Freedom of information request
OPSI 'governance committee' minutes, licensing framework & RPSI
- Freedom of information request reference
- CAS-325497
- Request resolved
Request
Background
The Ministry of Justice, in response to FOIA request 251023041 (December 2025), stated that it does not hold OPSI governance minutes relating to Registry Trust Ltd, and directed me to The National Archives as the appropriate authority:
'The former OPSI functions now sit with The National Archives (TNA).'
Information requested
Part A – OPSI governance committee minutes
All minutes of the OPSI Governance Committee (or any predecessor/successor body) relating to Registry Trust Ltd, the Register of Judgments, Orders and Fines, or the Register of County Court Judgments, from 2005 to present.
In particular, please provide the minutes from August 2005 (or thereabouts) in which the OPSI Governance Committee discussed RTL's permitted use of Register data, including any discussion of "bulk re-sale" or restrictions on commercial redistribution.
Any subsequent OPSI Governance Committee minutes that amended, superseded, or replaced the decisions made in August 2005 regarding RTL.
Part B – licensing framework
Any OPSI licensing framework documentation, policy guidance, or authorisation documents relating to RTL's authority to:
License Register data to third parties
Supply bulk data to credit reference agencies
Commercially redistribute judgment information
Any correspondence between OPSI and the Ministry of Justice (or Lord Chancellor's Department / Department for Constitutional Affairs) regarding RTL's data licensing activities.
Part C – re-use of public sector information
Any determination, assessment, or decision document regarding whether the Register of Judgments, Orders and Fines is subject to The Re-use of Public Sector Information Regulations 2005 (SI 2005/1515) or subsequent regulations.
Any records of complaints, reviews, or appeals to OPSI regarding RTL's licensing practices or fees.
Format
Please provide responses electronically in PDF format to this email address.
Outcome
Some information provided.
Response
I can confirm that The National Archives holds information relevant to your request. We are pleased to be able to provide some of this information to you.
We are unable to provide you with some of the information you have requested because it is covered by the exemption at section 40(2) of the FOI Act, which exempts information if personal information about a ‘third party’ (someone other than the requester), if revealing it would break the terms of Data Protection Legislation For further information about this exemption, please see the explanatory annex at the end of this response:
Part A – OPSI governance committee minutes
- All minutes of the OPSI Governance Committee (or any predecessor/successor body) relating to Registry Trust Ltd, the Register of Judgments, Orders and Fines, or the Register of County Court Judgments, from 2005 to present.
Information not held.
The National Archives does not hold information about an OPSI Governance Committee not about any decisions made regarding Registry Trust Limited. - In particular, please provide the minutes from August 2005 (or thereabouts) in which the OPSI Governance Committee discussed RTL's permitted use of Register data, including any discussion of "bulk re-sale" or restrictions on commercial redistribution.
Information not held
Advice and assistance: The Director of OPSI was the officeholder also known at the time as the Controller of Her Majesty’s Stationery Office. We hold no information about the former officeholder making decisions about RTL data. - Any subsequent OPSI Governance Committee minutes that amended, superseded, or replaced the decisions made in August 2005 regarding RTL.
Information not held.
Part B – licensing framework
- Any OPSI licensing framework documentation, policy guidance, or authorisation documents relating to RTL's authority to:
- Supply bulk data to credit reference agencies
- Commercially redistribute judgment information
- License Register data to third parties
Information not held
2. Any correspondence between OPSI and the Ministry of Justice (or Lord Chancellor's Department / Department for Constitutional Affairs) regarding RTL's data licensing activities. The National Archives holds some information relevant to this request from 2014. The information being released relates entirely to correspondence with the Ministry of Justice regarding PSI licensing authority for the Department and as regards non-commercial licensing of aggregated data.
To request a copy of the documentation listed in the table below please contact RMDclosedrecordsrequests@nationalarchives.gov.uk
| File Title | Document Description | The National Archives' Notes |
|---|---|---|
| Item 01 | Email dated 11/11/2014: Business case - OPSI assessment and recommendation | Some of this information is withheld under section 40(2). |
| Item 01a | Email attachment: Business case application | Some of this information is withheld under section 40(2). |
| Item 02 | Email dated 06/10/2014: Business case submission | Some of this information is withheld under section 40(2). |
| Item 02a | Email attachment: Business case application | Some of this information is withheld under section 40(2). |
| Item 03 | Email chain May to June 2014: First draft of business case application | Some of this information is withheld under section 40(2). |
| Item 03a | Email attachment: Business case application draft | Some of this information is withheld under section 40(2). |
| Item 04 | Email chain dated May 2014 | Some of this information is withheld under section 40(2). |
| Item 04a | Email attachment: Business case application draft with further draft notes | Some of this information is withheld under section 40(2). |
| Item 05 | Email chain dated May 2014 | Some of this information is withheld under section 40(2). |
| Item 05a | Email attachment: Business case application draft with draft notes | Some of this information is withheld under section 40(2). |
| Item 06 | Email dated 19/11/2014 | Some of this information is withheld under section 40(2). |
Advice and assistance: We do not hold any record of this process being concluded with the issuance of any formal authority.
Part C – re-use of public sector information
- Any determination, assessment, or decision document regarding whether the Register of Judgments, Orders and Fines is subject to The Re-use of Public Sector Information Regulations 2005 (SI 2005/1515) or subsequent regulations.
Information not held. - Any records of complaints, reviews, or appeals to OPSI regarding RTL's licensing practices or fees.
Information not held.
Advice and assistance: OPSI ran a complaints process until 2015 for Crown licensing activities of public sector organisations participating in the Information Fair Trader Scheme, which itself ran until 2018.
The Ministry of Justice was not part of the Scheme (and RTL was not eligible to be). Between 2005 and 2015, there was a statutory, independent Advisory Panel on Public Sector Information (APPSI) appointed under the Re-use of Public Sector Information Regulations 2005 to hear complaints under those regulations. Its web archive including those complaints it handled is available at: Archive Timeline - UK Government Web Archive.
APPSI was abolished on commencement of the Re-use of Public Sector Information Regulations 2015 and the appointment of the ICO as the re-use regulator.
This concludes our response to your request.
Annexe
Exemptions applied:
Section 40(2): Personal Information where the applicant is not the data subject
Section 40 exempts personal information about a ‘third party’ (someone other than the requester), if revealing it would breach the terms of Data Protection Legislation. Data Protection Legislation prevents personal information from release if it would be unfair or at odds with the reason why it was collected, or where the subject had officially served notice that releasing it would cause them damage or distress. Personal information must be processed lawfully, fairly and in a transparent manner as set out by Art. 5 of the United Kingdom General Data Protection Regulation (UK GDPR).
In this case the exemption applies because the requested material contains information which would identify junior members of staff.
Publishing the names and contact details of junior members of staff is considered an unfair use of personal data. Junior members of staff would have no expectation that information about their positions would be made available in the public domain; to do so would be unfair and contravene the first data protection principle of the Data Protection Act. As such, the names, positions and contact details of junior officials are withheld under section 40 (2) of the FOI Act.
Further guidance about the publication of junior staff names can be found here: Requests for personal data about public authority employees
Further guidance on the application of this exemption can be found here: Section 40 and Regulation 13 – personal information | ICO