Chapter 3: Decisions

Formal decisions

Significant decisions

Formal decisions

In 2012 a total of 200 cases were reviewed by my Office. As I mentioned earlier, this total is comprised mainly of formal decisions, settlements and withdrawals. The outcome of the reviews which went to formal decision in the years 2009, 2010, 2011 and 2012 is highlighted in the table below.

Percentage comparison of formal decisions 2009 - 2012

Percentage comparison of formal decisions 2009 - 2012

The table shows that in cases which went to formal decision, the Office recorded an increase in annulled decisions in 2012 over 2011.

Annulled decisions – Section 29

A number of the decisions annulled by my Office in 2012 were due to non-compliance by the public body concerned with certain provisions of section 29, in that consultation procedures did not take place within the prescribed statutory deadlines.

Section 29 of the FOI Act sets out the procedures to be followed where the public body considers that although a record is exempt from disclosure because it contains information given in confidence (section 26), commercially sensitive information (section 27) or personal information relating to a third party (section 28), on balance, the record falls to be released in the public interest.

Where section 29 applies, the body is required to notify an affected third party, within a specified period of time, before making a final decision on whether or not the exemption(s), otherwise found to apply, should be overridden in the public interest.

In cases where the public body did not adhere to the statutory deadlines, I take the view that it is appropriate for my Office to accept such applications for review in the first instance. If my Office were to refuse to accept defective section 29 applications, the initial decision of the public body would, arguably, remain and there would be no mechanism available to my Office to ensure that the rights of all affected parties were protected. A more detailed explanation of the provisions of section 29 can be found in my Annual Report 2011.

The following are a number of formal decisions issued during 2012, which highlight points of interest to public bodies and FOI users alike. The full text of each decision is available on my Office website (

Significant decisions

Mr. X and the Department of Communications, Energy and Natural Resources – Case 080288

In September 2008, the applicant sought access to the “database of coverage information that informs the map entitled ‘Wireless and Broadband Coverage’”, which had been published in August 2008 as part of the National Broadband Scheme (NBS). The request followed one of a similar nature that ultimately gave rise to case 080184, which I discussed in my Annual Report 2011. Unlike case 080184, the database which was the subject of the applicant’s request in this case still existed, but the Department made claims for exemption under sections 23, 24, 26, and 27 of the FOI Act. The question that immediately arose, however, was whether the information contained in the database could, with effort, be sourced from the public domain or not. The apparent availability of at least some of the information concerned in the public domain, for instance, by accessing the ‘Siteviewer’ service on the website of the Commission for Communications Regulation (ComReg), seemed to undermine the claims of sensitivity that had been made with respect to the database at issue.

In reaching my decision, I had regard to the comments of Costello J in House of Spring Gardens Limited v. Point Blank Limited [1984] I.R 611. I observed that if it takes skill, time and labour to compile the information concerned, the information may still be regarded as confidential even if the component parts were sourced from the public domain. In relation to the database at issue, I accepted that, while certain individual details therein could be obtained from publicly available sources such as ‘Siteviewer’, or the various planning authorities, no single source of such comprehensive information about the telecommunications infrastructure of this country could be found in the public domain. Moreover, in the context of the claims for exemption made by the Department under sections 23 and 24 of the FOI Act, I attached significant weight to the views of members of the security services who had made presentations at a meeting held in May 2012.

The evidence presented by the Department in this case was relevant to a number of the exemption provisions of the FOI Act, but in light of what I was free to disclose, I considered that section 23(1)(c) was the most appropriate exemption to apply. Describing the database as “a directory giving the precise locations and antennae height of the majority of the broadband transmission sites in the country, including the exempted structures on property in private ownership”, I was fully satisfied that granting access to the database in full could reasonably be expected to facilitate the commission of an offence, whether mere theft and vandalism of a particular transmission site, or a larger criminal enterprise such a bank robbery. Accordingly, I found that section 23(1)(c) applied.

The Irish Times and the Department of Finance – Case 100173

This case concerned the refusal of the Department of Finance to release a number of records relating to correspondences between the then Minister for Finance, Mr. Brian Lenihan, and the CEO of an identified public service body. During the course of the review the Department released certain records but withheld others either in full or in part, in accordance with sections 21(1)(c), 31(1)(a) and (b) of the FOI Act. Three of the records at issue related to financial issues including the liquidity of the banking system.

