May v Information Commissioner [2025] UKFTT 1314 (GRC) (04 November 2025)

May v Information Commissioner [2025] UKFTT 1314 (GRC) (04 November 2025)

The Tribunal has no jurisdiction under section 166 DPA 2018 where the Information Commissioner has provided an outcome to the complaint and taken appropriate procedural steps; the Tribunal's powers are limited to procedural issues and do not extend to ordering substantive remedies or compelling data disclosure by third parties.

Citation
[2025] UKFTT 1314 (GRC)
Parties
Appellant: Claire May; Respondent: Information Commissioner
Jurisdiction
United Kingdom
Judgment Date
04 November 2025
Procedural Posture
First Tier Tribunal (general Regulatory Chamber) Information Rights / Strike Out Decision After Reconsideration
Outcome
Application struck out for want of jurisdiction and no reasonable prospect of success.
Legal Topics
Data Subject Access Request, Tribunal Jurisdiction, Procedural Requirements Under DPA 2018, Section 166 DPA 2018, ICO Complaint Handling
Data Protection Administrative Law Data Subject Access Request Tribunal Jurisdiction Procedural Requirements Under DPA 2018 Section 166 DPA 2018 ICO Complaint Handling

Case Brief

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Parties

Claire May

Appellant

Information Commissioner

Respondent

Procedural Posture

First Tier Tribunal (general Regulatory Chamber) Information Rights / Strike Out Decision After Reconsideration

Legal Issues

  1. 1 Whether the Tribunal has jurisdiction under section 166(2) DPA 2018 to order further steps by the Information Commissioner after an outcome has been provided
  2. 2 Whether the Information Commissioner failed to take appropriate procedural steps in handling the applicant's complaint

Ratio Decidendi

The Tribunal has no jurisdiction under section 166 DPA 2018 where the Information Commissioner has provided an outcome to the complaint and taken appropriate procedural steps; the Tribunal's powers are limited to procedural issues and do not extend to ordering substantive remedies or compelling data disclosure by third parties.

Court Disposition

Application struck out for want of jurisdiction and no reasonable prospect of success.

Orders

  • Decision of Registrar Bamawo dated 17 October 2025 set aside.
  • Proceedings struck out under Rule 8(2)(a) for lack of jurisdiction and Rule 8(3)(a) for no reasonable prospect of success.