Harrison v Information Commissioner [2025] UKFTT 1363 (GRC) (21 November 2025)

Harrison v Information Commissioner [2025] UKFTT 1363 (GRC) (21 November 2025)

Section 166 DPA 2018 limits the Tribunal's powers to procedural issues. The Commissioner provided an outcome and updates to the complaint, fulfilling procedural obligations. The Tribunal has no jurisdiction to order a substantive investigation or review the merits of the Commissioner's decision. There is no reasonable prospect of the appeal succeeding.

Citation
[2025] UKFTT 1363 (GRC)
Parties
Appellant: Ann Harrison; Respondent: The Information Commissioner
Jurisdiction
United Kingdom
Judgment Date
21 November 2025
Procedural Posture
First Tier Tribunal (general Regulatory Chamber) Information Rights / Strike Out Application Decided Without a Hearing
Outcome
Application struck out
Legal Topics
Section 166 Data Protection Act 2018, Procedural Jurisdiction of Tribunal, Scope of Tribunal Powers Under DPA 2018, Right to Complain to Information Commissioner
Data Protection Information Rights Administrative Law Section 166 Data Protection Act 2018 Procedural Jurisdiction of Tribunal Scope of Tribunal Powers Under DPA 2018 Right to Complain to Information Commissioner

Case Brief

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Parties

Ann Harrison

Appellant

The Information Commissioner

Respondent

Procedural Posture

First Tier Tribunal (general Regulatory Chamber) Information Rights / Strike Out Application Decided Without a Hearing

Legal Issues

  1. 1 Whether the Tribunal has jurisdiction to order a substantive investigation by the Information Commissioner under section 166 DPA 2018
  2. 2 Whether the Commissioner failed to comply with procedural requirements under section 166(1) DPA 2018

Ratio Decidendi

Section 166 DPA 2018 limits the Tribunal's powers to procedural issues. The Commissioner provided an outcome and updates to the complaint, fulfilling procedural obligations. The Tribunal has no jurisdiction to order a substantive investigation or review the merits of the Commissioner's decision. There is no reasonable prospect of the appeal succeeding.

Court Disposition

Application struck out

Orders

  • The application is struck out under Rule 8(3)(c) of The Tribunal Procedure (First-tier Tribunal)(General Regulatory Chamber) Rules 2009.