The Department argued that disclosure of the records would disclose positions taken for the purpose of negotiations (section 21(1)(c)) and could cause the financial markets to take a negative view of Ireland’s capacity to repay borrowing which could reasonably be expected to have a serious adverse effect on the financial interests of the State, or on the ability of the Government to manage the national economy (section 31(1)).

However, the exemptions in both section 21 and section 31 can be dis-applied where the public interest, on balance, is better served by granting than by refusing the request. In conducting this exercise in this particular case, I considered the extent to which release of the records might undermine the public interest in protecting the functions and negotiations of public bodies in so far as they relate to the financial interests of the State and possible effects of release in negotiations in the financial environment. I also considered the extent to which release of the records might undermine the public interest in protecting the financial and economic interests of the State and the possible effects of release on those financial and economic interests and on the Government’s ability to manage the national economy.

In my view the prospect that release of records causing significant harm as claimed by the Department with the type of consequences suggested by it, cannot be lightly disregarded or dismissed, especially given the uncertainty and volatility of international markets. While the Department asserted that release of the records would have negative consequences for how it performs its functions and engages in negotiations, I was not satisfied that it supported this assertion to any real extent.

However, I also consider that the release of a record which could reasonably be expected to have a serious adverse affect on the financial interests of the State should only be contemplated where there is a significant public interest served by releasing such a record. I recognise that the public interest in transparency is served only where records are released and that refusing release is contrary to the public interest in achieving transparency. In this case, however, having accepted the Department’s contention that the release of the records could reasonably be expected to have a serious adverse affect on the financial interests of the State, I did not consider that the public interest in achieving transparency was sufficient to outweigh the public interest in ensuring that such harm does not arise. I therefore affirmed the Department’s decision to refuse access to the records.

Mr Gavin Sheridan and the Industrial Development Agency – Case 110092

This case concerned the refusal of the IDA to release names of individuals from whom it leased various premises, on the basis that such details comprised the individuals’ personal information.

The IDA released details of the location and size of the properties, the start and end dates of the leases (all commenced in the early 1980s, with one commencing in 2007), and the amount of rent payable by the IDA in each year specified in the request.

Section 28(1) of the FOI Act must be applied to a record which, if released, would “involve the disclosure of personal information” about an identifiable individual. My Office accepted that disclosure of the withheld names would disclose to the world at large a number of inextricably linked facts about the parties concerned i.e. their ownership of, and yearly income from, particular properties. Information about an individual’s financial affairs and property is defined by the FOI Act to be personal information. Consequently, my Office found that section 28(1) applied and that such details were not already in the public domain. If they had been, section 28(1) would not have applied.

In considering the public interest at section 28(5)(a), I had regard to the 2011 judgment of the Supreme Court in the case of The Governors and Guardians of the Hospital for the Relief of Poor Lying-In Women v The Information Commissioner (the Rotunda judgment). A number of obiter comments were made which, although concerning the public interest test at section 26(3) of the FOI Act, provide useful guidance in considering any public interest test contained in the FOI Act.

Essentially, a public interest (“a true public interest recognised by means of a well-known and established policy, adopted by the Oireachtas, or by law”) must be distinguished from a private interest, and the public interest test concerned would not weigh in favour of release where the interest identified is exclusively private. Thus, when considering the public interest test in the release of personal information, privacy rights will be set aside only where the public interest served by granting the request is sufficiently strong to outweigh the public interest in protecting privacy.

Arguments made against release included concerns as to the potential impact of release on the personal safety of any elderly third parties and the expectation of secrecy attaching to leases signed in the 1980s.

I took the view that the breach of privacy that arises in the cases of those who leased properties to the IDA in the 1980s may be somewhat more than minimal. However, I did not feel it appropriate to accept that any particular class of citizen, or age group, should have a greater right to privacy than any other. Neither did I accept that the parties could have had any justifiable belief that details of annual payments they were due to receive from the State, further to arrangements entered into for commercial advantage, would be kept secret indefinitely, particularly where those with leases dating from the 1980s sought rent reviews in either 2007 or 2008. I consider an expectation of a diminution of privacy rights, at least in relation to the disclosure of details of commercial transactions with public bodies, to be a necessary consequence of entering into such arrangements.

