Application to hold event in Thornton Heath Recreation Ground
Dear Croydon Borough Council,
Please provide,
• A copy of the application to hold a “Big Lunch/Father’s Day” event in Thornton Heath Recreation Ground on 16 June 2019. The document should show clearly and without ambiguity whether the application was for a Big Lunch or Father’s Day Event. If the application was made by e-mail (s) or via telephone conversation (s) please provide details of the contents of the e-mails, transcripts of telephone conversations and copies of the notes made as a result of any telephone conversation (s).
• Please provide copies of correspondence, be it via e-mail, conversation transcripts, text messages, or any other form of communication between Croydon Council and the organisers concerning the conditions the organisers must comply with relating to (a) the sale and consumption of alcohol in Thornton Heath Recreation Ground (b) limiting the number of attendees to 50, (c) conditions as to anti-social behaviour (d) the instructions which were issued to the organiser re noise levels and (e) that the event must close by 19:00.
• Please provide copies of correspondence showing the hire charge paid. If no hire charge was paid, please provide copies of the documents containing the guidelines which indicate no hire charge was payable.
• Please provide a copy of the Risk Assessment. If there was no Risk Assessment provided, please provide copies of the documents containing the guidelines which indicate no hire charge was payable.
• A copy of the Public Liabilities Insurance arranged by the organisation/person making the application. If no Public Liabilities Insurance was required, please provide copies of the documents containing the guidelines which indicate no hire charge was payable.
• A copy of the Temporary Event Notice and a copy of the receipted invoice showing the fee being paid.
• Copies of any correspondence saying the event would not include the setting up of bouncy castles, or alternatively, copies of any correspondence saying the event would not include the setting up of bouncy castles.
• Copies of any correspondence saying the event would not include using a BBQ, or alternatively, copies of any correspondence saying the event would NOT include the use of a BBQ.
• Correspondence and documents that prove conclusively that Council Officers attended at 19:00 to ensure that the event closed on time.
• Correspondence and documents showing that the organisers were required to collect and remove all refuse and litter from Thornton Heath Recreation Ground.
• Copies of correspondence and documents between departments showing arrangements being made for Council NSO’s and officers from the Council’s Horticultural and Parks Event Teams to attend the event.
• Correspondence and documents between the Council NSO’s, the Council’s Horticultural and Parks Events Team and the department responsible for authorising the event, confirming that arrangements had been made for officers to attend.
• Correspondence and documents showing that Council NSO’s and Officers from the Horticultural and Parks Events Teams attended the event. The correspondence should show the times the various NSO’s and officers were in attendance.
• A copy of the Permit to serve food. A copy of the application to use a BBQ and the permission issued by Croydon Council to use a BBQ
• Copies of any correspondence and documents showing whether a music licence was required. If a music licence was required and issued, please provide a copy.
• Copies of the correspondence and documents relating to the provision of toilet facilities. Please provide copies of the correspondence from the organisers where they set out the toilet facilities which were to be available.
• Correspondence and documents showing conclusively that the local Police were advised of the event taking place. If the local Police acknowledged this correspondence and documentation, please provide copies of the acknowledgement.
• Please provide details of the number of complaints received about the event.
• Please provide copies of correspondence, or documents which clearly show whether any other Council Officers attended apart from the ones mentioned above. For example, Noise Control etc.
Yours faithfully,
Norbury Brook
Freedom of Request
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Yours sincerely
Ahtisham Riaz
FOI Co-ordinator
Croydon Council
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at [1]http://www.croydonobservatory.org/. Also responses to previous
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Hello,
Thank you for contacting Croydon Council regarding an event which took
place on 16^th June 2019 at Thornton Heath Recreation Ground.
The application for this event was submitted through the Big Lunch/Street
Party scheme. It was stated on the organisers application form that there
was to be no sale of alcohol, that the event would be taking place from
10:00am – 7:00pm, and that the event would be private with 50 attendees.
The information stated in the organisers application form did not raise
any concerns, and therefore was approved to proceed.
This event did not require a Risk Assessment or Public Liability Insurance
as their application did not warrant these documents, being that it was a
private event. A Temporary Event Notice (TEN) was not required for this
event, as there was no sale of alcohol. As stated in the Big Lunch Street
Party FAQ’s ‘At a private party, sharing drinks with your neighbours does
not require a licence’.
Neighbourhood Safety Officers (NSO’s) attended the site multiple times
during the day, first in the morning, then during the afternoon where it
was reported that there were people in attendance and finally in the
evening around the close of the event.
