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Use of section 30 for FOI2022/71614
Source: WhatDoTheyKnow
Authority: HM Revenue and Customs
Status: The request was
refused
by
HM Revenue and Customs
.
Imported path: /opt/loancharge/imports/wdtk/requests/use_of_section_30_for_foi2022716
Open original request on WhatDoTheyKnow
Imported text
SOURCE: WhatDoTheyKnow
SOURCE_URL: https://www.whatdotheyknow.com/request/use_of_section_30_for_foi2022716
TITLE: Use of section 30 for FOI2022/71614
AUTHORITY: HM Revenue and Customs
AUTHORITY_URL: https://www.whatdotheyknow.com/body/hmrc
STATUS: The request was
refused
by
HM Revenue and Customs
.
REQUEST_SLUG: use_of_section_30_for_foi2022716
CAPTURED_AT: 2026-05-19T07:21:51+00:00
PROVENANCE: {"first_seen_at": "2026-05-18T12:55:41", "first_seen_page": "2", "first_query_term": "\"Loan Charge\"", "first_date_after": "2023/01/01", "first_date_before": "2024/01/01", "matched_query_terms": "\"Loan Charge\"", "matched_date_ranges": "2023/01/01 to 2024/01/01", "first_search_url_template": "https://www.whatdotheyknow.com/search/%22Loan%20Charge%22/requests?commit=Filter&query=%22Loan+Charge%22&request_date_after=2023%2F01%2F01&request_date_before=2024%2F01%2F01&request_variety%5B%5D=sent&request_variety%5B%5D=response&request_variety%5B%5D=comment&sortby=&utf8=%E2%9C%93&page="}
ATTACHMENTS:
- FOI2023_21978.pdf | https://www.whatdotheyknow.com/request/use_of_section_30_for_foi2022716/response/2281146/attach/3/FOI2023%2021978.pdf?cookie_passthrough=1 | application/pdf | 4422938 bytes
- [not downloaded] | https://www.whatdotheyknow.com/request/use_of_section_30_for_foi2022716/response/2281146/attach/html/3/FOI2023%2021978.pdf.html | | 0 bytes
================================================================================
MESSAGE 1 [outgoing]
HEADER: Anne Charlesworth
17 February 2023
Delivered
--------------------------------------------------------------------------------
Dear HM Revenue and Customs,
In HMRC's response to FOI2022/71614 several paragraphs of information were redacted. HMRC used section 31(1)(d) of the FOIA to exempt themselves from releasing it. This exemption applies to information held where the disclosure of which would, or would be
likely to, prejudice the assessment or collection of tax.
HMRC quote that there is strong public interest in public transparency but also a strong public interest in HMRC being able to enforce the law properly. They then state it could damage the general climate of honesty.
Witholding these paragraphs reduces the transparency to the public and implies that HMRC is not certain of its use of the law in collecting taxes. This FOI is trying to ascertain that HMRC is using the law as parliament intended and collecting the right amount of tax.
Its also worth pointing out that the HMRC charter states that HMRC collects the right amount of tax, not the maximum amount of tax.
Releasing the information does not stop HMRC collecting the correct amount of taxes.
This request asks for
1) The documentation showing that a suitable officer undertook the public interest test for section 31 information in FOI2022/71614.
2) The paragraphs redacted using section 31 in FOI2022/71614 as HMRC have used this exemption incorrectly
Yours faithfully,
Anne Charlesworth
================================================================================
MESSAGE 2 [outgoing]
HEADER: Anne Charlesworth
21 March 2023
Delivered
--------------------------------------------------------------------------------
Dear HM Revenue and Customs,
I have not received a response to this request. By law HMRC should have responded by 20/3/2023.
Please advise the reason for the delay.
Yours faithfully,
Anne Charlesworth
================================================================================
MESSAGE 3 [outgoing]
HEADER: Anne Charlesworth
24 March 2023
Delivered
--------------------------------------------------------------------------------
Dear HM Revenue and Customs,
I still have no received an acknowledgement of this request for information despite the WhatDoTheyKnow website confirming the delivery of the initial request on 17/2/2023 and the follow up request on the 21/3/2023.
This is in breach of the FOIA.
Yours faithfully,
Anne Charlesworth
================================================================================
MESSAGE 4 [incoming]
HEADER: Team, FOI,
HM Revenue and Customs
31 March 2023
--------------------------------------------------------------------------------
Our ref: FOI2023/21978
Dear Anne Charlesworth,
Freedom of Information Act 2000 Acknowledgement
Thank you for your communication of 17 February.
