Cabinet Office

The complainant has requested information on WhatsApp communications between the Prime Minister at the time, Boris Johnson, and particular individuals. The Cabinet Office eventually relied on FOIA section 12(1) to withhold the requested information, on the basis that the cost of compliance would exceed the appropriate limit. The Commissioner’s decision is that the Cabinet Office is entitled to refuse the request in reliance of section 12(1). The Commissioner also finds a breach of section 17(5) in the late reliance on section 12 and a breach of section 16 by failing to engage sufficiently with the complainant to provide meaningful advice and assistance. The Commissioner requires the public authority to provide appropriate advice and assistance to the requester to enable them to refine their request.