Instructions to IPS January 2009

Dear Sir or Madam,

Liverpool City Council contracts IPS Services (through a system of
obscure arrangements involving 2020 Liverpool and a contract which
has been lost[1]) to do work on many of their empty properties.

Please can I have copies of

* all instruction notices transmitted to IPS Services by the
Council or its agents.

* internal decisions, justifications, site inspection reports,
recommendations for work to be done resulting in those instruction
notices being transmitted to IPS Services.

* all invoices, receipts and any communications about the work done
sent in by IPS services to the Council or its agents.

--for the months of January 2009 and February 2009.

Further notes:

* There are no data protection, health and safety, or criminal
issues involved in the disclosure of this information since the
properties are all empty, controlled by the Council, and have
notices on them that are visible from the street that they are part
of this contract.

* There are no commercial interest issues caused by the disclosure
of any financial figures since the Council is obliged to use this
supplier and therefore there can be no reduction in IPS's income as
a result of any disclosure.

* There are no commercial confidentiality issues in any of these
disclosures because this information can be accessed by any persons
interested under the Audit Commission Act 1998 at the appropriate
time of year.

Yours faithfully,

Julian Todd

[1] Letter sent to me sent 16 September 2008 (FOI 24704)

Dear Andrea Glanville,

In case the Non Stop Gov software is giving you false results, my
requests on this matter are disclosed at:

http://www.whatdotheyknow.com/body/liver...

On 25 August 2008 I requested "a copy of the spreadsheets provided
by IPS Services to their paying customer (the Council) in their
original electronic format for the months of January to June 2008."

This does not overlap January February 2009.

On 21 January 2008 I requested the contract with IPS Services and
finally received on 16 September a letter stating: "Unfortunately
we have been unable to locate a copy of the Contract between
Liverpool City Council and IPS. We have made exhaustive checks with
service areas within the City Council, officers at 2020 Liverpool
and indeed IPS themselves but none of these have been unable to
provide a copy."

Can you confirm that you are referring to a request by someone
other than myself for "exactly the same information requested"
(January-February 2009)?

Yours sincerely,

Julian Todd

Dear Wendy Twigge,

Thank you for answering my FOI request for IPS Services on 3 March
(your ref FOI/WT/52469) which I have only just found -- it was
misfiled by the whatdotheyknow site.

I happen to be working with the whatdotheyknow website programmer
today, and have learnt that the reason the the email addresses from
the system contain computer generated strings of numbers and
letters is so that spammers cannot recreate them and fill the site
with junk. The codes also work as the our reference numbers, so
when you re-use one of these email addresses from an earlier
communication, it gets filed into the wrong place. It's a weakness
in our design which needs to be addressed. We have manually moved
the messages to the correct place.

http://www.whatdotheyknow.com/request/80...

The IPS Services invoices you sent me were in good order, except
that the addresses have been redacted. There is no explanation for
this in your letter.

I thought I had argued in earlier correspondence that no exemption
could apply to this information because the houses were (a) not
privately owned, and (b) visibly vacant with LCC stickers on their
doors.

The only information that is effectively being withheld from me is
which house is getting which repair. I am not able to see why this
should not be disclosed.

Yours sincerely,

Julian Todd

Dear Wendy Twigge,

Thank you for letter of 31 March relating to me the reasons for the
exemptions applied to my Freedom of Information Request 52469
(Instructions to IPS Services January-February).

In the letter, it was revealed to me the basis for redacting the
full address information of entirely vacant, physically secured and
uninhabitable properties that are owned either by Liverpool City
Council or associated housing associations. Not only are these
properties uninhabited, but there appears to be no plans to house
any new people in them in the future. (There are in fact plenty of
plans to demolish them.)

I wish to seek an internal review of this decision on account of
the fact that there are no persons involved. There is no such
individual for whom these addresses could be considered as their
personal information. Therefore the Data Protection Act does not
apply under any of the circumstances given in the Act.

Having reviewed the Information Tribunal cases that were cited in
order to justify these exemptions, I can be specific about their
non-application:

The Information Tribunal's decision of Turcotte v the Information
Commissioner & Camden LBC (EA/2007/0129) related to a request for
all addresses of a community housing group, as well as names and
addresses of tenants who had been evicted.

The case for the exemption of addresses in that case was made under
Section 11 of the Data Protection Act (the right to prevent
processing for the purposes of direct marketing). As there are no
residents of these properties to whom mail deliveries can be made,
or former residents to whom there are any forwarding arrangements
for mail, this case is completely irrelevant.

In the Camden LBC v the Information Commissioner (EA/2007/0021)
case, a journalist had asked for a copy of the database of names
and addresses of people had been issued with ASBOs.

Again, the key issue in that case is that there were actual persons
involved for whom this was arguably "Sensitive personal data" 2(g).

The final sentence in your 31 March letter which outlined the
reason for the exemption of addresses of totally vacant and
uninhabitable properties in the IPS Services instructions, said:

"The reason it is considered unfair, is that the data relates to
the addresses of people raising requisitions for repairs to their
property. Members of the public would not reasonably expect that
their addresses, which by reference to the Electoral register might
enable them to be identified, to be given out to others unconnected
with Council business."

Now, I already know who is raising requisitions for these
not-privately-owned or inhabited properties: Liverpool City
Council. There are no members of the public associated to these
addresses. If any of these addresses are on the Electoral register,
then the Electoral Registration Officer needs to be notified
immediately as there are no residents in any of these properties.

I look forward to receiving un-redacted copies of these
instructions to IPS services from Liverpool City Council relating
to the maintenance of these uninhabitable properties (because
that's what IPS Services are hired to do), as soon as this internal
review is complete.

Yours sincerely,

Julian Todd

Dear Edwina Hunter,

Thank you for your letter about the completion of the internal
review into my FOI request for instructions to IPS Services.

Please can you indicate the findings of the review and why the
pages cannot be scanned and sent like the last batch.

Yours sincerely,

Julian Todd