Please accept our sincere apologies for the oversight with your request.
We have allocated the above reference which you should quote if you need
to contact us.
We are currently finalising our response and will respond as soon as
possible.
Yours sincerely
HMRC Freedom of Information Team
================================================================================
MESSAGE 5 [incoming]
HEADER: Team, FOI,
HM Revenue and Customs
5 April 2023
--------------------------------------------------------------------------------
1 Attachment
FOI2023 21978.pdf
4.2M
View
Download
Dear Anne Charlesworth,
We are writing in response to your request for information, received 17
February.
Yours sincerely,
HMRC Freedom of Information Team
================================================================================
ATTACHMENT TEXT EXTRACTION / OCR
================================================================================
--------------------------------------------------------------------------------
ATTACHMENT: FOI2023_21978.pdf
TEXT_FILE: FOI2023_21978.pdf.txt
METHOD: pdf_native
OCR_USED: False
PAGES: 66
--------------------------------------------------------------------------------
--- PDF page 1 ---
If you need extra support, for example if you have a disability, a mental health condition, or
do not speak English/Welsh, go to www.gov.uk and search for ‘get help from HMRC’.
Text Relay service prefix number – 18001
OFFICIAL
Freedom of Information Team
S1715
6 Floor
Central Mail Unit
Newcastle Upon Tyne
NE98 1ZZ
Anne Charlesworth
By email: request-950749-
0a0755c0@whatdotheyknow.com
Email
foi.request@hmrc.gov.uk
Web
www.gov.uk
Date: 5 April 2023
Our ref:
FOI2023/21978
Dear Anne Charlesworth
Freedom of Information Act 2000 (FOIA)
Thank you for your request, which was received on 17 February, for the following
information:
“In HMRC's response to FOI2022/71614 several paragraphs of information were redacted.
HMRC used section 31(1)(d) of the FOIA to exempt themselves from releasing it. This
exemption applies to information held where the disclosure of which would, or would be
likely to, prejudice the assessment or collection of tax.
HMRC quote that there is strong public interest in public transparency but also a strong
public interest in HMRC being able to enforce the law properly. They then state it could
damage the general climate of honesty.
Withholding these paragraphs reduces the transparency to the public and implies that
HMRC is not certain of its use of the law in collecting taxes. This FOI is trying to ascertain
that HMRC is using the law as parliament intended and collecting the right amount of tax.
Its also worth pointing out that the HMRC charter states that HMRC collects the right amount
of tax, not the maximum amount of tax.
Releasing the information does not stop HMRC collecting the correct amount of taxes.
This request asks for
1) The documentation showing that a suitable officer undertook the public interest test for
section 31 information in FOI2022/71614.
2) The paragraphs redacted using section 31 in FOI2022/71614 as HMRC have used this
exemption incorrectly”
Our response
We have interpreted the first part of your request as a ‘meta-request’, a request for the
recorded information we hold about the handling of the original request and the application
of FOIA exemptions.
--- PDF page 2 ---
2
OFFICIAL
This information, subject to FOIA exemptions has been provided as an annex to this letter.
As part of your request, we have reconsidered the application of section 31(1)(d) and have
concluded that the use of this exemption was appropriate in the circumstances. Accordingly,
redactions have been applied consistently with that of your original request.
If you are not satisfied with our reply, you may request a review within 40 working days of
receiving this letter by emailing foi.review@hmrc.gov.uk or by writing to our address at the
top.
If you are not content with the outcome of an internal review you can complain to the
Information Commissioner’s Office.
Yours sincerely,
HM Revenue and Customs
--- PDF page 3 ---
OFFICIAL
EMAIL 1 – 1 ATTACHMENT
From: Team, FOI <foi.team@hmrc.gov.uk>
Sent: 16 February 2023 13:26
To:
Subject: Request for information - Ref: FOI2022/71614
Dear
We are writing in response to your request for information, received 15 November.
Yours sincerely,
HMRC Freedom of Information Team
40(1
40(1
--- PDF page 12 ---
OFFICIAL
19/03/2019
17:31pm
Nick
Jones
9
…
[and]
…
31(1)(d)
31(1)(d)
--- PDF page 13 ---
OFFICIAL
18/03/2019
13:39pm
Ruth
Stainer
13
[Just to flag that we have noticed some of the above lines are repeated in Ruth’s email and so consequentially we
will redact these in this email too. I have set those out below for ease of reference.]
.
