Secretary of State for the Home Department (Home Office)

The complainant requested specified information about the imposition of sanctions under the Russia regime “on persons regarded as associated with Mr Roman Abramovich”. The Home Office initially refused to provide any information, citing the FOIA exemptions contained in section 24(1) – national security and sections 31(1)(a) and (c) - law enforcement. At internal review, the Home Office maintained that these exemptions applied, but additionally relied on sections 27(1) and (2) – international relations, and section 40(2) – personal information, of FOIA. During the course of the Commissioner’s investigation, the Home Office partly revised its position. It now said it no longer wished to rely on section 24(1) of FOIA “independently” to protect some of the withheld information. Instead the Home Office said it was relying on section 23(1) – security bodies or section 24(1) ‘in the alternative’, in addition to sections 27(1) and (2) and 31(1) of FOIA to protect that information. The Commissioner’s decision is that the Home Office has properly relied on section 27(1) of FOIA to withhold the requested information in its entirety. As he has found this exemption to be engaged, he has not deemed it necessary to consider the Home Office’s reliance on the remaining exemptions. No steps are required as a result of this notice.