Recently in HO Comms Data Retention regulations ISP list Category

Another Decision by the Information Commissioner's Office, colluding with Whitehall, against the interests of the vast majority of the law abiding public:


ICO.

Information Commissioner's Office

Upholding information rights

Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
T. 0303 123 1113 F. 01625 524510
mail@ico.gsi.gov.uk www.ico.gov.uk

[name]
[address]


Case Reference Number FS50259480

Dear [name]

Freedom of Information Act 2000: Section 50(1)
The Home Office

Please find enclosed a Decision Notice issued under section 50(1) of the Freedom of Information Act 2000. This Decision Notice relates to your complaint about a request for information that you submitted to the Home Office on 2 June 2009.

Your complaint has been carefully considered and the enclosed Decision Notice sets out the reasons for the Commissioner's decision.

If you disagree with any aspect of the attached Decision Notice, you have the right to appeal to the First-Tier Tribunal (Information Rights). Contact details for the First-Tier Tribunal (Information Rights) are included in the Decision Notice.

The Decision Notice includes details about you and the public authority. This is to ensure that there is no doubt as to the request for information to which the Notice relates. The Commissioner will publish the decision on the ICO website, but will remove all names and addresses of complainants.

Although public authorities may choose to reproduce this Decision Notice, the Commissioner would expect that they would take similar steps. The Commissioner considers that these may be necessary in order to comply with the requirements of the Data Protection Act.

Yours sincerely

[name of ICO official]
Senior Case Officer

ICO.


Freedom of Information Act 2000 (Section 50)

Decision Notice

Date: 15 November 2010

Public Authority: Address:

The Home Office
2 Marsham Street
London
SW1P4DF


Complainant: Address:

[address]

Summary

The complainant requested information concerning the names and / or the categories of the Public Communications Providers to which the Secretary of State has given a written notice bringing them under the Communications Data Retention scheme.

The Home Office confirmed it held the requested information but refused to provide it on the basis that it was exempt from disclosure by virtue of sections 31 (law enforcement) and 43 (commercial interests). The Home Office subsequently told the complainant that it did not in fact hold any information about the categories of providers.

The Commissioner has investigated and concluded that section 43(2) was correctly applied. However, he identified procedural shortcomings relating to delay. He requires no steps to be taken.

The Commissioner's Role

1. The Commissioner's duty is to decide whether a request for information made to a public authority has been dealt with in accordance with the requirements of Part 1 of the Freedom of Information Act 2000 (the "Act"). This Notice sets out his decision.

Background

2. The UK Government first introduced legislation on communications data retention in 2001. The Anti-Terrorism, Crime and Security Act 2001 (ATCSA) included at Part 11 provisions for a voluntary regime for the retention of communications data by communications companies. This scheme started in 2003 and involved a number of key communications companies being paid to retain their data, for the purpose of being accessed by the police, security and intelligence agencies and additional public authorities under the Regulation of Investigatory Powers Act 2000 (RIPA).

3. The Notice system arises from The Data Retention (EC Directive) Regulations 2009 which came into force on 6 April 2009. The regulations oblige notified communication service providers (CSPs) to retain communications data for 12 months from the date of communication. The regulations cover fixed, mobile and e-mail telephony, communications over the internet and email data.

4. Although the regulations do not require CSPs to retain the content of communications, CSPs must retain electronic and traffic data that might identify the sender and recipient of the communication, the date and time of the call or e-mail, and the geographical location (and direction of travel) of users.

The Request

5. The complainant wrote to the Home Office on 2 June 2009 making the following request:

Under the Freedom of Information Act, please disclose:

1. the names of the public communications providers and / or
2. the categories of public communications providers

to which the Secretary of State has given a Written Notice, bringing them under the mandatory Communications Data Retention scheme which came into force on 6 April 2009, under Regulation 10 of the Data Retention (EC Directive) Regulations 2009.

6. The Home Office responded on 18 September 2009 confirming that it had issued Notices to "several" Communication Service Providers (CSP's) since the Regulations came into effect on 6 April 2009. It also confirmed that it held the related details the complainant had requested but cited the exemptions in sections 31(l)(a), 31(l)(e) and 31(2) (law enforcement) and 43 (commercial interests) of the Act.

7. The complainant requested an internal review on 22 September 2009.

8. In its internal review correspondence, which it sent to the complainant on 30 November 2009, the Home Office told him that it did not hold some of the requested information, namely information about the categories of communications providers. It apologised for not having established this in its earlier correspondence.

9. In relation to the remaining information within the scope of the
request, the Home Office upheld its decision. It clarified that, where it has not previously cited the relevant subsection, it was relying on subsections 31(2)(a) and 43(2). It additionally cited 31(l)(b).

The Investigation

Scope of the case

10. On 1 December 2009 the complainant contacted the Commissioner to complain about the way his request for information had been handled. In this correspondence, he disputed the exemptions cited by the Home Office in relation to the requested information it confirmed it held. He also acknowledged that the Home Office had ultimately said that no Notices had been issued to categories of Public Communications Providers (which covered the second element cited in the request), "implying that they have been issued to specific individual companies only". This matter is therefore not addressed further in this Decision Notice.

11. The complainant contacted the Commissioner again on 25 March 2010, at which time he specifically asked the Commissioner to consider the following points:

"This request has nothing to do with any individual communication data records, nor for any details of the analysis algorithms etc. It is NOT about the general usefulness or uselessness of Communications Traffic Data in criminal or intelligence investigations. It asks simply for the names of the companies which have been notified/ordered to comply with the European Union inspired Data Retention Regulations.

Even those companies which have not been served with Notices, will still be providing law enforcement with communications data records, when properly asked under section 29 of the Data Protection Act, via the Single Point of Contact system".

