Peter Whyton v Information Commissioner & Anor
Disclosure of the names and addresses was not reasonably necessary for the Appellant’s interests or the public interest, and any such interests were overridden by the data subjects’ privacy rights. There was no lawful basis for disclosure under EIR, and STC was entitled to withhold the information under regulation 13(1).
- Parties
- Appellant: Peter Whyton; First Respondent: Information Commissioner; Second Respondent: Sodbury Town Council
- Jurisdiction
- England and Wales
- Judgment Date
- 11 September 2024
- Procedural Posture
- Appeal / Final Judgment
- Outcome
- Appeal dismissed
- Legal Topics
- Environmental Information Regulations, Personal Data Disclosure, Freedom of Information, Legitimate Interests Test
Case Brief
Summary, issues, holding and outcome
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Parties
Peter Whyton
Appellant
Information Commissioner
First Respondent
Sodbury Town Council
Second Respondent
Procedural Posture
Appeal / Final Judgment
Legal Issues
- 1 Whether Sodbury Town Council was entitled to withhold names and addresses under regulation 13(1) EIR
- 2 Whether disclosure of personal data was lawful under the legitimate interests test
- 3 Whether the interests in disclosure were overridden by data subjects’ privacy rights
Ratio Decidendi
Disclosure of the names and addresses was not reasonably necessary for the Appellant’s interests or the public interest, and any such interests were overridden by the data subjects’ privacy rights. There was no lawful basis for disclosure under EIR, and STC was entitled to withhold the information under regulation 13(1).
Court Disposition
Appeal dismissed
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