Number of new starters in each MP's office since 2019 general election

I can confirm that we hold information relevant to your request. A spreadsheet entitled New Staff Dec 2019 to Sept 2020, accompanies this letter.

A total of 1638 people are listed as having started work during the period from 13 December 2019 to 16 September 2020. Please note that the terms used by our system are different from the published job titles, for example, ‘Administration 1-London’ on the system equates to the job title ‘Secretary’ in our published data. A column has been included on the spreadsheet mapping system job families to job titles.

Please note that:

• Staff working for more than one MP, or who transferred from one MP to another, have been recorded as a new starter for each MP.

• The starting date and job family are at the time of recruitment and do not reflect the current job family or date of promotion.

Please be aware that we have aggregated the starting dates and names of MPs to avoid the potential for specific individuals to be identified. The exact starting dates and employing MPs are, therefore, subject to a Refusal Notice under sections 40(2) and 40(3A)(a) of the FOIA.

FOIA section 40

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

If an exact date were to be disclosed this, in combination with the job title and other information publicly available, would enable these individuals to be identified. The data, therefore, falls within the above definition of personal data.

IPSA then considered whether disclosure of the data would breach any of the principles relating to the processing of personal data in the UK GDPR. The relevant principle is at Article 5(1)(a):

Personal data shall be:

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

There were two relevant lawful bases under Article 6 of the UK GDPR.

1) Article 6(1)(a) UK GDPR consent. In the light of the number of requests which it receives IPSA does not routinely seek consent for the disclosure of personal data from individuals.

2) Article 6(1)(f) GDPR legitimate interests of IPSA and the person making the FOIA request. The Information Commissioner’s guidance makes it clear that a public authority may not rely on its own legitimate interests for the disclosure of personal data under the FOIA.

IPSA considered whether there is a third-party legitimate interest in disclosing the names of the individuals and whether it is necessary to do so to respond to the request. The organisation is mindful of the need for accountability and transparency when considering any request for information.

However, in this case, we also have to consider whether disclosure would outweigh the interests, rights and fundamental freedoms of the individuals concerned. IPSA maintains that, at the time the data was collected, the individuals would have a reasonable expectation that information concerning the exact starting date of their employment would not be disclosed.