Hi David

I do not think this is about creating new information as it clearly exists in your organisational chart. It is about how far you have to go in acceding to his request to put the information into a particular format.

You need to read section 11 of the Act and the ICO Awareness Guidance No: 29 "Means of Communication".  This states that you have to give effect to the preference of the applicant  "so far as is reasonably practicable". However section 11 only applies if the applicant expresses his preference at the time of making the request. See the ICO decisions in :

Case Ref: FS50094281
Date: 17/05/2007
Public Authority: Bath and North East Somerset
Council

I discuss this in episode 7 of my podcast.

Case Ref: FS50217416
Date: 04/02/2009
Public Authority: Student Loans Company Ltd

I discuss this in episode 17 of my podcast.

In considering what is reasonably practicable you can take account of the cost of putting the information into a spreadsheet. Note that these are not allowable costs for fees purposes but it is arguable that they are the cost of putting the information into a particular format (and so chargeable just like photocopying and postage).

Note also your duty of advice and assistance (under section 16 and the Section 46 Code) which requires you to consider your duties under the Disability Discrimination Act (i.e. the applicant's disability and what "reasonable adjustments" you can make). However I agree with you that putting the information into a spreadsheet will not necessarily help him around any obstacles created by his impairment in understanding this information.

In conclusion my view is that, the information should be provided "as is". If he wants it in spreadsheet format you can say that there will be a charge for putting into that format (based on £25 per hour) unless you can argue that it is not practicable.

Hope this helps. Please note that this is just my view as there are no ICO  cases directly on this issue. I would be happy to hear other colleagues' views on this.