Leaney v Information Commissioner [2025] UKFTT 1106 (GRC) (19 September 2025)

Leaney v Information Commissioner [2025] UKFTT 1106 (GRC) (19 September 2025)

The Tribunal has no jurisdiction under section 166 DPA 2018 to review the substantive outcome of the Information Commissioner's decision or to require review of prior cases. The Information Commissioner provided an outcome to the Second Complaint, and no further procedural steps were required. The Tribunal cannot address the handling of the SAR where the ICO is the data controller. The application is struck out for lack of jurisdiction and no reasonable prospect of success.

Citation
[2025] UKFTT 1106 (GRC)
Parties
Appellant: Paul Gerard Leaney; Respondent: Information Commissioner
Jurisdiction
United Kingdom
Judgment Date
19 September 2025
Procedural Posture
First Tier Tribunal (general Regulatory Chamber) Information Rights / Strike Out Application Decided Without a Hearing
Outcome
Application struck out for lack of jurisdiction and no reasonable prospect of success.
Legal Topics
Section 166 Data Protection Act 2018, Subject Access Request, Tribunal Jurisdiction, Procedural Requirements, ICO Complaints Handling
Data Protection Information Rights Administrative Law Section 166 Data Protection Act 2018 Subject Access Request Tribunal Jurisdiction Procedural Requirements ICO Complaints Handling

Case Brief

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Parties

Paul Gerard Leaney

Appellant

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 under section 166 DPA 2018 to order the Information Commissioner to take further steps regarding the applicant's complaint
  2. 2 Whether the Tribunal can review the substantive outcome of the Information Commissioner's decision on a data protection complaint
  3. 3 Whether the Tribunal can require the Information Commissioner to review prior cases or the handling of a Subject Access Request

Ratio Decidendi

The Tribunal has no jurisdiction under section 166 DPA 2018 to review the substantive outcome of the Information Commissioner's decision or to require review of prior cases. The Information Commissioner provided an outcome to the Second Complaint, and no further procedural steps were required. The Tribunal cannot address the handling of the SAR where the ICO is the data controller. The application is struck out for lack of jurisdiction and no reasonable prospect of success.

Court Disposition

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

Orders

  • The application is struck out under Rule 8(2)(a) because the Tribunal does not have jurisdiction to deal with it.
  • The application is struck out under Rule 8(3)(a) because there is no reasonable prospect of it succeeding.