Information about the production of IPSA's "myth busting" video

I can confirm that we do not hold information relevant to your points relating to the production and publication of the article, but we can tell you that the article was produced by our Communications Team as part of their routine work. The draft was circulated for comments and any amendments made in the document and then accepted or rejected to create the final copy.

We do hold information about the production of the video. Copies of information relevant to this part of your request have been provided as an attached zip folder. Some of the information has been redacted and is subject to a Refusal Notice under sections 21, 31 and 40; other information we have redacted because it is out of the scope of your request. We have also not provided copies of documents which were obvious duplicates.

You will see that we have provided copies of invoices which IPSA received from Magneto, but that these have been redacted. The reason for this is that Magneto carried out a number of pieces of work for IPSA and submitted invoices to cover all this, with descriptions and a total. IPSA has published the amount spent on this video in response to other FOI requests, and these can be found in our FOI Disclosure Log under references RFI-202206-06 and RFI-202206-07.

As this information is in the public domain it is subject to a Refusal Notice under section 21 of the FOIA – information accessible by other means.

Section 31(1)(a) – law enforcement

This exemption applies where the disclosure of information would or would be likely to prejudice the prevention of crime. IPSA relies on this exemption to withhold the banking details of Magneto. IPSA believes that the disclosure of these details could leave the company more vulnerable to financial crime, in particular fraud and electronic crime, especially with the increase in cyber attacks.

This exemption is subject to a public interest test. IPSA does not consider that the withholding of this information has a negative impact on the understanding of the information. We therefore find that the public interest in withholding this information outweighs the public interest in disclosure at this time.

Sections 40(2) and 40(3A)(a) – personal data

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 2016 (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

IPSA considers that the following are personal data within this definition; names, email addresses and contact numbers of Magneto’s staff; names and email addresses of IPSA staff below the level of director; other personal information. We then considered whether disclosure of this personal data would breach any of the Principles relating to the processing of personal data in the UK GDPR.

The relevant principle is Article 5(1)(a):

Personal data shall be:

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

As IPSA was unable to find a lawful basis on which it could rely, within Article 6 of the UK GDPR, it therefore finds that the information is exempt under section 40.