Legal Updates - Data Protection & Freedom of Information

Data Protection – Freedom of Information – Personal Data – Information Commissioner’s Office – Public Authorities – Revealing too much – Pivot Tables


The Information Commissioner’s Office (“ICO”) has investigated the issue surrounding the disclosure of personal data by public authorities.


Often when public authorities respond to freedom of information requests, they supply the information requested in a spreadsheet format. On occasions, the information would be in the form of ‘pivot tables’. Pivot tables summarise the information of individuals without revealing personal information upon which the summary is based.


However, the issue that has arisen is that public authorities do not always remove the personal data. Furthermore, pivot tables retain copies of the source data used. Although the source data are hidden from view, they can be accessed. Examples can be found on the ICO’s website.


The ICO has the following five key messages for organisations:


  1. Disclosure of hidden personal data in pivot table spreadsheets may be a breach if the Data Protection Act. The data is not secure and is easily accessible, even if not immediately viewable
  2. Avoid using pivot tables for any disclosures or data sharing involving personal data. Consider using CSV files
  3. Check the file sizes before disclosure—larger than expected file sizes should be a trigger for further checks
  4. Ensure your organisation has the right procedures and checklists in place for staff involved in disclosing data
  5. Consider running quick training sessions or drop-in surgeries to ensure staff understand how to safely prepare spreadsheets for release.


More information can be found on the ICO’s website.


For any advice and assistance in relation to data protection, you may contact us by email Visit


© RT COOPERS, 2013. This Briefing Note does not provide a comprehensive or complete statement of the law relating to the issues discussed nor does it constitute legal advice. It is intended only to highlight general issues. Specialist legal advice should always be sought in relation to particular circumstances.


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