{"check":null,"uid":"cb3ea2f06642cf77","title":"Ben Lotz v The Information Commissioner & Anor","title_generated":false,"country":"Великобритания","organ":"Суды Англии и Уэльса","kind":"case","kind_name":"Судебная практика","lang":"en","date":"2026-09-08","summary":"Суд рассмотрел апелляцию гражданина против решения Комиссии по информации Великобритании отказать ему в доступе к контактным адресам сотрудников трёх команд (JSA, ESA, UC) в каждом из лондонских Jobcentres. Комиссия признала правомерность отказа ДWP сослаться на раздел 12 Закона о свободе информации (стоимость выполнения запроса), но указала на нарушение обязательств оператора по предоставлению консультаций и помощи гражданину при уточнении запроса. Суд подтвердил обоснованность оценки стоимости выполнения запроса и отклонил апелляцию.","snippet":"","topics":["Персональные данные"],"status":"ok","error":"","text_len":32747,"versions":1,"url":"https://caselaw.nationalarchives.gov.uk/ukftt/grc/2026/1286","first_seen":"2026-09-11","last_checked":"2026-09-17 01:33","relevance":"hit","score":7,"query":"personal data","source_key":"caselaw_uk","verdict":{"relevance":"hit","score":7,"topics":["Персональные данные"],"need_body":3,"authorities":[{"kind":"орган","name":"Information Commissioner","topic":"Персональные данные"}],"evidence":[{"topic":"Персональные данные","term":"personal data","weak":false,"pos":2745,"ctx":".  … etc.”  the dwp’s reply  4.  the dwp replied on 31 may 2024 relying on section 40(2) (personal data) to withhold the information. on internal review the dwp relied instead on section 12(1)","zone":"текст","weight":1},{"topic":"Персональные данные","term":"data protection","weak":false,"pos":11078,"ctx":"mit. “  27.  the relevant appropriate limit, prescribed by the freedom of information and data protection (appropriate limit and fees) regulations 2004 (‘the regulations’) is £600.  28.  in makin","zone":"текст","weight":1},{"topic":"Персональные данные","term":"gdpr","weak":false,"pos":19523,"ctx":"e to use e-mail as a main channel of communication because of the associated security and gdpr risks. however, in line with the requirements of the equality act 2010 , we do offer e-ma","zone":"текст","weight":1},{"topic":"Персональные данные","term":"gdpr","weak":false,"pos":25414,"ctx":"o use email as a main channel of communication is ‘because of the associated security and gdpr risks’.  64.  most london jobcentres do have an email address that is available to be use","zone":"текст","weight":1},{"topic":"Персональные данные","term":"Information Commissioner","weak":false,"pos":15,"ctx":"Ben Lotz v The Information Commissioner & Anor Introduction  1.  This is an appeal against the Commissioner’s decision notice IC-","zone":"орган","weight":3}],"dropped":[]},"last_changed":"2026-09-11","meta":{"neutralCitation":"[2026] UKFTT 01286 (GRC)","court":"United Kingdom First-tier Tribunal (General Regulatory Chamber)"},"source_url":"https://caselaw.nationalarchives.gov.uk/ukftt/grc/2026/1286","text":"Introduction\n\n1.\n\nThis is an appeal against the Commissioner’s decision notice IC-316713-L5R8 of 4 December 2024 which held that the Department for Work and Pensions (the DWP) was entitled to rely on\nsection 12\nof the\nFreedom of Information Act 2000\n(FOIA) (cost of compliance) to refuse to comply with the request for information. The Commissioner held that the DWP had breached its obligations under section 16 FOIA to offer advice and assistance. The Commissioner required the public authority to provide Mr Lotz with advice and assistance regarding how to refine his request.\n\nProcedural issues\n\n2.\n\nThe Commissioner had made a rule 14 application in relation to the redacted version of the second respondent’s submissions. The Judge refused that application in an order dated 6 May 2026 and ordered that an unredacted copy be provided to the appellant. The appellant was given the opportunity to provide additional submissions but did not do so. Instead he indicated in an email dated 9 May 2026 that he had previously made an application on 3 March 2025 to exclude the second respondent’s submission. In that application the appellant had asked that the submission was put in the open bundle, which has now been done, but he also stated that ‘I prefer that it is not included at all, because I did not have access to it when I was asked to formulate my appeal’. That is not a reason for excluding evidence. The appellant has now been provided with the unredacted version, which forms part of the open evidence, and has had the opportunity to make submissions.