The public interest arguments favouring release were ensuring openness and accountability for the expenditure of public monies, particularly given the length of time over which the monies are payable (21 years in the case of the lease signed in 2007 and 35 years in all others) and given that the monies were payable regardless of whether the IDA sublet the premises, or sublet them for a rental amount less than that payable to the landlord.

I take the view that public bodies should be open as to with whom they do business and to whom state monies are paid, and to show that they are ready to be held accountable, if necessary, for those arrangements. My Office ultimately found that the public interest warranted the release of the names at issue.

Mr X, on behalf of the Irish Fire and Emergency Services Association (IFESA) and Dublin City Council - Cases 110102 & 110198

Case 110102 concerned nine FOI requests (with 58 different elements) made to the Council by one requester between 12 January and 14 February 2011. The same requester made three further requests to the Council, containing 12 separate elements, on 20 June, 19 July and 21 July 2011 (case 110198 refers). The Council refused the requests on a number of grounds, including that they were frivolous or vexatious or formed part of a pattern of manifestly unreasonable requests from the same requester (section 10)(1)(e)). Both cases were dealt with as a composite review.

In another decision, I had previously set out a number of non-exhaustive factors that I consider relevant in assessing whether a request may be categorised as “frivolous or vexatious”:

  • the number of requests made;
  • the nature and scope of the requests;
  • the purpose of the requests;
  • the intent of the requester.

I also consider these factors to be equally relevant in determining whether or not there is evidence of a pattern of manifestly unreasonable requests.

My Office considered the number of requests to be excessive, in light of the extent of information sought in each, and the short time period over which they were made. In addition, the requests were considered to be excessively broad and unusually detailed, having regard to the diverse range of records sought in the various elements thereof. In light of particular comments in the applicant’s letters to the Council, my Office agreed with the Council’s view that the requests had been made with the intention of accomplishing an objective unrelated to the access process i.e. with the aim of forcing the Council to liaise with, and/or ultimately recognise the representative association with which the applicant was involved. In this regard, it should be noted that section 8(4) of the FOI Act, as amended, allows a public body to take into account the motive of a requester when considering if section 10(1)(e) applies.

Accordingly, I took the view that the various requests comprised a pattern of manifestly unreasonable requests, and that using FOI in such a way was an abuse of the right of access such that the requests appeared to be vexatious. I held that, in either scenario, section 10(1) (e) of the FOI Act applied.

Ms X and the Health Service Executive Dublin Mid-Leinster - Case 110106

This review was remitted to the Information Commissioner by the President of the High Court for determination in accordance with the law.

In this case, the applicant sought a review of the decision of the HSE to grant access to seven reports compiled and held by the HSE, following its investigation of complaints regarding a nursing home. The applicant was the Person-in-Charge at that nursing home. Having conducted my review, I found that that HSE’s decision to grant access was justified. My decision was appealed to the High Court on a point of law and, on 31 May 2011, the High Court remitted the review back to my Office for determination on the ground that a number of procedural issues had been identified.

In my decision, I had referred to published reports of prior inspections of the nursing home which were not within the scope of the FOI request but the applicant was not given an opportunity to make a submission to my Office in relation to those reports. Further procedural issues were identified, including an issue relating to whether or not the names of nurses at the nursing home constituted personal information.

In accordance with the Order of the High Court, the decision of the HSE was reviewed afresh by my Office. In the intervening period, the nursing home in question had closed which, in my view, directly undermined the applicant’s arguments as to the potential harm which might arise from the release of what was considered to be commercially sensitive information.

The applicant also argued that all the information she provided, or that was provided by the staff of the nursing home, was provided in confidence and that the publication of the information would constitute a breach of a duty of confidence owed. I considered that there is a public interest in members of the business community (including nursing home proprietors/operators) being able to communicate with public bodies (such as the HSE) without fear of disclosure in relation to sensitive matters. However, I did not accept that any understanding of confidence could exist in circumstances where the HSE was involved in the investigation of alleged breaches of regulations.

On the matter of where the balance of the public interest lay, I considered that there is a significant public interest in optimising openness and transparency in relation to inspections carried out by the HSE under the Nursing Homes (Care and Welfare) Regulations, 1993. I also considered that there is a significant public interest in ensuring accountability in respect of the substantial sums paid out by the Exchequer in terms of subventions to patients resident in nursing homes. Having considered the matter at length, I found that the public interest would be better served by granting access to the reports sought.