12. During the course of his investigation, the Home Office confirmed to the Commissioner that it was no longer relying on the exemption in section 31(2)(a). However, as outlined in the Chronology section below, it belatedly cited section 24(1) (national security). Accordingly, the Commissioner has focussed his investigation on whether the Home Office was correct to cite the exemptions in sections 24(1), 31(l)(a), (b) and (e) and 43(2) of the Act in relation to part (1) of the complainant's request for information.


Chronology

13. Following an attempt at informal resolution, the Commissioner wrote to the Home Office on 22 March 2010 asking it for further explanation of its reasons for citing sections 31 and 43 in relation to the request, including its reasons for concluding that the public interest in maintaining the exemptions outweighed the public interest in disclosure of the information requested. The Commissioner also asked the Home Office to clarify references in its correspondence with the complainant to elements of information which the complainant did not appear to have requested.

14. The Home Office provided a substantive response on 14 May 2010. In relation to the extraneous references it told the Commissioner:

"confusion occurred when we were dealing with two simultaneous requests concerning the Notices".

15. During the Commissioner's investigation, the Home Office raised the issue of further exemptions being applicable in this case. On 30 July 2010, it confirmed in writing that it was additionally citing section 24(1).


Analysis

Exemptions

Section 43 Commercial Interests

16. Section 43(2) provides that:

"Information is exempt information if its disclosure under this Act would, or would be likely to, prejudice the commercial interests of any person (including the public authority holding it)".

17. The term "commercial interests" is not defined in the Act. However, the Commissioner has considered his Awareness Guidance on the application of section 43. This comments that:

"...a commercial interest relates to a person's ability to participate competitively in a commercial activity, i.e. the purchase and sale of goods or services".

18. The Commissioner has also referred, when considering this case, to guidance issued by the Scottish Information Commissioner in relation to commercial interests and section 33(l)(b) of the FOI (Scotland) Act 2002. This guidance states that:

"commercial interests will specifically relate to any commercial trading activity it undertakes, e.g. the ongoing sale and purchase of goods and services, commonly for the purpose of revenue generation. Such activity will normally take place within a competitive environment".

19. The Home Office has explained that the aim of the Notice system within the United Kingdom is to provide clarity to specific companies that they have a responsibility for retaining communications data and what specifically that retained data should be.

20. The Home Office confirmed that it has issued Notices to several
Communications Service Providers (CSPs). However, it explained to the Commissioner that the decision about which companies to serve a Notice upon "is not necessarily obvious".

21. As the withheld information relates to the names of companies providing services relevant to the environment in which communications providers compete (for example to win customers), the Commissioner is satisfied, with respect to the CSPs involved, that the withheld information is commercial in nature and therefore falls within the scope of the exemption contained in section 43(2).

Identifying the applicable interests

22. In this case, the Home Office has argued that the withheld information constitutes "the names of companies who have agreed to retain information about their customers' use of their communication networks".

This misleadingly implies some sort of voluntary agreement. See paragraph 52 below where it the compulsion is clear.

23. Accordingly, the Commissioner understands the applicable interests in this case to be those of companies in the business of providing communications services. After considering the arguments, the Commissioner is satisfied that the potential prejudicial effects relate to the service providers.

24. During his investigation, the Home Office also argued that the release of the names of the Notice holders would have a financial impact on the Home Office itself.

25. With respect to its argument that the release of the names would have a financial impact on the Home Office, the Commissioner considers there is a distinction to be drawn between commercial interests and financial interests. In this case, he is not persuaded by the arguments put forward by the Home Office, that prejudice to its financial interests may affect its commercial interests. He has therefore only considered the prejudice arguments in relation to the commercial interests of the CSPs.

Nature of the prejudice

26. The Information Tribunal in Hogan and Oxford City Council v The Information Commissioner (EA/2005/2006 and EA/2005/0030) commented:

"An evidential burden rests with the decision maker to be able to show that some causal relationship exists between the potential disclosure and the prejudice and the prejudice is, as Lord Falconer of Thoroton has stated "real, actual or of substance' (Hansard HL (VOL. 162, April 20, 2000, col. 827)".

27. The Commissioner's view is that the use of the term "prejudice" is
important to consider in the context of the exemption at section 43. It implies not just that the disclosure of information must have some effect on the applicable interest, but that this effect must be detrimental or damaging in some way.

28. In support of its reasons for withholding the information under section 43, the Home Office argued:

"given the controversial nature of this issue, and past experience, it is clear that disclosure would be commercially damaging".

29. The Commissioner understands that the reference to "past experience" relates to a story in the national press in November 2009 which resulted in some communications companies receiving "an influx of telephone calls from irate customers". The Home Office argued that one of the impacts of this "unexpected news story" was a financial implication with regard to the companies' brand image.

30. The Commissioner is satisfied that, with respect to detriment to the principle of competition and with respect to brand image, there are commercial interests in this case that are capable of being prejudiced. He has therefore gone on to consider whether the disclosure of the information in question in this case would cause such a prejudice.

Likelihood of prejudice

31. With regard to the likelihood of prejudice, the Home Office told the
complainant that "it would be harmful" to the commercial interests of relevant companies if the requested information was released. It also told him that releasing this information "might change consumer behaviour" which, in its view, would be to the detriment of the companies concerned.

32. However, the Home Office referred to both elements of the likelihood test when it told the Commissioner that:

"disclosure of the names of the CSPs who have been served the Data Retention Notices would cause harm to the companies named as it would be likely to cause financial and reputational harm".

33. Having taken account of the arguments put forward by the Home Office in support of this statement, the Commissioner considers them more relevant to the "would be likely to prejudice" limb. This second limb of the test places a lesser evidential burden on the public authority to discharge and the Commissioner has therefore considered whether, in this case, the lower threshold is met.

34. Importantly, when considering prejudice to a third party's commercial interests, the Commissioner's view is that the public authority must have evidence that this does in fact represent or reflect the view of the third party. The public authority cannot speculate in this respect - the prejudice must be based on evidence provided by the third party, whether during the time for compliance with a specific request or as a result of prior consultation, and the relevant arguments are those made by the third party itself. This approach has been confirmed by the Information Tribunal in the case of Derry City Council v ICO (EA/2006/0014).

