Ammanford Park Splashpad CCTV costs and performance

The request was partially successful.

Dear Ammanford Town Council, Carmarthenshire,

I'm still looking for information regarding the surveillance cameras installed for community safety overlooking the Splashpads in Ammanford Park. The system, often referred to as CCTV appears to have cost £17,000. Looking for this initial information, and a simple planning query, led me down the rabbit-hole of missing and inadequate Council records, including the ICO enforcement action begun last summer (10 Jul 2018) as Ammanford Town Council had never registered as a Data Controller (put right 25 Feb 2019 by Ms Hope, following our phone call).

The recent release of Ammanford Town Council Minutes from 2016 & 2017 reveal a characteristic pattern of procrastination, poor specification, splurge and subsequent regret (with bonus points for re-purchasing a raft of systems, such as telephony and office equipment, sometime later). I note ongoing complaints by Councillors that the CCTV system didn't work for months after installation, but as so many Minutes are missing (or in draft only form) it is hard to work out the true story.

Please could you confirm the full cost of the system, who specified the system and who installed it? Please identify if costs include or exclude VAT.

Please can you explain where the images are viewable from? Is there live/active monitoring and who has access to the recordings?

Does the system have a service contract? How much does this cost? Please provide the Service Agreement.

I understand the camera system was connected wirelessly to a control centre and was installed over winter. What verification steps have been performed to ensure the system operates correctly within a range of environmental conditions? How frequently has this been tested/validated (ie when there are leaves on the trees, does the system work? - as this tends to coincide with when children play on the Splashpads...)?

Yours faithfully,

Daniel Morris

Town Clerk, Ammanford Town Council, Carmarthenshire

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Dear Mr Morris,

I am still making enquiries in to your request for information regarding
the CCTV cameras situated in Ammanford Park.

I endeavour to respond to your queries within the next 30 days.


Clare Hope

Interim Clerk

Dear Town Clerk,

I am disappointed that Ammanford Town Council has chosen not to comply with its legal obligations defined in the Freedom of Information Act 2000.

I had expected that you would have supplied the information that I requested some time ago - the law requires that you provide the information promptly and in any event no later than 20 days after the request. Endeavouring to respond in your own time-frame does not comply with the Act passed by Parliament. I suggest that you avail yourself of the resources provided by the Information Commissioner's Office, or call their helpline for further advice.

A complaint file has been opened with the Information Commissioner's Office.

When do you expect that you will comply with the Act/Regulations and supply the information requested?

Yours sincerely,

D Morris

Town Clerk, Ammanford Town Council, Carmarthenshire

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Dear Mr Morris,

I will return to you with a response to this request by Wednesday 1st May

Thank you

Clare Hope

Interim Clerk

Tel:  01269 839570

Daniel Morris left an annotation ()

ICO unimpressed. Decision Notice will be issued and is now considering placing the authority on its monitoring programme. Town Clerk written to (by ICO 9 May), spelling out the time limits chosen by Parliament, and instructing Council to comply within 10 days.

Town Clerk, Ammanford Town Council, Carmarthenshire

Dear Mr Morris,

Following our recent discussion, I would like to clarify the information I
have been able to obtain on this subject.

I have spoken with PC 672 Chapman of Dyfed Powys Police.  PC Chapman has
advised the following:

* There are 2 cameras in Ammanford Park
* The images are recorded and visible in Ammanford Police Station
* There have been some issues with lack of signal

PC Chapman has advised you are welcome to contact him by ringing 101 and
requesting to speak to him and he will go in to this in more detail if

Unfortunately, I am unable to confirm the costings as I have been unable
to find the paperwork relating to the CCTV installation.  There is no
breakdown of the cost of the cameras or the cost of the pillar.  I am
unsure as to whether the VAT has been claimed back.  The Responsible
Financial Officer is looking in to this for me.

To my knowledge, there is no SLA in force as I have not come across this
to date.

Thank you

Clare Hope

Interim Clerk

Dear Ms Hope,

Thank you for looking for the information and explaining the current configuration of the Park cameras, daisy-chaining with Rec camera to build a composite stream that is finally delivered to the Police Station on Foundry Rd.

It is a relief to know that Dyfed Powys Police are in charge of the cameras and have access to some recordings. It is however very concerning that (as you confirmed at our meeting) the transmission of the composite images over radio links is routinely disrupted by vegetation/leaves growing on the trees.

The 2018 CCTV upgrade programme across Carmarthenshire has been highly politicised, with many parties seeking to claim credit for delivering an important service that ought to protect and reassure members of the public.

