Maidstone Borough Council
Freedom of Information Act Request
Request and Response
Thank you for confirming that under the Local Authorities (Contracting
Out of Tax Billing, Collection and Endorsement Functions) Order 1996
Maidstone Borough Council is instructing and paying your contractor J E
Baring & Co as a limited company registered on Companies House as J E
Baring Ltd and not as a partnership (solicitors firm) and without a
contract or deed of assignment in place to instigate bankruptcy as
enforcement proceedings under the Act . Is this correct?
The Council has been paying J E Baring & Co as a partnership. Cases are
assigned on an individual basis and J E Baring & Co carry out work in accordance
with the regulations, not a contract.
Has Maidstone Borough Council also previously instructed and paid their
former limited company J E Baring & Co Ltd a dormant company
incorporated 25.1.2013 - 29.3.2016 that does not appear to have filed
any financial trading accounts and was voluntary struck off after and
application was made to Companies House on 16.12.2015, because you
have not provided any clarification as to how the council is managing to
pay funds to a dormant company, that you have no contract with.
Payments were made to J E Baring & Co (partnership).
Is Sheila Coburn a Data Processor and who is the Data Controller
(Maidstone Borough Council is not the Data Controller but must have a
person responsible as a Data Controller ) that authorised her to share
private data and information of natural individual persons with the
company J E Baring Ltd and previous company J E Baring & Co Ltd and
with further agent (sub-contractors) who are not employees of either of
We have already explained that Maidstone Borough Council is the Data
Controller and that Maidstone Borough Council authorises Sheila Coburn to pass
customers' data to J E Baring & Co.
Are the agents sub-contractors, employees of your contractor J E Baring
Ltd (trading as J E Baring & Co, that you say is how they refer to
themselves on there website), if they are not, then under whose
authority did they receive the right to have access to anyone's private
data and who within Maidstone Borough Council gave them
authorisation under the Data Protection Act 2018 and GDPR.
J E Baring & Co are instructed by Maidstone Borough Council in accordance with
the Council Tax (Administration & Enforcement) Regulations 1992.
How is it possible to share any natural person's data or information with
a company you have no contract or deed of assignment with, and
without naming the person within that company ( J E Baring & Co ) the
council is claiming has been authorised by your un-named Data
Controller, to enable a Data Processor to access and share this valuable
data and information belonging to natural living individuals whose
fundamental rights and freedoms must be strictly protected, by at least
a contract or deed of assignment authorising a transfer to only those
This is not a request for held information.
Please define what you mean by Sheila Coburn passes on "customers
data" to a limited company , are you saying that these natural
individual persons that you share the data of, are the council's
customers; please define "customer".
Our customers are anyone who receives a service from or comes into contact
with Maidstone Borough Council.