At least we’re not vexatious

On 17 December 2015, Ron Davis, Bruce Levin, David Tuller and I requested trial data from the PACE study of treatments for ME/CFS published in The Lancet in 2011. Below is the response to our request from the Records & Compliance Manager of Queen Mary University of London. The bolded portion of our request, noted in the letter, is the following: “we would like the raw data for all four arms of the trial for the following measures: the two primary outcomes of physical function and fatigue (both bimodal and Likert-style scoring), and the multiple criteria for “recovery” as defined in the protocol published in 2007 in BMC Neurology, not as defined in the 2013 paper published in Psychological Medicine. The anonymized, individual-level data for “recovery” should be linked across the four criteria so it is possible to determine how many people achieved “recovery” according to the protocol definition.”

Dear Prof. Racaniello

Thank you for your email of 17th December 2015. I have bolded your request below, made under the Freedom of Information Act 2000.

You have requested raw data, linked at an individual level, from the PACE trial. I can confirm that QMUL holds this data but I am afraid that I cannot supply it. Over the last five years QMUL has received a number of similar requests for data relating to the PACE trial. One of the resultant refusals, relating to Decision Notice FS50565190, is due to be tested at the First-tier Tribunal (Information Rights) during 2016. We believe that the information requested is similarly exempt from release in to the public domain. At this time, we are not in a position to speculate when this ongoing legal action will be concluded.

Any release of information under FOIA is a release to the world at large without limits. The data consists of (sensitive) personal data which was disclosed in the context of a confidential relationship, under a clear obligation of confidence. This is not only in the form of explicit guarantees to participants but also since this is data provided in the context of medical treatment, under the traditional obligation of confidence imposed on medical practitioners. See generally, General Medical Council, ‘Confidentiality’ (2009) available at The information has the necessary quality of confidence and release to the public would lead to an actionable breach.

As such, we believe it is exempt from disclosure under s.41 of FOIA. This is an absolute exemption.

The primary outcomes requested are also exempt under s.22A of FOIA in that these data form part of an ongoing programme of research.

This exemption is subject to the public interest test. While there is a public interest in public authorities being transparent generally and we acknowledge that there is ongoing debate around PACE and research in to CFS/ME, which might favour disclosure, this is outweighed at this time by the prejudice to the programme of research and the interests of participants. This is because participants may be less willing to participate in a planned feasibility follow up study, since we have promised to keep their data confidential and planned papers from PACE, whether from QMUL or other collaborators, may be affected.

On balance we believe that the public interest in withholding this information outweighs the public interest in disclosing it.

In accordance with s.17, please accept this as a refusal notice.

For your information, the PACE PIs and their associated organisations are currently reviewing a data sharing policy.

If you are dissatisfied with this response, you may ask QMUL to conduct a review of this decision.  To do this, please contact the College in writing (including by fax, letter or email), describe the original request, explain your grounds for dissatisfaction, and include an address for correspondence.  You have 40 working days from receipt of this communication to submit a review request.  When the review process has been completed, if you are still dissatisfied, you may ask the Information Commissioner to intervene. Please see for details.

Yours sincerely

Paul Smallcombe
Records & Information Compliance Manager

Comments on this entry are closed.

  • tomkindlon 19 January 2016, 6:14 pm

    “This is because participants may be less willing to participate in a planned feasibility follow up study”
    This looks to me like a red herring. The latest follow-up I recall being talked about was at five years. The trial is over now longer than that.

  • Rob Wijbenga 19 January 2016, 6:28 pm

    so if I tell a lie which causes harm to tens of thousands of people and there’s a legal procedure against me, I’m not allowed to repeat that same lie on request, even when I’m convinced it is the truth

  • weyland 19 January 2016, 6:57 pm

    Anonymized data was clearly requested by Davis et al. What a ridiculous response.

  • Brendan Guthrie 19 January 2016, 7:09 pm

    “One of the resultant refusals, relating to Decision Notice FS50565190, is due to be tested at the First-tier Tribunal (Information Rights) during 2016.”

    This statement deliberately misleads. The “refusal” being referred to has already been tested at the ICO. The ICO directed QMUL to release the data. It is QMUL who refused to accept this decision and have chosen to pursue an appeal.