I can confirm that there were 6 complaints made regarding this event, all
of which were responded to accordingly.
This event was applied for under the Big Lunch Scheme which is a
countrywide event and we, as a local authority, are encouraged to support
and allow this events to happen.
Regards
Jade Grizzell
Parks Events Officer
Place Department
Environment & Leisure
Public Realm Office
Stubbs Mead Depot
Factory Lane
Croydon
CR0 3RL
Tel: 02087266000 ext: 61444
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Dear Grizzell, Jade,
Thank you for your message.
I would like an Internal Review to be carried out as you have deliberately failed to provided the information I requested.
Will you please review and let me have a full reply within the next 7 days. Otherwise, the natural progression seems for me to contact the Information Commissioner.
I look forward to hearing from you.
Yours sincerely,
Norbury Brook
BY EMAIL ONLY
Internal Review Request under the Environmental Information Regulations
2004
Our reference: Internal Review 11596
Dear Norbury Brook,
I acknowledge receipt of your request for an internal review dated 22 July
2019 regarding the council’s response to your request for information
under the Environmental Information Regulations 2004 (EIR) relating to an
event at Thornton Heath Recreation Ground (request ref. F/CRT/10011596). I
apologise for the delay in sending this acknowledgement to you.
Your complaint regarding the way the council has processed your request
for information has been passed to me, to investigate, and respond to you.
I am sorry you are dissatisfied with the council’s handling of this EIR
request. Under the EIR, the council is required to investigate and provide
a full response to internal review requests within 40 working days. I
therefore calculate that a full response will be provided to your internal
review request by 17 September 2019.
Yours sincerely,
Sarah Kelly
Corporate Solicitor
cid:image002.png@01D407E8.20701350
Legal Team
Resources Department
Floor 7 , Bernard Wetherill House, Mint Walk, Croydon, CR0 1EA
[1][email address]
Internal 64851 | External 020 8726 6000 x64851
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Dear Norbury Brook
I write further to my colleagues email.
I apologise, but it will not be possible to send you the full response to
your internal review by the 17 September. The Council has been
investigating your complaint, liaising with various officers and searching
the information it holds, but we do need more time. We plan to have it
ready by Friday 20^th. I am sorry for any inconvenience this delay may
cause you.
Yours sincerely
Mr Thoday
Corporate Solicitor
Legal and Democratic Services
Floor 7 Zone C
London Borough of Croydon
Ext 88174
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BY EMAIL ONLY
Internal Review Request under the Environmental Information Regulations
2004
Our reference: Internal Review 11596
Dear Norbury Brook,
I refer to the email from my colleague Mrs Thoday of 16 September 2019
regarding the response to your request for an internal review under the
Environmental Information Regulations 2004.
As set out in that email, we had hoped to send you the internal review
response by today’s date (20 September 2019). Unfortunately we will not be
able to send the response to you today, as I am still in the process of
completing the final discussions with the relevant departments which are
required in order to finalise the internal review response. I confirm that
the council does hold further information which falls within the scope of
your request for information, which will be included in the internal
review response. Unfortunately it has taken longer than anticipated to
finalise the response, due to workload and planned absence within the
departments involved.
I now expect to issue the internal review response by next Friday (27
September 2019), and am therefore extending the deadline for response by a
further five working days, to that date. I can only apologise for this
further delay in issuing the internal review response, and for any
inconvenience this may cause you.
Should you wish to, you have the right to escalate your concerns to the
ICO ahead of completion of this internal review.
The ICO can be contacted as follows:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire, SK9 5AF
Telephone: 0303 123 1113
The ICO’s website is [1]www.ico.org.uk.
Yours sincerely,
Sarah Kelly
Corporate Solicitor
cid:image002.png@01D407E8.20701350
Legal Team
Resources Department
Floor 7 , Bernard Wetherill House, Mint Walk, Croydon, CR0 1EA
[2][email address]
Internal 64851 | External 020 8726 6000 x64851
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Dear Ms Kelly
As you appear to have the collation of the replies in hand I will accede to your request for an extension of the reply period to 27 September 2019.
Yours sincerely,
Norbury Brook
BY EMAIL ONLY
Internal Review Request under the Environmental Information Regulations
2004
Our reference: Internal Review 11596
Dear Norbury Brook,
Thank you for your email of 25 September 2019, below.
Unfortunately I will be unable to send you the response to your request
for an internal review today, as the response is still in the process of
completion.
I will send you an update regarding the status of this matter on Monday
(30 September 2019), if we are unable to issue the response that day.
I apologise again for the delay in issuing the internal review response,
and for any inconvenience this may cause you.
