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
Summary, issues, holding and outcome
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Parties
Stephen Parker
Appellant
Information Commissioner
First Respondent
Guildford Borough Council
Second Respondent
Procedural Posture
Appeal / Final Judgment
Legal Issues
- 1 Has the council disclosed all relevant information it holds across both requests?
- 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 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
Full Case Text
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