Mr. X and The Irish Greyhound Board (FOI Act 2014) [2017] IEIC 160356 (19 January 2017)

Mr. X and The Irish Greyhound Board (FOI Act 2014) [2017] IEIC 160356 (19 January 2017)

Disclosure of the names of greyhounds would identify owners, constituting personal information held confidentially by the IGB. The public interest in further disclosure does not outweigh the privacy rights of the individuals concerned, especially where no case to answer was found or investigations are ongoing. Section 37(1) applies and no exceptions under section 37(2) or 37(5) are met.

Citation
[2017] IEIC 160356
Parties
Applicant: Mr. X; Respondent: The Irish Greyhound Board
Jurisdiction
Ireland
Judgment Date
19 January 2017
Procedural Posture
Freedom of Information Review / Decision of the Information Commissioner Following Internal Review
Outcome
Refusal affirmed
Legal Topics
Personal Information Exemption, Public Interest Test, Disclosure of Records
Administrative Law Freedom of Information Personal Information Exemption Public Interest Test Disclosure of Records

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Parties

Mr. X

Applicant

The Irish Greyhound Board

Respondent

Procedural Posture

Freedom of Information Review / Decision of the Information Commissioner Following Internal Review

Legal Issues

  1. 1 Whether disclosure of greyhound names that tested positive for prohibited substances between 2013 and October 2015 is exempt under section 37 of the FOI Act

Ratio Decidendi

Disclosure of the names of greyhounds would identify owners, constituting personal information held confidentially by the IGB. The public interest in further disclosure does not outweigh the privacy rights of the individuals concerned, especially where no case to answer was found or investigations are ongoing. Section 37(1) applies and no exceptions under section 37(2) or 37(5) are met.

Court Disposition

Refusal affirmed

Orders

  • The decision of the Irish Greyhound Board to refuse access to the requested information is affirmed.