The public interest test under s.35(1)(a) has not been adequately demonstrated; selection criteria for the Behaviour Hubs programme are of significant public interest.
Comparable criteria for the Maths Hubs programme were released under FOI (ref DfE/2024/1182) without invocation of s.35.
The decision letter does not address Tribunal Case EA/2019/0211 (Department for Education v ICO).
Escalation path
{[
{ stage: "1", title: "Substantive response", desc: "20 working days from dispatch", state: "done" },
{ stage: "2", title: "Internal review", desc: "Up to 40 working days, typically 20", state: "active" },
{ stage: "3", title: "ICO complaint", desc: "If review unsatisfactory or not responded", state: "next" },
{ stage: "4", title: "First-tier Tribunal", desc: "Appeal against ICO decision notice", state: "future" }
].map((s, i, arr) => (