Government of Jersey

Removal of PFAS from ground near airport (FOI)

Produced by the Freedom of Information office
Authored by Government of Jersey and published on 23 February 2024.
Prepared internally, no external costs.

Original Request

No action been taken over the past ten years to require the removal of the PFAS contaminated ground from within and around the airport which leaches into the surrounding ground and water sources, making its way into the Island's water supply harming the health of Islanders.

In the late 1900s and early 2000s Jersey airport deployed fire-fighting foam containing PFAS. These chemicals were thought to be harmless but in the past 30 years it has become known that they are very toxic in miniscule quantities.

Limited remedial action was completed in 2004. Options:

Remove all the contaminated ground, 30 metres. £30M.
Remove the most affected ground, 10 metres. £22M.
Move 2 metres of ground elsewhere and insert a concrete wall to the East . £3.7M-£4.9M.

Last option was chosen and much of the contamination left in place.

Decades later and with growing public concern the Government established a PFAS Political Oversight Group then a Technical Group and now a Scientific Panel (costing many £100,000s) as well as providing blood analyses for some and is considering offering blood-letting.

Statutory Nuisances (Jersey) Law 1999 2(1) the following matters constitute statutory nuisances for the purposes of this Law:

(f)any accumulation or deposit which is prejudicial to health or a nuisance;

Water Pollution (Jersey) Law 2000

4(1) “pollution” includes the introduction directly or indirectly into controlled waters of any substance, or energy, where its introduction results or is likely to result in –
(a) a hazard to human health or water supplies;

The Minister is able to make Water Quality Orders and require compliance with them.

Water (Jersey) Law 1972

the water does not contain any substance (whether or not a parameter) at a concentration or value which, in conjunction with any other substance it contains (whether or not a parameter), would constitute a potential danger to human health;

That this ongoing pollution meets the criteria for action set out in these Laws cannot be in doubt:

In light of these three pieces of legislation then surely action should have been taken to remove the source of contamination.

Please therefore provide:

The dates in the last ten years when action to require that this pollution be stopped was discussed by the Minister for the Environment or their officers.

Copies of all reports generated during the last ten years which include "PFAS" or "PFOS" AND make reference to any of the three pieces of legislation above.

Copies of all reports generated in the last 10 years which include "PFAS" or "PFOS" AND have been submitted to the Law Officers' Department or Law Practice(s) for opinion.

Copies of all Ministerial Decision Records containing “PFAS” or “PFOS” AND make reference to any of the 3 pieces of legislation above.

NB: PFOS is a PFAS. PFAS is an abbreviation for a collection of chemicals. The foam contained many other PFAS. Initially the term PFOS was used to refer to the pollution whereas now the correct PFAS

Revised Response

The Government of Jersey does not maintain a list of when discussions between the Minister for the Environment and their officers are held, therefore, this information is not held and Article 10 of the Freedom of Information (Jersey) Law 2011 applies.

Under the Freedom of Information legislation the Government of Jersey is not required to create or manipulate data when responding to a Freedom of Information request if the information is not held in the format requested, for example if a list is not maintained regarding when a particular subject was discussed by the Minister or Government of Jersey officers. Therefore, it would be considered that this information is not held since it is not held in the format requested.

However, some of the requested information may be held within Government of Jersey records, such as the calendars and diaries of multiple individuals. A manual search of these records would need to be carried out to determine if this information is held and to extract the requested information since it is not stored in a centrally accessible area.

The Government of Jersey systems are not configured in a way that will allow extraction of the details requested.

It has been estimated that to provide the information requested would exceed the 12.5 hours allowed for Freedom of Information responses in accordance with Regulation 2 (1) of the Freedom of Information (Costs) (Jersey) Regulations 2014. Article 16 of the Freedom of Information (Jersey) Law 2011 has therefore been applied and this part of the request will not be processed further.

Therefore, Article 10 and Article 16 both apply in relation to question 1 since a list is not maintained in relation to the requested information and the Government of Jersey is not able to extract it within the allowable period for Freedom of Information responses.

Given the above it is helpful to outline the progress made to better understand and identify pragmatic options to safeguard water resources in St Ouen’s Bay and Pont Marquet catchments, and the pathways within the airport site.

As detailed in the 2019 interim report from the Officer Technical Group, a water sample taken in January 2019 showed traces of PFOS and PFOA and subsequently prompted a programme of water sampling in the wider vicinity. A link is provided in response to question two for access to the report.

