Foreign, Commonwealth & Development Office (Central government) [2023] UKICO 137228 (30 March 2023)
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Foreign, Commonwealth & Development Office
The complainant submitted a request to the Foreign, Commonwealth & Development Office (FCDO) seeking information from 2017 onwards held by its internal audit department about Transparency International. The FCDO confirmed that it held information falling within the scope of the request but it considered this to be exempt from disclosure in its entirety on the basis of sections 27(1)(c) and (d) (international relations), section 31(2)(f) (law enforcement), section 40(2) (personal data) and section 43(2) (commercial interests) of FOIA. The FCDO subsequently disclosed a redacted version of the information, relying on some of the above exemptions to redact information, and also withheld some documents in full on the basis of section 41(1) (information provided in confidence) of FOIA. During the course of the Commissioner’s investigation the FCDO confirmed that it was willing to remove some, but not all, of these redactions. The Commissioner has concluded that the FCDO has correctly applied sections 27(1)(a) and (c), 41(1) and 43(2) to withhold the information to which these exemptions are still being applied. However, the Commissioner has concluded that section 40(2) only provides a basis to withhold some of the information to which this exemption continues to be applied. The Commissioner has also concluded that the FCDO has, on the balance of probabilities, located all of the information falling within the scope of the request.
FOI 43:
Complaint not upheld
FOI 40:
Complaint partly upheld
FOI 27:
Complaint not upheld
FOI 41:
Complaint not upheld
FOI 1:
Complaint not upheld
Decision notice: 137228
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URL: http://www.bailii.org/uk/cases/UKICO/2023/137228.html
