The ICO determined that MOD file DEFE 68/1153, containing Intelligence Services Bill documentation, is properly withheld under section 23(1) of FOIA, which exempts information supplied by, or relating to, security bodies from disclosure. The Commissioner found the exemption applies and the public authority was entitled to refuse the request.

Government agencies and public authorities should note that section 23(1) exemptions for security bodies remain a valid basis for withholding documents, though such exemptions must still be properly invoked and documented. This decision confirms the high bar for overriding security-related exemptions in FOI proceedings.