The First‑tier Tribunal has dismissed an appeal by a requester seeking internal BBC documents relating to the 2017 security incident that led to the removal of public access to the Media Café at Broadcasting House, concluding that disclosure would create a “real and significant risk” to staff safety.
In Antony Williams v Information Commissioner & BBC [2026] UKFTT 307 (GRC), the Tribunal upheld the Information Commissioner’s decision that the material was exempt under section 38(1)(b) (health and safety) and section 40 (personal data) of the Freedom of Information Act 2000.
Mr Williams had argued that the BBC misled Westminster City Council in 2017 about its intentions for public access to the Media Café, claiming the corporation had already decided to close the space permanently while telling the council that access would resume. He sought internal records generated by the Director General’s Office concerning the incident and subsequent decisions.
The BBC disclosed some information but withheld detailed security assessments, action plans, and committee papers. The Commissioner agreed that releasing the remaining material would be likely to endanger staff and visitors, given the sensitivity of Broadcasting House’s security arrangements.
The Tribunal reviewed both open and closed evidence, including a witness statement from the BBC’s Safety, Security & Resilience Specialist, Mark Fewster. It found that the withheld documents contained:
- exact locations of departments previously subject to threats
- current security measures and protocols
- unimplemented security recommendations
- staff training and response procedures
The panel accepted that disclosure would assist individuals “with criminal intent” and that the BBC had demonstrated a clear causal link between release and potential harm. It rejected the appellant’s argument that the BBC had taken an “absolutist” approach to section 38, noting that non‑sensitive material had been disclosed.
While acknowledging that the likelihood of an incident was not high, the Tribunal stressed that the consequences of an attack on Broadcasting House, given its prominence, footfall and emergency broadcasting obligations, would be “extremely serious”.
A central plank of Mr Williams’ appeal was his allegation that the BBC misled Westminster City Council in 2017. The Tribunal found no support for this claim in the disclosed material, stating:
“There is nothing in the information which sheds light on any of the wrongdoing alleged… Any parts of the document that relate to the issues raised by Mr Williams have been disclosed.”
It went further, concluding that the documents did not indicate that the BBC had decided in March 2017 to permanently close public access, and that there was “no plausible suspicion” that false statements were made to the council.
The Tribunal held that the public interest in transparency around access decisions and security arrangements was outweighed by the “very strong” public interest in protecting staff and the public from harm.
The appeal was dismissed.