31(1)(d)
31(1)(d)
--- PDF page 14 ---
OFFICIAL
And s36:
--- PDF page 16 ---
OFFICIAL
From: Harra, Jim (HMRC) <jim.harra@hmrc.gov.uk>
Sent: 19 January 2023 08:09
To: Secs, Perm (HMRC) <perm.secs@hmrc.gov.uk>
Cc: Allen, Ian (HMRC Perm Secs Office) <ian.allen@hmrc.gov.uk>
Subject: RE: s36 application for Commissioner's decision - FOI2022_71614
Thanks,
I am content to approve this. I note that section 7 of the template form says this was submitted to
me on 13 December 2022. Is this right or does it need to be amended to say 18 January 2023?
Jim Harra
Chief Executive, and First Permanent Secretary, HMRC. Tel:
| mob:
| email: jim.harra@hmrc.gov.uk
(Chief of Staff: Ian Allen | tel:
mob:
email: ian.allen@hmrc.gov.uk)
40(2)
40(2)
40(2)
40(2)
40(2)
--- PDF page 23 ---
OFFICIAL
Best
Date/Time
Sender Page
Comments
19/03/2019
17:31pm
Nick
Jones
9
…
[and]
…
This goes into quite a bit
of detail about our
compliance systems,
how we clash data and
how they operate.
We agreed S31 FOI Act
2000 (prejudice to the
assessment and
collection of tax) could
apply.
40(2)
31(1)(d)
31(1)(d)
--- PDF page 24 ---
OFFICIAL
18/03/2019
13:39pm
Ruth
Stainer
13
[Just to flag that we have noticed some of the above lines are repeated in Ruth’s email and
so consequentially we will redact these in this email too. I have set those out below for ease
of reference.]
For the same reasons
above
31(1)(d)
31(1)(d)
--- PDF page 32 ---
OFFICIAL
that they
disclosed their
scheme
use...followed
are numbered
19,21,44...up
until - cannot
check HMRC
systems as not
enough detail
given
to other sections? was
this redacted due to
GDPR rules? If so, can
the remaining
information still be used
in conjunction with
other releases to
identify the cases and
individual taxpayers?
cannot use the
information to
realistically
identify the details
and therefore,
there isn’t a risk of
it being identified
by someone else
19/03/2019
17:31
Nick
Jones
9
Red text on
enquiry
coverage and
HMRC systems
The coverage of the
enquiry and the
discussions around
HMRC IT systems and
data sets could
prejudice the
assessment and
collection of tax
S31
Talking about
legacy IT systems
will likely have no
impact on
collection of tax in
the future. The
comments here is
also about
generating
statistics and not a
liability
18/03/2019
13:39
Ruth
Stanier
13
Red text on
enquiry
coverage and
HMRC systems
As above
As above
18/03/2019
13:26
Ruth
Stanier
15
The views from
ministers and
stakeholder
engagement could be
redacted under S36 as
they are part of the
policy evaluation
process/management
phase.
Could an argument be
made that the
evaluation/discussion
with CX could inhibit the
free and frank exchange
of views - Especially the
last 3 bullet points
This relates to the
pre-
implementation
and therefore the
material isn’t part
of the evaluation
process. The
material would
need to be tested
for S35, and we
would not meet
the threshold for
this. This is also
similar to material
we’ve released
before, from the
request
40
(2)
36(2)(b)(i) and (ii)
--- PDF page 36 ---
OFFICIAL
3E/03 | 100 Parliament Street, SW1A 2BQ |
|
40(2)
40(2)
--- PDF page 41 ---
OFFICIAL
Thanks,
40(2)
--- PDF page 50 ---
OFFICIAL
FOI Target:14th December
--- PDF page 51 ---
OFFICIAL
EMAIL 20 – NO ATTACHMENT
-----Original Message-----
From:
@whatdotheyknow.com>
Sent: 15 November 2022 15:03
To: Information Rights Unit (HMRC) <informationrightsunit@hmrc.gov.uk>
Subject: Re: Request for information - Ref: FOI2022/59332
[You don't often get email from
@whatdotheyknow.com. Learn why this
is important at https://aka.ms/LearnAboutSenderIdentification ]
Dear Team, FOI,
Thank you for your reponse to FOI2022/59332.
It seems strange that having raised a similar request to HMT that their information rights team can
immediately state that there are no emails within scope of this whilst HMRC invoke section 12 of the
FOIA.
Nevertheless I will start by trying to significantly reduce the scope of my request.
