Flanagan v Information Commissioner & Anor [2025] UKFTT 901 (GRC) (29 July 2025)

Flanagan v Information Commissioner & Anor [2025] UKFTT 901 (GRC) (29 July 2025)

Disclosure of the requested personal data was not reasonably necessary for the legitimate interest of transparency in the grant assessment process, as alternative means of redress exist and the information already provided suffices; thus, disclosure would not be lawful under Article 6(1)(f) UK GDPR and is exempt...

Source-derived case information.

Citation
[2025] UKFTT 901 (GRC)
Parties
Appellant: Phil Flanagan; First Respondent: The Information Commissioner; Second Respondent: Fermanagh and Omagh District Council
Jurisdiction
United Kingdom
Judgment Date
29 July 2025
Procedural Posture
Appeal / First Tier Tribunal (general Regulatory Chamber) Decision on the Papers
Outcome
Appeal dismissed
Legal Topics
Freedom of Information, Personal Data, Conflicts of Interest, Public Authority Transparency, UK GDPR, FOIA S40(2) Exemption
Information Law Data Protection Freedom of Information Personal Data Conflicts of Interest Public Authority Transparency UK GDPR FOIA S40(2) Exemption

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Parties

Phil Flanagan

Appellant

The Information Commissioner

First Respondent

Fermanagh and Omagh District Council

Second Respondent

Procedural Posture

Appeal / First Tier Tribunal (general Regulatory Chamber) Decision on the Papers

Legal Issues

  1. 1 Whether the Council was entitled to withhold names and details of officers involved in grant assessment under s40(2) FOIA
  2. 2 Whether disclosure of personal data was necessary and lawful under Article 6(1)(f) UK GDPR

Ratio Decidendi

Disclosure of the requested personal data was not reasonably necessary for the legitimate interest of transparency in the grant assessment process, as alternative means of redress exist and the information already provided suffices; thus, disclosure would not be lawful under Article 6(1)(f) UK GDPR and is exempt under s40(2) FOIA.

Court Disposition

Appeal dismissed

Orders

  • The appeal is dismissed.