Communication relating to preparation of COP26 UN climate change summit: FOI review

Information request and response under the Freedom of Information (Scotland) Act 2002

Information requested

For copies of all correspondence since March 2020 to the present day between the Scottish Government and the Scottish Events Campus venues concerning planning and preparation for the hosting of the upcoming COP26 UN climate change summit, due to be held in Glasgow in November 2021.

  • The disclosure should include, but not be limited to, correspondence between Leslie Evans, Roseanna Cunningham, Gerard Howe, Tessa Ferry, and Kersti Berge (as well as other members of the Scottish Government’s COP26 policy and strategy, delivery and operations, and strategic communication teams), with Councillor Susan Aitken, Glasgow City Council, Scottish Events Campus Limited, and City Property (Glasgow) LLC, as well as officials and management at the SEC Hydro, SEC Armadillo, SEC Centre, and Glasgow Science Centre and its charitable trust.
  • It should also include any correspondence between the above Scottish Government parties and Glasgow Life and the Gallery of Modern Art in Glasgow concerning use of the venue around COP26.
  • The correspondence disclosed should include, but not be limited to, letters, emails (and any attachments that were included to them), texts, social media messages, briefings, and minutes and transcripts of conversations and/or telephone and video calls.


Attached is a copy of most of the information you requested at ANNEX A. I have put the relevant correspondence into a table.

Whilst our aim is to provide information whenever possible, in this instance we are unable to provide some of the information you have requested because exemptions under the following sections of FOISA apply:

  • Section 38(1)(b) applies to the personal data of a third party.
  • Sections 31(1), information is exempt if exemption from disclosure is required for the purpose of safeguarding national security.

The reasons why this exemption apply are explained in ANNEX B.


Section 38(1)(b) - applies to the personal data of a third party.

An exemption under section 38(1)(b) of FOISA (personal information) applies to some of the information requested because it is personal data of a third party, ie the names and contact details of individuals, and disclosing it would contravene the data protection principles in Article 5(1) of the General Data Protection Regulation and in section 34(1) of the Data Protection Act 2018. This exemption is not subject to the ‘public interest test’, so we are not required to consider if the public interest in disclosing the information outweighs the public interest in applying the exemption.

Section 31(1) - applies to safeguarding national security
Under section 31(1) of FOISA, information is exempt information if exemption from disclosure is required for the purpose of safeguarding national security. In our view, it is necessary to exempt a small amount of the information requested. The information in question would identify prospective venues or concerns the planning arrangements for those venues. At this time, we consider that this information requires to be withheld for the purpose of safeguarding national security, for the following reasons.

The planning and preparation for events hosted by the Scottish Government at COP26 is ongoing, including significant security preparations in order to ensure the protection of attendees as well as local communities. Evidence both from high profile summits and previous COPs indicates a wide range of threat actors including extremists and terrorists targeting the subject matter, specific attendees or locations. Indeed experience has highlighted that the earlier details are disclosed about the venues that are to be used in connection with events of this nature, the greater the risk that threat actors will undertake venue reconnaissance in advance of the event taking place. If the information is disclosed in a controlled manner closer to the event, then this enables mitigating measures to be put in place before the venues become public knowledge as well as limiting the available time for reconnaissance.

This exemption is subject to the ‘public interest test’. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exemption. We have found that, on balance, the public interest lies in favour of upholding the exemption. We recognise that there is a public interest in disclosing information as part of open, transparent and accountable government, and to inform public debate. However, there is a greater public interest in ensuring that national security is safeguarded by not prematurely disclosing the identity of the prospective venues. We would also observe that the public interest in the location of these venues will largely be served because they will be made public in due course, once the necessary security arrangements have been made, and that this will substantially address the public interest in disclosing this information.

About FOI
The Scottish Government is committed to publishing all information released in response to Freedom of Information requests. View all FOI responses at

FOI202100205635 - Annex A


Please quote the FOI reference
Central Enquiry Unit
Phone: 0300 244 4000

The Scottish Government
St Andrews House
Regent Road

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