metadata.”
 
Our response
 
I’ve reviewed our response to your request and the searches we have done,
I consider that the searches are reasonable and appropriate. Therefore, I
do not uphold your complaint. I agree that we do not hold information
which falls within the scope of your request.

Mr Aspbury provided you with links to resources available to ICO staff
concerning data and metadata. I have also included below a link to the
ICO’s guidance concerning data and metadata under FOI which I hope you
find of assistance. 
 
Please refer to the section on information on the properties of electronic
documents (metadata)
[1]https://ico.org.uk/media/for-organisatio...
 
 
Finally, it might be more helpful, looking at the nature of the questions
you pose, to raise the issues as enquiries with the ICO. We do not handle
enquiries via the whatdotheyknow website but if you would like to discuss
this matter further, or would like an explanation/clarification concerning
the difference between data and metadata, please call our helpline on 0303
123 1113 or use our [2]live chat service. You can also send a written
enquiry to [3][email address]
 

Yours sincerely
 
Iman Elmehdawy
Information Access Service Manager
 
Records and Information Management
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire SK9 5AF

 
Next Steps
 
If you remain dissatisfied with the outcome of this review you can make a
formal complaint with the ICO in its capacity as the regulator of the
Freedom of Information Act. Please follow the link below to submit your
complaint
[4]https://ico.org.uk/concerns/
 

 

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Dear Information Commissioner’s Office,

Thank you.

But you seem to be confusing a request for a review with a complaint.

‘Therefore, I do not uphold your complaint’.

A review is not a complaint.

And I would therefore appreciate it if you would not treat any FOIA requests as complaints.

If I’d wished to make a complaint I would have gone through the is complaint channels instead of making an FOIA request.

==

However, from your response, I am am now satisfied that caseworkers do not have the guidance of a definition to distinguish between the two terms - I had wrongly assumed that the ICO would have provided a clear definition for caseworkers.

So no blame can given be to an individual caseworker who makes a decision solely on metadata.... when the requester has already removed the requirement for metadata from a SAR request..

So thank you for providing it.

===

Are the now any plans to help and assist caseworkers who might confused by the two terms ?

Yours faithfully,

Jt Oakley

AccessICOinformation, Information Commissioner's Office

Thank you for contacting the Information Commissioner’s Office. We confirm
that we have received your correspondence.

If you have made a request for information held by the ICO we will contact
you as soon as possible if we need any further information to enable us to
answer your request. If we don't need any further information we will
respond to you within our published, and statutory, service levels. For
more information please visit [1]http://ico.org.uk/about_us/how_we_comply

If you have raised a new information rights concern - we aim to send you
an initial response and case reference number within 30 days.

If you are concerned about the way an organisation is handling your
personal information, we will not usually look into it unless you have
raised it with the organisation first. For more information please see our
webpage ‘raising a concern with an organisation’ (go to our homepage and
follow the link ‘for the public’). You can also call the number below.

If you have requested advice - we aim to respond within 14 days. 

If your correspondence relates to an existing case - we will add it to
your case and consider it on allocation to a case officer.

Copied correspondence - we do not respond to correspondence that has been
copied to us.

For more information about our services, please see our webpage ‘Service
standards and what to expect' (go to our homepage and follow the links for
‘Report a concern’ and ‘Service standards and what to expect'). You can
also call the number below.

For information about what we do with personal data see our [2]privacy
notice.

If there is anything you would like to discuss with us, please call our
helpline on 0303 123 1113.

Yours sincerely

The Information Commissioner’s Office

Our newsletter

Details of how to sign up for our monthly e-newsletter can be found at
[3]http://www.ico.org.uk/tools_and_resource...

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phsothefacts Pressure Group left an annotation ()

It makes me very suspicious when organisations don't respond on public sites but ask you to contact them privately. I would have thought that the ICO should be a bastion of transparency but clearly not.

Jt Oakley left an annotation ()

Agreed phsothefacts

Since a recent decision stated that it was based on ‘metadata’, rather than ‘data, its important to know the distinction.

As you have spotted, it’s no use questioning a decision, so the ‘get in touch ‘ response (above ) must be ironic.
Especially as it confuses a complaint with an FOIA request, on WDTK - which isn’t a platform for complaints.

After seemingly confusing metadata with data inna complaint response.

* After a case is closed and a decision made ...as everyone knows, there is no contacting the ICO.

- Even if there is later proof that a requester was right in stating that an organisation withheld data, ( when the previously withheld information is suddenly divulged - after the ICO confidentially decided it didnt exist) ) the ICO has no process to right a wrong.

It doesn’t do apologies.

==

Confusion betwen Pears (metadata) and Apples (Data).

The oddest thing is that the part of the REQUEST for METADATA relating to was REMOVED ...to speed up the process.

Therefore, since we are told: ‘If you don’t understand something - ask’ ....it’s relevant to ask, in an FOIA , what is the difference in terminology? Since the complaint decision referred to metadata.

Why didn’t he caseworker grasp that only apples remained on the fruit bowl?
And make his decision on pears instead?

Which is something that could affect anyone asking for their SAR.

1.Was it just a mistake on his part?

2. Is there something about the distinction between the two terms that is not understood by the public?
And the ICO has a combined ‘pears and apples’ definition ....making ‘fruit’?

3.Does the ICO give enough guidance between the terms, and, if there has been a mistake, is it a systemic problem?

==

The response above has indicated that the ICO seemingly doesn't provide its caseworkers with clear definitions of the difference in the terminology between metadata and data .

Therefore can the caseworker be blamed for not knowing the difference?

Even though metadata was explicitly withdrawn ....so making a decision exclusively on pears....rather than the requested apples?

From the response to the request, I’m still not sure

Jt Oakley left an annotation ()

Metadata

Information on the properties of electronic documents (metadata)13

Summarising the information from the building blocks 13.

In the previous example the applicant wanted a summary of the contents of each document.

This is not information that could be directly lifted from the documents in the same way as dates or the name of the document’s author.

However, under section 11 of FOIA, a public authority is obliged to comply with a request to present the information as a summary or digest if the applicant expresses this preference from the outset and it is reasonably practicable to do so.

https://ico.org.uk/media/for-organisatio...

phsothefacts Pressure Group left an annotation ()

I actually believe that they 'make it up as they go along' with the guiding principle of protecting those in authority. They assume that we only know our own requests so no pattern emerges but social media allows us to share this information and then the anomalies and contradictions are clear for all to see. But they don't care in the end as they are unaccountable. All just a facade to maintain public confidence.

Jt Oakley left an annotation ()

Agreed. The ICO never apologises either.

...Even if you later prove the Decision is wrong, by presenting compulsive factual evidence.

Eight years ago it seemed to be an organisation which sought the truth but now seems that the easiest way to hit targets is to agree with the organisation that data cannot possibly exist, even though, logically, it must.

Or declare a complainant to be frivolous, or vexatious, for daring continue to ask for the data, which is mentioned in other parts of a SAR. You have to wonder whether caseworkers ever read entire complaint cases.