FOI reference - FOI-119
Date - 7 June 2023
Request
Response
I confirm that we hold the information you have requested. However, we are unable to supply some of the information requested for the reasons set out below.
Information we are able to supply
Please see attached the spreadsheet containing the information for TPR's bonus distribution for the financial year 2021-2022.
Information we are unable to supply
Please see the explanation below for the redactions applied to the figures within the breakdown of the bonuses awarded by Directorate and Grade.
Section 40(2) Personal Information
Under section 40(2) of the FOIA, third party personal data (personal information of another person) is exempt from disclosure if releasing would contravene any of the provisions of the UKGDPR and Data Protection Act 2018.
Where individuals in a small group may be identifiable, it is standard statistical reporting practice to suppress the disclosure of personal data. In this case, information would be withheld under section 40(2) where it relates to fewer than five people. Information would also be withheld if disclosing it would allow a sub-set of fewer than five persons to be identified. Information in response to the questions listed above involve small numbers which increases the risk of mosaic identification i.e. personal data from which a living individual can be indirectly identified. We do not have these individuals’ consent to disclose information pertaining to them and do not consider it reasonable in the absence of such consent to give out this information.
Disclosure of personal data whether directly or indirectly in these circumstances i.e. a disclosure to the world at large would be unfair and contrary to the requirements of the first UK GDPR Principle: Lawfulness, fairness and transparency. Individuals and members of staff can expect TPR to secure their personal information and only process their personal information in line with data protection legislation. This exemption is an absolute exemption and therefore is not subject to the public interest test.
Further information
For context on the figures and details for EDs and the CEO, please see annual report and accounts.