Internal investigation into a Monetary Penalty Notice has to be released under FOIA
Public authorities should be prepared that, if they are subject to enforcement action by the Information Commissioner (e.g. Monetary Penalty Notice, Undertaking, Audit, Enforcement Notice etc), that internal reports into why the action was taken might become the target for FOI requests. This is the outcome of a recent Decision Notice involving the London Borough of Ealing. Implicitly, the ICO is signalling that he thinks such reports and investigations should be published where practicable. In February 2011, Ealing Council reported a




