Copies of a number of invoices submitted by Alex Salmond MP for overnight hotel accommodation
IPSA holds the information that you request.
Under the MPs’ Scheme of Business Costs and Expenses (‘the Scheme’), all claims for reimbursement under the Scheme must be supported by evidence. You can view a copy of the Scheme on our website via this link. As such, we hold all supporting documentation provided in support of claims made by MPs.
Accommodation Expenditure is designed to meet costs necessarily incurred on overnight accommodation which is required for the performance of an MP’s parliamentary functions. It may only be claimed in relation to hotel accommodation up to a maximum cost of £150 per night in the London Area. Any additional costs in excess of this limit are covered by the MP themselves.
Please click here to download the invoices submitted by Mr Salmond in support of the claims listed in your request. As noted above, any additional costs included on the invoices and not published on our publication website were not claimed by the MP.
Section 12 - where cost of compliance exceeds appropriate limit
Under section 12 of the FOIA, complying with your request for copies of associated correspondence would exceed the appropriate cost limit of £450. Providing copies of correspondence associated with claims requires a manual search of all the MPs’ correspondence over a period of a number of months, to ensure all correspondence is captured.
In calculating the estimated cost of compliance, we have aggregated your seven requests received between 15 March 2016 and 17 March 2016.
Guidance from the ICO advises that public authorities can include the costs of complying with two or more requests if the conditions laid out in regulation 5 of the Fees Regulations can be satisfied. Those conditions require the requests to be:
- made by one person, or by different persons who appear to the public authority to be acting in concert or in pursuance of a campaign;
- made for the same or similar information; and
- received by the public authority within any period of 60 consecutive working days.
We consider these conditions to be satisfied. In the interests of providing assistance, we have not extended this aggregating to your request for receipts, which can be more easily located, extracted and retrieved from our systems.
Section 31 – law enforcement
We have withheld the order ID, invoice number and bank account details contained within the invoices under Section 31(1)(a) (Law enforcement) of the FOI Act. This section of the Act states that information is exempt if its disclosure under the FOI Act would, or would be likely to, prejudice the prevention (or detection) or crime. After considering the nature of the withheld information it is our opinion that were a disclosure to be made into the public domain it is probable that this information could be traced back to sensitive personal or commercial information which could be used for criminal activity. Although we recognise the public interest in transparency surrounding the publishing of information relating to MPs’ expenses, there is also a strong public interest in ensuring that we are able to protect our service users (and third parties) from the threat of being subjected to criminal activity. In our opinion the public interest in protecting the security of third parties outweighs the public interest in disclosing the information.
Section 38 – health and safety
We have withheld some information from the invoices (such as the specific location of hotels utilised by the MP, or any information which may identify the specific location of the hotels) under Section 38(1)(b) (Health and safety) of the FOI Act. This section of the Act states that information is exempt if its disclosure under the FOI Act would, or would be likely to, endanger the safety of any individual. After considering the nature of the withheld information it is our opinion that were a disclosure to be made into the public domain it is likely that this information could be used to endanger the safety of the individuals who rely upon these locations for accommodation. Although we recognise the public interest in transparency surrounding the publishing of this information there is also a strong public interest in ensuring that as an organisation we are able to protect our service users from threats to their safety. In our opinion the public interest in protecting the personal safety of MPs’ outweighs the public interest in disclosing the information.
Section 40 – personal information
This names and data relating to third parties is ‘personal data’, as defined by the Data Protection Act 1998 (DPA). As such, we have withheld such information in accordance with section 40 of the FOIA. For reference, section 40(2) provides that personal information about third parties is exempt information if disclosure would breach the fair processing principle (Principle 1) of the DPA, where it would be unfair to those persons or is confidential. You can find out more information about personal data and FOI via guidance from the Information Commissioner’s Office (ICO) on their website: http://ico.org.uk.