Mr & Mrs Y c/o Solicitors and the Health Service Executive (HSE) – Case 110158

This case concerned the refusal of the HSE to release details of who reported the applicants to the HSE concerning their children. The HSE initially relied on the exemptions in sections 26(1)(a) and 28(1) to refuse to grant access but during the course of the review it also invoked the exemption in section 23(1)(b) to withhold the information sought.

In this case I further developed my Office’s approach to the consideration of the section 23(1)(b) exemption, which provides for the protection of the identity of persons who have given information in confidence to public bodies in relation to the administration of the civil law. The exemption is aimed at ensuring that members of the public are not discouraged from cooperating with agencies engaged in the enforcement or administration of the civil law. For the exemption to apply, three specific requirements must be met. The first is that release of the withheld information could reveal, whether directly or indirectly, the identity of the supplier of the information. The second is that the information must have been given to the public body in confidence, while the third is that the information must have been supplied to the public body in relation to the enforcement of administration of the civil law.

In this case, the applicants argued that the information given to the HSE was maliciously motivated and thus could not have been made in confidence. In support of their argument, they referred to the case of Cruise v Bourke [1919] 2 IR 182 where Madden J. held that malice could be inferred if it could be shown that the Defendant had no reasonable or probable cause for advancing the prosecution and had no honest belief in the Plaintiff’s guilt. The HSE’s position was that every such report it receives is acted upon in good faith. While it was of the opinion that it was likely the report was malicious, the HSE stated that it was not in a position to take a more unequivocal view of the matter and that it was not in a position to know definitively whether the person(s) who made the report was acting in good faith.

Previous decisions of my Office indicated that the issue of whether information was provided in good faith is a factor to be considered in the determination of whether or not information has been given in confidence. In this case, while I accepted that some circumstantial evidence existed to suggest that the report to the HSE may have been maliciously motivated, I was not convinced that sufficient evidence existed to state categorically that this was the case. In any event, I accepted that the HSE acts upon every such report in good faith. I further acknowledged that when one considers the person who, in good faith, supplies information which is subsequently found on investigation to be inaccurate or mistaken, the difficulty for the HSE in handling such reports in any other manner becomes apparent.

I accepted that the disclosure of the identity of complainants, even where the evidence suggests that the complaint was maliciously motivated, could prejudice the flow of information from the public and that the HSE relies upon such information to carry out its functions. In this case, I gave significant weight to safeguarding the inherent importance in protecting the free flow of information to the HSE and I accepted the HSE’s position that the information was given in confidence in this case, notwithstanding the fact that the allegations were subsequently regarded as unfounded. Accordingly, I found that all three conditions for section 23(1)(b) to apply were met and I upheld the decision of the HSE to refuse access to the information sought.

Mr “C” and the Department of Health - Case 110166

The applicant sought from the Department of Health certain information relating to mortality rates for Mayo General Hospital, Castlebar. He argued that the information should be released as the Minister for Health had put similar information for hospitals in Galway and Roscommon on public record. The Department decided to defer access to the information sought in accordance with section 11(1)(b) of the FOI Act. Section 11(1)(b) allows a public body to defer access to certain information where it considers that release before a specified day would be contrary to the public interest.

This provision is rarely used by public bodies and I view the case as helpful in explaining how I address the public interest test associated with section 11(1) of the Act. The public interest test contained in section 11 is stronger than those found elsewhere in the Act insofar as it will only justify the withholding of a record where its disclosure on or before a particular day is contrary to the public interest. There is no need to show that the disclosure of the record is positively in the public interest.

The Department decided to defer release of the information under section 11(1)(b) of the FOI Act, on the basis that “a report is in final preparation which will provide the data requested in relation to all hospitals as well as other important indicators” and that it is “ expected that the report will be completed by the end of September [2011] and published following discussion with the Minister”.

During the course of the review, it became clear to my Office that the publication of the report containing the information sought would be delayed. Regardless, the Department argued that the release of the information sought prior to the publication of the report would be contrary to the public interest.