    The honest response would be: “We are due to APPEAL one of the recent ICO decisions IN FAVOUR of releasing of the data”

  • clark ellis 19 January 2016, 7:32 pm

    Comical. I laughed at loud. Now I understand why they went with ‘vexatious’ for so long until it created such widespread attention that they realized they looked so childish that to continue using it would risk further ire from the wider scientific community.

    This was their best ‘reasonable sounding’ excuse. It’s patently ridiculous. This is anonymised trial data we are talking about here, the same as released by PACEs sister trial (FINE) already without any problems or concerns. They go on as if it is was participant’s cash machine PIN numbers, or their most embarrassing text messages that had been requested. It’s like a Monty Python sketch. And to think they made us wait until the last legally allowable second (as they always do whenever PACE data is requested, interestingly enough) to give this excuse? Even with all that time they couldn’t come up with something more reasonable?

    And this bit here needs special attention I feel:
    “we believe that the public interest in withholding this information outweighs the public interest in disclosing it.”
    Seriously? On the one hand, a seriously controvertial study paid for from the public purse where large parts of the promised data have never seen the light of day, which nevertheless has been highly influential in setting treatment and social security policy with questions over its safety, as well as its effectiveness, and an 11,000+ strong patient petition for retraction of inaccuracies verses another follow up paper (for which data has surely already been collected anyway) which like the last one (recently published) will show that CBT and GET are no better than standard medical practice at follow up (in other words a resounding failure) yet will somehow create headlines in the press claiming the complete opposite anyway because of the way the authors spin it in their comments to press. Pretty easy to see which one will be in the interest of patients and which will not.

  • Gwebo 19 January 2016, 7:35 pm

    Thanks very much Dave, Profs Davies, Levin and Racaniello for making the FOI request. Their reasons for rejecting it are so spurious, so incredibly lame! I hope you can take this issue further. And why does it always take them the full 28 days (or whatever it is) to respond to FOI requests, they could have written this within hours of receiving your request.

  • mesupport 19 January 2016, 7:38 pm

    Anonymised data for Cochrane review when principal investigators were on the steering panel so this is just a delaying tactic.

  • A.M. 19 January 2016, 7:52 pm

    QMUL refer to the ” General Medical Council, ‘Confidentiality’ (2009) available at The information has the necessary quality of confidence and release to the public would lead to an actionable breach.”

    But the GMC’s guidelines are primarily concerned with “identifiable information about patients”, and also states that “For many secondary uses, it will be sufficient and practicable to disclose only anonymised or coded information.”

    As the Information Commissioner has concluded for Decision Notice FS50565190, QMUL has no convincing evidence that individual participants from the PACE trial can or will be identified from the requested data.

    With S.22A, the public interest in disclosure clearly outweigh the public interest in non-disclosure, when considering the major problems identified with how QMUL analyzed the trial data for the 52 week followup and how much distress the misleading publications of the trial results e.g. “recovery” continue to cause the patient community. It is concerning that QMUL continue to the ignore this and show no consideration for the welfare of the patient community who are now exposed to inflated expectations of improvement and recovery because of QMUL’s mistakes. Their mistakes were made during major and mostly post-hoc deviations from the published trial protocol after the trial was over, which were mostly poorly justified and in the case of physical function was justified with a factual error stemming from a simple misinterpretation of basic statistics from a population study). Only disclosure and re-analysis of trial data more in line with the published trial protocol is going to resolve the ongoing and escalating controversy now.

    The 5+ year longer term followup was not actually part of the original research programme anyway, and based on critique of the 2.5 year followup data, it will not provide any useful information, as the preservation of randomization has been destroyed, making most of the results extremely difficult to interpret with any confidence, and there are no longer any significant or meaningful differences between the groups regardless whether they received additional therapy or not. It is therefore unlikely that the longer term followup will be different, and it is more important that the 52 week followup data is further analyzed in order to correct QMUL mistakes, which they fail to sufficiently acknowledge or address (despite that awareness of these mistakes is growing among senior academics and research scientists and causing further damage to the reputation of QMUL and research in the UK in general).

    If I was a PACE trial participant, I would not want to contribute to any followup study, not because of concerns about privacy, but because of QMUL’s poor handing of the previous data collected and dismissal of the concerns raised about how they analyzed that data.

  • weyland 19 January 2016, 8:06 pm

    Monty Python came to my mind too when reading their response.

