001 - FOI
Copies of video recording
Freedom of information request for video copies of meetings recorded between myself and MMO staff.
Recording from previous meetings had been provided.
Filing Date: 26th May 2023
Reply Date: 14th July 2023
MMO Ref: SAR934
Tier 1 Response:
Tier 2 Complaint
Filing Date: 3rd August 2023
MMO Ref: C2301
I am making a formal request for video copies of meetings recorded between myself MMO staff.
These meetings were with MMO I-VMS management and took place on Teams on the following dates:
16th March 2023
24th April 2023
18th May 2023
These meetings were video recorded and all members on meeting provided acceptance for it to be recorded.
Daniel Hallam of the MMO will be able to provide the details and times of the recordings you require.
As per the UK Government information, I expect to receive these within 20 working days.
Please acknowledge the receipt of this request.
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:
Tel 0303 123 1113
There is no charge for making an appeal to the ICO.
Service Exception Lead
Ref No: SAR934
Thank you for your response to my information request, sent on 14th July 2023, copy attached.
I am dissatisfied with the handling of my request for the following reason(s):
In previous meetings with the MMO, a copy of the video has been provided.
During one of the meetings provided, visual evidence was shown, and this is not explained in the transcript and so a video copy if required.
All parties agreed to the recording of the meeting.
I also have reason to believe that the transcripts provided are not complete, and this needs to be verified against the video copy.
In the meeting on the 19th May, it was agreed by all present that the video copy would be supplied to be within a short timescale.
There is no reason not to provide the video copies. I believe that these copies are being purposely withheld to prevent me establishing the true facts.
I would be grateful if you would carry out an internal review of the handling of my request and make this confirmation.
I look forward to receiving your response within the next 20 working days, as outlined in the Information Commissioner’s guidance:
“The Information Commissioner’s Office recommends that public authorities carry out internal reviews within 20 working days.”