Please search for emails that contain the term 'Loan charge'
and the word 'concession' (this may also include the plural 'concessions') This should be for the
emails during the month of March 2019.
This should only be for emails that have been sent or received by Sir Jonathan Thompson, Chief
Executive and Permanent Secretary
Jim Harra, Second Permanent Secretary
Angela MacDonald, Director General Customer Services
Justin Holliday , Chief Finance Officer
Penny Ciniewicz, Director General Customer Compliance
Jacqueline (Jacky) Wright, Director General Chief Digital & Information Officer
Ruth Stanier, Director General Customer Strategy & Tax Design
Alan Evans, General Counsel & Solicitor
Mary Aiston, Director Counter Avoidance
Yours sincerely,
-----Original Message-----
Dear
,
We are writing in response to your request for information, received 26 September.
Yours sincerely,
HMRC Freedom of Information Team
-------------------------------------------------------------------
Please use this email address for all replies to this request:
@whatdotheyknow.com
40(1
40(1
40(1
40(1
40(1
--- PDF page 52 ---
OFFICIAL
Disclaimer: This message and any reply that you make will be published on the internet. Our privacy
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Please note that in some cases publication of requests and responses will be delayed.
If you find this service useful as an FOI officer, please ask your web manager to link to us from your
organisation's FOI page.
--- PDF page 53 ---
OFFICIAL
EMAIL 1 – ATTACHMENT 1
DISCLOSED UNDER FOI2022/71614
EMAIL 2 – ATTACHMENT 1
DISCLOSED UNDER FOI2022/71614
EMAIL 2 – ATTACHMENT 2
DISCLOSED UNDER FOI2022/71614
EMAIL 4 – ATTACHMENT 1
DISCLOSED UNDER FOI2022/71614
--- PDF page 55 ---
2
OFFICIAL
Where requested information contains the personal information of officials or members of
the public to a degree which is contrary to their expectation of privacy, this has been
withheld under section 40(2) FOIA.
Section 40(2) of the FOI Act, by virtue of section 40(3A) provides an absolute exemption for
third party personal data, where disclosure would contravene any of the data protection
principles set out in Article 5 of the General Data Protection Regulation. The first data
protection principle requires the disclosure of third-party personal data to be lawful, fair and
transparent. We believe that releasing the information would breach the first data protection
principle, since it would be unlawful and unfair to release the information.
The exemption in section 40(2) is absolute, meaning that there is no need to weigh up the
public interest in releasing the information against the public interest in maintaining the
exemption. On this basis, all identifying information relating to junior officials and members
of the public has been withheld.
Taxpayer confidentiality
Requested information which constitutes ‘revenue and customs information relating to a
person’, where disclosure would either identify the ‘person’ or would enable the identity of
the ‘person’ to be deduced, has been withheld pursuant to section 44(1)(a) FOIA.
In this context, ‘revenue and customs information relating to a person’ means information
about, acquired as a result of, or held in connection with the exercise of a function of the
Revenue and Customs in respect of the person.
Section 44(1)(a) provides:
44 Prohibition on disclosure
(1) Information is exempt information if its disclosure (otherwise that under this Act) by
the public authority holding it –
a)
is prohibited by or under any enactment, ; …
The enactment in this case is the Commissioners of Revenue and Customs Act 2005 (the
CRCA).
Section 18(1) of the CRCA states that HMRC officials may not disclose information which is
held by HMRC in connection with one of its functions.
For the purposes of FOIA, section 18(1) only acts as a statutory prohibition where section
23(1) of the CRCA is also satisfied:
23 Freedom of information
(1) Revenue and customs information relating to a person, the disclosure of which is
prohibited by section 18(1), is exempt information by virtue of section 44(1)(a) of the
Freedom of Information Act 2000 (prohibitions on disclosure) if its disclosure—
(a)
would specify the identity of the person to whom the information relates, or
(b)
would enable the identity of such a person to be deduced.
(1A) Subsections (2) and (3) of section 18 are to be disregarded in determining for
the purposes of subsection (1) of this section whether the disclosure of revenue and
customs information relating to a person is prohibited by subsection (1) of that
section.
(2) Except as specified in subsection (1), information the disclosure of which is
prohibited by section 18(1) is not exempt information for the purposes of section
44(1)(a) of the Freedom of Information Act 2000.
EMAIL 5 ATTACHMENT 1
--- PDF page 56 ---
3
OFFICIAL
(3) In subsection (1) ‘revenue and customs information relating to a person’ has the
same meaning as in section 19.
