Individual's Name And Personal Data Protection

Efifiom Edem v. Information Comissioner and Financial Services Authority [2014] EWCA Civ 92 (7 February 2014)

The Court of Appeal had to try a case in which an applicant made a request under the Freedom of Information Act 2000 to obtain details of a complaint he had made to the FSA about the way the FSA had regulated Egg plc, an internet bank. As part of this request the applicant sought the disclosure of the names of three junior staff involved with the matter but which had been redacted from emails supplied to him by the FSA on the basis that the names were personal data and could not therefore be disclosed under the FOIA. 
The Court of Appeal now ruled that a person’s name constitutes personal data for the purposes of the Data Protection Act 1998 unless the name is so common that without further information, such as its use in a work context, a person would remain unidentifiable despite its disclosure.