A recommendation in the interim report, included undertaking a PFAS hydrogeological study and risk assessment within the water catchments of St Ouen’s Bay and Pont Marquet.

The overall objective of the study is to further understand the PFAS impacts, including their distribution, fate and transport as well as to assess the potential risks to human health and the environment. In addition, the study will also help identify pragmatic and sustainable risk management options to assist to ensure the safety and future security of drinking water supplies in Jersey.

The Phase 1 assessment that reviewed available data to develop an initial conceptual site model that sets out potential pollutant linkages within the two catchments has been completed. Please see the following link:

PFAS Hydrogeological Study Phase 1 report.pdf (gov.je)

This defined further sampling to address identified data gaps and will continue to inform the PFAS hydrogeological study and risk assessment as part of Phase 2 of the study. This work is currently ongoing.

A further recommendation of the interim report was that ‘An investigation is undertaken to determine the sources of these higher levels of PFOS and PFOA, especially those emanating from the drainage of the airport’. This information will potentially inform possible remediation options. As a result, a formal regulatory position should, at this stage, be reserved.

Ports of Jersey are currently undertaking a site investigation of the airport to identify the presence of PFAS from historic activities undertaken on the site.

For information, fire-fighting foam containing PFOS / PFOA were removed from service by Ports of Jersey in the first quarter of 2020. Old stocks of the previous chemical have been appropriately disposed of or returned to the manufacturer.

The information requested is exempt under Article 23 of the Freedom of Information (Jersey) Law 2011 as the information is available on www.gov.je and can be accessed using the following link.

PFAS in Jersey (gov.je)

It should be noted that further reports may be held by Ports of Jersey, so you might wish to send your information request in writing to the following details, however, Ports of Jersey is not a Scheduled Public Authority (SPA) under the Freedom of Information (Jersey) Law 2011, therefore, they are not required to respond.

ask@ports.je

or by post to:

Ports of Jersey, St Peter, Jersey, JE1 1BY

The requested information is exempt under Article 31 (Advice by the Bailiff, Deputy Bailiff or a Law Officer) and Article 32 (Legal professional privilege) of the Freedom of Information (Jersey) Law 2011.

Article 31 and Article 32 are qualified exemptions, therefore, public interest tests have been applied and are shown at the end of this response.

Article 31 of the Freedom of information legislation applies to information that relates to legal advice. The underlying purpose of this exemption is to protect fully informed decision making by allowing government to seek legal advice or comment on documents in private, without fear of any adverse inferences being drawn, and ensures that government is neither discouraged from seeking advice or comment on documents in appropriate cases, nor pressured to seek advice in inappropriate cases. As such, requests for information about whether or not advice was sought, or will be sought, falls within the Article 31 exemption.

The information requested is exempt under Article 23 of the Freedom of Information (Jersey) Law 2011 as the Ministerial Decisions (MD) are available on www.gov.je and can be accessed using the following links.

Ministerial Decisions (gov.je)

MD-PE-2021-0076

PFAS in Private Water Supplies (revised): Subsidy for sampling

MD-PE-2021-0040

PFAS in Private Water Supplies: Subsidy for sampling

MD-PE-2020-0090

PFAS and water quality in Jersey 2020: An update report from the Government of Jersey Officer Technical Group

MD-PE-2019-0064

PFAS and Water Quality in Jersey: 2019 Report

There are two unpublished Ministerial Decisions in relation to requested information, however, further information is exempt under Article 35 (Formulation and development of policies) of the Freedom of Information (Jersey) Law 2011.

Article 35 is a qualified exemption; therefore, a public interest test has been applied and is shown at the end of this response.

Ministerial Decisions have been made by the Minister for Economic Development (2014) and the Minister for Health and Social Services (2022) relating to, respectively, settlement avenues and testing, and which have been exempted and not published, or provided as part of this response.

Articles applied

Article 10 - Obligation of scheduled public authority to confirm or deny holding Information

(1) Subject to paragraph (2), if –

(a) a person makes a request for information to a scheduled public authority; and

(b) the authority does not hold the information, it must inform the applicant accordingly.

Article 16 A scheduled public authority may refuse to supply information if cost excessive

(1) A scheduled public authority that has been requested to supply information may refuse to supply the information if it estimates that the cost of doing so would exceed an amount determined in the manner prescribed by Regulations.

