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)
    . 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
    • 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).