Peter Stead v Information Commissioner

Peter Stead v Information Commissioner

The cost of complying with the appellant's request would exceed the statutory limit of 18 hours of work, as the data systems require manual matching and collation of diversity forms to applications, making BFI entitled to rely on the section 12(1) FOIA exemption.

Parties
Appellant: Peter Stead; Respondent: Information Commissioner
Jurisdiction
England and Wales
Judgment Date
24 February 2025
Procedural Posture
Appeal / Final Judgment
Outcome
Appeal dismissed
Legal Topics
Freedom of Information, Cost Exemption, Public Authority Duties
Administrative Law Information Law Freedom of Information Cost Exemption Public Authority Duties

Case Brief

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Parties

Peter Stead

Appellant

Information Commissioner

Respondent

Procedural Posture

Appeal / Final Judgment

Legal Issues

  1. 1 Whether the cost of complying with the FOIA request would exceed the statutory limit under section 12(1) FOIA
  2. 2 Whether BFI holds the requested diversity data for all applicants and employment
  3. 3 Whether BFI's data systems and processes justify reliance on the cost exemption

Ratio Decidendi

The cost of complying with the appellant's request would exceed the statutory limit of 18 hours of work, as the data systems require manual matching and collation of diversity forms to applications, making BFI entitled to rely on the section 12(1) FOIA exemption.

Court Disposition

Appeal dismissed