Before you begin
- Keep the complete decision and proof of when it was received.
- Check review, appeal and limitation deadlines immediately.
- Do not assume a complaint pauses another legal route.
- Use documents and dates rather than unsupported conclusions.
Identify the information—not the document title
Authorities hold recorded information, which may exist across email, case systems, minutes or spreadsheets. Describe subject, date range, people or teams and likely record type precisely.
Analyse the refusal notice
Record each exemption, whether a public-interest test was applied, the searches described and any advice and assistance offered. Separate information said not to be held from information withheld.
Ask focused internal-review questions
Challenge a search by identifying likely locations or known records. Challenge an exemption by addressing its elements and the public interest. Avoid simply repeating the original request.
Build the ICO pack
Include the request, acknowledgement, response, internal-review request and outcome in date order. Add a short schedule showing the disputed information and why the response is deficient.
Do not use FOI as disclosure in disguise
FOI has its own purpose and exemptions. If the real need is personal data, litigation disclosure or access under another regime, use the correct route or obtain specialist advice.
A reliable challenge structure
- The decision and date.
- The applicable rule, policy or standard.
- The finding disputed.
- The evidence supporting your correction.
- The procedural failure, if any.
- The practical impact.
- The precise remedy requested.
Need help applying this structure to your documents? Request an initial assessment.