Stephen Parker v Information Commissioner & Anor

Stephen Parker v Information Commissioner & Anor

The Tribunal found that the Council had disclosed all relevant information it holds across both requests, was entitled to withhold some information under Regulation 13 as personal data, and was entitled to rely on regulation 13(5A) EIR to neither confirm nor deny holding information in scope of Request 2 relating to complaints or concerns about a specific individual. Disclosure of personal data was not necessary to meet legitimate interests and would breach data protection principles.

Parties
Appellant: Stephen Parker; First Respondent: Information Commissioner; Second Respondent: Guildford Borough Council
Jurisdiction
England and Wales
Judgment Date
21 August 2025
Procedural Posture
Appeal / Final Judgment
Outcome
Appeal dismissed
Legal Topics
Environmental Information Regulations, Freedom of Information, Personal Data Exemption, Disclosure, Public Authority Obligations

Case Brief

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Parties

Stephen Parker

Appellant

Information Commissioner

First Respondent

Guildford Borough Council

Second Respondent

Procedural Posture

Appeal / Final Judgment

  1. 1 Has the council disclosed all relevant information it holds across both requests?
  2. 2 Was the council entitled to withhold some information under Regulation 13 on the basis it was personal data of the neighbour and council staff?
  3. 3 Was the council entitled to rely on regulation 13(5A) EIR to neither confirm nor deny holding information in scope of Request 2 which related to whether or not a complaint or concerns were raised about a specific individual?

Ratio Decidendi

The Tribunal found that the Council had disclosed all relevant information it holds across both requests, was entitled to withhold some information under Regulation 13 as personal data, and was entitled to rely on regulation 13(5A) EIR to neither confirm nor deny holding information in scope of Request 2 relating to complaints or concerns about a specific individual. Disclosure of personal data was not necessary to meet legitimate interests and would breach data protection principles.

Court Disposition

Appeal dismissed