\n\nThe request\n\n3.\n\nThe appeal relates to a request made by Mr Lotz on 20 May 2024 in which he requested the following information:\n\n“\n…I need an email address for a staff contact in the JSA (Jobseeker’s Allowance) Team, the ESA (Employment and Support Allowance) Team, and the UC (Universal Credit) Team. Only one per team per Jobcentre; but for every Jobcentre in London.\n\nPlease provide the most appropriate one for claimants to contact that provides the appropriate team.\n\nThe most appropriate could, for example, be the most senior public-facing contact in that team.\n\nIn terms of practicality, I suggest you contact the Manager of each Jobcentre to provide these contacts and email addresses.\n\nMy request also implies a list of Jobcentres in London, so that it is clear for claimants who to contact in which Jobcentre.\n\nExample:\n\nJobcentre-Name1, email address for JSA, email address for ESA, email address for UC.\n\nJobcentre-Name2, email address for JSA, email address for ESA, email address for UC.\n\nJobcentre-Name3, email address for JSA, email address for ESA, email address for UC.\n\n… etc.”\n\nThe DWP’s reply\n\n4.\n\nThe DWP replied on 31 May 2024 relying on section 40(2) (personal data) to withhold the information. On internal review the DWP relied instead on\nsection 12(1)\n(cost of compliance).\n\nThe decision notice\n\n5.\n\nIn a decision notice dated 4 December 2024 the Commissioner decided, that the DWP was entitled to rely on\nsection 12(1)\nFOIA but had failed to provide reasonable advice and assistance within section 16 FOIA.\n\n6.\n\nThe Commissioner accepted that complying with the request would exceed the appropriate limit, taking account of the DWP’s sampling exercise in which it found that it took on average 17.5 minutes per team to extract the information:\n\n49 Jobcentres in London with six temporary sites = 55 Jobcentres in total.\n\n17.5\n\nminutes (average time taken per team) x 3 benefit teams = 52.5 minutes per Jobcentre.\n\n52.5\n\nminutes x 55 sites = 2,887.5 minutes needed for all Jobcentres to attempt to extract the required information.\n\n7.\n\nThe Commissioner found that the request was for ‘the most appropriate’ email for claimants to contact each benefit office, not simply for a non-personal email address for the most senior member of the team. He said that Mr Lotz was asking DWP to designate a set of emails that can receive electronic correspondence from any claimant attending that Jobcentre. He accepted that email contact was approached on a case by case basis and was not simply a matter of whether the email address is external or belongs to a senior employee.\n\n8.\n\nThe Commissioner said that determining what information was held involved making a judgement on whether each Jobcentre has an associated set out three emails that can publicly be announced as ‘appropriate’ for all of the specific benefit claimants of that Jobcentre to use, potentially resulting in hundreds or thousands of emails being sent outside of DWP’s set processes.\n\n9.\n\nThe Commissioner noted that as part of its submissions to the Commissioner the DWP said that:\n\n“the requester may be able to narrow their request to ask for external email addresses currently used by Jobcentres in London for customers. I apologise that this had not previously been identified as a suggestion under section 16 of the FOI Act.”\n\n10.\n\nOn that basis the Commissioner required DWP to provide Mr Lotz with advice and assistance on how to refine the request.\n\nNotice of appeal\n\n11.\n\nThe grounds of appeal are, in summary, that:\n\n11.1.\n\nThe Commissioner was wrong to conclude that the estimate was reasonable and that the Trust was entitled to rely on\nsection 12(1)\n.\n\n11.2.\n\nThe Commissioner’s investigation was flawed, because he did not require evidence of the Trust’s assertions.\n\n12.\n\nIn particular Mr Lotz argued that:\n\n12.1.\n\nDWP did not inform him of the email address\ncorrespondence@dwp.gov.uk\n\n12.2.\n\n2 rather than 17.5 minutes ought to be sufficient for identifying the best email address.\n\n12.3.\n\nDWP did not inform Mr Lotz of the structure of the Digital Directorate as set out in [24] of the decision notice.\n\n12.4.\n\nThe DWP has a duty to be accessible and should be prepared and have the relevant information readily available or should proactively publish the information on their website.\n\n12.5.\n\nThe requested information should fall under the publication scheme.