35. In response to the Home Office's claim that releasing the requested information might change consumer behaviour, the complainant protested:

"That is just unfounded speculation. ... Predictions of consumer choices and market trends in the telephone, mobile phone and internet markets depend on many factors, and is something well beyond the expertise of the Home Office ...The Home Office does not appear to have consulted any of the commercial internet service providers nor any telecommunications companies ....who are in a far better position than the Home Office to assess any 'consumer behaviour' in several complicated, multiple market places".

36. The Home Office failed to address this point in its internal review
correspondence. However, during the course of his investigation, the Home Office told the Commissioner that it received representations from service providers during the development of the legislation, arguing that they should not be publically identified "because of the risk that customers would transfer their business to services (or companies) not named on a retention Notice". In this respect, the Commissioner notes the ease with which consumers can move between service providers.

37. On the subject of data retention, the Commissioner considers it reasonable to assume that most customers expect their service providers to retain some data about them for business purposes, for example billing. However, in his view, it is not unreasonable to consider that some customers will have a negative perception of how companies named on a Notice are protecting the privacy of their data, given the nature and extent of the data being retained and the length of time it is kept.

38. The Home Office also argued that identifying which CSPs have been served Notices may prejudice the commercial interests of the communications providers "by revealing the capabilities and inabilities of individual providers". Further, it told the Commissioner that identifying which CSPs have been served Notices may prejudice the commercial interests of the communications providers "in their ability to be competitive when providing services to the public sector".

The Home Office did not expand on this point.

39. The Commissioner has reflected on the actual wording of the request in this case when considering these arguments. He has also taken into account the extracts from the third party representations which the Home Office provided on the subject of disclosure.

40. Examples of these representations are as follows:

"It is my view that such action would represent potential brand damage to [company name redacted] and attendant financial and commercial risk".

"Confidentiality must be assured for the CSP....... in short, the status
quo should be maintained and non disclosure of CSP details to the public should be retained".

"We do not, as such, have any problem with the release of the names of those with notices in itself, as most people assume that we fulfil such obligations, as long as each and every CSP and ISP is on the list. What we do not want is to be part of a select few whose names are made public ... this practice would leave those publicly named with a disadvantage, both reputationally and competitively. ... It is not the naming that concerns us but the creation of an uneven playing field in such a crucial and highly competitive market which may impact our customer's perception (and by default our brand)".

"It should be a level playing field therefore every company should be under the same obligations".

41. Taking into account the arguments put forward by the Home Office and the representations of the third parties whose commercial interests are alleged to be at issue in this case, the Commissioner is satisfied that the public authority has demonstrated a real or significant likelihood of prejudice resulting to the commercial interests of third parties through the disclosure of the information in question. Therefore, the Commissioner finds the exemption provided by section 43(2) is engaged.

Both the Home Office and the Information Commissioner have ignored the argument made to them in the the correspondence, that because the Home Office is only serving Notices on some of the Communications Services Providers, presumably the largest ones and that they are paying them millions of pounds of financial compensation, that this is very far from a "level playing field". from the perspective of their smaller rivals or of new entrants into the market.

The Home Office is too naive and technologically incompetent to know if the money claimed for extra disk storage and database infrastructure and personnel to handle the vast amount of Data Retention is not also in fact secretly subsidising say the customer billing systems of these companies.

Perhaps we should see if Ofcom and the European Commission will investigate such secret financial subsidies to some favoured companies.

Have any Home Office civil servants or Labour politicians retired to take up directorships or consultancy jobs with any of these large Communications Service Providers ?

Public interest arguments in favour of disclosing the requested information

42. The Home Office acknowledged that release of the requested
information would give the public the opportunity to identify which providers have been asked to retain information about their customers' use of their networks. If this were to happen, the Home Office recognises that customers "would then be able to decide if they still wished to use these providers".

43. It also recognised that, in providing the names of the companies who have been served Notices, the public would be in a position to hold them accountable "for the safe, correct and legal use of their data".

44. It also told the complainant that releasing the requested information would increase the transparency of how the Home Office has implemented the European Directive, giving the public the opportunity to see how the regulations are used by government.

45. In correspondence with the Commissioner, the Home Office
acknowledged the public interest in openness and transparency about the use of public funds. The Commissioner understands this to refer to the fact that the Regulations give the Secretary of State a discretionary power to reimburse any expenses incurred by a CSP in complying with the Regulations.

Public interest arguments in favour of maintaining the exemption

46. The public interest factors in favour of withholding the information
requested should be seen in the context of, and in connection with, the prejudice-based arguments, described above, which the Home Office has made to the Commissioner.

47. According to the Home Office Explanatory Memorandum to the Data Retention (EC Directive) Regulations, communications data has proved valuable for law enforcement purposes, for example in identifying suspects, tracing criminal contacts, placing people in specific locations at specific times, and confirming or disproving suspects' alibis. Nevertheless, the Home Office recognised that the retention of data is a controversial issue. In this respect, the Commissioner notes the extent of the media coverage on the topic of opposition to the increasing amount of surveillance in Britain.

48. Arguing against disclosure, the Home Office told the complainant that releasing the names of the companies who have agreed to retain information about their customers' use of their communications networks "is likely to result in customers changing their supplier", which would have a detrimental impact on the commercial revenues of those companies. It also said that a reduction in the number of customers "is likely to threaten their ability to secure finance on world money markets and harm their brand image, as well as offer employment".

49. In this respect, the Commissioner notes the concerns expressed by the service providers, when they contacted the Home Office, in relation to the adverse effect of disclosure on their commercial interests. As an example, one company stated that it willingly met all its obligations laid down by the law as well as those it fulfils "in what it sees as its corporate responsibility". The Commissioner notes, however, that the company qualified this, stating that it did so "on the assumption that there will be no competitive disadvantage by doing so".

