Freedom of Information request (FOI 22/605)
Published 17 January 2024
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23rd August 2022
FOI 22/605
Dear
Thank you for your emails of 6th and 7th April 2022 where you requested correspondence
between Professor Sir Munir Pirmohamed and the MHRA from 1 March 2022 referencing
COVID-19 vaccines or Yellow Card data. I apologise for the delay in responding to your
request. Please accept this response as further to the Decision Notice issued by the Information Commissioner’s Office on 25 July 2022.
As you may be aware, Professor Sir Munir Pirmohamed is the Chair of the Commission on
Human Medicines and also the Chair of the COVID-19 Vaccines Benefit Risk Expert
Working Group.
Please find attached copies of the information requested, specifically ‘COVID-19 vaccines’
and/or ‘Yellow Card data’ covering the time period between 1st March 2022 to 6th April 2022. I can confirm that emails, text messages, Whatsapp and Microsoft Teams messages
were all considered to be within the scope of the request and searched for. Only emails
returned results. Please note that the following information has been redacted under
Section s40(2) FOIA (Personal Information):
Names, email addresses and telephone numbers of non-Senior Civil Service (SCS) MHRA
staff and information concerning expert committee members and co-investigators of the
Thrombosis with Thrombocytopenia Syndrome (TTS) consortium which is not in the public
domain.
Our justification for using this absolute exemption is, as this is personal data that is not in
relation to you as requestor, we considered the exemptions under section 40(2) of the FOIA
- Is the data requested personal data?
The Agency first considered whether the information requested is personal data i.e. if the
person is identifiable from the data, either by itself or with other data. Clearly naming an
individual or providing identifiable data such as an email address would meet this criterion.
- Do any of the exemptions under s40(2) FOIA apply?
We then considered the next step of meeting this exemption, namely that the personal
information is exempt if it meets exemption criteria. Under section 40(3A) the information
would be exempt if its disclosure would be in contravention of any of the data protection
principles. Disclosing the personal data of MHRA staff would contravene the first condition
that processing of data should be lawful and fair, in this instance, specifically UK GDPR
principle Article 5 (1) (a): “personal data shall be processed lawfully, fairly and in a transparent manner in relation to individuals (lawfulness, fairness and transparency)’’. We
consider that Senior Civil Servants can reasonably expect that they will be named in disclosure releases and therefore, do not consider the principles apply to those members of
staff. However, in relation to other members of staff we would consider that disclosure is
neither fair nor limited to what is necessary.
I hope this is helpful.
Yours sincerely,
MHRA FOI Team
The MHRA information supplied in response to your request is subject to Crown copyright.
The FOIA only entitles you to access to MHRA information.