Ed Ryland v The Information Commissioner & Anor

Ed Ryland v The Information Commissioner & Anor

Section 36(2)(b)(i) and (ii) FOIA exemptions were properly engaged and the public interest favoured maintaining them; section 40(2) FOIA justified withholding personal data except for senior C4 staff names and emails; section 12 FOIA applied to the First Request due to excessive cost; C4 did hold further information...

Source-derived case information.

Parties
Appellant: Ed Ryland; First Respondent: The Information Commissioner; Second Respondent: Channel 4 Television Corporation
Jurisdiction
England and Wales
Judgment Date
24 September 2025
Procedural Posture
Appeal / Final Judgment
Outcome
appeal allowed in part
Legal Topics
Freedom of Information Act, Public Interest Exemption, Personal Data, Settlement Agreements, Non Disclosure Agreements, Employment Confidentiality
Information Rights Administrative Law Data Protection Freedom of Information Act Public Interest Exemption Personal Data Settlement Agreements Non Disclosure Agreements +1 more

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Parties

Ed Ryland

Appellant

The Information Commissioner

First Respondent

Channel 4 Television Corporation

Second Respondent

Procedural Posture

Appeal / Final Judgment

Legal Issues

  1. 1 Correct interpretation of FOIA requests
  2. 2 Application of section 12 FOIA (cost limit)
  3. 3 Engagement and balancing of section 36(2)(b)(i) and (ii) FOIA exemptions

Ratio Decidendi

Section 36(2)(b)(i) and (ii) FOIA exemptions were properly engaged and the public interest favoured maintaining them; section 40(2) FOIA justified withholding personal data except for senior C4 staff names and emails; section 12 FOIA applied to the First Request due to excessive cost; C4 did hold further information responsive to the Second Request and must inform the appellant accordingly.

Court Disposition

appeal allowed in part

Orders

  • C4 must within 35 days inform the appellant whether it holds further information responsive to the Second Request.
  • If such information is held, C4 must provide it or issue a notice specifying any exemption and reasons.