Assessment and collection of tax
Section 31 is a qualified exemption which means it must be considered whether the balance
of the public interest favours withholding or disclosing the information. This means that even
though the exemption is considered to be engaged; it is necessary to consider whether the
public interest in maintaining the exemption outweighs the public interest in disclosure.
Sections 31 provides an exemption if the information, which is not exempt information by
virtue of section 30, is exempt information if its disclosure under this Act would, or would be
likely to, prejudice - the assessment or collection of any tax or duty or of any imposition of a
similar nature:
There is a strong public interest in ensuring that HMRC is accountable and as transparent as
possible about the way resources are applied. Publishing the information requested would,
on the face of it, reassure the public that our compliance activities are fair and robust, and
applied equitably across the range of customers served by HMRC.
Against that, there is a strong public interest in HMRC being able to enforce the law properly
so that the tax burden is shared equally and fairly. Providing this information may put at risk
our compliance activities which could undermine public confidence in the tax system.
This could damage the general climate of honesty among the overwhelming majority of
taxpayers who use the system properly and that too is not in the public interest.
On balance, it is not in the public interest to disclose this information
Prejudice to the effective conduct of public affairs
Section 36 provides an exemption if in the opinion of a qualified person, disclosure would or
would be likely to:
(a) prejudice collective responsibility or the equivalent in Wales and Northern Ireland;
(b) inhibit the free and frank provision of advice or exchange of views; or
(c) otherwise prejudice the effective conduct of public affair
In this instance, the email on page 15 is considered exempt pursuant to sections 36(2)(b)(i)
and (ii) FOIA.
The information relates to reports of briefings and discussions between ministers and senior
stakeholders, on policy options. HMRC’s qualified person considers that the disclosure of
such information at this time would likely result in a chilling effect on officials’ ability to
discuss and evaluate future policies.
To discuss policy options effectively, officials necessarily need to be introspective, with free
and frank discussion of what has gone well and what hasn’t. Officials must be able to
criticise aspects of the policy that (for example) are not meeting their aims, or do not
constitute value for money. They need to be able to do so without trepidation that these
discussions could be publicly released during a period when the policy is still subject to
external criticism and debate.
If officials have to consider that these discussions could be released during such a period,
their ability to interrogate a policy with the candidness and frankness required for an
effective evaluation process will be severely inhibited.
EMAIL 5 ATTACHMENT 1
--- PDF page 57 ---
4
OFFICIAL
Section 36 is qualified by the public interest. This means that even though the exemption is
considered to be engaged; it is necessary to consider whether the public interest in
maintaining the exemption outweighs the public interest in disclosure.
HMRC accepts that there is a clear public interest in government departments being as open
and transparent as possible, so as to increase accountability and inform public debate.
However, it is argued that there is a more compelling public interest in preserving the safe
space in which officials can deliberate issues and protecting the department’s ability to
operate effectively.
It is in the public interest for officials to be able to have confidential dialogue in the execution
of their duties and for them to exchange views freely and frankly. Advice provided and
received must be detailed and candid if it is to be of value. For all of this to occur, officials
must be free of any inhibitions that might interfere with their ability to offer comprehensive
input based on free and frank discussion
If such information were to be disclosed, sensitive issues might not be able to be raised in
the future, for fear that information about such issues might be disclosed and be exposed
prematurely to public scrutiny and comment. Disclosures of this information would likely
undermine the quality and nature of this dialogue in the future and would not be in the public
interest.
If you are not satisfied with our reply, you may request a review within 40 working days of
receiving this letter by emailing foi.review@hmrc.gov.uk or by writing to our address at the
top.
If you are not content with the outcome of an internal review you can complain to the
Information Commissioner’s Office.
Yours sincerely,
HM Revenue and Customs
EMAIL 5 ATTACHMENT 1
--- PDF page 58 ---
OFFICIAL
EMAIL 6 – ATTACHMENT 1
WITHHELD INFORMATION
--- PDF page 59 ---
Record of the qualified person’s opinion
November 2011 Version: 1.0
OFFICIAL
Record of the qualified person’s opinion
Freedom of Information Act 2000 Section 36
When dealing with a complaint regarding section 36 of the Freedom
of Information Act 2000, the ICO will expect to see evidence of the
qualified person’s opinion and how it was reached. We require this
evidence in order to decide whether the opinion was a reasonable
one. The following form sets out the minimum information that we
expect public authorities to provide to us about the qualified
person’s opinion, in the event of a complaint.
