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I certainly see it as different - but with a potentially large overlap. many things done with "official authority" are clearly in the public interest.

Main difference it seems to me is that there is less angst with official authority over such questions as necessity and "substantial" public interest.

Take my current role with an NHS Trust. Much is done under explicit legal obligation (e.g. keeping health records) and it is easy to bring most the rest of what we do, outside of legal obligation as such,  under "official authority" - we are required under NHS Act to deliver health services on behalf of the Secy of State and the necessity is not hard to find. However it is not always  so easy to say it is "necessary in the substantial public interest" to do all of those things given the existence of private / insured medicine etc. Sched 1 Part 2 Para 6 doesn't necessarily help either. I could be wrong of course but the 'official authority' means I can rest easy. 

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