FOIMan explains how he looks after your personal data.

There aren’t many reasons why I need to collect or use personal data (information that can be used to identify you), but there are a few which are listed below. Data protection laws require me to have a lawful basis – a legal justification – to use your data, and to let you know how long it will be kept for amongst other things. Most of the time the people I deal with are representatives of a public authority or business so it is rare that I handle personal data relating to a person’s home or personal life.

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Who I am

My name is Paul Gibbons and I provide training and consultancy services under the FOIMan brand as well as writing blogposts and providing other content on this website. I am based in London in the UK. You can contact me using the contact form at the foot of the page, by calling me on +44 (0)7799 654509 or you can email me. You can find out more about me elsewhere on this site.

When I collect data

you submit your name and contact details to me with your enquiry. My lawful basis for using your contact details is your consent in these circumstances. Once I’ve answered your enquiry I will delete your details within 3 months unless you ask me to keep in touch.
the resulting data (IP address, user agent, email address, site URL, and comment) will be scanned by Akismet (a sister company of WordPress) to filter out spam. My lawful basis for this is my legitimate interest in securing my website and computer systems against cyber-attacks. Your rights are unlikely to be adversely affected as the data will only be used if you are spamming me – which hopefully you are not! Akismet keep data collected as part of this process for up to 3 months.
your name and contact details will be used to help me to fulfil the contract and to ensure that I get paid for the work when it is completed. My lawful basis in these circumstances is that it is necessary for the fulfilment of the contract for me to use these details. Once the contract is completed, your details will remain in my accounts and associated correspondence for 6 years.
you provide your email address so that you can receive email alerts when my blogposts are published. My lawful basis for this is your consent. You can unsubscribe at any time and your email address will not be retained.
you provide your name and contact details. My lawful basis for this is your consent. You can unsubscribe at any time and your details will be deleted from my marketing list.
your IP address is collected by my webhost, 34sp. My lawful basis for doing so is that it is necessary for the purpose of my legitimate interest in securing my website (the IP address would be used to investigate and prevent attacks on the site). Your rights are unlikely to be adversely affected as the data will only be used to identify you if you are attacking my site – which hopefully you are not planning to do! The IP address is retained for 1 month after your visit.

Storage and security

The FOIMan website and blog is hosted by 34sp ( who also are my email provider. Their servers are in the UK and I am assured that they provide appropriate levels of security.

Contact details (along with your bank details where you have provided these) are stored in FreeAgent (, which is a service I use to maintain my accounts and send invoices.

Otherwise data is stored on my own devices (regularly backed up of course) and is not made available to third parties. Unless I am legally obliged to disclose personal data (for example, HMRC want to audit my accounts), I will not share your personal data with third parties without your agreement.

I regularly deliver training and consultancy for third party providers. If you have questions about how data is collected in relation to these services, including their training courses, you should check the privacy notice of the provider you booked your training through, or contact them directly. For ease of reference, those companies are currently:

Your rights

I have no wish to use your data in a way that you would not approve of. If you have any concerns at all, please let me know so that I can put things right. In any case, you have rights in law as set out below, subject to some exceptions:

  • to request a copy of information held about you
  • to have inaccurate data corrected
  • to have data about you erased
  • to place a restriction on the processing of your data
  • to object to me processing your data
  • to request that your data is transferred on (data portability).

Should you wish to exercise any of these rights, or have any concerns about my use of your data, please contact me using the contact form, telephone number or email address provided below. If this means that I am unable to provide a service you have requested I will let you know. If you are dissatisfied with my response, you can contact the Information Commissioner’s Office via their website. Their other contact details are as follows:

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Telephone: 0303 123 1113 (local rate) or 01625 545 745

Fax: 01625 524 510

I am registered with the Information Commissioner and you can consult my entry at (registration number ZA071135).


Cookies are small computer files placed on devices by websites. I’ve tried hard to limit their use on this website. For example, I no longer collect statistics that rely on cookies, and I have also turned off comments on the FOIMan website (in practice very few people chose to respond to blogposts this way anyway). Here are the remaining circumstances in which cookies are set.

  • a cookie that records whether you have seen the cookie message (cookielawinfo-checkbox-necessary)
  • a cookie that checks whether essential cookies are in place (wordpress_test_cookie).

In addition to the cookies set for all FOIMan website visitors, the following additional cookies will be set:
  • a cookie that stores authentication details on login (wordpress_[hash])
  • a cookie that is used to indicate when you are logged in, and who you are (wordpress_logged_in_[hash])
  • a cookie that is used to customise the view of your admin interface and the front-end of the website (wp-settings-{time}-[UID]).

These cookies are necessary for the functioning of WordPress (which is the solution used to create the FOIMan site). You can block them using the settings in your browser, but this may affect the functioning of the FOIMan site or your own use of WordPress.

I can’t guarantee that other sites linked to from the FOIMan site won’t use cookies so make sure that you check any privacy or cookie notices on linked sites if this concerns you.

This page was last updated on 20 December 2019.

Files on shelf image: © Can Stock Photo / viperagp