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The Society and the SRA are not designated public authorities under the FOIA 2000, so the ICO has no jurisdiction over them for FOI purposes. It does, of course, have jurisidiction over them in respect of the Data Protection Act 1998.

Because the FOIA does not apply to the Society and the SRA, there is no prospect of complaining/appealing to the ICO or the Tribunal: they simply do not have jurisdiction to entertain such a complaint/appeal. Instead, a dissatisfied requester is obliged to go to "adjudication" under the Society's "Code of Practice on Freedom of Information". In effect, this is an arbitration clause, the fairness/lawfulness of which is very debatable.

As Rosemary will confirm, such "adjudications" are carried out without any published rules, by an Adjudicator who is contracted to and appointed by the Society/SRA. All adjudications are passed to the same Adjudicator. The current Adjudicator is...a solicitor regulated by the SRA. The requester is allowed no say in the choice of Adjudicator.

Complaints have been made about these arrangements, but have produced no improvements.