Boreham Parish Council v The Information Commissioner

Facts

On 15 July 2024 a member of the public sent Boreham Parish Council a six-part request for information under the Freedom of Information Act 2000, concerning a dog training business operating on the parish recreation ground. Parts 4, 5 and 6 sought, respectively, what provision the Council had made to alert users of the recreation ground to the business's activities, copies of all risk assessments held in relation to the business and its events, and the number of complaints received about the business. The Council responded on 18 July 2024, gave an internal review outcome on 30 July 2024 maintaining its position, and disclosed further material during the Commissioner's investigation, including an appendix to the terms and conditions of use and partially redacted risk assessments. The requestor complained to the Information Commissioner, who on 31 January 2025 issued Decision Notice IC-323744-H0S6 concluding that, on the balance of probabilities, the Council had not disclosed all the information it held within the scope of parts 4, 5 and 6, and requiring further searches, a fresh response and disclosure of the total number of complaints. The Council appealed to the First-tier Tribunal, its grounds asserting simply that it genuinely believed it had supplied as much information as it could.