\n\nThe Commissioner’s response\n\n13.\n\nThe Commissioner submitted that DWP had provided clear and cogent evidence as to why a time of 17.5 minutes (per benefit team, per Jobcentre) to extract the information is a reasonable estimate. The Commissioner submitted that Mr Lotz had provided no further elaboration or evidence on why the correct figure should be 2 minutes. In the absence of any contradicting evidence the Commissioner maintained that the DWP had provided reasonable and accurate cost calculations based on its clear and cogent evidence.\n\n14.\n\nThe Commissioner submitted that if Mr Lotz was suggesting that the provision of the email address\ncorrespondence@dwp.gov.uk\nor information about the Digital Directorate would have assisted him in relation to the scope of the request, the Commissioner said that Mr Lotz was entitled to make any further information request to DWP as they see fit. He submitted that this does not disturb the findings of the decision notice.\n\n15.\n\nGiven that the DWP were using a publication scheme that reflects the ‘Model Publication Scheme’ from the Commissioner’s website, the Commissioner submitted that DWP had provided sufficient contact information on its website and disagreed that DWP should be expected to provide specific granular email addresses on its website or under its publication scheme. He submitted that Mr Lotz had requested very specific information and he could not envisage any reasons why the DWP should be expected to have this information readily available in the event that a relevant FOIA request is made. In any event, the Commissioner submitted that the focus of the appeal is on whether the decision notice is correct and this does not disturb the findings in the decision notice.\n\nReply by Mr Lotz\n\n16.\n\nMr Lotz submitted that the tribunal has jurisdiction to consider whether the Commissioner had failed to interpret FOIA in accordance with a legal or moral obligation, in this case ignoring relevant duties under the Public Sector Equality Duty and the publication scheme.\n\n17.\n\nMr Lotz argued that under the Public Sector Equality Duty (PSED) the DWP should have already ensured that it was accessible by email as an anticipatory reasonable adjustment.\n\n18.\n\nHe submitted that the Commissioner should have incorporated this duty into its Model Publication Scheme and related guidance and should not approve publication schemes that fail to comply. He asked the tribunal to rule on his interpretation of section 19 and 20 FOIA (publication schemes and model publication schemes).\n\n19.\n\nMr Lotz submitted that as a result of the PSED the Commissioner should, on the balance of probabilities assume that the DWP have the information readily available. He said that he had made attempts at obtaining the information in the weeks before the request, so the DWP should have had the necessary foreknowledge to crate the missing team email addresses, and should, in line with its duty, have created them prior to his request.\n\n20.\n\nIn relation to the estimate, Mr Lotz submitted that from the ‘sparse morsels’ of evidence that the DWP and Commissioner have released, primarily in the decision notice, there is no way of telling whether the exercise that the DWP undertook and the sample was robust, or whether they retrieved and identified the most appropriate email address in under 2 minutes and spent the rest of the time doing something else that should not count towards the costs.\n\n21.\n\nHe said that:\n\n21.1.\n\nIt is not clear what the shortest and longest time, was, because only the average was provided.\n\n21.2.\n\nThe total number of staff in the teams is not clear\n\n21.3.\n\nIt is not clear to what degree the Commissioner investigated Mr Lotz’s suggestions about automating or filtering the search\n\n21.4.\n\nHe claimed that he was able to identify the most appropriate email address in a batch of 40 within under 2 minutes.\n\n22.\n\nMr Lotz submitted that the email address\ncorrespondence@dwp.gov.uk\n, disclosed in a later decision notice (IC-314156-S9W4) would have been retrievable within the\nsection 12\ncost limit and is usable to contact the various teams, as long as the postal address is included.\n\n23.\n\nHe said that he availability of this email address, along with the lack of information on the Digital Directorate, was relevant to the duty to provide advice and assistance.\n\n24.