Section 40 FOIA provides for a number of exemptions in respect of ‘personal data’. The exemption which is most frequently prayed in aid by public authorities is the one provided for under s. 40(2), read together with s. 40(3)(a)(i). In essence, under these provisions, information will be absolutely exempt from disclosure under FOIA if: (a) it amounts to personal data, as defined in s. 1 of the Data Protection Act 1998 (“DPA”) and (b) its disclosure would contravene one or more of the data protection principles provided for under schedule 1 to the DPA. In practice, it can be very difficult to apply this exemption, particularly where the information in issue may comprise personal data relating to a number of different individuals. It was precisely this issue which the Tribunal had to tackle in the recent case of Bryce v IC & Cambridgeshire Constabulary (EA/2009/0083). In Bryce, a request had been made by Ms Bryce for disclosure of a police investigation report. The report addressed concerns which had been raised by Ms Bryce and others about the way in which the Cambridgeshire Constabulary had investigated the death of Ms Bryce’s sister, who had been killed by her husband. The Tribunal held that the report contained a multiplicity of different types of personal data including: Ms Bryce’s personal data; the husband’s personal data; personal data relating to the husband’s family; the personal data of witnesses; personal data relating to the deceased’s family; and personal data relating to officers who had conducted the investigation. Apart from Ms Bryce’s own personal data, which was exempt from disclosure under s. 40(1) FOIA, the Tribunal approached the question of how the s. 40(2) exemption applied to the remaining data by conducting a discrete analytical exercise in respect of each type of data. It is clear from the Tribunal’s analysis that it was of the view that very different considerations applied, for example, in respect of officers’ data as compared with the data relating to the husband’s family. The key implication of this judgment is that a public authority will expose itself to challenge under FOIA if it simply adopts a blanket ‘one size fits all’ approach to information comprising diffuse types of personal data. The judgment is also notable in that it applies the approach to the concept of ‘personal data’ which was approved in Durant v Financial Services Authority, rather than the arguably more liberal approach embodied in the Commissioner’s guidance: Determining What is Personal Data’.