In this case the Information Commissioner is both the public authority

which is the subject of the complaint and the regulator of the FOIA responsible for investigating the complaint. The notice will use the term Information Commissioner’s Officer (ICO) when referring to the Information Commissioner as the public authority subject to the complaint and the term Commissioner will be used to refer to her as the regulator. The complainant has requested from the ICO information about the scope of the exemption for processing data for personal and household activities contained in Article 2(2)(c) and Recital 18 of the EU General Data Protection Regulation (GDPR). The ICO refused to disclose the information citing sections 22 (information intended for future publication) and 42 (legal professional privilege) of the FOIA. The Commissioner’s decision is that the ICO has correctly applied sections 22 and 42 of the FOIA in this case and that the public interest in favour of disclosure is outweighed by the public interest in favour of maintaining the exemption. The Commissioner does not require any steps to be taken as a result of this decision notice.