\n\nMr Lotz said that he had referred the DWP response to his refined request to the Commissioner. He said that it ‘offers little’ in terms of what was originally requested, and that it begs the question relevant to\nsection 12\nof how these email addresses were obtainable by the methodology that the DWP applied in this appeal.\n\n25.\n\nMr Lotz said that the Commissioner should have dealt with the delay by DWP in providing advice and assistance.\n\nLegal framework\n\nSection 12\nCosts Limit\n\n26.\n\nUnder\nsection 12(1)\nFOIA a public authority is not obliged to comply with a request for information where:\n\n“the authority estimates that the costs of complying with the request would exceed the appropriate limit. “\n\n27.\n\nThe relevant appropriate limit, prescribed by the Freedom of Information and Data Protection (Appropriate Limit and Fees) Regulations 2004 (‘the Regulations’) is £600.\n\n28.\n\nIn making its estimate, a public authority may only take account the costs it reasonably expects to incur in relation to the request in–\n\n(a)\n\ndetermining whether it holds the information,\n\n(b)\n\nlocating it, or a document which may contain the information,\n\n(c)\n\nretrieving it, or a document which may contain the information, and\n\n(d)\n\nextracting it from a document containing it. (See Regulation 3).\n\n29.\n\nThe 2004 Regulations specify that where costs are attributable to the time which persons are expected to spend on the above activities the costs are to be estimated at a rate of £25 per person per hour.\n\n30.\n\nThe estimate must be sensible, realistic, and supported by cogent evidence (\nMcInerney v IC and Department for Education\n[2015] UKUT 0047 (AAT) para 39-41).\n\n31.\n\nThe test is not a purely objective one of what costs it would be reasonable to incur or reasonable to expect to incur. It is a test that is subjective to the authority but qualified by an objective element. It allows the Commissioner and the tribunal to remove from the estimate any amount that the authority could not reasonably expect to incur either on account of the nature of the activity to which the cost relates or its amount. (\nReuben Kirkham v Information Commissioner\n[2018] UKUT 126 (AAC)\n).\n\n32.\n\nFOIA is not a means of reviewing a public authority’s record-keeping and testing it against best practice (\nCommissioner for the Metropolis v Information Commissioner and\nMackenzie\n[2014] UKUT 0479\nparagraph 37). As the Upper Tribunal stated in\nCruelty Free International v Information Commissioner\n[2017] UKUT 0318 at paragraph 25:\n“The requestor has to take the public authority’s record keeping practices as they are, even if they are defective. That holds true whether the defect is poor administration or breach of a legal obligation.”\n\nThe role of the tribunal\n\n33.\n\nThe tribunal’s jurisdiction is governed by section 58 FOIA. This requires the tribunal to consider whether the decision made by the Commissioner is in accordance with the law or, where the Commissioner’s decision involved exercising discretion, whether he should have exercised it differently. The tribunal may receive\nevidence that was not before the Commissioner and may make different findings of fact from the Commissioner.\n\nIssues\n\n34.\n\nThe issues for the tribunal to determine are:\n\n34.1.\n\nWas the DWP entitled to rely on\nsection 12\n? Was the DWP’s estimate that the costs of complying with the request would exceed the appropriate limit reasonable and supported by cogent evidence?\n\nEvidence and submissions\n\n35.\n\nWe read and took account of an open bundle and written submissions from all parties.\n\nWritten submissions in response to the order of Judge Dwyer\n\n36.\n\nBy directions dated 20 November 2025 Judge Dwyer ordered the respondents to provide further information in relation to the DWP’s processes.\n\n37.\n\nThe Commissioner relied on the DWP’s submissions to the Commissioner\nin the letter to the Commissioner dated 21 October 2024.\n\n38.\n\nThe DWP provided submissions dated 9 January 2026.\n\n39.\n\nThe DWP said that e-mail addresses are stored in the Department’s global address list (GAL). At the time of the review conducted for the Commissioner, as of 21 October 2024, there were over 209,000 e-mail addresses within this database.\n\n40.\n\nThe DWP submitted that as it is not mandatory for sites to have e-mail addresses for external communications, the GAL would have to be fully interrogated to determine what e-mail addresses would be held. This would involve going through all DWP e-mail addresses manually or using the filters available. This would not be determinative as it is down to what information has been included in setting up the e-mail, for example, whether the creator of the e-mail address included linked information which can be filtered.