50. The Home Office argued that a reduction in customer numbers as a result of damage to its brand image would be likely to weaken a CSP's position "in what is a very competitive environment". It went on to argue that it would not be in the public interest if the credit ratings and brand images of service providers were harmed as this would not only affect their ability to offer employment but also their ability to fund future improvements to their networks and services.

We would be reluctant to trust the Treasury on such matters. The Home Office has no expertise or knowledge of such things whatsoever, so they should not be allowed to speculate about them, which is just what they have done, exactly contrary to the ICO Guidance.

51. The Commissioner gives weight to the argument that the impact of disclosure would potentially not only be on the companies themselves but also on their employees and those members of the public who use their services.

52. The Home Office also told the complainant:

"It is also worth noting that these companies have no option but to comply with these regulations".

This makes a nonsense of the claim in para 22 above that the companies had somehow voluntarily "agreed" to retain information about their customers' use of their communications networks i.e. our data.

53. The Commissioner recognises the public interest in ensuring that companies are able to compete fairly. In this respect, the Commissioner understands that on receiving a Notice, CSPs must buy or construct data retention solutions that meet the needs of UK law enforcement and intelligence agencies in terms of their ability to retrieve information "without delay" as well as meeting the commercial requirements of the provider.

Balance of the public interest arguments

54. The Commissioner is mindful of the strong public interest arguments for disclosure of the information in this case. However, in balancing the public interest arguments, the Commissioner is mindful that he has found that disclosure of the withheld information would be likely to cause actual prejudice to the commercial interests of the third parties concerned.

55. Notwithstanding this, the Commissioner accepts that there are many scenarios where companies may be prepared to accept greater public access to information about their business as a cost of doing business with the public sector: the overall value of public sector contracts is a great incentive to tender for them. In this case, however, the service providers who receive Notices are not involved in the decision-making process as to who receives a Notice. In other words, they neither volunteer to participate in the scheme, nor submit a tender for consideration. Rather, they are required by the Home Office to comply.

56. However, he must take account too of the level of prejudice that may be caused to the commercial interests of the CSPs and the wider effects that any such prejudice would have on the public, particularly the customers to which they provides services.

57. In this case, he considers that those publicly named would be
disadvantaged both reputationally and competitively as a result of negative customer perception about the collection and retention of communications data.

58. Having carefully balanced the opposing factors involved, the
Commissioner has concluded that, in all the circumstances of the case, the public interest in maintaining the exemption outweighs the public interest in disclosure of the information in this instance. Accordingly his decision is that the Home Office correctly withheld the requested information by reference to section 43(2).

The Home Office and the Information Commissioner have ignored the fact, pointed out to them in the correspondence, that if any such major shifts of consumers from CSPs who have been served with a Notice under the Data Retention regulations does actually happen, then they can simply serve Notices on to the CSPs where the privacy and security aware law abiding members of the public have moved their business to.

Yet again The Information Commissioner seems to be colluding with Whitehall rather than standing up for the rights of the law abiding tax paying public.


Other exemptions

59. As the Commissioner has concluded that the exemption in section
43(2) was correctly applied, he has not gone on to consider the other exemptions cited by the Home Office in this case.


Procedural Requirements

60. Section 10(1) provides that:-

"Subject to subsections (2) and (3), a public authority must comply with section 1(1) promptly and in any event not later than the twentieth working day following the date of receipt."

61. Section 17(1) provides that:-

"A public authority which, in relation to any request for information, is to any extent relying on a claim that any provision of Part II relating to the duty to confirm or deny is relevant to the request or on a claim that information is exempt information must, within the time for complying with section 1(1), give the applicant a notice which -

(a) states that fact,

(b) specifies the exemption in question, and

(c) states (if that would not otherwise be apparent) why the exemption applies."

62. In this case, the complainant's request was received by the Home Office on 2 June 2009 but the Home Office did not issue its refusal letter until 18 September 2009. It therefore took the Home Office more than 50 working days to respond to the information request. Accordingly, the Commissioner finds that, in failing to confirm or deny within 20 working days whether it held the requested information, the Home Office breached the requirements of section 10(1) and that it also breached section 17(1) by failing to provide the details required by that section within 20 working days.

The Decision

63. The Commissioner's decision is that the public authority dealt with the following elements of the request in accordance with the requirements of the Act:

• it correctly applied section 43(2).

However, the Commissioner has also decided that the following elements of the request were not dealt with in accordance with the Act:

• the Home Office breached section 10(1) by failing to inform the complainant whether it held the requested information within 20 working days of the request; and

• it breached section 17(1) by failing to issue the refusal notice within the statutory time limit.

Steps Required

64. The Commissioner requires no steps to be taken.

Other Matters

65. Part VI of the section 45 Code of Practice makes it desirable practice that a public authority should have a procedure in place for dealing with complaints about its handling of requests for information, and that the procedure should encourage a prompt determination of the complaint. As he has made clear in his 'Good Practice Guidance No 5', published in February 2007, the Commissioner considers that these internal reviews should be completed as promptly as possible. While no explicit timescale is laid down by the Act, the Commissioner has decided that a reasonable time for completing an internal review is 20 working days from the date of the request for review. In exceptional circumstances it may be reasonable to take longer but in no case should the time taken exceed 40 working days. The Commissioner is concerned that in this case, it took over 40 working days for an internal review to be conducted, despite the publication of his guidance on the matter.

Time and time again the Home Office and other Public Bodies simply shrug off the fact that they have cynically broken the law (FOIA sections 10(1) and 17(1)) and have also totally ignored the ICO's "Good Practice Guidance"

When will there be some financial or criminal sanctions which can be applied to these bureaucrats when they obstruct our right to public information ?

