The First-tier Tribunal (General Regulatory Chamber) has upheld the Information Commissioner's reliance on section 14(1) of the Freedom of Information Act 2000 to refuse a request about a parish council's data protection registration, finding that the request formed part of a campaign of harassment against the council even though the appellant claimed the requesting history relied on belonged not to him but to his son, who lives at the same address and shares his name.
The tribunal of Judge Hughes, Marion Palmer-Dunk and Emma Yates, deciding the appeal after a hearing on 15 June 2026, held that it did not need to resolve whether one or two individuals were behind the correspondence, because a request can be vexatious under section 14(1) where a requester acts in concert with another person, and the evidence demonstrated a clear pattern of linkage between the two requesters directed at a small parish council which had attracted no comparable interest from anyone else.
In February 2024 a request was made to the ICO, in its capacity as a public authority, for details of Irby upon Humber Parish Council's registration as a data controller over the previous five years. The ICO refused the request under section 14(1) and maintained that position in its decision notice, relying on a history of some 15 information requests recorded on its casework system between 2019 and 2022 concerning the parish council, together with associated complaints. The council had been dissolved in around 2022, and the ICO noted that the requests resumed as soon as it was reconstituted in 2024, characterising the February 2024 request as an attempt to resume a campaign of disruption.
The appellant, Colin Webb, born in 1948, appealed on the basis that he had made no previous requests to the ICO and that the regulator had wrongly attributed to him the correspondence of his son, Colin Andrew Alan Webb, born in 1971, who lives at the same address. He accused the ICO of incorrectly merging the personal data of two different people. His son provided a witness statement confirming that he had not made the February 2024 request. Neither the appellant nor his son attended the hearing to give oral evidence, and the tribunal declined the Commissioner's request for a direction that both men provide photographic identification and proof of address.
Section 14(1) of FOIA provides that a public authority is not obliged to comply with a request for information if the request is vexatious. The leading authority, Information Commissioner v Devon County Council and Dransfield, requires consideration of the burden imposed on the public authority, the motive of the requester, the value or serious purpose of the request and any harassment or distress caused, with the underlying question being whether the request represents a manifestly unjustified, inappropriate or improper use of the Act.
The evidence before the tribunal included pairs of near-identical emails and subject access requests sent to Humberside Police and to the ICO within minutes of each other from two similar email addresses at different providers, each beginning with the same "caa" prefix. The tribunal found that whether the correspondence was the work of one individual or two, the material demonstrated coordination between the requesters, and that the February 2024 request was nearly identical to a request made in February 2021, indicating an intention to continue the harassment of the parish council and to impose a burden on it for no valid reason.
The tribunal was satisfied that the request had no serious purpose proportionate to its impact, that the history of correspondence pointed to a campaign against the council, and that the Commissioner had correctly applied section 14(1). The appeal was dismissed.
Colin Webb v Information Commissioner [2026] UKFTT 990 (GRC)
