Alan M Dransfield

Email: alanmdransfield@gmail.com

10/05/26

ICO Human Resources Team

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire SK9 5AF

CC: Department for Science, Innovation and Technology; Ministry of Justice

Subject: Evidence relevant to ICO workplace culture and the treatment of FOI requesters under Section 14 FOIA

Dear Sir or Madam,

I write to draw your attention to evidence contained in the transcript of the Independent Commission on Freedom of Information, dated 20 January 2016. In my respectful view, this evidence is relevant not only to FOIA policy, but also to the wider culture, governance standards, and public-facing conduct expected of the Information Commissioner’s Office and those operating within the FOI regime.

The central concern is that senior public-sector figures appeared to discuss Section 14 FOIA not merely as a statutory test applied to an individual request, but as a label or character assessment attached to the requester.

Key passages from the transcript

Speaker / context	Relevant wording
Christopher Graham, then Information Commissioner	“public authorities who are complaining about how terrible life is and how burdensome it is because of all of these sad, mad and bad people who are bombarding them with questions are most reluctant to use the section 14 power”
Ian Readhead, National Police Chiefs Council	“We readily employ vexatiousness where we think that somebody fits within that exemption.”
Ian Readhead, National Police Chiefs Council	“it’s sometimes difficult to deal with a person who is just making the ridiculous application and it doesn’t necessarily fit the vexatious definition within the exemption.”
Mark Wise, National Police Chiefs Council	“I think part of the Act should allow us or encourage us, when we’re training across the UK, in encouraging our FoI staff to actually challenge the applicant and ask why they want the information.”
Lord Howard quoting the evidence	“The time has now come where a real analysis of the true and pure motivations of some applicants should be addressed.”

Source: Independent Commission on Freedom of Information, oral evidence transcript, 20 January 2016, evidence of Christopher Graham, Ian Readhead and Mark Wise; relevant passages appear around pages 26-27 and 42-45 of the transcript/PDF.

Why this matters

Section 14(1) FOIA is concerned with whether a request is vexatious. It is not, on its face, a statutory licence to brand a citizen, requester, complainant, campaigner, journalist, whistleblower, or member of the public as inherently vexatious.

The language quoted above is therefore highly significant. The words “somebody fits within that exemption”, “a person who is just making the ridiculous application”, and “the true and pure motivations of some applicants” all point towards an assessment of the person, not simply an assessment of the request.

That distinction is not a technicality. It goes to fairness, dignity, public trust, lawful decision-making, and the culture promoted within public authorities when members of the public exercise statutory information rights.

The former Information Commissioner’s phrase “sad, mad and bad people” is also troubling. In my respectful submission, such language risks normalising a dismissive or prejudicial attitude towards FOI requesters, particularly persistent requesters, campaigners, whistleblowers, disabled persons, vulnerable individuals, or those attempting to expose public safety concerns or maladministration.

Request for HR and governance consideration

I am not asking the HR team to determine individual FOI appeals. I am asking the ICO to consider whether the language, culture, and training assumptions reflected in this evidence are consistent with the standards expected of a statutory regulator and public authority.

In particular, I respectfully ask that ICO HR and relevant governance officers consider whether the use of person-focused labels such as “sad, mad and bad”, “somebody fits”, and “true and pure motivations” is compatible with the Nolan Principles, the ICO’s public duties, equality and dignity standards, and the obligation to approach citizens exercising statutory rights fairly and without institutional prejudice.

This issue is especially important where Section 14 FOIA can have a lasting reputational and practical effect on a requester. Once a citizen is treated as “vexatious”, the risk is that future requests, complaints, SARs, correspondence, and appeals may be approached through that prejudicial lens rather than on their own merits.

I therefore ask the ICO to confirm whether this evidence will be reviewed as part of any wider consideration of workplace culture, FOI case-handling culture, requester treatment, and training on Section 14 FOIA.

Conclusion

The statutory question under Section 14(1) should be whether the request is vexatious. The evidence above shows a worrying drift towards treating the requester as vexatious. That drift is precisely what undermines public confidence in the FOI regime.

I would be grateful if this correspondence could be acknowledged and placed before the appropriate HR, governance, and senior management officers within the ICO.

Yours faithfully,

Alan M Dransfield

Email: alanmdransfield@gmail.com

Alan M Dransfield – ICO HR Section 14 Culture Letter

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