Completing this form is a convenient way for public authorities to
give us the information we need. It is intended as a tool to assist
public authorities, but there is no statutory requirement for them to
use it; if instead they are able to send us other documents that
record the same information about the qualified person’s opinion,
we will accept those.
While the purpose of the form is to help in providing information to
us when we are investigating a complaint, public authorities may
also wish to use it when they are considering applying section 36,
as part of the internal process of obtaining and recording the
qualified person’s opinion.
Please see the notes at the end for help in completing this form. For
further information on section 36 of the Freedom of Information Act
2000, please see our guidance document on Prejudice to effective
conduct of public affairs (section 36).
This form only records the qualified person’s opinion under section
36(2) of the Freedom of Information Act. If the qualified person’s
opinion is that section 36(2) is engaged (ie that disclosure of the
information would or would be likely to cause prejudice or
inhibition), the public authority must then carry out the public
interest test. As a matter of good practice, public authorities should
also keep a record of the factors considered in the public interest
test and the outcome of that test.
EMAIL 6 ATTACHMENT 2
--- PDF page 61 ---
Record of the qualified person’s opinion
November 2011 Version: 1.0
OFFICIAL
I believe that this exemption applies
to the entirety of the email.
Disclosure of this material would
affect officials’ ability to meet with
ministers for the purposes of free
and frank discussion.
The process of meeting ministers is
integral to officials’ ability to
function effectively. Officials must
be able to report on policy, discuss
potential changes, and respond to
ministers’ questions openly and
frankly. Officials must also be able
to freely relate the relevant content
of these meetings to other officials,
so that the department can work in
harmony with ministers’ views.
It is essential that senior officials
are kept up to date with ministers’
opinions on policy issues,
particularly where the policy in
question is controversial and/or
subject to significant external
scrutiny. It is very important that
ministers feel they can discuss live
policy freely and frankly, to fully
explore options for change and
refinement.
Similarly, it is essential that officials
can report the substance of these
discussions with colleagues, so that
senior officials can be kept abreast
of ministers’ views.
Given the continued external
interest in this policy area, the
disclosure of these lines at this time
would be likely to inhibit similar full
and frank exchange of views in
future if ministers and officials
thought that their decisions and
views would be published. This
would have a negative effect on the
minister-official meeting process.
EMAIL 6 ATTACHMENT 2
--- PDF page 64 ---
Record of the qualified person’s opinion
November 2011 Version: 1.0
OFFICIAL
Notes for completing this form
2. Where the public authority itself, rather than an individual, has
been authorised as the qualified person, the name will be that of
the highest decision making body of the authority.
4. Please refer to section 36(5) of the Freedom of Information Act
2000 for the list of qualified persons.
8. This lists the subsections of section 36 which the qualified person
was asked to consider.
The full text of section 36(2) is as follows:
(2) Information to which this section applies is exempt
information if, in the reasonable opinion of a qualified person,
disclosure of the information under this Act—
(a) would, or would be likely to, prejudice—
(i) the maintenance of the convention of the
collective responsibility of Ministers of the Crown,
or
(ii) the work of the Executive Committee of the
Northern Ireland Assembly, or
(iii) the work of the Cabinet of the Welsh
Assembly Government.
(b) would, or would be likely to, inhibit—
(i) the free and frank provision of advice, or
(ii) the free and frank exchange of views for the
purposes of deliberation, or
(c) would otherwise prejudice, or would be likely
otherwise to prejudice, the effective conduct of public
affairs.
12. This lists the subsections of section 36 which the qualified
person decided were engaged. Please tick the relevant
subsection(s), and in each case indicate whether the prejudice or
inhibition would or would be likely to occur and the reasons for this.
13. This is the date on which the qualified person’s opinion was
given. If the form is completed after that, the date entered here
must still be the date on which the opinion was given.
14. Where the public authority itself, rather than an individual, has
been authorised as the qualified person, the form should be signed
on behalf of the highest decision making body of the authority. In
that case, please also print the name of the person signing on
behalf of that body.
EMAIL 6 ATTACHMENT 2
--- PDF page 65 ---
OFFICIAL
EMAIL 7 – ATTACHMENT 1
DUPLICATE OF EMAIL 6 – ATTACHMENT 2
EMAIL 9 – ATTACHMENT 1
DUPLICATE OF EMAIL 6 – ATTACHMENT 2
EMAIL 9 – ATTACHMENT 2
WITHHELD INFORMATION
EMAIL 11 – ATTACHMENT 1
DISCLOSED UNDER FOI2022/71614 IN REDACTED FORMAT