Edem v Information Commissioner and another

Data protection – Processing of information. The claimant sought the disclosure of the names of three Financial Services Authority officials. The First-tier Tribunal (General Regulatory Chamber) (the FTT) ordered disclosure, but the Upper Tribunal (Administrative Appeals Chamber) reversed that decision. The claimant appealed. The Court of Appeal, Civil Division, in dismissing the appeal, held that to disclose the names of the three individuals would be to disclose their personal data. A name was personal data unless it was so common that, without further information, a person would remain unidentifiable despite its disclosure. Further, the FTT had been wrong to apply the notions in Durant v Financial Services Authority ([2003] All ER (D) 124 (Dec)).

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