The Department argued that release of the information sought would lead directly to negative impacts on the public and have serious public health implications and that releasing inaccurate information would have an impact on, and undermine, public confidence in future reports that are due to be published and which will provide important data in relation to health care provision in Ireland. This argument was based on the argument that the information at issue may be inaccurate and, therefore, misleading. The Department considered that the information may be related by individuals or their families to care that they received in the hospital, giving rise to concerns which might well be unfounded. Separately, the Department argued that the release of the information may subvert its wider intentions in relation to the improvement of quality of data which, it argues, is not in the public interest.

The applicant, on the other hand, argued that the Minister for Health put the mortality rate for cardiac patients in both Roscommon and Galway Hospitals on the public record in a Dáil debate on 5 July 2011 and that it was very difficult to see how the Department could argue that the release of the information for the third major hospital in that region would be contrary to the public interest. He suggested, in fact, that it would serve the public interest to release the information relating to Mayo General Hospital to allow for a more informed public debate.

In my view, the fact that the release of factual information may not be without consequences and may prompt questions from the media or other sources does not, of itself, suggest that release would be contrary to the public interest. One would imagine that it would be quite easy to provide a fuller explanation to any member of the public who might query the figures or to provide additional explanatory background information when releasing the information sought.

In this case, I also found the Department’s concerns in terms of the potential for having serious health implications to be overstated, and I did not accept that the release of the information at issue would be likely to undermine public confidence in future reports.

On the matter of whether the release of the information might subvert the Department’s wider intentions in relation to the improvement of quality of data, I understood that this argument related to concerns expressed by some hospitals as to the accuracy of the data contained in the report. However, I was also aware that the Department had since engaged in a consultation process with the hospitals to address concerns relating to its intention to publish the report and I did not see how the release of the information sought in this case could give rise to the harm identified, particularly given that the Department fully intended to publish the report with the information at issue unchanged.

I found that the Department had not presented any compelling arguments that showed that the release of the information sought would be contrary to the public interest. I found that the Department was not justified in deciding to defer access under section 11(1)(b) of the FOI Act.

Mr X and the Health Service Executive - Case 110204

Mr X applied to the HSE for access to the ‘’medical records’’ of his deceased parents. The HSE relied on section 28(1) of the FOI Act to refuse access to the medical records of the applicant’s late father because his G.P. held a record wherein the applicant’s late father expressed his wish to change his “next of kin” from the applicant to other person(s). A record also existed which indicated that the applicant’s late father informed his G.P. of his wish that a named person other than the applicant should be contacted if anything happened to him.

Section 28(1) of the FOI Act provides that a public body shall refuse to grant access to a record where access would involve the disclosure of personal information relating to a third party, including personal information relating to a deceased individual. However, regulations made in 2009 (the Freedom of Information Act 1997 (Section 28(6) Regulations) 2009 (S.I. No 387 of 2009)) provide, at article 4(1)(b)(iii), that subject to the other provisions of the FOI Act, a request for access to records of a deceased individual shall be granted to

“the spouse or the next of kin of the individual where in the opinion of the head, having regard to all the circumstances and to any relevant guidelines published by the Minister, the public interest, including the public interest in the confidentiality of personal information, would on balance be better served by granting than by refusing the request”

“Next of kin” is defined in Article 4(2) of the 2009 Regulations and in the Guidance Notes for consideration by decision makers in applying the 2009 Regulations. I was satisfied from an examination of these provisions that the applicant qualified as the deceased’s “next of kin”, regardless of any expressed wish by his late father to change this. Therefore, I decided that the applicant’s request for access to his late father’s medical records fell to be considered in accordance with the provisions of Section 28(6) of the FOI Act, the 2009 Regulations and the relevant Guidance Notes published by the Minister for Finance.

Section 28(6) of the FOI Act and the associated 2009 Regulations provide for the release of personal information of deceased persons to “next of kin” under certain circumstances.

The Guidance Notes specify that certain factors should be taken into consideration in determining whether the public interest would be better served by granting than by refusing the request. Factors include:

  • The confidentiality of personal information;
  • Whether or not the deceased would have consented to the release of the records to the requester when living;
  • The nature of the relationship of the requester to the deceased; and
  • The nature of the records to be released. In relation to medical records, due regard should be had to the confidentiality of medical records in accordance with the Irish Medical Council Guide to Ethical Conduct and Behaviour.

