From: alan dransfield []
Sent: 11 July 2019 11:49
To: elizabeth.denham; <>
Subject: Fwd: Panopticon: The Facebook Appeal and Procedural Grounds

Elizabeth Denham

Information Commissioner

Please see this article ref the ICO and Facebook. In
particular, scroll down to the list ofQC’s who represented the ICO and Facebook, all of which work for 11KBW. Are you aware of this irregularity? Is
this not conflict of interest?

As you are aware I had a FOIA request on this topic
refused under Section 14/1 and section 50 (2) (c) about 12 months ago.

May I take this opportunity to submit a FOIA request
seeking copies of all 11 KBW invoices for legal service to the ICO
for this particular case please? I do concede this may well appear to be a
repeated request, but in the event of a serious legal irregularity,
I suggest my FOIA request is benign, politely written, in the
interest of the general public and serious purpose and, therefore, should not be
deemed vexatious or frivolous under either section 14/1 or 50 (2) (C) of the
FOIA 2000.

As you are well aware, the ICO has advised me before via
your Mr Adam Sowerbutt that all future FOI requests from me will be treated as
vexatious or frivolous without due process. Could this be the main reason
why 99% of UK QC’s are self Employed as a legal loopholes to circumvent conflict of interest regulations?

With thanks

Alan M Dransfield.

FOI Campaigner and Social Watchdog