University of York FOIA Complaint - Not Upheld

The ICO issued a Decision Notice in case IC-407347-P6Y7 concerning a complainant's request for professional emails exchanged between four named individuals at the University of York from January 2023. The university disclosed information within scope, redacting personal content, and withheld some data under section 40(2) FOIA as third-party personal data. The Commissioner found on the balance of probabilities that no further information is held and the exemption was correctly applied.\n\nFor public authorities handling FOIA requests, this decision confirms that disclosing non-exempt information while withholding third-party personal data under section 40(2) is appropriate where disclosure would contravene UK GDPR obligations. Universities and similar public authorities should ensure email management systems can identify responsive records and apply exemptions correctly when disclosing to requesters.