The disclosure of climate data from the Climatic Research Unit at the University of East Anglia - Science and Technology Committee Contents

3  Freedom of information issues

74. We are not a tribunal reviewing whether breaches of the Freedom of Information Act 2000 (FOIA) have taken place but see as our role in this inquiry as considering whether:

    (a)   the arrangements for examining whether CRU breached FOIA are adequate;

    (b)  whether the six-month time limit on the initiation of a prosecution where a public authority acts so as to prevent intentionally the disclosure of requested information needs to be revised; and

    (c)  whether UEA ensured that CRU was able to meet the requirements of the legislation when it received FOIA requests.

Freedom of Information legislation

75. The FOIA creating new rights of access to information came into operation on 1 January 2005. CRU, as part of UEA, is classed as a "public authority" for the purposes of the FOIA. In his submission Richard Thomas, who was Information Commissioner from 2002 until June 2009, explained the application of the FOIA to scientific data held by UK universities:

    the public must be satisfied that publicly-funded universities, as with any other public authority in receipt of public funding, are properly accountable, adopt systems of good governance and can inspire public trust and confidence in their work and operations [...] The fact that the FOIA requests relate to complex scientific data does not detract from this proposition or excuse non-compliance.[105]

76. When he gave oral evidence, we asked Mr Thomas if the legislation drew a distinction between, on the one hand, scientific data and modelling and, on the other hand, administrative records. He replied:

    the broad answer [...] is no [...] First of all, the legislation applies to information held by the public authority, and information is not elaborated in that sense. [...] It is not ownership. The legislation uses the word "held", and in the Environmental Information Regulations [EIR] that phrase "held" is slightly elaborated. If I can quote the regulation for you there, "It is held by a public authority if the information: (a) is in the authority's possession and has been produced or received by the authority, or (b) is held by another person on behalf of the authority." So that is an elaboration of the concept of "held". It is not ownership.[106]

77. Mr Thomas considered that the issues in this case which were most relevant to the information law appeared to be:

    (a)  the relevance and impact of the information laws on scientific and academic research conducted within universities;

    (b)  the adequacy of section 77 of FOIA to deal with suggestions that CRU researchers deleted information, not in the course of normal work, but to frustrate FOIA/EIR[107] requests;

    (c)  the handling of a large number of FOIA/EIR requests by UEA relating especially to climate change research which (within CRU) it "held"; and

    (d)  whether this case illustrates that there is scope to extend the "proactive" disclosure provisions of FOIA as they relate to universities.[108]

78. Parliament has created a presumption in favour of disclosure but there are exclusions.[109] Mr Thomas explained:

    There are over 20 exemptions to the fundamental duty to disclose requested information in FOIA.[...] Eight of the main exemptions are absolute and 16 are qualified. Qualified means that there is a "public interest override," which means that, even where the exemption applies, the public interest considerations must be considered. In formal terms, there must still be disclosure—even though the qualified exemption applies—unless the public interest in the exemption outweighs the public interest in disclosure.

Mr Thomas added that:

    The exemptions are similar to those found in other Freedom of Information laws in force in the world. I am not aware which exemptions were considered by the University as potentially applicable to some or all of the requests to CRU. I can speculate that some or all of the following [...] might have been considered:

    (a)  Section 22—where the requested information is intended for future (but imminent) publication;

    (b)  Section 40—where disclosure of personal data would breach any of the data protection principles;

    (c)  Section 41—where the information had been obtained from elsewhere in such circumstances that its disclosure would constitute an actionable breach of confidence under common law;

    (d)  Section 43 (qualified)—where disclosure would, or would be likely to, prejudice the commercial interests of any person, including the public authority;

    (e)  Section 44—where disclosure is prohibited by another enactment or inconsistent with an EU obligation (which may include some intellectual property restrictions); and

    (f)   Section 14 (not an exemption, strictly speaking)—where the request is vexatious.[110]

79. We were grateful to Mr Thomas for explaining the operation of the FOIA and EIR. He did, however, point out that he did not have detailed knowledge of events at UEA since leaving the Information Commissioner's Office:

    I have no idea at all what has happened inside my former office. I cannot say because this is a serious matter. It depends a great deal on the circumstances of the particular case, the evidence. I have had no direct contact with the office as to how this case is being handled.[111]