Regulation 2 (1) of the Freedom of Information (Costs) (Jersey) Regulations 2014 allows an authority to refuse a request for information where the estimated cost of dealing with the request would exceed the specified amount of the cost limit of £500. This is the estimated cost of one person spending 12.5 working hours in determining whether the department holds the information, locating, retrieving and extracting the information.

Article 23 - Information accessible to applicant by other means

(1) Information is absolutely exempt information if it is reasonably available to the applicant, otherwise than under this Law, whether or not free of charge.

(2) A scheduled public authority that refuses an application for information on this ground must make reasonable efforts to inform the applicant where the applicant may obtain the information.

Article 31 - Advice by the Bailiff, Deputy Bailiff or a Law Officer

Information is qualified exempt information if it is or relates to the provision of advice by the Bailiff, Deputy Bailiff or the Attorney General or the Solicitor General.

Public Interest Test

Article 31 of the Freedom of Information (Jersey) Law 2011 recognises the longstanding constitutional Convention that government does not reveal whether Law Officers have or have not advised on a particular issue, or the content of any such advice.

The underlying purpose of this confidentiality is to protect fully informed decision making by allowing government to seek legal advice in private, without fear of any adverse inferences being drawn from either the content of the advice or the fact that it was sought. It ensures that government is neither discouraged from seeking advice in appropriate cases, nor pressured to seek advice in inappropriate cases.

The request for information about whether or not advice was sought or will be sought falls within the Article 31 exemption.

With regard to the public interest arguments, HM Treasury v IC [2009] EWHC 1811 Blake J recognised that when engaged, the Convention will carry significant weight in the public interest test. The Convention has been considered by the Office of the Information Commissioner and was held to be part of Jersey law. Whilst it is recognised that the strong public interest in protecting Law Officers’ advice may still be overridden in some cases if there are particularly strong factors in favour of disclosure, conversely, disclosing the advice or whether advice was or will be sought could inhibit the Law Officers from (1) giving frank advice (2) inhibit government bodies in taking advice for fear of its publication; and (3) inhibit the full disclosure to the Law Officers of all material relevant to the advice being sought and therefore real weight ought to be afforded to this aspect of the Law Officers’ Convention. Disclosing either the legal advice or the fact of whether specific advice was sought to the public is not a greater consideration of public interest that requires disclosure of the advice or confirmation of what advice was given. It does not outweigh the three principles set out above which require the long-standing Law Officer Convention to be maintained. Therefore, the balance is in favour of maintaining the exemption and it is not considered the public interest in disclosure outweighs the preservation of the Convention on this occasion.

Article 32 - Legal professional privilege

Information is qualified exempt information if it is information in respect of which a claim to legal professional privilege could be maintained in legal proceedings.

Public interest test

Whilst disclosure of the requested information would support transparency to the general public it is considered that the legal professional privilege outweighs the public interest in favour of disclosure at this time.

Article 35 - Formulation and development of policies

Information is qualified exempt information if it relates to the formulation or development of any proposed policy by a public authority.

Public Interest Test

In applying this article, the following considerations were taken into account.

Public interest considerations favouring disclosure

Disclosure of the information would support transparency and promote accountability to the general public, providing confirmation that the necessary discussions have taken place.
Disclosure to the public fulfils an educative role about the early stages in policy development and illustrates how the department engages with parties for this purpose.

Public interest considerations favouring withholding the information

In order to best develop policy and provide advice to Ministers, officials need a safe space in which free and frank discussion can take place – discussion of how documentation is presented and provided is considered as integral to policy development as iterations of documents are demonstrative of the policy development process.
The need for this safe space is considered at its greatest during the live stages of a policy.
Release of the information at this stage might generate misinformed debate. This would affect the ability of officials to consider and develop policy away from external pressures, and to advise Ministers appropriately.
Premature disclosure of this information may limit the willingness of parties to provide their honest views and feedback. This would hamper and harm the policy–making process not only in relation to this subject area but in respect of future policy development across wider departmental business.

Following assessment, the Government of Jersey has concluded that, on balance, the public interest in maintaining the exemption outweighs the public interest in disclosing the information.

It should also be noted that once a policy is formulated and published, the public interest in withholding information relating to its formulation is diminished, however, the use of the exemption can be supported if it preserves sufficient freedom during the policy formulation phase to explore options without that process being hampered by some expectation of future publication.