I will follow-up with Dyfed Powys Police. The Park & Rec cameras are not shown at all on the DPP website - the key obliterates most of the park with the recreation fields not even on the map, which you can see here:
Yours sincerely,

D Morris

Daniel Morris left an annotation ()

Ammanford Town Council has totally misunderstood the situation with the CCTV cameras in the Park. Dyfed Powys Police are not responsible for operating nor maintaining the system.

Dyfed Powys Police confirm the cameras probably send but the receiving equipment may not be recording and the display is switched off. All the receiving/display equipment is waiting for Carmarthenshire County Council to collect for de-commissioning.

Additionally the reception has always been dodgy during the summer months, as the signal is relayed from the Rec camera through a "gap" between two houses back to Foundry Rd. A tree grows in the garden at the gap and the leaves interfere with the signal.

A radio link had to be used as there wasn't a duct under the railway line to allow cabling through to the new Police station on Foundry Rd from any town centre cameras (as configured with the old Carmarthenshire County Council system). All DPP cameras were replaced in 2018 with live monitoring at Division HQ.

Daniel Morris left an annotation ()

(Note the 17 June update is several weeks after the Police helped, and I relayed the information back to the Council. The delay should have given adequate time for ATC to reconfigure the cameras and re-site the recording/display units).

Daniel Morris left an annotation ()

Town Clerk confirms ATC have made four attempts to contact CCC regarding the receiver/display equipment awaiting collection at Foundry Rd, the cameras are no longer recording.

There was an incident in the park around 2pm on 18 June 2019 with a young family, DPP have appealed for witnesses/information.

Dear Ammanford Town Council, Carmarthenshire,

I am writing to request an internal review of Ammanford Town Council, Carmarthenshire's handling of my FOI request 'Ammanford Park Splashpad CCTV costs and performance'.

On the 17 May 2019 the Interim Clerk was unable to find paperwork relating to the CCTV installation, nor find a breakdown of the costings and was unsure if the VAT had been claimed back. Ms Hope wrote "The Responsible Financial Officer is looking in to this for me".

Ms Hope was, as ever, very helpful on the phone when we spoke regarding these matters on 31 May and also 19 June. Nothing fresh had been found then; which I accepted at face value from the period the PSOW declared that the Council had been in serious maladministration.

110 days since the ICO's last correspondence, a case officer now been assigned. It seems I have not followed the proper procedures. At first I had not exhausted Ammanford Town Council's complaints procedure, which allows for telephone complaints (even though not ratified until 16 June 2019). Having relayed our conversations the Case Officer now advises (regarding the Information Commissioner):

" she cannot consider a second-hand report of what the Council
told you during a phone conversation to have been a proper internal
review. The Commissioner requires documented evidence showing both your
position and the Council's. "

A full history of my FOI request and all correspondence is available on the Internet at this address:

Please pass this on to the person who conducts Freedom of Information reviews.

Yours faithfully,

D Morris

Daniel Morris left an annotation ()

ICO assigned a Case Officer on 14 October 2019, who will now complete the investigation as Ammanford Town Council hadn't bothered to respond to the request for an Internal Review.

Daniel Morris left an annotation ()

Case officer stated "Unfortunately, the Commissioner has had difficulty obtaining the necessary information from the Town Council and has been forced to issue an information notice." (2019-12-16). I doubt this simple review will have been helped by four Councillors resigning and a new Clerk taking up post in the last week. Plus ça change...

Daniel Morris left an annotation ()

Case office update "Unfortunately the Council is yet to comply with the Commissioner's Information Notice. They have been given a final deadline of Thursday to do so, after which the matter will be passed to the Commissioner's solicitors."

Daniel Morris left an annotation ()

Case was passed to ICO's solicitors on Friday 24 January 2020.

"If a public authority fails to comply with an IN the Commissioner may commence Court proceedings under section 54 of the Act, which may be dealt with as contempt of Court"

Daniel Morris left an annotation ()

ICO would like to conclude case. Council claims to have provided more information, but none received.
Clerk lied to whole Council and MOP on 9 March 2020, saying all ICO issues resolved in February. ICO checked their records on 13 March and rejected this claim. Blogged about on 15 March:

Daniel Morris left an annotation ()

427 days since making this request I have had sight of the Internal Review response from the Council, provided by the Lead Case Officer at ICO.

