The Information Tribunal has partially allowed an appeal against the Information Commissioner's decision that Yorkshire Forward (YF), a public authority, was entitled to withhold the names of delegates who had attended events or corporate hospitality organised by it. The Tribunal rejected the Commissioner's finding that such information amounted to "personal data" under section 40 of the Freedom of Information Act 2000 (FOIA) and was exempt from disclosure. The Tribunal held that, taking into account the two factors of biographical significance and focus identified in Durant v Financial Services Authority [2003] EWCA Civ 1746, the disclosure of the names of those attending YF events did not involve the release of personal data. The same applied to the disclosure of the organisations they represented, provided that the two could not be correlated. In reaching this decision, the Tribunal had some difficulty reconciling the approach in the Commissioner's 2007 guidance note on determining personal data under the Data Protection Act 1998 and the Durant case, commenting that the guidance had broadened the definition again (see Legal update, ICO publishes new guidance on personal data). However, as the cost of providing such information exceeded the cost limit set by section 12 of the FOIA, YF did not have to disclose it. Case: Tony Harcup and Yorkshire Forward v Information Commissioner, 5 February 2008.