    “We’d like your oranges please”
    ‘Sorry, we cannot give you our apples’

  • urbantravels 19 January 2016, 8:24 pm

    It certainly does give a shifty appearance. If patient confidentiality is such a paramount concern, why wasn’t it invoked in refusing earlier requests for data?

    I seem to recall, but hope someone has exact information, that at least some of the earliest data requests were rejected on the grounds that the data could not be released while new publications using the data were pending – NOT on the grounds of patient confidentiality and NOT on the grounds that the requests were “vexatious.” When you keep changing your reasons like this, increasingly it looks like you are making excuses.

  • clark ellis 19 January 2016, 8:34 pm

    “Any release of information under FOIA is a release to the world at large without limits. The data consists of (sensitive) personal data…”

    This is a lie and it’s pure scaremongering. The data is limited in that you cannot identify participants from the anonymized data that has been requested. No matter how many times the PACE authors scaremonger that it’s possible, it isn’t. There are no personal details. The most personal item is that you took X number of steps in a session. So there is a clear limit there and it is not sensitive data. It’s a complete lie. What you can do with the data is look at it and decide whether the authors of the PACE trial were honest in their conclusions about whether the treatments work or not.

    If I was a PACE trial participant I’d be pretty pissed if I realized that the PACE authors were lying to me and everybody else about this. Using me in this way, as some kind of tool to deny the failure of this study to further their own careers. Several participants have already come forward on the net and said they were involved in the trial and were met with kindness and support by their fellow patients, and some of them raised concerns about the study, but I hope these poor people who kindly took part to try and further research aren’t misled by these claims from the PACE authors.

  • clark ellis 19 January 2016, 9:10 pm
  • Sasha 19 January 2016, 9:14 pm

    I agree. I’d be pretty angry if I’d been a patient in PACE and the authors were using me as an excuse to continue to hide their data from legitimate scientists who wanted to do the protocol-specified analyses instead of the inflationary nonsense that the study authors perpetrated upon that data.

    In the Lancet Psychiatry response, the PACE authors refer to patients in the trial as their “collaborators”. Pity they don’t treat their collaborators with respect.

  • CureCFS 20 January 2016, 2:57 am

    From their own link:

    “For many secondary uses, it will be sufficient and practicable to disclose only anonymised or coded information.”

  • Paul_Watton 20 January 2016, 5:46 am

    This case is of huge importance to the research community and a severe test of strength for the UK Freedom of Information Act ……….. one in which the real public interest is not currently winning !

    I fear that if the PACE trial Investigators’ bogus reasons for withholding the anonymised data are allowed to stand, then a precedent will be set that will give carte blanche to researchers who would wish to deny access to patient trial data of any kind in the future.
    Therefore, if the wider public interest is to be upheld, the Information Commissioner must prevail over QMUL’s malevolent appeal in relation to the Mathees request.

    I trust that you will be requesting an immediate review of QMUL’s decision.

  • pinklil 20 January 2016, 6:20 am

    And if they cared so much about the safety of patient data they wouldn’t have carelessly left it in an unlocked drawer to be stolen.

  • Danny Scippio 20 January 2016, 6:44 am

    I’m afraid the outcome of the request for PACE data was entirely predictable:

    The FOIA position will take precedence in all of QMUL’s thinking on data requests that are PACE related – this is inevitable if their lawyers are even half competent, and the chances are QMUL has very good lawyers given the experience that they’ve built up in the PACE saga. 1st Tier Appeal Tribunals are often symathetic to the appellants and at this stage QMUL can have a reasonable expectation it will win and thus close the door on future request that have any resemblance to previous ones. Even if the 1st Tier appeal fails, a 2nd Tier appeal is likely to be allowed. And Jim Coyne’s attempt to get PLOS1 agreements may not fare any better as the FOI situation will more than likely to be argued by QMUL to have an overarching impact.

  • Findlow 20 January 2016, 7:29 am

    Yes, it all rather puts one in mind of that time-honoured excuse: The dog ate my homework.

