Written by Imperial College London has once again demonstrated a blatant disregard for transparency, this time resorting to a last-minute cost exemption under Section 12 of the Freedom of Information Act 2000 (FOIA) to avoid scrutiny over its legal spending. This follows its initial, now-overturned, attempt to label my request as “vexatious”—a decision that the Information Commissioner’s Office (ICO) rightly rejected in Decision Notice IC-331009-H9W2 (ICO, 2025).
As the requester, I sought to uncover how Imperial allocates public funds for legal services, particularly in cases involving Employment Tribunals, staff grievances, and research misconduct. Their refusal to release this data raises serious concerns about how the institution wields its financial power to deter claimants and whether it is attempting to bury inconvenient truths.
The Shifting Sands of Imperial’s Excuses
Initially, Imperial argued that my FOIA request was vexatious, suggesting—without evidence—that I was connected to the claimants in the tribunal cases. This argument was soundly rejected by the ICO, which ruled that my request was both legitimate and in the public interest. Forced to abandon this line of attack, Imperial has now invoked Section 12, claiming that retrieving the information would exceed the cost limit of 18 hours.
But here’s the problem: Imperial has provided no detailed breakdown of how it reached this conclusion. Case law and ICO guidance are clear—public authorities must demonstrate, not assume, that compliance would be too burdensome. In FS50713699, the ICO ruled that vague assertions of administrative burden are insufficient; a detailed cost analysis is required. Imperial has failed to meet this standard.
Financial Transparency or Institutional Amnesia?
Imperial’s claim that retrieving legal expenditure data would require trawling through invoices spanning 20 years is, at best, misleading. My request explicitly covered only 2021–2024. Either:
- Imperial does maintain structured financial oversight of legal costs, in which case its refusal is an intentional act of obfuscation; or
- It has no structured tracking of legal expenditure, which would constitute a staggering failure of governance for a publicly funded institution.
Imperial must now confirm whether such records exist. If they do, its refusal under Section 12 collapses.
Failure to Provide Meaningful Assistance
Under Section 16 FOIA, public authorities have a legal duty to assist requesters in refining their queries. Instead of engaging constructively, Imperial has dismissed my request wholesale, suggesting that I ask for generic “expenditure on all employee relations matters.” This is a blatant attempt to deflect from the original issue. FOIA guidance is explicit: authorities must work with requesters to refine their queries, not offer vague alternative topics.
The Ongoing Culture of Obstruction
Imperial’s refusal to conduct an internal review is particularly egregious. Internal reviews exist to ensure fairness in FOIA responses. The 2018 FOIA Code of Practice (s.5.3) makes it clear that every public authority should have a review process. By refusing outright, Imperial is not only breaching best practice but also reinforcing its reputation as an institution that treats transparency as an inconvenience rather than an obligation.
The ICO Must Step In
Imperial College London’s actions warrant regulatory intervention. The ICO should now consider:
- Issuing a compliance notice under Section 52 FOIA, compelling Imperial to issue a lawful response.
- Examining whether Imperial’s repeated refusals constitute contempt of court under Section 54 FOIA.
- Investigating whether this pattern of non-disclosure signals a systemic failure in compliance.
- Ordering an internal review of Imperial’s decision-making process on FOIA refusals.
Conclusion: What Is Imperial Hiding?
Imperial College London’s resistance to disclosure suggests it has something to hide. Whether it is excessive legal spending, improper procurement practices, or an entrenched culture of suppressing grievances, the public deserves answers. The ICO has already ruled against Imperial once (ICO, 2025). If the institution continues down this path, it must face the full force of regulatory scrutiny.
I pursued this FOIA request because transparency matters. Public institutions should not be able to spend taxpayer money on legal battles against whistleblowers and employees without accountability. The question remains: Why is Imperial so desperate to avoid scrutiny?
Disclaimer: This article is based on publicly available information, including FOIA requests and ICO decisions. It reflects an analysis of institutional transparency practices and does not make allegations of unlawful conduct.