\n\n41.\n\nThe DWP submitted that due to the fact that it is not mandatory for sites to have external e-mail addresses, the fact that these could possibly be produced at any period in time by any colleague, and the fact that the e-mail address may not have been named after its site name, searching through the GAL using the filters available.\n\n42.\n\nThe DWP gave the example that searching “Westminster” in the office filter produced over 140 e-mail addresses, which included e-mails for colleagues and room bookings. However, no team e-mail addresses appeared (as of 6 January 2026).\n\n43.\n\nThe DWP said that depending on when the e-mail was set up and who owns the e-mail address, if it exists, for the purpose of the requestor’s request, this would involve trying to historically extract information through inboxes, guessing possible e-mail titles through colleague inboxes or the GAL.\n\n44.\n\nThe DWP gave the example of the e-mail that was released for Barnsbury Jobcentre in FOI2024/102574. The DWP said the e-mail address does not have enough credentials for the filter tool to work effectively as there is no first name, last name, title, phone, location or department linked to the e-mail. Additionally, there is a typographical error in the ‘name’ as between the words ‘Barnsbury’ and ‘UC’ there are two spaces instead of one, which can further lose and hinder the extraction of the e-mail addresses requested.\n\n45.\n\nThe DWP submitted that additionally the searches and filters would be in respect of one Jobcentre’s inbox but the requestor had asked for a JSA, EA and UC email inboxes for each Jobcentre in London for claimants to contact.\n\n46.\n\nThe DWP said that on 13 January 2025 in response to FOI12024/102574 it provided Mr Lotz with the ‘active external email addresses currently used by Jobcentres for customers in London’ after Mr Lotz narrowed his request.\n\n47.\n\nIn relation to the emails addresses available for communication between Jobcentres and for central teams to contact individual Jobcentres, the DWP submitted that colleagues have access to the GAL, Microsoft Teams and the intranet which provide a list of colleague contacts for sites, broken down by Directorates to help narrow searches and find particular job roles. The DWP said that there are also internal only email address not for the purpose of the requestor’s request. The DWP said that each Jobcentre had a Customer Service Leader and the contact details of the appropriate person could be found internally by colleagues. The DWP said that Jobcentres are also structured within Areas, Groups and Districts so that individuals within those areas will be acquainted with sites within those locations.\n\n48.\n\nThe DWP explained that there are over 50 Jobcentres in London, all with multiple e-mail address for individuals, teams, rooms and shared inboxes. The DWP said that there were approximately 209k e-mail addresses on the GAL. Converting the 24 hour limit to seconds is equal to 86,400 seconds. c209k divided by 86,400 seconds would allow for 0.41 seconds for each e-mail address to be checked and determined if it is relevant to the request. Additionally, some e-mail addresses do not have the site name as the first part of its e-mail address or it may include special characters such as full stops which increases the challenge of identifying a Jobcentre. The DWP said that the GAL also includes e-mail addresses for meeting rooms, distribution lists and shared e-mail accounts for various sites including some within the London area which are not specific to any team or individuals.\n\n49.\n\nThe DWP submitted that providing all recorded information that is relevant\n\nto the request would require sites to provide all known e-mails that customers would have access to, including historical e-mail addresses. To establish this, it would require manually going through the Global Address list.\n\n50.