  • A.M. 20 January 2016, 8:13 am

    Here are some interesting figures about previous outcomes:

    First-tier Tribunal FoI appeals decided in 2014-15
    (Appeals brought by public authorities)

    Total: 34
    Upheld: 3 (9%)
    Partially upheld: 10 (29%)
    Dismissed / withdrawn: 21 (61%)

  • A.M. 20 January 2016, 9:08 am

    Most FoI appeals to the First-tier Tribunal are dismissed or withdrawn. The chances of success obviously depend on the circumstances of each case, but if using figures on the outcome of First-tier Tribunal FoI appeals decided in 2014-15, QMUL only has a 9% chance of having their appeal upheld (29% for partially upheld, and 61% for dismissed or withdrawal) :

    It is my understanding that appeals to the next stage, the Upper Tribunal (Administrative Appeals Chamber), face more difficulties. The appellant must first request permission from the First-tier Tribunal, and failing that, request permission from the UT(AAC), and also have evidence for an obvious error of law, which may not be so easy in this case.

  • JCB 20 January 2016, 1:21 pm

    An unlocked drawer in a shared office, as I understand it. The letter from the PACE people regarding it did refer to “the therapists’ office” not “the therapist’s office”.

    Interestingly Prof White wrote that “these recordings are not believed to contain any sensitive personal information”. Do the recordings include participants’ voices?

  • GQ 20 January 2016, 1:43 pm

    Thank you Dr Ranciello, Dr Tuller, Dr Davis and Dr Levin for pursuing this matter. ME patients are appreciative of your support and taking up these matters on behalf of them to expose these dangerous treatments particularly GET which is enforced on sick and disabled people. Their response was not unexpected.

    We all hope that you will be following this up with the Information Commissioners Office (which recently forced QMUL to release the withheld data which they are now appealing). The PACE PI Peter White has also been lobbying the UK government to exempt universities from the FOI Act and it appears they are delaying the release of the data in the hope that they may be able to exempt themselves. The reasons that they have provided this time round are pathetic and can be seen only as excuses.

    They are making excuses for this scientifically fraudulent trial which is of no benefit and in fact harmful for ME/CFS patients and only beneficial for the PACE Principal Investigator’s paymasters. These paymasters being the UK Department for Work and Pensions and and the wider disability insurance and reinsurance industry which Peter White, Michael Sharpe and Trudy Chalder have been working for.

    The PACE trial PI’s have never shown any interest for patients concerns and this is a pathetic excuse which they are attempting to hide behind. It is criminal that disabled people have been caused harm and injury by these doctors and the PACE trial and the public interest in this publicly funded trial is in releasing all data and being transparent so that patients and their doctors are fully aware of the flaws in this trial.

    Thank you for exposing the PACE PIs for what they are and keep up the pressure as they attract more attention to themselves and ridicule from the scientific and medical community and public at large with their actions to hide the data.

  • Steve Hawkins 20 January 2016, 8:47 pm

    There ought to be General Scientific Council, and a Universities Council, whereby scientists and universities that refuse to allow others to validate their research, are publicly shamed and all further research from that source is blacklisted because it cannot be trusted.

    In fact, for starters, the Science Media Centre, Retraction Watch, and All Trials, should set up a database of scientists and research establishments who’s work cannot be trusted, so that nobody has to waste money on employing them, or going to study there in the future.

    There is no need to wait for civil servants to decide. These ‘researchers’ have already been up before their peers in the wider scientific community, and have treated them with contempt.

    What more proof could anyone need?

    Strike them off the international research agenda.

    Enough is enough.

  • Steve Hawkins 20 January 2016, 10:30 pm

    This issue should be decided by the research community. I don’t see why there is any need to wait for non-scientist civil servants to pronounce after another lengthy process, wasting even more money.

    The research community is being held in open contempt by a small group of incompetent would-be scientists, and their research establishment is aiding and abetting their unprofessionalism, amounting to insolence from both parties.

    These researchers and their establishments should simply be blacklisted by the legitimate scientific world, and all their publications be henceforth marked as suspect and not to be trusted.

    Retraction Watch already has the makings of a go-to site for checking scientific reputability. Just let it be registered that QMUL and its research output is unverifiable and not to be trusted, and is best avoided by the wider research establishment, and prospective degree students, in future.

    Compare and contrast the handling of the XMRV controversy in the US: The alleged finding of a useful treatment for M.E is every bit as momentous as the claimed discovery of a virus being behind it. Yet the XMRV controversy was swiftly investigated in a manner involving very real vexation of the researchers involved: notebooks were confiscated; lawsuits were launched; one researcher had to spend time in prison; laboratories were turned upside down, and everything was retested in multiple labs, at the cost of many millions of dollars. The truth was rooted out. The matter was settled, lessons were learned, and the research community went on to different lines of investigation.

