Details of correspondence between IPSA and Open Democracy


I would like to request the following under the Freedom of Information Act:

  1. All correspondence between IPSA and Open Democracy or anyone acting on its behalf, including Jenna Corderoy.

  2. All correspondence between IPSA and the Information Commissioner concerning the European Research Group.


IPSA holds the information that you request.

IPSA’s correspondence with Open Democracy extends only insofar as our handling of requests for information from the group.

IPSA has already published much of the correspondence we have had with Open Democracy on our website.

The additional correspondence, as well as our correspondence with the Information Commissioner’s Office accompanies this response.

We have withheld some information from this correspondence in accordance with s.40 FOIA (Personal Information). Further information on the application of this exemption can be found below.

Exemptions applied

Section 40 – Personal information

Information relating to an identified or identifiable natural person is ‘personal data’, as defined by the General Data Protection Principle (GDPR).

Section 40(2) of the FOIA provides that personal information is exempt information if:

(a) it constitutes personal data; and

(b) the condition set out in s. 40(3A)(a) of FOIA is satisfied, namely that disclosure to a member of the public would contravene any of the data protection principles in the GDPR.

In our view (a) is satisfied because the information sought by you relates to an identifiable, living individual, and (b) is also satisfied because disclosure would breach the first data protection principle in Article 5(1)(a) of the GDPR, which requires that personal information is processed fairly, lawfully and in a transparent manner; processing includes disclosure. In relation to fairness, IPSA is required to process personal data in a manner in which people, would reasonably expect.

We do not consider it within the reasonable expectations of third parties engaged in or named in the correspondence, that their personal information would be disclosed in response to a Freedom of Information Act request, which is deemed to be disclosure to the world at large.

As such, we are obliged to withhold the information from disclosure under section 40(2) of the FOIA.

This part of the section 40 exemption is an absolute exemption and so no consideration of public interest arguments for and against disclosure is required.

This concludes our response to your request.

30 July 2019
Exemptions Applied:
Section 40