Parker v Information Commissioner & Anor [2025] UKFTT 874 (GRC) (23 July 2025)

Parker v Information Commissioner & Anor [2025] UKFTT 874 (GRC) (23 July 2025)

The Council disclosed all relevant information it held in response to both requests, was entitled to withhold personal data under Regulation 13 EIR, and was entitled to rely on Regulation 13(5A) EIR to neither confirm nor deny holding information relating to complaints about specific individuals. Disclosure of additional personal data was not necessary to meet legitimate interests and would breach data protection principles. The Tribunal's remit does not extend to ordering reinvestigation of the Information Commissioner's process; the appeal is dismissed.

Citation
[2025] UKFTT 874 (GRC)
Parties
Appellant: Stephen Parker; First Respondent: Information Commissioner; Second Respondent: Guildford Borough Council
Jurisdiction
United Kingdom
Judgment Date
23 July 2025
Procedural Posture
First Tier Tribunal Appeal (information Rights) / Final Judgment
Outcome
Appeal dismissed
Legal Topics
Environmental Information Regulations, Freedom of Information Act, Personal Data Exemption, Disclosure Obligations, Planning Decisions, Transparency, Legitimate Interest, Necessity Test, Regulation 13 EIR, Regulation 13(5 A) EIR
Information Law Data Protection Administrative Law Environmental Information Regulations Freedom of Information Act Personal Data Exemption Disclosure Obligations Planning Decisions +5 more

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Parties

Stephen Parker

Appellant

Information Commissioner

First Respondent

Guildford Borough Council

Second Respondent

Procedural Posture

First Tier Tribunal Appeal (information Rights) / Final Judgment

Legal Issues

  1. 1 Has the Council disclosed all relevant information it holds across both requests?
  2. 2 Was the Council entitled to withhold information under Regulation 13 EIR as personal data?
  3. 3 Was the Council entitled to rely on Regulation 13(5A) EIR to neither confirm nor deny holding information in scope of Request 2?

Ratio Decidendi

The Council disclosed all relevant information it held in response to both requests, was entitled to withhold personal data under Regulation 13 EIR, and was entitled to rely on Regulation 13(5A) EIR to neither confirm nor deny holding information relating to complaints about specific individuals. Disclosure of additional personal data was not necessary to meet legitimate interests and would breach data protection principles. The Tribunal's remit does not extend to ordering reinvestigation of the Information Commissioner's process; the appeal is dismissed.

Court Disposition

Appeal dismissed