    Contrast the UK: Strange results are published, that clash with the life experience of the vast majority of M.E patients, and ‘treatments’ are then recommended for them on the basis of these strange results, even though there were no confirmed M.E patients in the study. 

    The experience and sanity of an entire patient community is then called into question for many years, no matter how many times they point out the obvious flaws in the study, and the erroneous assumptions that underlie it.

    Eventually, scientists outside the cosy world of English psychiatry, get wind of the controversy, and ask, politely, for the necessary information to verify these research findings that have held thousands of patients in limbo, and denied them further investigation for nearly a decade.

    What do they get: a flat ‘No’!

    What is *wrong* with this country? In the US, QMUL and its researchers, would have been turned upside down and the data shaken out of them by now! Where is the pride of the British research and educational establishments, that they will just sit back and do nothing while one small clique of mere questionnaire pushers, holds the whole of British science up to international ridicule?

    Our whole UK scientific and medical establishments seem to have gone down with a severe case of Post Experimental Malaise, and its immune system is compromised and incapable of recognising and removing the obvious cause.

    Over XMRV, the US gave us a very good demonstration of the vital importance of showing that it means business when it demands research integrity and transparency. The World saw that America takes its science seriously.

    In contrast: the UK scientific establishment is either ignoring the situation entirely, or actively working to aid in the concealment and deception. The matter is having to be dealt with by the international community of scientists, because the UK is incapable of policing itself.

    Shame on us.

  • Danny Scippio 21 January 2016, 6:23 am

    The key figure is ‘partially upheld’ – that often allows the institution to keep the most significant data underwraps while only being required to reveal some of the window dressing. You also have to look at motivation for this class of appeal; most are from local authorities which are firefighting on a short term issue and want to hold information back in advance of a legal judgement, contract agreement or election. In these cases delay is the real objective and the grounds are only strong enough to get permission to go for appeal of the Commissioner’s decision. The test for each level of appeal is supposed to be progressively more difficult so yes getting through to the 2nd Tier may be a challenge but if the lawyers are competent then they will have designed their 1st Tier appeal to expose any useful legal ambiguities a judgement against QMUL might involve. One can hope QMUL will throw in the towel if the 1st Tier judgement does go against them – but don’t bank on it.

  • Findlow 21 January 2016, 12:06 pm

    Unfortunately, I think it would be unwise to put your faith in the UK Science Media Centre:

    “Researchers are questioning two of the SMC’s claims: to provide neutral
    scientific views to promote better representation of science in the
    media, and to be independent of its many funders, who are largely the corporate world and the government.

    Instead, they said at PCST2014, corporate lobbyists feature high on the
    agenda, which is dominated by the topics close to corporate rather than
    public interest.”

    As regards ME/CFS, and PACE, the Science Media Centre is very much part of the existing problem (17 comments) (13 comments)

  • Trish Davis 22 January 2016, 7:03 am

    Have you seen this?

    It’s an article in the Annals of Internal Medicine entitled:
    Sharing Clinical Trial Data: A Proposal From the International Committee of Medical Journal Editors.
    Unfortunately the proposals are not retrospective.
    One of the signatories is Astrid James, MBBS, Deputy Editor, The Lancet

    Here are a few extracts:

    ‘As a condition of consideration for publication of a clinical trial report in our member journals, the ICMJE proposes to require authors to share with others the de-identified individual-patient data (IPD) underlying the results presented in the article (including tables, figures, and appendices or supplementary material) no later than 6 months after publication.

    ICMJE already requires the prospective registration of all clinical trials prior to enrollment of the first participant. This requirement aims, in part, to prevent selective publication and selective reporting of research outcomes,

    Prospective trial registration currently includes documenting the planned primary and major secondary end points to be assessed, which enables identification of incomplete reporting as well as post hoc analyses.

    Data sharing is a shared responsibility. Editors of individual journals can help foster data sharing by changing the requirements of the manuscripts they will consider for publication in their journals. Funders and sponsors of clinical trials are in a position to support and ensure adherence to IPD sharing obligations. If journal editors become aware that IPD sharing obligations are not being met, they may choose to request additional information; to publish an expression of concern; to notify the sponsors, funders, or institutions; or in certain cases, to retract the publication.

