Peter Tilson v The Information Commissioner
Disclosure of the Council officer's name is not necessary to meet the legitimate interest pursued by the appellant, as alternative methods exist to obtain the relevant information without disclosing personal data. The officer's role as a communication link does not justify disclosure, and the reasonable expectation of privacy is not outweighed by the appellant's interest.
- Parties
- Appellant: Peter Tilson; Respondent: The Information Commissioner
- Jurisdiction
- England and Wales
- Judgment Date
- 21 June 2024
- Procedural Posture
- Appeal / Final Determination
- Outcome
- appeal dismissed
- Legal Topics
- FOIA Section 40(2), Personal Data, GDPR Article 6(1)(f), Legitimate Interest, Balancing Test
Case Brief
Summary, issues, holding and outcome
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Parties
Peter Tilson
Appellant
The Information Commissioner
Respondent
Procedural Posture
Appeal / Final Determination
Legal Issues
- 1 Whether disclosure of the Council officer's name is lawful under FOIA and UK GDPR
- 2 Whether the legitimate interest in disclosure outweighs the data subject's rights
Ratio Decidendi
Disclosure of the Council officer's name is not necessary to meet the legitimate interest pursued by the appellant, as alternative methods exist to obtain the relevant information without disclosing personal data. The officer's role as a communication link does not justify disclosure, and the reasonable expectation of privacy is not outweighed by the appellant's interest.
Court Disposition
appeal dismissed
Orders
- No substituted decision notice issued
Full Case Text
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