Social Audit Ltd
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Mr S Fawbert, VRRooM 14-110
Medicines and Healthcare products Regulatory Agency
Market Towers, 1 Nine Elms Lane
London SW8 5NQ

27 November 2006


Dear Mr Fawbert,

Re: FOI 06/350 I note your wish that your letter of 20 November "answers any remaining questions" I might have about the Agency’s handling of the evidence on the Seroxat/paroxetine placebo suicides. Your optimism seems barely evidence based – but perhaps that is just the point. However, our correspondence seems to be doing wonders for the Social Audit website ratings: this recent surge brings us to over 5,000 visitors (over 12,000 hits) each day.

I am now writing to request a formal review of your interpretation of section 40 of FOIA, specifically in relation to the ‘Email 2’ attachment in your letter. In my FOI request of 21 October, I asked about communications to and from your office, wanting to know which bits of the MHRA were taking an interest, or playing some part, in our correspondence. This is a point I shall elaborate in a website note: I cannot accept that the Act was ever designed to encourage you not to reveal simply the names of involved Agency officials, in this fashion:

From: [text redacted Section 40 FOIA]
Sent: 13 October 2006 17:20
To: [text redacted Section 40 FOIA]
Cc: [text redacted Section 40 FOIA]
Subject: FW: FOI 06/324 (re. 06/236)
[text redacted Section 40 FOIA]
I suggest the following response:

The members of the CSM Expert working Group on SSRIs were supplied with an assessment of of MAH responses for the paroxetine referral at their meeting of 27 Feb 04. This assessment (of which I believe you have a copy) contained a summary of the cases of suicide with paroxetine. I would like to correct one of the points made in Miss Wark's letter of 4 September 2006. The case narratives themselves were not supplied to the SSRI Expert Working Group but were supplied to the European scientific advisory committee, the Committee for Medicinal Products for Human Use (CHMP).

This has to be taking the Special Agent stuff too far. Your reticence is such that you don’t even say how many names you obliterated, nor even the MHRA departments involved. This level of censorship seems unwarranted and unhelpful (one reason for wondering if the guardians of the Agency’s Communications Strategy 2005-2007 were, or should be, guiding your hand).

In each of the above four instances, please will you now explain and justify (within the meaning of the relevant Acts) why the simple disclosure of names would be "unfair" (See DCA Guidance), or otherwise unacceptable or in breach of the Data Protection Principles.

Yours sincerely,

Charles Medawar