    Sharing data will increase confidence and trust in the conclusions drawn from clinical trials. It will enable the independent confirmation of results, an essential tenet of the scientific process.

    t will help to fulfill our moral obligation to study participants, and we believe it will benefit patients, investigators, sponsors, and society.’

  • Steve Hawkins 22 January 2016, 11:07 am

    Most certainly not putting any faith in the SMC. Far from it: I want to force it to quit the bias and be the useful resource for promoting science and debunking quackery that it likes people to think it is.

    Unfortunately Ben Goldacre himself has just started speaking out *against* magazine publishers’ agreement to demand more data sharing!!!

  • Steve Hawkins 22 January 2016, 11:10 am

    Ben Goldacre himself has just objected to this. From his tone, it might even be him writing the QMUL objections. 🙁

  • Steve Hawkins 22 January 2016, 11:11 am

    Ben Goldacre’s latest missive reads just like Queen Mary Uni London’s latest excuse for not letting fellow scientists see PACE trial data! He’s now arguing *against* magazines agreeing that such data be made available!!!

  • P.M. 23 January 2016, 2:22 am

    There are understandable concerns about the routine sharing of *all* IPD from clinical trials. But the wider research community is already moving towards open data initiatives which account for these concerns and have safeguards in place. PLOS One is the largest research journal in the world and they now require all data underlying the article to be published as well, including IPD. It is very interesting that the FINE trial (sister to PACE) recently published data in this journal, along with IPD which met the liberal PLOS data sharing policy anonymity and confidentiality.

    Another point to make is that the FOIA request by Tuller et al. only represents a tiny fraction of the entire PACE trial database, and it does not contain any direct or indirect identifiers as defined by the PLOS data sharing policy. Given the major problems identified with how QMUL analyzed the trial data and apparently refuse to disclose data to anyone who may challenge their previous publications, it is difficult for many in the patient community to escape the conclusion that QMUL are more concerned with avoiding embarrassment (about their flawed and erroneous changes to the protocol) than they are about patient privacy.

    Note that FINE trial data suggests components of the PACE trial recovery criteria were so lax that they may have inflated the “recovery” estimates by up to sixfold. Grossly inflated and highly misleading claims about “recovery” from ME/CFS is unethical and it would be very disappointing if QMUL supports such behaviour. With the PACE trial, QMUL have also claimed that they are consulting patients about how to handle data sharing, but the outcome of such consultations should be treated with skepticism until QMUL provides details about how these patients are being solicited and what they are being told.

  • Steve Hawkins 23 January 2016, 3:01 am

    Goldacre has a letter in this week’s Lancet complaining about a paper on handwashing where outcomes were either changed, or not reported, yet he’s not lifted a finger when QMUL shrinks did the same.

  • Steve Hawkins 23 January 2016, 3:06 am

    More Goldacre double standards. Here he writes in this week’s Lancet, complaining of a handwashing study that failed to follow its protocol or report all its outcomes, yet we’ve been drawing his attention to very similar problems with PACE for months, and he’s done nothing.

  • deboruth 19 February 2016, 9:52 pm

    It seems PACE investigators had claimed that data were successfully anonymized for at least one purpose. Mr. Smallcombe for QMUL seems to maintain that they were not. Perhaps some person with standing in the matter might ask Mr. Smallcombe to clarify how it is, and by whom, that the data have been induced to surrender their anonymity. In addition, Mr. Smallcombe’s defense of QMUL’s refusal appears provoked by the request that the data be served “raw.” Indeed, persons of a certain educational background might argue that if the data were to be raw (i.e. untouched; exactly as gathered) they could not yet have been anonymized. Perhaps the request might be re-phrased to eliminate the offending word, instead describing the precise bits of data sought as they may already exist in anonymized form or as they shall be anonymized presently (in timely fashion.) Thereby it will no longer be possible for Mr. Smallcombe to accuse the data of harboring anything “personal.”

  • alan m dransfield 5 October 2016, 2:59 am

    I am afraid the ICO have lost their moral compass with these Vexatious and manifestly unreasonable BS decisions and I should know because I am the Vexatious King Of England.
    The ICO are doing the complete opposite to their public duty and have knowingly and willfully breached the FOIA/Human and civil rights .Not tomention the willfull breach of section 77 of the FOIA
    Unfortunately, the new IC Lizzie Denham has adopted the corrput status quo introduced by Christopher Graham
    Alan M Dransfield