Yours sincerely,
Sarah Kelly
Corporate Solicitor
cid:image002.png@01D407E8.20701350
Legal Team
Resources Department
Floor 7 , Bernard Wetherill House, Mint Walk, Croydon, CR0 1EA
[1][email address]
Internal 64851 | External 020 8726 6000 x64851
Dear Ms Kelly
You failed to provide a response on 30 September 2019 and I find the continuing delay and now failure to meet your own deadlines vexatious and irritation. I still expect a full reply to my FOI Application as I assume you have done much of the "gathering" and that effort would be wasted.
However, I have to consider making a personal complaint about the conduct of the staff at Croydon Council who have been obstructive or failed to let you have the information to provide a full response. If there's no update today with a view to saying when the information will be provided I will start lodging complaints.
I would not expect you to say that it will take longer than 7 working days to provide a full reply to my request.
Yours sincerely,
Norbury Brook
BY EMAIL ONLY
Internal Review Request under the Environmental Information Regulations
2004
Our reference: Internal Review 11596
Dear Norbury Brook,
Thank you for your email of today’s date, below. I apologise that I was
unable to send this update to you yesterday.
I confirm that the Legal team is aiming to issue a partial response to
your internal review request by the end of this week (Friday, 04 October
2019). The partial response should cover most of the questions raised in
your EIR request. We are now in the process of obtaining approval from the
relevant departments regarding the partial response. We will confirm in
the partial response letter, the date by which we expect to issue the
final response to this internal review, covering the remaining questions
in your EIR request.
I apologise again for the delay in sending you our response to this
internal review, and for any inconvenience this may have caused you. We
are seeking to complete this internal review as soon as possible, as we
are aware that you have been seeking the requested information for some
time. Unfortunately the process of finalising the full internal review
response has taken longer than anticipated.
Please note that I am now out of the office until 15 October 2019. In my
absence, my colleague Mr Passman, copied in, will be co-ordinating the
internal review responses.
As previously outlined, should you wish to, you have the right to escalate
your concerns to the ICO ahead of completion of this internal review.
The ICO can be contacted as follows:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire, SK9 5AF
Telephone: 0303 123 1113
The ICO’s website is [1]www.ico.org.uk.
Yours sincerely,
Sarah Kelly
Corporate Solicitor
cid:image002.png@01D407E8.20701350
Legal Team
Resources Department
Floor 7 , Bernard Wetherill House, Mint Walk, Croydon, CR0 1EA
[2][email address]
Internal 64851 | External 020 8726 6000 x64851
Dear Ms Kelly and Mr Passman
I'm disappointed that I didn't receive either a partial response or an update by 4 October 2019. By law, Croydon Council should have responded by now, and I must say that I find Croydon Council's delays persistently vexatious and deeply disturbing. There can't be many Department Heads involved (are there?) and as you have obviously gotten to an advanced state please get this done and let me have a full reply..
The Department Heads have (in my view) had ample time to gather the information and respond. Accordingly, I shall consider making complaints about the Department Heads via the formal complaints procedure as I am dissatisfied by the council's lack of action..
I find this
Yours sincerely,
Norbury Brook
I am currently out of the office, returning on Tuesday, 15 October 2019.
If you require urgent assistance during this time, please email the Legal
Business Team at [email address]
Otherwise I will respond to your message, when I return.
Kind regards
Sarah Kelly
Corporate Solicitor
Council services, online, 24/7 www.croydon.gov.uk/myaccount.
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Dear Norbury Brook,
I write further to your request for an Internal Review of 22 July 2019,
under the Environmental Information Regulations 2004 (‘EIR’), in respect
of your request for information regarding an event in Thornton Heath
Recreation Ground. My colleague Ms. Kelly requested that issue the
response to you.
This is a partial Internal Review response, which contains responses to 14
of the 19 questions in your EIR request. The Legal team is now in the
process of preparing a final response which will address the remaining
five questions in your EIR request. The final response will also include
any further information held by the Council which can be disclosed in
response to the questions covered by this partial response.
I have set out below, details of your request for information (‘EIR
Request’), your internal review request, and my internal review
investigation.
EIR Request
I understand the council received your EIR request (request ref.
F/CRT/10011596), on 23 June 2019. The EIR request contained a series of
questions relating to a Big Lunch event at Thornton Heath Recreation
Ground. A full copy of the EIR request is attached.
EIR Response and Internal Review Request
A response to your EIR Request (EIR Response) was issued on 22 July 2019.