Right of Appeal

66. Either party has the right to appeal against this Decision Notice to the First-tier Tribunal (Information Rights). Information about the appeals process may be obtained from:

First-tier Tribunal (Information Rights)
GRC & GRP Tribunals,
PO Box 9300,
Arnhem House,
31, Waterloo Way,
LEICESTER,
LEI 8DJ

Tel: 0845 600 0877
Fax: 01162494253
Email: informationtribunal@tribunals.asi.aov.uk.
Website: www.informationtribunal.gov.uk

If you wish to appeal against a decision notice, you can obtain information on how to appeal along with the relevant forms from the Information Tribunal website.

Any Notice of Appeal should be served on the Tribunal within 28 calendar days of the date on which this Decision Notice is sent.

Dated the 15th day of November 2010
Signed

[signature]

Jon Manners
Group Manager
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF


Legal Annex

Commercial interests.

Section 43(1) provides that -
"Information is exempt information if it constitutes a trade secret."
Section 43(2) provides that -
"Information is exempt information if its disclosure under this Act would, or would be likely to, prejudice the commercial interests of any person (including the public authority holding it)."
Section 43(3) provides that -
"The duty to confirm or deny does not arise if, or to the extent that, compliance with section l(l)(a) would, or would be likely to, prejudice the interests mentioned in subsection (2)."

How many months or years will this Complaint to the Information Commissioner's Office drag on for ?

Information Commissioner's Office,
Wycliffe House,
Water Lane,
Wilmslow,
Cheshire,
SK9 5AF


Email to: mail@ico.gsi.gov.uk

Freedom of Information Act 2000 Complaint against the Home Office
regarding the non-disclosure of the Names of the Communications
Service Provider companies which have been formally Notified under
the Data Retention (EC Directive) Regulations 2009


Tuesday 1st December 2009

Dear Sir or Madam

Please find attached my email correspondence with the Home Office and the Information Commissioner's Office, regarding my Freedom of Information Act 2000 request from the 2nd of June 2009.

1) the Names of the Public Communications Providers

and / or the

2) the Categories of Public Communications Providers

to which the Secretary of State has given a Written Notice, bringing them under the mandatory Communications Data Retention scheme, which came into force on 6th April 2009, under Regulation 10 of the

The Data Retention (EC Directive) Regulations 2009

http://www.opsi.gov.uk/si/si2009/draft/ukdsi_9780111473894_en_1

The Home Office eventually refused to disclose any of the requested Names of the Public Communications Providers who have been issued with Notices whatsoever, apart from saying that they did hold such information, and that there were no Notices issued to "Categories
of Public Communications Providers" (a term from the text of the Data Retention (EC Directive) Regulations 2009), implying that they have been issued to specific individual companies only.

After informal contact from the ICO, after the Home Office failed to acknowledge let alone respond with a substantial reply, the Home Office did eventually reply.

The Home Office also conducted an Internal Review of the handling of the timing of their response and, admitted to failing to respond with the 20 working day statutory limit.

The Home Office have, after the eventual Internal Review, claimed Exemptions under

Section 31(1) and (2)

"Information which is not exempt information by virtue of section
30 is exempt information if its disclosure under this Act would, or
would likely to, prejudice-
(1)(a) the prevention or detection of crime
(1)(b) the apprehension or prosecution of offenders
(1)(e) the operation of the immigration controls.

(2)(a) the purpose of ascertaining whether any person has failed to
comply with the law. "

"Arguments against disclosure

If the information were to be released, a considerable degree of harm would be caused to the law enforcement purposes that the regulations are designed to serve (including in relation to
immigration). Disclosure would damage the effectiveness of the arrangements in place and therefore law enforcement, as a result of the likely harm to the working relationship between the law enforcement community and communications providers in relation to this issue. This is not in the public interest. "

I fail to understand how making public just the names of the Communications Service Providers will in way "damage the effectiveness of the arrangements in place and therefore law
enforcement, as a result of the likely harm to the working relationship between
the law enforcement community and communications providers in relation to this issue"

It will have no effect whatsoever on the Single Point of Contact system, through which Police forces and Intelligence Agencies etc.channel their Data Protection Act 1998 section 29 requests for Communications Data, which will still operate with Internet Service
Providers and Telecommunications companies which have *not* been formally Notified that they are subject to the Data Retention Regulations.

As the Home Office's Internal review itself notes, those companies which have been Notified under these Data Retention (EC Directive) Regulations 2009, "have no option but to comply with these regulations.", whether they have been named in public or not.

There are, however, no legal sanctions available in the Regulations if a Communications Service Provider completely or partially fails to comply with them. It would be inconceivable for a public limited company to fail to do so, if it their own staff and shareholders were actually aware that the company had been Notified under the Regulations. This beneficial aspect of transparency has not been considered by the Home Office.

The Home Office have also claimed an Exemption under:

Section 43(2)

"Information is exempt information if its disclosure under this Act would, or would be likely to, prejudice the commercial interests of any person (including the public authority holding it). "

When I asked for an Internal Review of this refusal, I pointed out that, according to the Information Commissioner's Office Guidance on such Commercial interests exemptions, that they should have contacted the third party companies concerned.

The Home Office have not bothered to do so, and they have not even contacted the relevant independent industry and market regulatory body OFCOM (www.ofcom.org.uk) .

Contrary to the ICO guidance,

Information Commissioners Office FOIA Guidance - Section 43 - Commercial detriment of third parties


http://www.ico.gov.uk/upload/documents/library/freedom_of_informatio
n/detailed_specialist_guides/commercialdetrimentof3rdparties.pdf


The Home Office has speculated wildly, on possible future market conditions in areas completely out of their expertise, such as future consumer behaviour in the market, credit ratings, brand images, the ability to raise finance etc.

