I would agree. The names and addresses on the petition would not seem to me to be personal data of the requester and therefore outside the scope of an SAR.
 
You still have to deal with the FOI implications, and the issue there is essentially one of fairness. There you have a mild dilemma.
 
If the requester has kept a copy - disclosing would clearly not be unfair and therefore probably not exempt. If he has no copy it may be unfair (see below) and the safest course would be to not disclose. If he protests on the basis that he has a copy he has shot himself in the foot (FOI exempt as already reasonably accessible). If he protests on the basis that not unfair you can review in the light of any representations he makes - effectively you have to decide if he can satisfy a schedule 2 condition - consent or more likely Condition 6(1).
 
Consent may be relevant, particularly if he was the petition organiser. Before making any decision if that is the case see if there is any indication on the petition itself. If it e.g. refers to the organiser keeping signatories up to date, you may be able to infer consent, and disclosure to this applicant may not be unfair. This is one area where FOI is not necessarily applicant blind as you are considering the particular processing event under DPA.
 

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From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Tim Trent
Sent: 07 December 2007 12:10
To: [log in to unmask]
Subject: Re: [data-protection] Disclose Petition

I think I would refer to the facts of the petition and state that, for the reasons you have stated, the petition itself will not form a part of the information given to him.

Brenda Scourfield wrote:
[log in to unmask] type="cite">
Someone who has made a SAR wrote to us in the past and attached a petition. 
I am copying his letter but wonder whether I shoud also enclose a copy of 
the petition and it's names and addresses. Whilst he sent it in, should I 
now send him a copy of all these third party names and addresses. I think 
perhaps not......

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