Administrative / Public Law · First-tier Tribunal (General Regulatory Chamber)
EG v The Information Commissioner
Checked against the judgment on 7 October 2026 · how we verify
Facts
The appellant, anonymised as EG, made two Freedom of Information requests to Guy's and St Thomas' NHS Foundation Trust on 11 October 2024. One (FOI 1018) concerned CCTV cameras in the Accident and Emergency Department at St Thomas' Hospital; the other (FOI 1019) concerned cameras in the Early Pregnancy and Acute Gynaecology Unit (EPAGU). Both sought camera numbers, operational status, locations and retention periods. The Trust answered FOI 1019 on 1 November 2024, disclosing 19 cameras with high-level location descriptions. On 28 November 2024 it answered FOI 1018, disclosing 52 operational cameras and a 30-day retention period but withholding locations under section 31 of the Freedom of Information Act 2000. On internal review the Trust upheld that refusal and said the FOI 1019 disclosure had been made in error. The Information Commissioner, in Decision Notice IC-433000-S4N8 dated 8 January 2026, concluded that the information was exempt under section 31(1)(a) of the Freedom of Information Act 2000 and under section 31(1)(g) of the Freedom of Information Act 2000, read with section 31(2)(i) of the Freedom of Information Act 2000, and that the public interest favoured maintaining the exemptions. He also found procedural breaches of sections 1, 10 and 17 of the Freedom of Information Act 2000 but required no steps. The appellant appealed to the First-tier Tribunal on 5 February 2026, contending that the prejudice was speculative, that the FOI 1019 disclosure was inconsistent, that less granular disclosure was not considered and that the public interest balance was misapplied.
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