"Arguments against disclosure

Releasing the names of the companies who have agreed to retain information about their
customers' use of their communication networks is likely to result in customers changing their supplier which would have a detrimental impact on the commercial revenues of these companies. A reduction in the number of customers is also likely to threaten their ability to secure finance on world money markets and harm their brand image, as well as offer employment. This is likely to weaken their position in what is a very competitive environment. It
is also worth noting that these companies have no option but to comply with these regulations.

Balance

I am satisfied that it is not in the public interest to release details of which telecommunication companies have been asked to retain information about their customers' use of their networks. I
am of the view that it is likely customers would change suppliers which would weaken the market share of those served with notices to retain information. If the credit ratings and brand images of these companies were to be harmed this is likely to reduce their abilities to raise funds for future improvements to their networks and services, as well as offer employment, which is not in the public interest. "

My FOIA request does *not* ask for details of the amount of financial compensation (or state subsidy) being promised to individual companies which have been Notified, only for the Names of the companies affected by the Regulations.

Small or Medium sized Internet Service Providers or Telecommunications companies, or New Entrants into the market(s), who are not receiving state subsidies from the Home Office, for the
implementation of the Data Retention Regulations, may very well have something to say to the Competition Authorities, both in the UK and at the European Union level, but they need to know for sure which of their bigger rivals are being Notified and therefore subsidised.

More generally, Retained Communications Data is just as likely to be used in *Civil Court* cases e.g. a Court Orders in Copyright Infringement or Divorce cases.

So there is a much wider Public Interest in the disclosure of names of the companies which are subject to these Regulations, which is *not* directly concerned with Criminal Law enforcement, which is all that the Home Office seems to have considered.

Please contact me if you need any further details, in order to consider this complaint.

Yours sincerely

[name]
[address]
[email]

The text of the Home Office's delayed Internal Review:

The Home Office has rejected the Freedom of Information Act request made
on 2nd June 2009 i.e. after 78 working days, and a complaint to the Information Commissioner's Office.

It is hard to believe that any of the Fixed Line or Mobile Phone companies would not be on this list of companies to which the Data Retention (EC Directive) Regulations 2009 have been made to apply, so it is really only which Internet Service Providers or the ISP divisions of larger companies, have or have not, been forced to comply with the Regulations, which are of interest.

[Home Office logo]
Direct Communications Unit
2 Marsham Street, London SW1P 4DF
Switchboard 020 7035 4848 Fax: 020 7035 4745 Textphone: 020 7035 4742
E-mail: public.enquiries@homeoffice.gsi.gov.uk Website: www.homeoffice.gov.uk


[name]
[email]

Reference: Tnnnn/n


Dear [name]

Thank you for your e-mail of 02/06/2009 requesting the names of companies that have received notices under the Data Retention (EC Directive) Regulations 2009. I am writing further to my letter of 26 August to provide you with a final response. I am sorry for not meeting the 16 September date as indicated in that letter.

I can confirm the Home Office has issued Notices to several Communication Service Providers (CSPs) since the Regulations came into effect on 6 April this year. You asked for further details, specifically for the names of the CSPs that have received the Notices and for the dates on which they were sent.

I am writing to confirm that the Home Office holds the information that you requested. However I am not obliged to disclose it to you. After careful consideration we have decided that this information is exempt from disclosure by virtue of Section 31 and Section 43 of the Freedom of Information Act. These provide that information can be withheld where disclosure would prejudice law enforcement operations and harm commercial interests respectively. The public interest in this instance falls in favour of non-disclosure.

If you are dissatisfied with this response you may request an independent internal review of our handling of your request by submitting your complaint within two months to the below address.



Information Rights Team
Information and Record Management Service
Home Office
4th Floor, Seacole Building
2 Marsham Street
London
SW1P 4DF
Email: info.access@homeoffice.gsi.gov.uk

During the independent review the department's handling of your information request will be reassessed by staff who were not involved in providing you with this response. Should you remain dissatisfied after this internal review, you will have a right of complaint to the Information Commissioner as established by section 50 of the Freedom of Information Act.

I realise that you may be disappointed with this response. However we have considered the application of exemptions with great care in this case, and the Home Office always seeks to provide as much information as it is able to.

Yours sincerely

[name of civil servant]


Annex
Section 31 of the FOIA law enforcement interests

Section 31(1)a refers to the prevention or detection of crime. The European Directive on Data Retention was introduced for the prevention and detection of Serious Crime.

Section 31 of the FOIA provides for the protection for law enforcement interests; its application turns on whether disclosure would be likely to prejudice those interests. The law enforcement organisations have confirmed the release of this information is likely to reduce the utility of retained data and thereby reduce law enforcement's ability to prevent and detect crime.

Paragraphs within section 31 of particular relevance are;

• Section 31(1)a; information prejudicial to the prevention or detection of crime.

• Section 31(1)e relates to the operation of the immigration controls; the UK Borders Agency use communications data in policing immigration.

• Section 31(2) refers to additional purposes under which disclosure of information can be withheld if there would be a prejudicial effect on law enforcement.

These Regulations are not about the usefulness of Communications Data in general, or about access to it by Law Enforcement bodies.

It is debatable just how useful the mass retention of millions of innocent people's communications data, which is up to a year out of date, really is, rather than the hundreds of thousands of supposedly narrowly targeted request for Communications Data made each year.

The Information Commissioner's Office latest Guidance (August 2009:

Section 31 Law Enforcement (AG 17) (.pdf)

is clear:

A public authority cannot withhold information, or refuse to confirm or deny that it holds information, unless the disclosure would, or would be likely to, prejudice any of the purposes or activities listed in the exemption. The prejudice must be genuine and of substance and its likelihood must be decided on a case-by-case basis. A public authority must therefore explain why the disclosure of the specific information requested would, or would be likely to, cause prejudice. It is not acceptable to say that disclosure of that type or class of information would, or would be likely to, cause prejudice.

Remember this FOIA request has nothing to do with any individual Communication Data records, or for any details of the analysis algorithms etc., it is simply for the names of the companies which have been ordered to comply with the Data Retention Regulations.

