Of course so far as Personal Data is concerned we need to remember that
post-Durant not all 'personal data' falls within the DPA definition so s40
FOI would not exempt the type of data which was excluded by the Court of
Appeal from a data subject access request.
s40 would not e.g. exclude personal data held in a manual filing system
which was not within the DPA / Durant definition of a relevant filing
system.
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