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Sales of Personal Data (524A/20)


1) Can I please have your records concerning the sales of personal data from 2019 and 2020, including trading partners and money earned from transactions?

2) Please can I have your records concerning the determining the price of personal data, for sales and sharing for the time period January 2019- Present.

3) What is your internal procedure for selling personal data? By this, I mean guidance given to internal staff and the buyer in question, for the time period of January 2019- Present.

4) What types of personal data do you sell and are there any limits placed on this? For the time period of January 2019- Present.

5) How many Subject Access Requests did you receive in the period 2017-2020, broken down by year?

6) What types of personal data did they typically receive? For example email addresses, home addresses and telephone numbers?


Our data are not organised in such a way as to allow us to provide this information within the appropriate (cost) limit within the Freedom of Information (FOI) Act.

This is because we do not collate specific data about what type of information is disclosed, therefore, we would have to go into each individual record to manually collate this which would exceed the appropriate limit (FOIA, s.12 (1)).

This means that the cost of providing you with the information is above the amount to which we are legally required to respond i.e. the cost of locating and retrieving the information exceeds the ‘appropriate level’ as stated in the Freedom of Information (Fees and Appropriate Limit) Regulations 2004.

In accordance with the Freedom of Information Act 2000, this letter acts as a Refusal Notice for this part of the request and if one part of a request exceeds the fees limit then S12 of the Act applies to the whole request.

Further information on section 12 of FOI is available here:

However, in accordance with Section 16 of the Act I have a duty to provide advice and assistance in relation to your request and can provide an answer to questions 1 – 5. Please see attached document.

This should not be taken as a precedent that additional information would be supplied outside of the time/fees legislation for any subsequent requests.