Even those companies which have not been served with Notices, will still be providing Law Enforcement with Communications Data records when properly asked under section 29 of the Data Protection Act, via the Single Point of Contact system.

Therefore it is quite likely that the Information Commissioner's Office will reject this Section 31 exemption, if it goes that far.

Section 43 of the FOIA provides an exemption from disclosure of information where that information would harm commercial interests. It is possible that releasing this information might change consumer behaviour to the detriment of those companies that have been issued with Notices.

That is just unfounded speculation.

"might change consumer behaviour" - by how much, over what period ?

Predictions of consumer choices and market trends in the telephone, mobile phone and internet markets depends on many factors, and is something well beyond the expertise of the Home Office.

Section 43 provides an exemption from disclosure of information where that information would harm commercial interests.

Releasing the requested information would increase the transparency of how the Home Office has implemented the European Directive. However, this public benefit is not sufficient to balance the detrimental effect upon law enforcement and separately the commercial interests at stake. It is therefore not in the public interest to disclose this material.

The Section 43 "justification" totally ignores the Information Commissioner's Office FOIA Guidance on this subject, following the rulings of the Information Tribunal:

Section 43 - Commercial detriment of third parties (.pdf)

[...]

A public authority which believes that the commercial interests of a third party will, or are likely to, be prejudiced must explain why this is the case.

• It will not be enough for the public authority to simply speculate as to why the third party's commercial interests would, or would be likely to be prejudiced; the third party where possible must be asked for their opinions.

• If the third party does not put forward any concerns regarding any prejudice to its commercial interests then a public authority should not speculate on their behalf.

[...]

The Home Office does not appear to have consulted any of the commercial internet service providers ad telecommunications companies,or even their industry competition regulator Ofcom about this, so they are just speculating about market conditions, which they have no expertise in.

The FOIA request does not ask for details of the amount of financial compensation (or state subsidy) being promised to individual companies, only for the names of the companies affected by the Regulations.

Smaller Internet Service Providers, or new entrants into the market, who are not receiving state subsidies from the Home Office, for the implementation of the Data Retention Regulations, may very well have something to say to the competition authorities, both in the UK and at the European Union level.

Therefore it is very likely that the Information Commissioner's Office will reject this Section 43 exemption, if it goes that far.

Communications Data is not just of interest to Law Enforcement public authorities, there can be a National Security aspect as well. It is somewhat surprising that the Home Office did not try to use the Section 24 National Security exemption as well.

However, Retained Communications Data is just as likely to be used or abused in civil court cases e.g. a Court Order in Copyright infringement or Divorce cases,

So there is a much wider Public Interest in the names of the companies which are subject to these Regulations, which is not directly concerned with Criminal Law enforcement

This FOIA request has, unusually, already sparked off an Internal Review and a complaint to the Information Commissioner's Office, even before this Substantial Reply / Rejection.

That Internal Review about the apparent silence and lack of any response (despite email Read Receipt acknowledgments of the original 2nd of June 2009 request and of the later reminder emails.

Hopefully the results of that Internal Review will be available by the end of this week.

Spy Blog will put in another Internal Review request (without much hope of the Home Office changing their minds), before having to complain to the Information Commissioner.

Home Office FOIA Internal Review - now delayed 3 times

There appears to be something seriously wrong with the FOIA request management systems in the Home Office.

Even this Internal Review has now been delayed 3 times !

From: [IMS civil servant]@homeoffice.gsi.gov.uk>
To: "[email]
Date: Tue, 01 Sep 2009 12:07:56 +0100

Dear [name]

Further to my correspondences below, I regret to inform you that your
internal review (Time Complaint) is yet to be completed. I am
experiencing difficulty In ascertaining the specifics of the case and
have elevated these issues up the managerial chain. I apologise for
this ongoing delay and again assure you that I am doing everything in my
power to get the response issued to you as soon as possible. I now aim
to respond to you by no later than the 25th September 2009.

You have the right of complaint to the Information Commissioner, as
established by section 50 of the Freedom of Information Act. Please
find below the address you can write to him at:

Wycliffe House

Water Lane

Wilmslow

Cheshire SK9 5AF

Many Thanks

{IMS civil servant]
Information Management Service | Financial and Commercial Group
Ground Floor | Seacole Building | Home Office | 2 Marsham Street |
London SW1P 4DF
Switchboard Number: 0207 035 4848


-----Original Message-----
From:{IMS civil servant}
Sent: 14 August 2009 11:39 AM
To: [email]
Subject: nnnnn - [name] - Internal Review - Time Complaint -
Further Deadline extension and apology

Dear [name]

Further to my correspondence on the 30th July 2009, I must once again
inform you that your Internal Review (Time Complaint) has not yet been
completed. I apologise for this delay and assure you that I am doing
everything within my power to complete this Time Complaint review and am
also still pushing for the response to be issued in regard to your
original request for information.

I now aim to respond to you by no later than the 1st September 2009.

If you have any questions please feel free to contact me.

Many Thanks


[IMS civil servant]
Information Management Service | Financial and Commercial Group
Ground Floor | Seacole Building | Home Office | 2 Marsham Street |
London SW1P 4DF
Switchboard Number: 0207 035 4848


-----Original Message-----
From: [IMS civil servant]
Sent: 30 July 2009 3:14 PM
To: [email]
Subject: nnnnn - Internal Review - Time Complaint - Deadline extension
and apology letter

Dear [name]

I write further to my original correspondence below sent on the 20th
July 2009. I regret to inform you that the Internal Review (Time
Complaint) has not yet been completed. This is due to a number of
issues surrounding this case. I offer my sincerest apologies and now
aim to complete the review no later than the 14th August 2009.

In the mean time I will still be pressing that a response to your case
should be issued as soon as possible.

If you have any questions please feel free to contact me.