\n\nThe DWP explained that it had conducted a sampling exercise and still\n\nbelieve that the request would exceed the cost limits under\nSection 12(1)\n:\n\nFor the sampling exercise, we approached 2 sites in each of the four London Districts to extract and locate the e-mail addresses requested. Please note that it is not a requirement for Jobcentres to have customer e-mails as DWP is a largely telephony-based service providing a range of initial contact methods including online services for many of our customers. Unfortunately, we are not able to use e-mail as a main channel of communication because of the associated security and GDPR risks. However, in line with the requirements of the\nEquality Act 2010\n, we do offer e-mail as a reasonable adjustment when providing written communication to customers who require information in an alternative format. This can be requested and considered on a case-by-case basis due to the individual needs of the customer and it may be the e-mail address of a colleague.\n\nThe results of the sample exercise is as follows:\n\n• The average time it took for each team to determine if the information was held or not was 17.5 minutes. This is once the\n\nappropriate person had been assigned to carry out the extraction.\n\n• 75% of the Jobcentres provided a UC e-mail address only.\n\n• 25% of the Jobcentres confirmed that they do not have a JSA or ESA e-mail address, with 75% of the Jobcentres unable to completely confirm this without manually going through the GAL.\n\n• 1 Jobcentre provided an e-mail address that can be used for all benefits.\n\n• 1 Jobcentre confirmed that it did not have any e-mail addresses for any benefit lines for external use.\n\nAs there is not a readily available list, the only robust way to determine if the required e-mail addresses are held for each site would require a full manual scan of the c.209k e-mail addresses on the GAL. As it is not required for Jobcentres to have an e-mail address, historical accounts may not be recognised due to the continuous changes Jobcentres face with teams and staffing.\n\nWorking out of the costs incurred based on the sample.\n\nIf we convert the 24 hour limit into minutes, this would be 1,440 minutes.\n\nThere are 49 Jobcentres in London with 6 temporary sites, 55 in total.\n\n17.5\n\nminutes (average time taken per team) x 3 Benefit Teams = 52.5 minutes per Jobcentre.\n\n52.5\n\nminutes x 55 sites = 2,887.5 minutes needed for all sites in Jobcentres to attempt to extract the required information.\n\nSubmissions of Mr Lotz dated 10 April 2026\n\n51.\n\nMr Lotz reiterated and expanded upon the submissions in his reply. He reiterated that in his view the information should be available because of the operation of the public sector equality duty.\n\n52.\n\nIn particular he provided the following worked alternative estimate. He said that there were\n55 Job Centres at the time of his request and he asked for one email address for each of the 3 teams, which makes for 165 email-addresses and 55 Job Centre names. He submitted that even if it would take each Job Centre manager 5 minutes per team to identify the appropriate email address, that would only come to 825mins in total and would be well below the 1440mins that equate to 24 hours.\n\n53.\n\nHe submitted that Job Centre managers would hold that information readily available, but even if not, they would know their staff, and it would not take more than 1 minute to sift through the names in each team to identify who would be the most appropriate contact if there was no team-email-address per team. That would make it 1 to 2 minutes per team, so 3 to 6 minutes per Job Centre. Multiplied by 55 JC that comes to between 165 - 330mins, i.e. 330mins maximum. He said that this is well below the 1440 mins that equate to the 24 hours.\n\n54.\n\nFurther he said that an average team would not have more than 40 staff and that he could identify the most appropriate email address from a batch of 40 within under 2 minutes.\n\n55.\n\nMr Lotz asked the tribunal to consider with the overall delay caused by DWP’s refusal to allow their submission to be shared and to advise the Commissioner on how to interpret sections 19 and 20 and on external legal duties.\n\n56.\n\nIn relation to the narrowed request, he said that it is unclear why the problems identified by the DWP did not apply equally to the narrowed request. He says that this suggest that the proposed methodology was bogus.\n\nDiscussion and conclusions\n\n57.\n\nAs the tribunal carries out a full merits review it stands in the shoes of the Commissioner and it is not necessary for us to make findings on whether or not the Commissioner took into account certain arguments or in relation to the Commissioner’s approach to the evidence.\n\n58.