Alleged breaches of the Freedom of Information Act 2000


80. Some of the hacked e-mails appear to reveal scientists encouraging their colleagues to resist disclosure and to delete e-mails, apparently to prevent them from being revealed to people making FOIA requests. Below are examples, in chronological order, of e-mails sent by Professor Jones which address FOIA and requests for information.
    E-mail: 1107454306 [Extract]

    At 09:41 AM 2/2/2005, Phil Jones wrote:

    Mike,[...]Just sent loads of station data to Scott. Make sure he documents everything better this time! And don't leave stuff lying around on ftp sites - you never know who is trawling them. The two MMs have been after the CRU station data for years. If they ever hear there is a Freedom of Information Act now in the UK, I think I'll delete the file rather than send to anyone. Does your similar act in the US force you to respond to enquiries within 20 days? - our does ! The UK works on precedents, so the first request will test it. We also have a data protection act, which I will hide behind. Tom Wigley has sent me a worried email when he heard about it - thought people could ask him for his model code. He has retired officially from UEA so he can hide behind that. IPR should be relevant here, but I can see me getting into an argument with someone at UEA who'll say we must adhere to it !. [...]
    E-mail: 1219239172 [Extract]

    From: Phil Jones <>

    To: Gavin Schmidt <>

    Subject: Re: Revised version the Wengen paper

    Date: Wed Aug 20 09:32:52 2008

      [...] Keith/Tim still getting FOI requests as well as MOHC and Reading. All our FOI officers have been in discussions and are now using the same exceptions not to respond - advice they got from the Information Commissioner. As an aside and just between us, it seems that Brian Hoskins has withdrawn himself from the WG1 Lead nominations. It seems he doesn't want to have to deal with this hassle.

        The FOI line we're all using is this. IPCC is exempt from any countries FOI - the Sceptics have been told this. Even though we (MOHC, CRU/UEA) possibly hold relevant info the IPCC is not part our remit (mission statement, aims etc) therefore we don't have an obligation to pass it on.


        E-mail: 1228330629

        From: Phil Jones <>

        To:, Tom Wigley <>

        Subject: Re: Schles suggestion

        Date: Wed Dec 3 13:57:09 2008

        Cc: mann <>, Gavin Schmidt <>, Karl Taylor <>, peter gleckler


          When the FOI requests began here, the FOI person said we had to abide by the requests. It took a couple of half hour sessions - one at a screen, to convince them otherwise showing them what CA was all about. Once they became aware of the types of people we were dealing with, everyone at UEA (in the registry and in the Environmental Sciences school - the head of school and a few others) became very supportive. I've got to know the FOI person quite well and the Chief Librarian - who deals with appeals. The VC is also aware of what is going on - at least for one of the requests, but probably doesn't know the number we're dealing with. We are in double figures.

            One issue is that these requests aren't that widely known within the School. So I don't know who else at UEA may be getting them. CRU is moving up the ladder of requests at UEA though - we're way behind computing though. We're away of requests going to others in the UK - MOHC, Reading, DEFRA and Imperial College. So spelling out all the detail to the LLNL management should be the first thing you do. I hope that Dave is being supportive at PCMDI. The inadvertent email I sent last month has led to a Data Protection Act request sent by a certain Canadian, saying that the email maligned his scientific credibility with his peers!

              If he pays 10 pounds (which he hasn't yet) I am supposed to go through my emails and he can get anything I've written about him. About 2 months ago I deleted loads of emails, so have very little - if anything at all. This legislation is different from the FOI - it is supposed to be used to find put why you might have a poor credit rating ! In response to FOI and EIR requests, we've put up some data - mainly paleo data. Each request generally leads to more - to explain what we've put up. Every time, so far, that hasn't led to anything being added - instead just statements saying read what is in the papers and what is on the web site! Tim Osborn sent one such response (via the FOI person) earlier this week. We've never sent programs, any codes and manuals.

                In the UK, the Research Assessment Exercise results will be out in 2 weeks time.

                These are expensive to produce and take too much time, so from next year we'll be moving onto a metric based system. The metrics will be # and amounts of grants, papers and citations etc. I did flippantly suggest that the # of FOI requests you get should be another.

                  When you look at CA, they only look papers from a handful of people. They will start on another coming out in The Holocene early next year. Gavin and Mike are on this with loads of others. I've told both exactly what will appear on CA once they get access to it!


