The Commissioner’s decision is that West Lindsey District Council (‘the Council’) correctly applied section 40(2) to one element of the requested information about its officers. That information is the officers’ personal data and disclosing it wouldn’t be lawful. However, the Council incorrectly applied section 40(2) to the remaining element. The Commissioner requires that the Council takes the following step to ensure compliance with the legislation: Disclose to the complainant the job titles they requested.