You asked for the Scottish Government’s policy on the redaction of names of Scottish Government employees from FOI responses.
We redact the names and direct contact details for Scottish Government staff below senior civil service level of the organisation. We consider that these individuals can be directly identified from this information and therefore consider it to be personal data as defined by section 3(2) of the DPA 2018. We consider that disclosing this information would contravene the first data protection principle in Articles 5(1)(a) of the GDPR.
The Scottish Government has a general approach of disclosing information about senior members of staff, releasing details of those within Senior Civil Service (SCS) roles but withholding those details for more junior members of staff. It would be unfair to release the information because the officials in question hold roles below SCS level and as such we consider that these more junior staff concerned have a greater right to expect privacy, and would not expect their personal data to be processed in this way. For these reasons, the names and contact details of Scottish Government employees below SCS meets the requirements set out in section 38 (1) (b) of FOISA and Regulation 11(2) of the EIRs.
We will on occasion, release names of staff below SCS level or redact those of SCS staff, on a case by case basis. In taking decisions on the release of personal data in these cases, we follow the advice set out in the Scottish Information Commissioner’s briefings on personal data, linked to below:
The Scottish Government is committed to publishing all information released in response to Freedom of Information requests. View all FOI responses at http://www.gov.scot/foi-responses.
Please quote the FOI reference
Central Enquiry Unit
Phone: 0300 244 4000
The Scottish Government
St Andrews House
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