Icebergs Avoided: Navigating the s23 Case Law

Anyone who has had a FOIA case in the national security space will have faced the near-impossible task of trying to work out what on earth Corderoy & Ahmed v Information Commissioner & Attorney General & Cabinet Office [2017] UKUT 495 (AAC) means; a front-runner for most impenetrable Upper Tribunal decision on FOIA. Now Judge Markus QC has had a go at squaring the circle in Lownie v Information Commissioner & Foreign and Commonwealth Office & The National Archives [2020] UKUT 32 (AAC). Continue reading

Section 166 DPA 2018: Leighton off the ICO?

Relatively unnoticed in the morass of GDPR and Data Protection Act 2018 provisions is the right under section 166 DPA 2018 to apply to the First-tier Tribunal for an order that the ICO progress a complaint which has been made to it under section 165 or Article 77 GDPR. In other words, the core aim of the provision is to deal with situations in which the ICO has taken too long to address a complaint made about, for example, compliance with a subject access request. But what is the nature of the FTT’s role? Continue reading

Spam sandwiches: Tribunal dismisses Leave.EU PECR appeals

Regulation 22 of PECR 2003 – the prohibition on non-consensual electronic direct marketing communications – has been a favourite ICO hunting ground for monetary penalties for many years. Nevertheless, its dos and don’ts have remained stubbornly fuzzy at the edges. Thankfully, the Tribunal’s most recent decision on direct marketing communications is helpful and illuminating. It’s also quite entertaining: a nice montage of Arron Banks, spam, kangaroos and stuff. Continue reading