Internal Review Request

The dates in the last ten years when action to require that this pollution be stopped was discussed by the Minister for the Environment or his Officers.

The Government of Jersey does not maintain a list of when discussions between the Minister for the Environment and their officers are held, therefore, this information is not held….A manual search of records would be required in order to obtain this information.

Aside from the response not matching the request "OR" being misinterpreted, even on the revised version of the response. as "BETWEEN":

I did not ask for a "list". I Just asked for dates. It could be argued that a sequence of dates becomes a list but on this basis any Freedom of Information (FOI) request that results in more than one piece of data being produced is actually calling for a list. There can never have been an Intention in the minds of those involved in the creation of the FOl regime that all responses must be limited to one piece of data unless such a "list" already had been constructed.

I accept that there may have been ad-hoc discussions between individuals that were not recorded but inherent in any meeting Is discussion; these should have had their dates recorded.

I don't see that a manual search would be required. A simple Boolean search for PFAS OR PFOS AND Environment should yield an appropriate seed.

Coples of all reports generated during the last 10years which Include "PFAS" or "PFOS" AND make reference to any of the 3 pieces of legislation above

The information requested is exempt under Article 23 of the Freedom of Information (Jersey) Law 2011 as the information Is available on www.gov.je and can be accessed using the ·following link.

I do not believe that ALL such reports held by the Government of Jersey can be accessed by the given link.

Copies of all reports generated in the last 10 years which Include "PFAS" or "PFOS" AND have been submitted to the Law Officers' Department or Law Practice(s) for opinion

The requested Information is exempt under Article 31 (Advice by the Bailiff, Deputy Bailiff or a Law Officer) and Article 32 (Legal professional privilege) of the Freedom of Information (Jersey) Law 2011.

The response continues to note that these exemptions are "qualified exemptions" and not "absolute" ones. However, there is no evidence that a "Public Interest" test has been applied to this information, rather a blanket reference to a judicial Judgement with no specifics of my application. This applied "test" would apply to any request for Information concerning legal aspects. You are behaving as if Articles 31 and 32 are absolute exemptions and not qualified ones.

It is not stated whether the legal privilege engaged is litigation privilege or advice privilege. I suggest that it is inconceivable that litigation could be contemplated for the perpetrator pf the pollution/nuisance is the Ports of Jersey, itself 100% owned by the States of Jersey and as such the Ports of Jersey can be ordered to carry out the owners wishes. Furthermore in the Deed of Settlement, 2004, the manufacturer of the chemicals was indemnified against any future legal action pertaining to Jersey.

It has already admitted that the Law Officers have been consulted (emails from Tim du Feu dated 31 July and 10 September 2020) and the advice "concludes that the use of this Law would not be appropriate in this case." and "the Government does not consider that the present situation satisfies the definition o fa statutory nuisance according to the Statutory Nuisances (Jersey) Law 1999. Further, the law was not in existence at the time of the historic contamination." This aspect of the communications has therefore lost its privilege. The relevance of the last statement, that the law was not in existence at the time, is unclear. The contamination of the public's water sources continues day in, day out. Regardless of this aspect the Statutory Nuisances (Jersey) Law 1999 is from 1999, the so-called "historic contamination" was in full flow in that year and later.

The information request was only for reports submitted TO Law Officers and so forth, and not for any advice provided. The only explanation I have been able to envisage for why such learned people would advise that the use of the Law is inappropriate and the present situation does not meet the definition of a statutory nuisance is that the information provided to them is out-of-date (from the era when PFAS were seen as innocuous harmless substances). Hence my request for reports provided TO legal authorities.

To put this into context the three Laws include:

Statutory Nuisances (Jersey) Law 1999

2(1) the following matters constitute statutory nuisances for the purposes of this Law:
(f)any accumulation or deposit which is prejudicial to health or a nuisance;

Water Pollution (Jersey) Law 2000

4(1) “pollution” includes the introduction directly or indirectly into controlled waters of any substance, or energy, where its introduction results or is likely to result in –
(a) a hazard to human health or water supplies;

The Minister is able to make Water Quality Orders and require compliance with them.

Water (Jersey) Law 1972

the water does not contain any substance (whether or not a parameter) at a concentration or value which, in conjunction with any other substance it contains (whether or not a parameter), would constitute a potential danger to human health;

The Public Interest Test

As the two claimed exemptions are "qualified" exemptions a public interest evaluation of the specific information requested should have been carried out rather than the non-specific generic conclusion that the public interest Is outweighed by the legal privilege.