I would note:
1) On 9 March 2020 Ammanford Town Clerk (Duncan S Morgan) told the whole of the Council (including Members of the Public present - myself included) that all the "not so nice letters" from the ICO had been dealt with in February. I wrote about this lie on 15 March 2020, after fact checking with the ICO.

2) Response is dated "27 April 2020", but the Office 365 metadata shows it was created in the afternoon of 28 April. I guess one can't wind the clock back with Azure. April still isn't February.

3) Response may have been physically mailed. The Request was electronic. An ICO officer confirmed on 13 March that they had received correspondence from the Town Clerk (FS50904938) and told him that he must send it to the Requester, and that should be done on the WhatDoTheyKnow platform as that is where the email request will have originated. This appears to be a cynical second attempt to avoid scrutiny. It also breaches the ICO's "form & format" guidance and extensive hand-holding that the ICO has afforded to the Council over the last two years.

4) Response only costs the CCTV camera at £9,540 excluding VAT (+20% =£11,448). The Council did not opt for a self-levitating model, nor one using Tesla coils or any other means of wireless power transmission. The focus of the request was to find out the full cost of the system; the various references in the Minutes, as well as local knowledge and information verbally confirmed by the previous Interim Clerk, suggest that the support stanchions and mains wiring cost an additional "about £5K".

5) An Internal Review that has taken nearly a year has still failed to answer the original request, but now shows that the Council does hold records for the camera that it initially said it didn't have. It is therefore very likely that the Council holds (but has chosen not to disclose) the costs for the support stanchions, their foundations, the excavations and mains wiring of the same ("full cost of the system").

6) The figures presented so far do not account for whether the VAT paid was lawfully reclaimed. Given that this request revealed that Ammanford Town Council had failed to complete its accounts properly (multi-year complaints by its own internal auditors) and was under investigation by the Wales Audit Office (multiple years), it seems unlikely that a duly filed form VAT126 will have been submitted in time, nor whether the wireless camera portion would meet the conditions of "non business activities" (including the the "significant" threshold of £7,500) for refund. HMRC have unrivalled powers to deal with buccaneers, and the like, and don't treat "mistakes" on paperwork kindly.

7) Response included the following:

"It should however be appreciated that you have every right to
request information under the Freedom of Information Act,
however, you should be mindful that requests of this nature
preoccupies the time of those required to answer such requests
which would be better spent improving the services that
Ammanford Town Council can provide."

The Public Services Ombudsman for Wales wrote to the Council in March saying it would be appropriate to commence an investigation, summarising as follows:

" In my letter to the Council I detailed my concerns in relation to the following

1) Failure to comply with Section 55(1)(b) of the Local Government
(Democracy) (Wales) Act 2013.

2) Failure to publish minutes of the council meetings in accordance with
section 55 1(c) of the Local Government (Democracy) (Wales) Act 2013.

3) Failure to publish “any documents referenced in the minutes” in
accordance with section 55 1(c) of the Local Government (Democracy)
(Wales) Act 2013.

4) Failure to publish “any audited statements of the Council’s accounts” in
accordance with section 55 (d) of the Local Government (Democracy)
(Wales) Act 2013.

5) Failure to make available electronically “any documents relating to the
business to be transacted at the meeting” in accordance with Section 57 of
Local Government (Democracy) (Wales) Act 2013.

6) Failure to publish details of members interests.

7) Failure to maintain the Council website in good order.

I explained in my letter in broad terms what steps the Council will need to
take to ensure compliance with the above statutory obligations."

That investigation has been temporarily Corona-suspended (although Town Councillors had not been informed of this letter in early May).

These themes resonate with the Information Commissioner's previous Decision Notices against Ammanford Town Council. In DN FS50711667 (para 27-34) she lamented how the Council had refused to engage, frustrated and prolonged her investigation. In DN FS50755792 she reflected again on failures to follow the "section 46 code", even finishing with:

" it is clear that significant time and resources could have been
saved if all of the information that was eventually uncovered had
been done so at the outset. She expects that the Council’s future
practice in this regard will conform to the recommendations of the section
46 code."

I would note that this FOI request:

a) has simply asked for information that the Council was duty-bound to publish in the first instance by law and according to its own publication scheme

b) has consumed an inordinate amount of personal and public resources as the Council has repeatedly failed to disclose the information it holds

c) sought information relating to:
i) expenditure relating to nearly one-fifth of the Council's annual budget (at the time)
ii) a system that never worked properly and has since been scrapped
iii) a system that was deemed to be necessary to monitor the groups of drunk men and known paedos that had been attracted towards the splashpads where children playing were partly clothed.