                  E-mail: 1237496573 [Extract]

                  From: Phil Jones <>


                  Subject: Re: See the link below

                  Date: Thu Mar 19 17:02:53 2009

                    [...] CRU has had numerous FOI requests since the beginning of 2007. The Met Office, Reading, NCDC and GISS have had as well - many related to IPCC involvement. I know the world changes and the way we do things changes, but these requests and the sorts of simple mistakes, should not have an influence on the way things have been adequately dealt with for over a century.



                  81. In his submission Andrew Montford stated that:

                    Research materials should be made available to outsiders as a requirement of the scientific method. That scientists have failed to do so is reprehensible, but the fact that they have apparently also resorted to breaches of the Freedom of Information Act in order to do so requires urgent attention from policymakers.[112]

                  82. As we explained in the previous chapter, David Holland was the author of several FOIA requests that were mentioned in the leaked e-mails. In his submission he pointed out that on 9 May [2008] in e-mail 1210367056, Professor Jones sent "my formal information request to 'team' members Mann, Hughes and Ammann" writing:

                    You can delete this attachment if you want. Keep this quiet also, but this is the person who is putting in FOI requests for all emails Keith and Tim have written and received re Ch 6 of AR4.[113] We think we've found a way around this.[114]

                  83. Mr Holland also drew attention to e-mail 1212063122 dated 29 May 2008 in which Professor Jones asked Professor Mann:

                    Can you delete any emails you may have had with Keith re AR4? Keith will do likewise. Can you also email [Eu]Gene [Wahl] and get him to do the same? I don't have his new email address. We will be getting Caspar [Ammann] to do likewise.[115]


                  84. On 22 January 2010, when the Deputy Information Commissioner, Graham Smith, issued a statement which suggested that at l east some of the requested information should have been disclosed in the absence of applicable exemptions, it gave support to the criticisms of CRU's handling of FOIA requests. Mr Smith said:

                    The FOI Act makes it an offence for public authorities to act so as to prevent intentionally the disclosure of requested information. Mr Holland's FOI requests were submitted in 2007/8, but it has only recently come to light that they were not dealt with in accordance with the Act. The legislation requires action within six months of the offence taking place, so by the time the action came to light the opportunity to consider a prosecution was long gone.[116]

                  85. Mr Thomas commented that this was "clearly a reference to section 77 of the Act and/or the near-identical Regulation 19 of EIR".[117] Section 77 of the FOIA provides:

                    1. Where:

                    (a)  a request for information has been made to a public authority,

                    (b)  under section 1 of this Act or section 7 of the Data Protection Act 1998, the applicant would have been entitled (subject to payment of any fee) to communication of any information in accordance with that section,

                    any person to whom this subsection applies is guilty of an offence if he alters, defaces, blocks, erases, destroys or conceals any record held by the public authority, with the intention of preventing the disclosure by that authority of all, or any part, of the information to the communication of which the applicant would have been entitled.

                    2. Subsection (1) applies to the public authority and to any person who is employed by, is an officer of, or is subject to the direction of, the public authority.

                    3. A person guilty of an offence under this section is liable on summary conviction to a fine not exceeding level 5 on the standard scale.[118]

                  86. Mr Thomas added that the Deputy Commissioner also appeared "to have in mind" section 127(1) of the Magistrates Court Act 1980, which provides that

                    a magistrates' court shall not try an information or hear a complaint unless the information was laid, or the complaint made, within 6 months from the time when the offence was committed, or the matter of complaint arose.[119]

                  Mr Thomas confirmed in oral evidence that

                    because of the interaction with the Magistrates Court Act, any prosecution must be brought within six months of the offence being committed.[120]

                  87. In its memorandum to our inquiry, UEA defended its actions:

                    CRU has been accused of refusing to release data requested under the FOIA. There are many obstacles outside CRU's control surrounding the release of data provided by NMSs [National Meteorological Services]. Many FOIA requests made to CRU related to primary data provided by the NMSs. Some of these data are subject to formal non-publication agreements between the NMS and CRU. Other primary data had been provided to CRU on an individual-to-individual basis, with accompanying verbal agreements that they may be used within the gridded dataset, but should not be passed on to others. CRU responded to the FOIA requests for primary data by pointing out that approximately 90% of the stations in the CRU dataset are available from other sources, particularly GHCN.[121]

                  88. On 29 January there was an exchange between UEA and Mr Smith, the Deputy Commissioner. Brian Summers, the Registrar and Secretary of UEA responded forcibly to Mr Smith's 22 January press statement, which asserted that UEA had not dealt with FOIA requests "as they should have been under the legislation".[122] He did not consider it was "acceptable that such a statement which has led to an extremely damaging commentary on the University [was] first communicated to the University by a journalist".[123] His letter goes on to defend UEA's actions in detail and to ask that, if the Information Commissioner's Office (ICO) cannot retract the 22 January statement, it issue a clarification regarding the alleged breaches of the FOIA. A response from the ICO was issued the same day. It did not retract the original statement but offered clarification:

                    1.  [No] decision notice has yet been issued and no alleged breaches have yet been put to the University for comment. That matter has yet to be addressed, but it will be over coming months.

