Mr X and RTE [2019] IEIC OIC-53241-B3T2F0 (16 August 2019)

Mr X and RTE [2019] IEIC OIC-53241-B3T2F0 (16 August 2019)

The redacted information was high-level and generic, lacking sufficient detail or specificity to cause the harms identified in sections 30 or 36 of the FOI Act; therefore, RTÉ was not justified in redacting the information.

Citation
[2019] IEIC OIC-53241-B3T2F0
Parties
Applicant: Mr X; Respondent: RTÉ
Jurisdiction
Ireland
Judgment Date
16 August 2019
Procedural Posture
Freedom of Information Review / Final Decision by Information Commissioner
Outcome
RTÉ's decision to redact information annulled; full disclosure ordered.
Legal Topics
Redaction of Information, Public Access to Records, Exemptions Under FOI Act
Administrative Law Freedom of Information Redaction of Information Public Access to Records Exemptions Under FOI Act

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Parties

Mr X

Applicant

RTÉ

Respondent

Procedural Posture

Freedom of Information Review / Final Decision by Information Commissioner

Legal Issues

  1. 1 Whether RTÉ was justified in redacting information from a Memorandum of Understanding under sections 30 and 36 of the FOI Act

Ratio Decidendi

The redacted information was high-level and generic, lacking sufficient detail or specificity to cause the harms identified in sections 30 or 36 of the FOI Act; therefore, RTÉ was not justified in redacting the information.

Court Disposition

RTÉ's decision to redact information annulled; full disclosure ordered.

Orders

  • Annulment of RTÉ's redaction decision under sections 30 and 36 of the FOI Act
  • Direction to release the Memorandum of Understanding in its entirety