Edward Williams v The Information Commissioner

Edward Williams v The Information Commissioner

Confirming or denying whether the requested information is held would itself disclose personal data due to the small number of potential recipients, making them identifiable within the prison community. The legitimate interest in disclosure does not outweigh the fundamental rights and freedoms of the data subjects....

Source-derived case information.

Parties
Appellant: Edward Williams; Respondent: The Information Commissioner
Jurisdiction
England and Wales
Judgment Date
21 June 2024
Procedural Posture
Information Rights Appeal / Final Judgment on Written Submissions
Outcome
Appeal dismissed
Legal Topics
Freedom of Information, Personal Data, Neither Confirm Nor Deny, UK GDPR, Section 40 FOIA
Information Law Data Protection Freedom of Information Personal Data Neither Confirm Nor Deny UK GDPR Section 40 FOIA

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Parties

Edward Williams

Appellant

The Information Commissioner

Respondent

Procedural Posture

Information Rights Appeal / Final Judgment on Written Submissions

Legal Issues

  1. 1 Whether confirming or denying the existence of information about compensation/damages paid to biologically female prisoners assaulted by biologically male prisoners constitutes disclosure of personal data
  2. 2 Whether the legitimate interest in disclosure outweighs the data subjects' rights under UK GDPR

Ratio Decidendi

Confirming or denying whether the requested information is held would itself disclose personal data due to the small number of potential recipients, making them identifiable within the prison community. The legitimate interest in disclosure does not outweigh the fundamental rights and freedoms of the data subjects. Disclosure would not be lawful under Article 6(1)(f) UK GDPR. The appeal is therefore dismissed.

Court Disposition

Appeal dismissed