Reward and Recognition payments made by Peter Bone MP in December 2018

I can confirm that we do hold information relevant to your request, however, it is subject to a Refusal Notice under sections 40(2) and 40(3A)(a) of FOIA.

This exemption applies to information which IPSA considers to be personal data within the meaning of Article 4(1) of the General Data Protection Regulation 2016 (GDPR) which states:

‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

Obviously, the names of individuals employed by MPs and who have received a Reward and Recognition Payment would fall within this definition.

I then considered whether disclosure of this personal data would breach any of the Principles relating to the processing of personal data in the GDPR.

The relevant principle falls at Article 5(1)(a)

Personal data shall be:

(a)  Processed lawfully, fairly and in a transparent manner in relation to the data subject

I then considered whether there was a lawful basis within Article 6 of the GDPR and in particular whether there was a legitimate interest in disclosing the names of the recipients of this payment. I was mindful of the need for accountability and transparency when considering any request from the public and knowing who had received these amounts would assist in this. However, I also had to consider whether disclosure would outweigh the interests, rights and fundamental freedoms of the individuals concerned. I find that the recipients would have a reasonable expectation that their names would not be made public and that this is consistent with IPSA’s policy on not publishing the names of MPs’ staff. I, therefore, find that the personal data is exempt under sections 40(2) and 40(3A)(a) of FOIA.