67. A concise process for both elements of section 36 is to ask as follows:1) was the QP the appropriate person? 2) was it the QPO that the relevant exemption was engaged? 3) was the QPO reasonable? 4) if it was a reasonable opinion then in all the circumstances of the case does the public interest in maintaining the exemption outweigh the public interest in disclosing the information? 68. The appropriate QP is defined in section 36(5) FOIA. 69. As regards the question as to whether the QPO was reasonable we noted the UT Decision in Information Commissioner v Malnick & ACOBA [2018] UKUT 72 (AAC) at para 31-33 where the UT said:“...Section 36 (for present purposes – see section 2(3)(e)) confers a qualified exemption and so a decision whether information is exempt under that section involves two stages: first, there is the threshold in section 36 of whether there is a reasonable opinion of the QP that any of the listed prejudice or inhibition (“prejudice”) would or would be likely to occur; second, which only arises if the threshold is passed, whether in all the circumstances of the case the public interest in maintaining the exemption outweighs the public interest in disclosing it. “The QP is not called on to consider the public interest for and against disclosure. Regardless of the strength of the public interest in disclosure, the QP is concerned only with the occurrence or likely occurrence of prejudice. The threshold question under section 36(2) does not require the Commissioner or the F-tT to determine whether prejudice will or is likely to occur, that being a matter for the QP. The threshold question is concerned only with whether the opinion of the QP as to prejudice is reasonable. The public interest is only relevant at the second stage, once the threshold has been crossed. That matter is decided by the public authority (and, following a complaint, by the Commissioner and on appeal thereafter by the tribunal).” “Given the clear structural separation of the two stages, it would be an error for a tribunal to consider matters of public interest at the threshold stage…..” 70. In Guardian Newspapers Ltd & Brooke v IC & BBC (EA/2006/0011) (Judgment of 8 January 2007) at para 62 – 64 the UT said at para 64 that “...in order to satisfy the sub-section the opinion must be both reasonable in substance and reasonably arrived at." 19