Panossian v Information Commissioner [2025] UKFTT 610 (GRC) (05 June 2025)

Panossian v Information Commissioner [2025] UKFTT 610 (GRC) (05 June 2025)

The Tribunal is limited to considering whether the Commissioner has provided a procedural response to a complaint under section 166 DPA. Since the Commissioner provided an outcome letter and review, the Tribunal has no jurisdiction to consider the merits or adequacy of the response. The applicant's arguments do not...

Source-derived case information.

Citation
[2025] UKFTT 610 (GRC)
Parties
Applicant: Aram Panossian; Respondent: Information Commissioner
Jurisdiction
United Kingdom
Judgment Date
05 June 2025
Procedural Posture
First Tier Tribunal (general Regulatory Chamber) Information Rights / Strike Out Application; Reconsideration Following Set Aside for Procedural Irregularity
Outcome
Application struck out
Legal Topics
Section 166 Data Protection Act 2018, Tribunal Jurisdiction, Procedural Irregularity, Subject Access Requests, Personal Data Definition
Data Protection Information Rights Administrative Law Section 166 Data Protection Act 2018 Tribunal Jurisdiction Procedural Irregularity Subject Access Requests Personal Data Definition

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Parties

Aram Panossian

Applicant

Information Commissioner

Respondent

Procedural Posture

First Tier Tribunal (general Regulatory Chamber) Information Rights / Strike Out Application; Reconsideration Following Set Aside for Procedural Irregularity

Legal Issues

  1. 1 Whether the Tribunal has jurisdiction to consider the applicant's challenge to the Commissioner's handling of a complaint under section 166 DPA
  2. 2 Whether the Commissioner's actions amounted to a procedural failing under section 166 DPA
  3. 3 Whether the applicant's request related to his own personal data

Ratio Decidendi

The Tribunal is limited to considering whether the Commissioner has provided a procedural response to a complaint under section 166 DPA. Since the Commissioner provided an outcome letter and review, the Tribunal has no jurisdiction to consider the merits or adequacy of the response. The applicant's arguments do not demonstrate any procedural failing within the Tribunal's remit. The application has no reasonable prospect of success and must be struck out.

Court Disposition

Application struck out

Orders

  • The decision of 7 March 2025 striking out the application is set aside under Rule 41(2)(d) due to procedural irregularity.
  • The proceedings are struck out under Rule 8(3)(c) as there is no reasonable prospect of success.