South Tees Development Corporation Told Senior Officials’ Names Must Be Released...
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Information Commissioner Ruling Means Senior Public Officials Details Cannot Be Shielded From Freedom of Information Requests...
17th May 2026
The South Tees Development Corporation has been ordered to disclose the names and job titles of senior internal officers after the Information Commissioner found it had gone too far in redacting parts of an Freedom of Information response.
The decision, issued by the Information Commissioner’s Office on the 28th April 2026, followed a complaint about how STDC handled a request for correspondence and documents involving two named individuals during periods in 2020 and 2021.
The original request was made on 9 September 2024 and sought “all documents including correspondence of any sort, including emails” in which the named individuals featured between 1 January 2020 and 31 July 2020. The STDC initially refused the request on cost grounds under section 12 of the Freedom of Information Act before the requester narrowed the scope to specific date ranges.
The STDC then later released some information, including a Contract Justification Form and Award of Contract, but applied significant redactions to the document under section 40(2) of FOIA, which protects third-party personal data where disclosure would breach data protection principles.
Following an internal review, the development corporation accepted that some redactions were unnecessary, particularly where they related to a senior group officer whose name could reasonably be expected to be released. It also accepted that some company-owner information was already publicly available via Companies House.
However, the dispute continued after further correspondence was released in September 2025 with additional redactions. The complainant then challenged whether The South Tees Development Corporation was entitled to keep withholding names and other details under section 40(2).
The ICO accepted that STDC was entitled to protect the names, job titles and contact details of external contacts and junior internal officials. The Commissioner said junior staff, particularly those appearing in correspondence in administrative roles, would generally have a reasonable expectation that their names would not be disclosed to the world at large under FOIA. But the Commissioner reached a different conclusion for senior internal officers.
In the decision notice, the ICO said the senior officers held leadership or senior manager roles, giving “significant weight” to the public interest in accountability for decisions taken. The Commissioner also rejected STDC’s argument that disclosure could cause professional detriment, stress or distress, noting that no evidence had been provided to show such outcomes were likely.
The ICO found there was a legitimate interest in disclosing the names and job titles of senior internal officers and that this was necessary to meet the public interest in transparency and accountability. However, the Commissioner agreed that their direct contact details did not need to be disclosed.
As a result, STDC must now disclose the names and job titles of the senior internal officers identified in a confidential annex supplied to the authority. The decision notice gives STDC 30 calendar days to comply. Failure to do so could result in the matter being brought before the High Court and dealt with as contempt of court.
The ruling is likely to be seen as an important reminder that public bodies can't automatically hide the identities of senior officials involved in public decision-making simply by relying on personal data exemptions.
While the ICO accepted that junior staff and outside contacts may be entitled to greater privacy, it made clear that senior officials working within public bodies can be subject to a higher level of scrutiny, particularly where transparency and accountability are at stake.
Both STDC and the complainant have the right to appeal the decision to the First-tier Tribunal within 28 calendar days.