Yours Sincerely

[IMS civil servant]
Information Management Service | Financial and Commercial Group
4th Floor | Seacole Building | Home Office | 2 Marsham Street | London
SW1P 4DF
Switchboard Number: 0207 035 4848


-----Original Message-----
From:[IMS civil servant]
Sent: 20 July 2009 9:50 AM
To: [email]
Subject: nnnnn - Internal Review - Time Complaint - Acknowledgement
letter

[name]

I am writing to you in response to your request for an Internal Review
(Time Complaint) of the handling of your request within your email
received by the Home Office on the 16th July 2009.

I will be conducting the procedural review and the request case number
is nnnnn We aim to send you a response to this complaint by the 29th
July 2009. I will be in touch again shortly, but please do not hesitate
to contact me if you have any queries about the handling of your request
in the meantime.

Many Thanks

[IMS civil servant]
Information Management Service | Financial and Commercial Group
4th Floor | Seacole Building | Home Office | 2 Marsham Street | London
SW1P 4DF
Switchboard Number: 0207 035 4848


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solely for the use of the individual or entity to whom they are addressed.I
f you have received this email in error please return it to the address
it came from telling them it is not for you and then delete it from your system.

This email message has been swept for computer viruses.

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The original of this email was scanned for viruses by the Government Secure Intranet virus scanning service supplied by Cable&Wireless in partnership with MessageLabs. (CCTM Certificate Number 2009/09/0052.) On leaving the GSi this email was certified virus free.
Communications via the GSi may be automatically logged, monitored and/or recorded for legal purposes.


Finally after a request for an Internal Review (which itself has been delayed 3 time - see next blog article), aand a complaint to the Information Commissioner's Office (which was to be resolved informally), here is the sort of reply we were expecting in the early part of June 2009:


From: public.enquiries@homeoffice.gsi.gov.uk Add contact
To: [email]
Date: Wed, 26 Aug 2009 16:14:53 +0100

Reference : Tnnnn/9

Thank you for your e-mail enquiry of 02/06/2009 11:06:56 AM

An Interim reply is attached.

---------------------

Direct Communication switchboard 020 7035 4848
Fax: 020 7035 4745
Textphone: 020 7035 4742
E-mail: public.enquiries@homeoffice.gsi.gov.uk Website: www.homeoffice.gov.uk

[email]
[name]


Reference: Tnnnn/9

Dear [name],

Thank you for your e-mail of 02/06/2009 requesting the names of companies that have received notices under the Data Retention (EC Directive) Regulations 2009. I can confirm that this information is held, but I regret that we are unable to send you a full response to your request within 20 working days, as required by the Freedom of Information Act. This is because we are considering whether or not the information should be disclosed.

In reaching that decision, we need to consider whether Section 31 (Prejudice to Law Enforcement Concerns) or Section 43 (Commercial Interests) apply and whether disclosure of the information would be in the public interest.

I would like to apologise for this delay and for any inconvenience that this may cause. I would like to assure you that we are dealing with your request as a matter of urgency, and that we will send you a full reply as soon as possible. We now aim to send you a full reply by 16 September

If you have any queries about the handling of your information request in the meantime then please do not hesitate to contact me.

Yours sincerely,

[name of civil servant]

About this blog

This United Kingdom based blog has been spawned from Spy Blog, and is meant to provide a place to track our Freedom of Information Act 2000 requests to United Kingdom Government and other Public Authorities.

If you have suggestions for other FOIA requests,  bearing in mind the large list of exemptions, then email them to us, or use the comments facility on this blog, and we will see  what we can do, without you yourself having to come under the direct scrutiny of  "Sir Humphrey Appleby" or his minions.

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Please feel free to email us your views about this website or news about the issues it tries to comment on:

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Gary McKinnon is facing extradition to the USA under the controversial Extradition Act 2003, without any prima facie evidence or charges brought against him in a UK court. Try him here in the UK, under UK law.
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Petition to the European Commission and European Parliament against their vague Data Retention plans
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Home Office Watch blog, "a single repository of all the shambolic errors and mistakes made by the British Home Office compiled from Parliamentary Questions, news reports, and tip-offs by the Liberal Democrat Home Affairs team." - does this apply to the Conservative - Liberal Democrat coalition government as well ?

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Cracking the Black Box - "aims to expose technology that is being used in inappropriate ways. We hope to bring together the insights of experts and whistleblowers to shine a light into the dark recesses of systems that are responsible for causing many of the privacy problems faced by millions of people."

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Open Rights Group - Petition against the renewal of the Interception Modernisation Programme

Yes, Minister

Yes, Minister Series 1, Episode 1, "Open Government" First airtime BBC: 25 February 1980

"Bernard Woolley: "Well, yes, Sir...I mean, it [open government] is the Minister's policy after all."
Sir Arnold: "My dear boy, it is a contradiction in terms: you can be open or you can have government."

FOIA Links

Campaign for the Freedom of Information

Office of the Information Commissioner,
who is meant to regulate the Freedom of Information Act 2000 in England, Wales and Northern Ireland.

Scottish Information Commissioner,
who similarly regulates the Freedom of Information Act (Scotland) 2002

Information Tribunal - deals with appeals against decisions by the Information Commissioners.

Freedom of Information pages - Department for Constitutional Affairs

Friends of the Earth FOIA Request Generator and links to contact details for Central Government Departments and their Publication Schemes

UK Government Information Asset Register - in theory, this should point you to the correct Government documents, but in practice...well see for yourself.

Access all Information is also logging some FOIA requests

foi.mysociety.org - prototype FOIA request submission, tracking and publication website

Blog Links

Spy Blog

UK Freedom of Information Act Blog - started by Steve Wood, now handed over to Katherine Gundersen

Your Right To Know - Heather Brooke

Informaticopia - Rod Ward

Open Secrets - a blog about freedom of information by BBC journalist Martin Rosenbaum

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