The following list of activities indicate how serious and costly the PFAS situation Is for Jersey and how the health of all islanders is put in jeopardy by the lack of action by the public body tasked with protecting our environment from hazardous substances.

The States Assembly's establishment of a political body to manage the PFAS issue
The Government's establishment of a Technical Group to Investigate the PFAS problem
The Government's recruitment of a panel of scientific experts, at a cost of ~£1M, to advise on PFAS solutions
A number of public meetings have been arranged, and been very well attended, to explain the Government's approach to managing the PFAS issue
Not only have all the local media been reporting on the unfolding PFAS saga but the national media too (and have presented Jersey in a poor light):

i) BBC Radio 4 national Costing the Earth
ii) This won a coveted national award
iii) A 30-minute BBC 1 report on national television

The rationale put forward in the revised response for withholding any reports is:

No content of any advice provided has been asked for. The advice from Law Officers was sought and provided almost 4 years ago; any advice provided is rather dated therefore.

That the Environment Department refuses to release report(s) that it has sent enquiring about pollution affecting the whole Island raises serious questions about its accountability and its motives.

Could it be a cover-up to hide its lack of action to tackle a health hazard affecting the whole Island?

Or could it be that it won't do anything to require site cleanups as that would cost public money?

Why turn a blind-eye to Jersey Water's continued practice of pumping polluted water into our reservoirs?

It is very much in the public interest to have a safe environment and have clean water to drink. Jersey inhabitants have neither, courtesy of the Environment Department. Thanks to the secrecy employed by the Environment Department we can only speculate why.
The decision(s) not to require site-cleanup to remove the bulk of the PFAS contamination is bad government; the government is complicit in the cover-up and brings into question its integrity - it cannot be relied upon to "do the right thing" is seems.
Conflict within Government is clear. Whilst one arm, Public Health, is taking PFAS health issues very seriously, trawling the scientific world for best advice, spending millions of taxpayers' money and keeping the public informed, another arm, Environment Department, is busy obfuscating and procrastinating ignoring opinions from around the world, establishing an endless succession of groups and reports all to ensure that nothing is actually done. If the Environment Department had been doing its job the contaminated spoils would have been removed years ago (as Guernsey did) and there would be no need for Public Health to spend the vast sums on dealing with the PFAS poisoning of the Island's population.

Against the above reasons to release report(s) is the reason to maintain them as secret - that others in Government might be discouraged from seeking legal advice in future. Really?

Copies of all Ministerial Decision Records containing “PFAS” or “PFOS” AND make reference to any of the 3 pieces of legislation above

The information requested is exempt under Article 23 of the Freedom of Information (Jersey) Law 2011 as the Ministerial Decisions (MD) are available on www.gov.je and can be accessed using the following links.

The first two Ministerial Decisions listed are irrelevant, neither make any reference to any of the three laws detailed in my request; they are concerned with charging home owners to have their water supply tested for the pollution caused by the Government. There is however an admission in the revised response that there are indeed two further Ministerial Decisions which are unpublished. However they will not be released to me as they relate to the “formulation and development of policies”, Article 35 refers.:

Ministerial Decisions have been made by the Minister for Economic Development (2014) and the Minister for Health and Social Services (2022) relating to, respectively, settlement avenues and testing, and which have been exempted and not published, or provided as part of this response.

A Public Interest Test is claimed to have been carried out. However once more the public interest considerations are generic and would apply to every FoI request. It appears yet again that you do not accept that the Exception is a Qualified one and not an Absolute Exception.

Paraphrasing the four considerations quoted as calling for withholding are:

In order to best develop policy and provide advice to Ministers, officials need a safe space in which free and frank discussion can take place
The need for this safe space is considered at its greatest during the live stages of a policy.
Release of the information at this stage might generate misinformed debate.
Premature disclosure of this information may limit the willingness of parties to provide their honest views and feedback.

One of these policies is seems has been in development for almost 10 years and the other policy for more than a year. Perhaps these policies are being developed by the Environment department which has an excellent record of obfuscation and procrastination? The source of the pollution was deposited in the ground from before the 1960s and continued up until 2020. To claim that a policy is still in development after all this time is untenable.

The generic reasons to maintain secrecy in this case are poor. Releasing report(s) on factual background to the pollution would not erode any such “safe space”. I do not seek opinions or details of any actions being contemplated.

