If the payment was accompanied by any form of compromise or confidentiality agreement I would have thought that S41 1(b) would be more applicable? Don’t local authority accounts have to publish details of ex gratia /non-contractual payments made to employees? I know that exit packages are in NHS accounts. Regards Sandre Sandre Jones Information Governance Lead Nottingham CityCare Partnership 1 Standard Court Park Row Nottingham NG1 6GN Tel: 0115 883 9534 EXT 39534 Mob: 07545 422312 Nottingham CityCare Partnership CIC is registered as a company limited by guarantee. Company Registration Number: 07548602 Registered address: 1 Standard Court, Park Row, Nottingham, NG1 6GN From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Andrew Goodfellow-Swaap Sent: 30 April 2014 12:54 To: [log in to unmask] Subject: Re: [data-protection] A blanket "personal data" response- justified? Warning: This message contains unverified links which may not be safe. You should only click links if you are sure they are from a trusted source. Although I’ve only very briefly looked at this, I’m a little intrigued as to how they can use s.40(2) on, what they ‘ve already asserted as, anonymous information. Isn’t the whole point that they have been unable to identify who is in receipt of those payments? Even if they took the route of “Even though we don’t know, someone else might be able to identify them.”, it certainly seems possible that, as long as there was more than, say three, they could present the information in a manner that would increase the difficulty in associating any particular piece of information with any particular individual. Regards, Andrew Goodfellow-Swaap Senior Information Officer Tel: 0115 876 3855 Information Governance | Nottingham City Council | Loxley House | Station Street | Nottingham | NG3 2NG From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Paul C Sent: 30 April 2014 10:14 To: [log in to unmask] Subject: [data-protection] A blanket "personal data" response- justified? I was wondering whether this kind of blanket response (one of many by this data controller) to a detailed FoI request could be justified in classing monetary amounts, dates and associated information as ‘personal data’? https://www.whatdotheyknow.com/request/payouts_to_officers_of_wirral_co#comment-45480 I’m not sure that agreeing to disclose in accordance with the request (redaction of obvious personal information) could risk identifying persons? 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