\n\nThe appellant raises a number of issues in his submissions in relation to sections 19 and 20 FOIA. These are not challenges to the Decision Notice and do not form part of this appeal. The First-tier Tribunal (Information Rights) does not have a general regulatory oversight of all the Commissioner’s functions. This tribunal has no power to determine if the Commissioner, or any other public body is complying with the public sector equality duty.\n\n59.\n\nSections 19 and 20 concern the duty to adopt a publication scheme approved by the Commissioner and the Commissioner’s power to approve model publication schemes. The tribunal does not have jurisdiction to consider the following complaints:\n\n59.1.\n\na complaint that the Commissioner should have adjusted the model publication scheme and the related guidance to integrate the public sector equality duty\n\n59.2.\n\na complaint that the Commissioner should not have approved the DWPs publication scheme\n\n59.3.\n\na complaint that the Commissioner should review modifications to publication schemes.\n\n60.\n\nIt is not the tribunal’s role to ‘advise the ICO on how to interpret’ section 19 and 20 FOIA, nor to ‘advise the ICO on external legal duties’.\n\nSection 12\nFOIA – was there an estimate which was reasonable and supported by cogent evidence?\n\nFindings of fact\n\n61.\n\nWe make the following findings on the balance of probabilities.\n\n62.\n\nThe DWP does not make it mandatory for Jobcentres to have e-mail addresses for external communications. There is no requirement and no standard format for an email address to be used by a team for contact by claimants.\n\n63.\n\nThe DWP is a largely telephone based service. The DWP says that the reason that it is not able to use email as a main channel of communication is ‘because of the associated security and GDPR risks’.\n\n64.\n\nMost London Jobcentres do have an email address that is available to be used by customers either in the form [jobcentre].customerfeedback@dwp.gov.uk or [jobcentre].ucfullservice or similar. These email addresses are intended to be used for gathering general customer feedback.\n\n65.\n\nThe DWP also offers email communication as a reasonable adjustment when providing written communication to customers who require information in an alternative format. This is considered on request on a case-by-case basis and the email address provided may be an individual employee’s email address. For those reasons there is no ‘list’ of a staff contact for claimants in each of the relevant teams in each Jobcentre, whether nationally or within an individual Jobcentre.\n\n66.\n\nJobcentre Managers are responsible for the day to day running of a Jobcentre. They can create, amend or delete e-mail addresses, but they do not ‘manage’ a Jobcentre’s e-mail addresses. If a Jobcentre manager were asked to find the appropriate e-mail addresses for claimants to contact the teams on their sites, they would have to navigate through the GAL to determine what e-mails are associated with their individual site. Jobcentre colleagues, including managers, often can change sites and roles and e-mail accounts may no longer be active. Some colleagues may also have left the Department.\n\n67.\n\nAlthough the DWP does not, as a matter of course, have team email addresses that are appropriate for a claimant to use to contact a team, internal team email addresses do exist for various business purposes.\n\n68.\n\nE-mail addresses are stored within the DWP’s global address list (GAL). As at 21 October 20234 there were over 209,000 email addresses in the database. The ‘advanced find filters’ include, for example, ‘office’ ‘city’ and ‘Department’. Internally, using GAL or the intranet or Teams it is not difficult for members of staff working within the department to find an email address of either an individual or a particular team or to contact the manager of a particular Jobcentre.\n\n69.\n\nThe appellant submitted that the DWP is required to have readily available appropriate email addresses for claimants of the type requested as a result of the anticipatory duty to make reasonable adjustments under the public sector equality duty and/or because of its duty to provide an approved publication scheme.\n\n70.\n\nWhether that is right is not a matter for this tribunal to determine. However, it is clear, from the information provided that it is not the DWP’s practice to require Jobcentres and the teams within those Jobcentres to have a ‘staff contact’ with an email address that can be used by claimants and that, as a matter of fact, email addresses of the type requested are not readily available in the way the appellant submits they ought to be.\n\nConclusions on\nsection 12\n\n71.