Subject: Request for Internal Review – FOI 4620

2025-09-23

Dear Freedom of Information Officer,

I request an internal review of the refusal issued in relation to FOI 4620.

The House of Lords has relied on section 34 FOIA (Parliamentary privilege) as a blanket ground to withhold all information I requested. I must formally challenge this on three points:

1. Over-application of section 34
   Section 34 is an absolute exemption only where disclosure would infringe the privileges of either House. My request sought a list of file titles, references, and neutral metadata relating to 1,154 identified records. Such administrative information does not in itself disclose proceedings of Parliament. Applying s.34 to all material, without analysis, amounts to a carte blanche refusal, which is contrary to FOIA’s purpose and case law requiring exemptions to be applied narrowly.
2. Redaction rather than wholesale refusal
   Even if some individual file titles could reveal privileged content, the correct response would be to redact those specific entries and release the rest. The refusal to provide even a partial list demonstrates that the exemption has been applied as a blanket shield, which is not justified under the Act.
3. Failure to comply with section 16 FOIA
   The House of Lords has a statutory duty to provide advice and assistance. In this case, s.16 required you to consider whether partial disclosure, redaction, or provision of a neutral schedule would allow me to refine my request within the cost limit. By refusing outright, that duty has not been fulfilled.
4.   Live safeguarding and international obligations My request concerns information relevant to the disappearance of my daughter, who is the subject of an outstanding European/International Arrest Warrant. A refusal to provide even neutral metadata risks obstructing matters directly connected to a live safeguarding and judicial process. While section 34 is an absolute exemption, the House of Lords must still ensure that its application of FOIA does not place it in breach of wider international obligations, nor give the appearance of obstructing justice.

I therefore request that this internal review:

• Re-examines whether file metadata can reasonably be disclosed;
• Provides a redacted list where privilege genuinely applies;
• Sets out clearly how the House has discharged its duty under s.16.

If the House maintains its refusal after this review, I will have no option but to place the matter before the Information Commissioner for a formal decision under section 50 FOIA.

Yours sincerely,
Martin Newbold

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