                    2.  The fact that the elements of a section 77 offence may have been found here, but cannot be acted on because of the elapsed time, is a very serious matter. The ICO is not resiling from its position on this.

                    3.  The ICO's position is as stated in point 2 above. The statement may be read to indicate that.[124] Under section 77, an offence may be committed by an individual, not necessarily the public authority itself.

                    4.  Errors like this are frequently made in press reports and the ICO cannot be expected to correct them, particularly when the ICO has not itself referred to penalties or sanctions in its own statement.[125]

                  89. UEA responded on 1 February thanking the ICO for the clarification but setting out its concerns relating to the press coverage of the ICO's original statement:

                    Your clarification that the press cannot infer from your statement to the Sunday Times that it has been established that the University (or indeed any individual associated with the University) has breached the terms of the Freedom of Information Act is welcome. [UEA's] reputation which has been subjected to these damaging and incorrect assertions claiming to be based on your statement and we must take some steps to put this right. We will be writing to the media which carried reports based on your statement, pointing out the inaccuracies and asking them to rectify the position.[126]

                  90. In his oral evidence Professor Acton questioned the ICO statement of 22 January:

                    our principle is that prima facie evidence is evidence which on the face of it and without investigation suggests that there is a case to answer. To my mind if there is prima facie evidence; why did I set up the Muir Russell independent review? Prima facie evidence is not the same as, you have been found to breach. [...] If it is sub judice, if, as we had in the letter ten days ago from the ICO, the investigation has not even begun, I am puzzled how we could have been found to breach if there has been no investigation.[127]

                  91. The ICO's most recent letter, dated 3 March, in UEA's view, "makes plain that there is no assumption by the ICO, prior to investigation, that UEA has breached the Act; and that no investigation has yet been completed."[128] The ICO's letter confirmed that the "ICO is not pursuing any investigation under section 77 of the Act. That matter is closed as far as the ICO is concerned, given the statutory time limits for action". It added that:

                    The ICO acknowledges your concern about the statement made and the subsequent media and blog reports. Given that the Deputy Commissioner has already been publicly associated with the matter, any Decision Notice will be reviewed and signed off by another authorised signatory.[129]

                  We regret that the ICO made a statement to the press that went beyond that which it could substantiate and that it took over a month for the ICO properly to put the record straight. We recommend that the ICO develop procedures to ensure that its public comments are checked and that mechanisms exist to swiftly correct any mis-statements or misinterpretations of such statements.

                  92. The disclosed e-mails appear to show a culture of non-disclosure at CRU and instances where information (disclosable or otherwise) may have been deleted, to avoid disclosure. The Deputy Information Commissioner's letter of 29 January gives a clear indication that a breach of the FOIA may have occurred but that a prosecution was time-barred.[130] As, however, UEA pointed out, no investigation has been carried out.

                  93. It seems to us that both sides have a point. There is prima facie evidence that CRU has breached the Freedom of Information Act 2000. It would, however, be premature, without a thorough investigation affording each party the opportunity to make representations, to conclude that UEA was in breach of the Act. In our view, it is unsatisfactory to leave the matter unresolved simply because of the operation of the six-month time limit on the initiation of prosecutions. Much of the reputation of CRU hangs on the issue. We conclude that the matter needs to be resolved conclusively—either by the Independent Climate Change Email Review or by the Information Commissioner.

