Subject: Response to Refusal of Subject Access Request (Ref: DP7896184)
Dear Ms Lane,
Thank you for your response dated 5 August 2025 in relation to my Subject Access Request (SAR) submitted on 3 July 2025, reference number DP7896184.
I must respectfully challenge your decision to refuse my request under Article 12(5) of the UK GDPR on the grounds that it is “manifestly unfounded and excessive.” I do not accept that my request meets either threshold, and I believe the refusal represents a disproportionate response to a legitimate and narrowly focused SAR.
My request is clearly defined and seeks access only to personal data that refers to me being labelled as “vexatious” or similar, as well as the context, personnel involved, and rationale behind such designations. This request:
- Is specific in scope and subject matter,
- Does not overlap with previous requests made under Article 15 of the UK GDPR,
- Is directly relevant to understanding decisions made about me and my reputation,
- Is a lawful exercise of my rights under the UK GDPR.
As you will be aware, the Information Commissioner’s Office (ICO) has made it clear that SARs cannot be refused simply because an individual is persistent or challenging in their interactions. Nor can Article 12(5) be used to avoid accountability where the data subject is seeking to understand decisions that affect them, especially where labels such as “vexatious” may have been applied without transparency or recourse.
If the Council has internally described or treated me as “vexatious,” then I have a clear legal right to access the personal data that underpins this treatment. Refusing such access undermines the fundamental principles of fairness, transparency, and accountability enshrined in the UK GDPR.
I therefore ask you to reconsider your decision and respond to my SAR in full. If I do not receive a satisfactory resolution, I will exercise my right to lodge a formal complaint with the Information Commissioner’s Office without further delay.
Yours sincerely,
Sheila Oliver
Local Authority Specialist Researcher
Citizens 2022 Committee
From: Data Protection [mailto:dpa.officer@stockport.gov.uk]
Sent: 05 August 2025 11:09
To: ‘sheilaoliver@ntlworld.com’
Cc: Vicki Bates (Legal)
Subject: Response to Subject Access Request DP7896184
OFFICIAL
Good morning,
I refer to your recent Subject Access Request sent to the Council on the 3rd July 2025 and given reference number DP7896184
Subject Access Requests are considered under the provisions of the UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018. The legislation allows the Council to refuse requests that are manifestly unfounded and/or excessive under UK GDPR.
On review, I have found that your Subject Access Request is manifestly unfounded and excessive, and I am therefore refusing your request under Article 12(5) of the UK GDPR.
In this case, I have determined that your request forms part of a pattern of behaviour that appears to be intended to disrupt the Council’s operations and to exert pressure through repeated and overlapping correspondence. This includes:
- A sustained volume of requests and communications that are repetitive in nature.
- Overlap with previous requests for which responses have already been provided.
- Evidence that your Subject Access Request is being used as a tool within a broader campaign against the Council, rather than for the genuine exercise of data protection rights.
I have concluded that the threshold has been met and as such, we are not obliged to comply with your request.
This assessment is consistent with guidance from the Information Commissioner’s Office (ICO), which recognises that a request may be manifestly unfounded where it is part of an organised campaign or is being used to harass or cause disruption.
Please note the following information in relation to your information held by the Council
a) The purposes of processing.
b) The categories of personal data in this response.
c) The recipients or categories of recipient to whom the personal data have been or will be disclosed.
d) The envisaged period for which the personal data will be stored.
Can all be found in the privacy notice(s) below.
Freedom of Information privacy notice – Stockport Council
You may find further information about your rights and how to exercise them at: https://www.stockport.gov.uk/your-rights-data-protection/access-to-your-personal-information
If you are dissatisfied with this response, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO) or seek a judicial remedy. Details can be found at: https://ico.org.uk/make-a-complaint/
You should not expect to receive any further correspondence from me or the Information Governance team in relation to this matter.
I am sorry I am not able to help you further.
Kind Regards
Karen Lane
Information Governance Team Manager & Data Protection Officer
Stockport Metropolitan Borough Council
OFFICIAL
From: Sheila Oliver <sheilaoliver@ntlworld.com>
Sent: 03 July 2025 6:10 AM
To: FOI VERINT <foi@stockport.gov.uk>
Cc: Vicki Bates (Legal) <vicki.bates@stockport.gov.uk>
Subject: External: SAR request
Dear Data Protection Officer,
I am submitting a formal Subject Access Request under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
I would like to request all personal data held about me referring to me as vexatious:
1. All records, emails, notes, or internal communications in which I am referred to as “vexatious” or any similar wording (e.g. persistent, unreasonable, difficult).
2. All documents, emails, or memos discussing or recommending the application of a “vexatious” label to me or my communications.
3. The names and roles of any officers, councillors, third parties, or departments who have been informed—either internally or externally—that I have been designated or described as “vexatious.”
4. The dates and recipients of any such communications.
5. Any policies, criteria, or decision-making documents relied upon in applying this label to my name or communications.
Please treat this as a formal request for all personal data under Article 15 of the UK GDPR. I understand you are required to respond within one calendar month. If you need to verify my identity or require further clarification, please let me know as soon as possible.
Kind regards
Sheila Oliver
Local Authority Specialist Researcher
Citizens 2022 Committee
