Andrew Woodhead v WTTV Limited & Anor
The claim for misuse of private information fails because the disclosure by NPQ and the use by WTTV Limited were justified, proportionate, and within the scope of legitimate disciplinary procedures. WTTV Limited was not vicariously liable for NPQ's disclosure. However, the employer breached its duty of care by failing to inform the claimant that certain complaints would not proceed, and by insisting on unnecessary procedural steps during the claimant's ill health, which materially contributed to his psychiatric injury. The injury was indivisible and not apportionable.
- Parties
- Claimant: Andrew Woodhead; Defendant: WTTV Limited; Defendant: NBC Universal International Limited
- Jurisdiction
- England and Wales
- Judgment Date
- 05 December 2025
- Procedural Posture
- Civil / Liability Judgment; Quantum Outstanding
- Outcome
- Claim for misuse of private information dismissed; claim in negligence succeeds to the extent set out; quantum to be determined.
- Legal Topics
- Misuse of Private Information, Negligence, Vicarious Liability, Employer's Duty of Care, Disciplinary Procedures, Psychiatric Injury
Case Brief
Summary, issues, holding and outcome
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Parties
Andrew Woodhead
Claimant
WTTV Limited
Defendant
NBC Universal International Limited
Defendant
Procedural Posture
Civil / Liability Judgment; Quantum Outstanding
Legal Issues
- 1 Whether the disclosure and use of the claimant's private information by the complainant and employer amounted to actionable misuse of private information or breach of confidence
- 2 Whether the employer breached its duty of care in the conduct of disciplinary proceedings, causing foreseeable psychiatric injury to the claimant
Ratio Decidendi
The claim for misuse of private information fails because the disclosure by NPQ and the use by WTTV Limited were justified, proportionate, and within the scope of legitimate disciplinary procedures. WTTV Limited was not vicariously liable for NPQ's disclosure. However, the employer breached its duty of care by failing to inform the claimant that certain complaints would not proceed, and by insisting on unnecessary procedural steps during the claimant's ill health, which materially contributed to his psychiatric injury. The injury was indivisible and not apportionable.
Court Disposition
Claim for misuse of private information dismissed; claim in negligence succeeds to the extent set out; quantum to be determined.
Orders
- Claim for breach of privacy/confidentiality dismissed
- Claim in negligence succeeds as to liability; quantum to be determined at a further hearing
Full Case Text
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