                  94. On the question of the six-month time limit on the initiation of prosecutions, Mr Thomas pressed for a revision of the law. He pointed out that apart from in the most blatant cases "it will usually be impossible for the ICO to detect an offence within 6 months of its occurrence" and thus to be able to initiate a prosecution.[131] He drew attention to a recent debate in the House of Lords on a proposal to amend the time limit. In reply, in the debate the Parliamentary Under-Secretary of State at the Ministry of Justice said that:

                    The Freedom of Information Act 2000 came into force only in 2005, and [...] we have no evidence at present that the current six-month time limit presents a systemic problem for the Information Commissioner or any other prosecutor in taking action under Section 77. [...] We will listen to the views of the Information Commissioner and other interested parties on this point, and if there is evidence that the current legislation is causing systemic difficulties, we will look for ways to address the matter, if necessary by means of an alternative legislative vehicle in the future. However, I cannot go further than that today on behalf of the Government.[132]

                  No change was made to the legislation.

                  95. We consider that events at CRU throw light on the operation of the Freedom of Information Act 2000 and, in particular, whether there is a need to amend the time limit on prosecutions from six months from the time the alleged offence was committed. If the Minister was correct to assert in July 2009 that the Government had no evidence that the current six-month time limit presents a systemic problem, then it is now clear that such evidence exists. Irrespective of whether or not CRU breached the Freedom of Information Act 2000, we recommend that the Government review the operation of section 77 of the 2000 Act and the six month limit on the initiation of prosecutions provided by section 127(1) of the Magistrates Court Act 1980.

                  VOLUME OF REQUESTS

                  96. In the face of allegations of poor handling of FOIA requests, one of the explanations offered by UEA was that in:

                    July 2009 UEA received an unprecedented, and frankly administratively overwhelming, deluge of FOIA requests related to CRU. These amounted to 61 requests out of a 2009 total of 107 related to CRU, compared to annual totals of 2 in 2008 and 4 in 2007 (University totals for those years were 204, 72 and 44 respectively).[133]

                  97. At the oral evidence session Lord Lawson commented on the increase in the volume of FOIA requests:

                    what had happened was there had been a very, very small number of FOI Act requests to begin with and it was in response to those that there was all the evasion, the lack of disclosure and all the other things which we have seen in the emails: discussions about possibly destroying evidence and so on. All that came well before the 2009 flood of stuff. The 2009 flood, if you look at the sequence of events, was a response to the refusal to give disclosure of various things before. That was what came first.[134]

                  98. There are two issues here: the adequacy of CRU's handling of the FOIA requests and whether the increase in the number of requests in July 2009 was a deluge. On the latter, Mr Thomas said that, whilst agreeing that UEA had faced a significant rise in FOIA requests in July 2009, he did not consider that a total of 61 was a "huge number".[135]

                  99. On handling, CRU claimed that it could not cope with the significant rise in FOIA requests because it only had three full-time academic staff.[136] We therefore wrote to UEA on 2 March 2010 to ask what extra resources were provided to assist CRU cope with these requests. UEA responded that:

                    additional support was provided to the University's Information Policy Compliance Manager (IPCM) who handles FOI requests. This included rescheduling workloads to allow him to concentrate on the CRU FOI requests and diverting secretarial support to provide additional resource. Given the high volume of requests received, the Director of Information Services (DoIS) also took an active role in the first stage of a number of requests, thus providing additional support to the IPCM. (Should any cases where the DoIS was directly involved in the first stage be appealed then we have arranged for the PVC Academic to adjudicate to ensure impartiality). ISD also fast-tracked the merging of the Security Policy and Compliance team to ensure that a fully trained back-up to the IPCM was available.[137]

                  100. The Science Faculty also provided additional administrative support, including that of the Director of Faculty Administration, the most senior member of the Faculty's administrative staff. UEA pointed out that many of the requests were of a very technical nature and:

                    required scientific knowledge and understanding of the subject area in order to provide the details. Despite the additional administrative resources provided, the requirement to respond to the 61 requests received in July 2009 impacted considerably upon the work of CRU.[138]

                  101. We also asked UEA to outline what legal advice and guidance on handling had been offered to CRU in handling these FOIA requests. UEA confirmed that the:

                    IPCM provided advice to CRU on the requirements of the Act both generally, and in relation to any applicable sections, exemptions or exceptions pertaining to the specific request. In this latter role, the IPCM set out the requirements of any possible exemption or exception, inclusive of the public interest test, and elicited from CRU staff whether the public interest test had been met. Additional advanced training was provided to the 'FOI Contact' for the Faculty of Science, the Director of Faculty Administration. In this role, the FOI contact acted as a support to CRU in the location and retrieval of information and provided assistance to the IPCM in exploring the application of the Act to the specific requests.[139]

