001 - FOI

Dear Mr Glover,
I am writing in response to your request, received on 26 May 2023, for copies of recordings of the meetings which took place between the MMO and yourself on:
• 16th March 2023
• 24th April 2023
• 18th May 2023
• 19th May 2023
Whilst the MMO accepts that it agreed to record these meetings, there appears to be some misunderstanding around the reason why the meetings were recorded. MMO agreed to record these meetings to allow the production of a transcript of the discussions which could then be provided to you as an accurate record of our discussions. MMO did not record these meetings with the intention of providing you with a full visual recording of the meeting. MMO apologises if that was not properly understood.
In your email to us of 27 June 2023, you explained that you consider the video recordings to contain your personal data and that you seek to access to the recordings under the Subject Access provisions of the data protection legislation. The only personal data the recordings contain, over and above the information contained in the transcripts already provided to you, is your image. You will recall that there were a number of people present in those meetings whose personal data (images) will be captured in the recordings. Whilst those third parties consented to the recording of those meetings for the purpose of providing you with a transcript, they did not, and do not, consent to their personal information (images) being disclosed to you through the recordings.
MMO is unable to redact this third-party personal data from the recordings, therefore, MMO is not able to provide you with copies of the recordings. MMO is of the view that if it were to do so, the disclosure would constitute a breach of the data protection legislation.
MMO understands that part of the reason behind your requests for the recordings, as is explained in your email to us on 27 June 2023, is that during the meeting of 16 March 2023, you were provided with some visual evidence which was not captured by the transcript, but which would be captured in the recording.
MMO has reviewed all meeting minutes and recordings to identify what visual evidence you say was shown to you. MMO cannot see that any visual evidence was supplied to you during the meeting of 16 March 2023 or indeed during any of the meetings which were recorded. The transcripts of these meetings, as they were provided to you on 18 May 2023, are full and complete records of the meetings.
MMO notes your request is made under FOIA, personal data is exempt from disclosure under FOIA under section 40 of the Freedom of Access to Information Act 2000. Requests relating to personal data fall to be managed, not under FOIA legislation, but under the provisions of the data protection legislation. MMO has considered this request under the data protection legislation, in line with relevant obligations.
If you remain dissatisfied with the handling of your request, you have a right to appeal to the ICO.
The ICO can be contacted at:
Wycliffe House
Water Lane
Wilmslow
SK9 5AF
Tel 0303 123 1113
or http://www.ico.org.uk/complaints.
There is no charge for making an appeal to the ICO.
Yours sincerely,
Laurie Rodwell
Service Exception Lead
E laurie.rodwell@marinemanagement.org.uk