As far as misinformed debate is concerned the vacuum of reasons behind Government policy to allow the pollution to continue has led to much speculation as to the reasons for inaction.

I do not foresee any factual report that must have been provided TO the Law Officers as inhibiting anyone from providing their views and feedback, rather the opposite.

Internal Review Response

This review has been completed by two senior staff members of the Government of Jersey, independent of the original decision-making process.

The original response has been reviewed and assessed to identify whether the application of the exemption had been applied correctly and whether it was appropriate to withhold information.

The Panel’s decision is that the application of Article 10 (Obligation of scheduled public authority to confirm or deny holding Information) and Article 16 (A scheduled public authority may refuse to supply information if cost excessive) of the Freedom of Information (Jersey) Law 2011 had been correctly applied.

The reviewers, having considered the application of Article 10 and Article 16 in this instance, concluded that the exemption was appropriate and should be upheld. 

The Panel’s decision is that the application of Article 23 (Information accessible to applicant by other means) of the Freedom of Information (Jersey) Law 2011 had been correctly applied.

The reviewers, having considered the application of Article 23 in this instance, concluded that the exemption was appropriate and should be upheld. 

The Panel’s decision is that the application of Article 31 (Advice by the Bailiff, Deputy Bailiff or a Law Officer) and Article 32 (Legal professional privilege) of the Freedom of Information (Jersey) Law 2011 had been correctly applied.

The reviewers, having considered the application of Article 31 and Article 32 in this instance, concluded that the exemption was appropriate and should be upheld. 

Article 31 and Article 32 are qualified exemptions, therefore, public interest tests have been applied and are shown at the end of this response.

Decision 1: Economic Development 2015-0100

The Panel’s decision is that the application of Article 35 (Formulation and development of policies) of the Freedom of Information (Jersey) Law 2011 had been correctly applied.

The reviewers, having considered the application of Article 35 in this instance, concluded that the exemption was appropriate and should be upheld.

Decision 2: Chief Minister 2022 - 0002

Following the Panel’s review, it is considered that the Ministerial Decision should be released. It has been concluded that disclosure of the information would support transparency and the public interest in maintaining the exemption is limited.

Therefore, the Ministerial Decision is attached, however redactions have been applied where there is a possibility of identifying individuals.

Some information has also been redacted in accordance with Article 35.

MD-C-2022-0002_Redacted.pdf

Articles applied

Article 10 - Obligation of scheduled public authority to confirm or deny holding Information

(1) Subject to paragraph (2), if –

(a) a person makes a request for information to a scheduled public authority; and

(b) the authority does not hold the information, it must inform the applicant accordingly.

Article 16 - A scheduled public authority may refuse to supply information if cost excessive

Article 23 - Information accessible to applicant by other means

(1) Information is absolutely exempt information if it is reasonably available to the applicant, otherwise than under this Law, whether or not free of charge.

(2) A scheduled public authority that refuses an application for information on this ground must make reasonable efforts to inform the applicant where the applicant may obtain the information.

Article 31 - Advice by the Bailiff, Deputy Bailiff or a Law Officer

Information is qualified exempt information if it is or relates to the provision of advice by the Bailiff, Deputy Bailiff or the Attorney General or the Solicitor General.

Article 32 - Legal professional privilege

Information is qualified exempt information if it is information in respect of which a claim to legal professional privilege could be maintained in legal proceedings.

Article 35 - Formulation and development of policies

Information is qualified exempt information if it relates to the formulation or development of any proposed policy by a public authority.

Removal of PFAS from ground near airport (FOI)

​​​​​​​​Original Request

Revised Response

Articles applied

Article 10 - Obligation of scheduled public authority to confirm or deny holding Information

Article 16 A scheduled public authority may refuse to supply information if cost excessive

Article 23 - Information accessible to applicant by other means

Article 31 - Advice by the Bailiff, Deputy Bailiff or a Law Officer

Internal Review Request

Internal Review Response

Articles applied

Article 10 - Obligation of scheduled public authority to confirm or deny holding Information

Article 16 - A scheduled public authority may refuse to supply information if cost excessive

​Article 23 - Information accessible to applicant by other means

Article 31 - Advice by the Bailiff, Deputy Bailiff or a Law Officer

Article 32 - Legal professional privilege

​Article 35 - Formulation and development of policies

Original Request

Article 23 - Information accessible to applicant by other means

Article 35 - Formulation and development of policies