\n\nWhere a public authority estimates that the cost of complying with a request would exceed the appropriate limit, section 1(1) FOIA does not oblige the public authority to comply with the request. There is no requirement to provide a subset of the information up to the cost limit.\n\n72.\n\nThe scope of the request in this case was specific and extensive. The appellant requested information that satisfied the following conditions:\n\n-\nA list of email addresses\n\n-\nfor a staff contact\n\n-\nin each of three teams (JSA (Jobseeker’s Allowance), ESA (Employment and Support Allowance) and UC (Universal Credit)).\n\n-\nin each Jobcentre in London\n\n-\nthat is the ‘most appropriate’ email address for claimants to contact that ‘provides the appropriate team’\n\n73.\n\nIn terms of practicality, the appellant suggested that the DWP contacted the manager of each Jobcentre to provide the contacts and email addresses.\n\n74.\n\nThe appellant said that even if it would take the manager of each Jobcentre 5 minutes to identify the most appropriate contact if there was no team email address for each team. For 55 Jobcentres that would take nearly 14 hours which is less than the 24 hour limit. He submitted that Jobcentre managers would have the information readily available and, if not, would know their staff and he estimated that it would take 1-2 minutes per team and 3-6 minutes per Jobcentre.\n\n75.\n\nThe DWP carried out a sampling exercise in eight Jobcentres (two in each of the four London districts) to inform its estimate of how long it would take to retrieve the requested email addresses by contacting the manager of each Jobcentre.\n\n76.\n\nThe results of the sampling exercise were as follows:\n\nThe average time it took for each team to determine if the information was held or not was 17.5 minutes. This is once the appropriate person had been assigned to carry out the extraction.\n\n• 75% of the Jobcentres provided a UC e-mail address only.\n\n• 25% of the Jobcentres confirmed that they do not have a JSA or ESA e-mail address, with 75% of the Jobcentres unable to completely confirm this without manually going through the GAL.\n\n• 1 Jobcentre provided an e-mail address that can be used for all benefits.\n\n• 1 Jobcentre confirmed that it did not have any e-mail addresses for any benefit lines for external use.\n\n77.\n\nThe DWP explored whether it would be possible to search for the relevant email addresses on GAL, using the advanced search filters. The DWP searched for appropriate email addresses using ‘Westminster’ in the ‘office’ filter. This search produced over 140 e-mail addresses, which included e-mails for colleagues and room bookings. However, no team e-mail addresses appeared (as of 6 January 2026). Because it is not mandatory to have team email addresses of the type requested, and because there is no standard form for such addresses if they are created we accept that it is not possible to identify those addresses using the search filters available on GAL.\n\n78.\n\nWe note that the DWP has since assisted the appellant in narrowing his request to ask for ‘active external email addresses currently used by Jobcentres for customers in London’. This narrower request was answered by the DWP, who provided a list of email addresses for each of the London districts which are shared with customers. Most were in the form [jobcentre].customerfeedback@dwp.gov.uk or [jobcentre].ucfullservice email addresses.\n\n79.\n\nThe appellant relies on this to argue that the DWP could have answered the request in issue in this appeal within the appropriate limit. He also complains that he was not provided with the DWP’s general correspondence email address which he says could have been provided within the cost limit.\n\n80.\n\nHowever, the request in issue in this appeal asks for the email address for a staff contact in each team, appropriate for claimants to use. He did not ask for the email addresses of Jobcentres and he did not ask for the overall DWP correspondence email address. We are satisfied that the estimate is reasonable in relation to the provision of team email addresses of the type requested.\n\n81.\n\nIn the light of our findings of fact and for the reasons set out above, we accept that the DWP’s estimate based on their sampling exercise is a reasonable estimate based on cogent evidence. We find that the DWP was entitled to rely on\nsection 12\nand the appeal is dismissed.\n\nSigned Sophie Buckley\nDate:\n18 June 2026\n\nJudge of the First-tier Tribunal","changes":[]}