                  102. On the evidence we took we have concerns about the handling of FOIA requests by CRU. First, the disclosed e-mails betray an attitude to freedom of information that was antipathetic to the spirit of disclosure in the legislation. Mr Thomas pointed out that:

                    the simplest approach, particularly where requests tend to generate either a defensive attitude or place a great burden on the public authority, is proactive disclosure in the first place.[...] Public authorities ought to decide what really has to be kept away from the public. If it is particularly sensitive or there is a good reason for withholding it, fair enough, but where there is no good reason for withholding information, then why not proactively disclose it and avoid the hassle of large numbers of requests?[140]

                  103. Whether or not CRU liked it, those making FOIA requests were entitled to have their requests dealt with in accordance with the legislation and, if the information sought did not fall within one of the exclusions provided by the FOIA, it should have been disclosed. We have already recommended in paragraph 54 above that in future information, including data and methodology, should be published proactively on the internet wherever possible. However, a culture of withholding information—from those perceived by CRU to be hostile to global warming—appears to have pervaded CRU's approach to FOIA requests from the outset. We consider this to be unacceptable.

                  104. In the face of such an unhelpful approach we are not surprised that FOIA requests multiplied. When the surge in FOIA requests hit CRU in July 2009 UEA provided extra resources but because of their technical nature the same small group of staff at CRU had a pivotal role in handling the requests. We are not clear that the culture changed. We cannot reach a firm conclusion on the basis of the evidence we took but we must put on record our concern about the manner in which UEA allowed CRU to handle FOIA requests. Further, we found prima facie evidence to suggest that the UEA found ways to support the culture at CRU of resisting disclosure of information to climate change sceptics. The failure of UEA to grasp fully the potential damage to CRU and UEA by the non-disclosure of FOIA requests was regrettable. UEA needs to review its policy towards FOIA and re-assess how it can support academics whose expertise in this area is limited.

                  105   Ev 8, para 3.2 Back

                  106   Qq 59-60 Back

                  107   EIR: Environmental Information Regulations 2004. Deriving from European Directive 2003/4/EC these give rights of public access to environmental information held by public authorities. Back

                  108   Ev 8, para 2.2 Back

                  109   Ev 9, para 3.6 Back

                  110   Ev 9, para 3.7 Back

                  111   Q 58 Back

                  112   Ev 159, para 6 Back

                  113   Intergovernmental Panel on Climate Change: Fourth Assessment Report Back

                  114   Ev 117, para 23 Back

                  115   Ev 118, para 32 Back

                  116   Ev 9, para 4.1 Back

                  117   Ev 10 Back

                  118   Ev 10, para 4.1 Back

                  119   Ev 10, para 4.2 Back

                  120   Q 56 Back

                  121   Ev 20, para 3.7.2 Back

                  122   "Scientists in stolen e-mail scandal hid climate data", The Times, 28 January 2010 Back

                  123   Registrar and Secretary to Deputy Information Commissioner - 29 January 2010, UEA website, Correspondence between University of East Anglia and the Information Commissioner's Office,  Back

                  124   UEA had asked the Deputy Commissioner to confirm that "your statement cannot be taken to mean that there has been a demonstrable breach of Section 77, which is a breach of the FOI which can result in prosecution"; Registrar and Secretary to Deputy Information Commissioner, 29 January 2010, UEA website, Correspondence between University of East Anglia and the Information Commissioner's Office, Back

                  125   Deputy Information Commissioner to Registrar and Secretary - 29 January 2010, UEA website, Correspondence between University of East Anglia and the Information Commissioner's Office, Back

                  126   Registrar and Secretary to Deputy Information Commissioner - 1 February 2010, UEA website, Correspondence between University of East Anglia and the Information Commissioner's Office, Back

                  127   Q130 Back

                  128   Ev 39, para A Back

                  129   Ev 39, annex Back

                  130   UEA website, Correspondence between University of East Anglia and the Information Commissioner's Office, Back

                  131   Ev 10, para 4.3 Back

                  132   HL Deb, 21 July 2009, col 1571 Back

                  133   Ev 20, para 3.7.4 Back

                  134   Q 9 Back

                  135   Q 68 Back

                  136   Q 92 [Professor Acton], Ev 20, para 3.7.4; Ev 37, Q 1 Back

                  137   Ev 37, para 1 Back

                  138   Ev 37, para 1 Back

                  139   Ev 37, para 2 Back

                  140   Q 70 Back

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