https://ico.org.uk/media/action-weve-taken/decision-notices/2023/4023577/ic-169575-t0d9.pdf

  1. The emphasis on protecting public authorities’ resources from
    unreasonable requests was acknowledged by the Upper Tribunal (UT) in
    the leading case on section 14(1), Information Commissioner vs Devon
    County Council & Dransfield [2012] UKUT 440 (AAC), (28 January 2013)
    (“Dransfield”)2
    . Although the case was subsequently appealed to the
    Court of Appeal, the UT’s general guidance was supported, and
    established the Commissioner’s approach.
  2. Dransfield established that the key question for a public authority to ask
    itself is whether the request is likely to cause a disproportionate or
    unjustified level of disruption, irritation or distress.
  3. The four broad themes considered by the Upper Tribunal in Dransfield
    were:
    • the burden (on the public authority and its staff);
    • the motive (of the requester);
    • the value or serious purpose (of the request); and
    • any harassment or distress (of and to staff).