FOI request: anonymised FDG brain PET DICOM data
Case reference FOI2026/01971
Received 14 May 2026
Published 26 May 2026
Request
Response
The Trust has considered your request and is refusing disclosure under section 40(2) of the Freedom of Information Act 2000.
Section 40(2) – Personal Information
The information requested comprises diagnostic imaging data relating to identifiable living individuals. Although you have requested anonymised DICOM studies, the Trust is not satisfied that the requested imaging data could be rendered fully anonymous for the purposes of disclosure under FOIA.
Medical imaging data, including DICOM-format PET brain studies, may contain both direct and indirect identifiers within image metadata and image content itself. In addition, advances in imaging analysis and data linkage techniques mean there remains a risk that individuals could be identified from the requested data, either alone or when combined with other information reasonably available to third parties.
Disclosure under FOIA is considered disclosure to the public at large and the Trust cannot impose restrictions on further use or onward disclosure once information is released.
The Trust therefore considers the requested information to constitute personal data and special category personal data under the UK General Data Protection Regulation and the Data Protection Act 2018. Disclosure would contravene the data protection principles set out in Article 5(1)(a) UK GDPR and accordingly the exemption under section 40(2) FOIA applies.
Section 40 is an absolute exemption and there is therefore no requirement to consider the public interest test.
Information not held in the requested form
In addition, the Trust does not hold the requested information in the fully anonymised form specified in your request. Compliance with the request would require the Trust to identify suitable scans, extract imaging data, undertake anonymisation and quality assurance processes, and create a new dataset for disclosure.
FOIA provides a right of access to recorded information held by a public authority but does not require a public authority to create new information or datasets in order to answer a request.
The Trust frequently handles requests for access to imaging datasets for research purposes through formal research governance and data access processes to provide appropriate ethical, confidentiality, and information governance approvals. The first point of contact with OUH for a request of this nature is OUHTMA@oxnet.nhs.uk
If you have any queries regarding our response or you are unhappy with the outcome of your request and wish to seek a review of the decision, please contact:
Information Governance
Oxford University Hospitals NHS Foundation Trust
John Radcliffe Hospital
Headley Way
Headington
Oxford
OX3 9DU
Please quote the reference number above in any further communications.
If you are still not content with the outcome of the review, you may apply to refer the matter to the Information Commissioner for a decision. Generally, the ICO cannot make a decision unless you have exhausted the review procedure provided by the Trust.
The Information Commissioner can be contacted at:
Information Commissioner
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Yours sincerely,
Information Governance Team
Documents
This is Oxford University Hospitals NHS Foundation Trust's response to a freedom of information (FOI) or environmental information regulations (EIR) request.
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