I considered the HSE’s record relating to the wishes of the applicant’s late father. The G.P. involved subsequently informed the HSE of her opinion that the applicant’s late father was of sound mind when he made his request. In view of these factors, I was not satisfied that the applicant’s late father would have agreed to the release of the records at issue while he was living. The FOI Act recognises a very strong public interest in protecting privacy rights. Consequently, I found that the public interest would, on balance, be better served by refusing access to the medical records of the applicant’s late father in this case.

Mr X and a Public Body - Case 120023

The applicant sought records relating to an independent investigation, conducted at the request of his employer (a public body), into whether or not certain of his actions amounted to misconduct. Ultimately, the review concerned an email sent to the body by the person who conducted the investigation (the “third party”) after the investigation had ended, which the body withheld under section 26(1)(a) of the FOI Act.

Public bodies cannot rely on section 26(1)(a) in relation to records prepared by anyone providing a service for the body under a contract for service, in the course of performing his or her functions, unless a duty of confidence is owed to another, external, party (section 26(2) refers). However, the body contended that the third party was no longer a “service provider” when he sent the email, in which case section 26(1)(a), a mandatory exemption, was relevant.

In order for a record to be exempt under section 26(1)(a), it must contain information

  • given to a public body in confidence and,
  • on the understanding that it would be treated by it as confidential and,
  • in the opinion of the head, its disclosure would be likely to prejudice the giving to the body of further similar information from the same person or other persons and,
  • it is of importance to the body that such further similar information as aforesaid should continue to be given to the body.

As regards the first and second tests, my Office noted that the email, and its response, did not indicate that either the body or the third party had any kind of understanding that the latter gave the information in the email to the body in confidence and on the understanding that it would be treated by it as confidential. The public body’s arguments appeared to represent its understanding of the circumstances under which the third party sent the email, rather than why it, presumably, held the same position having regard to the circumstances in which that email was received. In this regard, I note Macken J.’s comments in the Rotunda judgment referred to earlier, regarding the importance of considering the “circumstances in which [the information] was imparted and received” (emphasis added). However, a finding was not made on these tests, given that my Office considered that the fourth test above was not met.

The body appeared to accept it did not need to continue to receive communications such as the email at issue. However, both it and the third party argued that release of the email could render service providers reluctant to undertake work for the body in future.

While the body appeared to argue that it was, accordingly, not in the public interest to release the record, the public interest is only relevant when one accepts that a record is prima facie exempt from release. I accept that it may be of importance to a body to continue to receive certain information from service providers (such as clarification on issues that only they can provide) after a contract has concluded. Also, I note that service providers may need to contact a public body, after conclusion of a contract, in relation to commercially sensitive or personal matters. However, neither consideration was relevant in this case.

What was relevant was the body’s apparent acceptance that it did not need to continue to receive information such as that contained in the email. I note that the body had not explained why it might consider that service providers would be reluctant to carry out a service for it in accordance with an agreed contract for service, which would set out rights and obligations of both parties, including those in relation to the provision of information.

I was not satisfied that sufficient argument had been made that the fourth test had been met in this case. I found that the body’s application of section 26(1)(a) was not justified. As no arguments had been made that any other provision of the FOI Act applied, I directed the release of the record.

Mr X c/o Y solicitors and the Department of Agriculture, Food and the Marine – Case 120084

In this case, I found that a decision by the Department of Agriculture, Food & the Marine to refuse a request pursuant to section 28 of the FOI Act (which relates to personal information) was justified. The applicant had sought information relating to third party claims submitted to and paid out by the Department relevant to his lands.

I was aware that my consideration of the public interest in this case ran contrary to the approach I had adopted in some previous cases where I considered that applicants for certain grant aid are, as farmers, comparable to sole traders and as such, information relating to the payment of such grants relates to the business affairs of sole traders and does not constitute personal information about the individuals concerned. However, those decisions were taken before the Rotunda judgment, which I referred to earlier.

Among other things, the Rotunda judgment required me to alter the approach I had previously adopted in my interpretation of the definition of personal information for the purposes of the FOI Act. I was satisfied, having regard to the Rotunda judgment, that information relating to the payment of grants, such as the information at issue in the records in this case, was personal information. As such, the manner in which I considered the public interest balancing test was necessarily affected.

Having considered the various public interest factors, I was satisfied that the public interest in granting the applicant’s request did not outweigh the public interest that the right to privacy of the individual or individuals to whom the information related should be upheld.

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