Speight v The Information Commissioner & Anor [2025] UKFTT 534 (GRC) (02 June 2025)

Speight v The Information Commissioner & Anor [2025] UKFTT 534 (GRC) (02 June 2025)

Disclosure of the withheld report numbers does not allow identification of any living individual with certainty or at all. The information does not constitute personal data under FOIA section 40(2), and the exemption is not made out. The appeal is allowed and the withheld information must be disclosed.

Citation
[2025] UKFTT 534 (GRC)
Parties
Appellant: Derek Speight; First Respondent: The Information Commissioner; Second Respondent: The Chief Constable of the Sussex Police
Jurisdiction
United Kingdom
Judgment Date
02 June 2025
Procedural Posture
FOIA Appeal / Final Judgment
Outcome
Appeal allowed
Legal Topics
FOIA Section 40(2) Exemption, Personal Data Definition, Disclosure of Report Numbers, Data Protection Principles
Information Rights Data Protection FOIA Section 40(2) Exemption Personal Data Definition Disclosure of Report Numbers Data Protection Principles

Case Brief

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Parties

Derek Speight

Appellant

The Information Commissioner

First Respondent

The Chief Constable of the Sussex Police

Second Respondent

Procedural Posture

FOIA Appeal / Final Judgment

Legal Issues

  1. 1 Whether withheld report numbers constitute personal data under FOIA section 40(2)
  2. 2 Whether disclosure would contravene data protection principles
  3. 3 Whether individuals can be identified from the withheld information

Ratio Decidendi

Disclosure of the withheld report numbers does not allow identification of any living individual with certainty or at all. The information does not constitute personal data under FOIA section 40(2), and the exemption is not made out. The appeal is allowed and the withheld information must be disclosed.

Court Disposition

Appeal allowed

Orders

  • Sussex Police must disclose the withheld report numbers to the Appellant within 28 days of the date of judgment.