The response provided some information in response to the questions
contained in the EIR Request, but did not provide a full response to those
questions. A copy of the EIR Response is attached.
You subsequently sent an email to the Council requesting an Internal
Review (attached), on the grounds that the Council had deliberately
withheld the requested information.
Internal Review Investigation
In carrying out this Internal Review, I have spoken to the Council’s
Events and Sports service which holds the requested information.
EIR responses are normally issued by the Council’s Information Management
Team, which liaises with the relevant departments then collates and issues
the EIR response. It appears that on this occasion, the EIR response was
issued from the Events and Sports service, due to a staff error, after the
service received the EIR Request. As set out above, the EIR response was
incomplete, as the questions in the EIR Request were not addressed in full
in the response letter.
On this basis, my Internal Review investigation has not found that
information was deliberately withheld from the EIR response, and the
complaint in your Internal Review request is not upheld. As stated above,
it instead appears that the EIR response was issued by the Events and
Sports service, and was incomplete, as the result of a staff error. I can
only apologise on behalf of the Council regarding the error which led to
you receiving an incomplete response to your EIR request. The Events and
Sports service has now arranged additional staff member training regarding
the correct procedures and process for handling these types of requests,
to ensure such errors do not occur again in the future.
Partial Internal Review Response
The questions listed in your EIR request which we can address in this
partial response, are numbered, and set out in bold italics below,
together with our responses. The 14 questions addressed below are
Questions 1, 2, 3, 4, 5, 6, 7, 8, 10, 14, 15, 16, 18 and 19. Our final
response will set out our responses to the remaining five questions
(Questions 9, 11, 12, 13, and 17).
Question 1. Please provide a copy of the application to hold a “Big
Lunch/Father’s Day” event in Thornton Heath Recreation Ground on 16 June
2019. The document should show clearly and without ambiguity whether the
application was for a Big Lunch or Father’s Day Event. If the application
was made by e-mail (s) or via telephone conversation (s) please provide
details of the contents of the e-mails, transcripts of telephone
conversations and copies of the notes made as a result of any telephone
conversation (s).
Response: Please see the attached copy of the application form submitted
to the council in respect of this event. Please note that the council has
withheld some personal data, from this document. The withheld information
consists of the name and contact information of the event applicant. Our
grounds for withholding this data under the EIR, are set out below.
Question 2. Please provide copies of correspondence, be it via e-mail,
conversation transcripts, text messages, or any other form of
communication between Croydon Council and the organisers concerning the
conditions the organisers must comply with relating to (a) the sale and
consumption of alcohol in Thornton Heath Recreation Ground (b) limiting
the number of attendees to 50, (c) conditions as to anti-social behaviour
(d) the instructions which were issued to the organiser re noise levels
and (e) that the event must close by 19:00.
Response: Please see the attached letter of 5 June 2019 from the council
to the event applicant confirming that the application to hold the event
had been approved. This letter contains information relating to
consumption of alcohol, attendee numbers, noise, event length and
conditions. Please note that:
· the first paragraph of the letter states the event is being held
at Addiscombe Railway Park. This reference to Addiscombe Railway Park
appears to be an error.
· the Council has withheld some personal data from this letter.
The withheld information consists of the name and contact information of
the event applicant, and the name, contact information, and signature, of
a junior council officer. Our grounds for withholding this data under the
EIR, are set out below.
Please also note that the Council holds a further email which falls within
the scope of Question 2, which we are preparing for disclosure in the
final response.
Question 3. Please provide copies of correspondence showing the hire
charge paid. If no hire charge was paid, please provide copies of the
documents containing the guidelines which indicate no hire charge was
payable.
Response: Big Lunches are held nationwide, and more than 98% are free of
charge, as this event was. Based on the details contained in the attached
application form, I am instructed that no hire charge would have been
requested. The attached document - Big Lunch FAQ’s, sets out the relevant
guidelines regarding hire charges.
Question 4. Please provide a copy of the Risk Assessment. If there was no
Risk Assessment provided, please provide copies of the documents
containing the guidelines which indicate no hire charge was payable.
Response: Based on the details contained in the attached application form,
I am instructed that no risk assessment would have been required. The
application form stated that the event would be a private party of up to
50 people, and no risk assessment would be required for such an event. The
attached Big Lunch Street Party FAQs, sets out the relevant guidelines
regarding risk assessments.
Question 5. Please provide a copy of the Public Liabilities Insurance
arranged by the organisation/person making the application. If no Public
Liabilities Insurance was required, please provide copies of the documents
containing the guidelines which indicate no hire charge was payable.
Response: Based on the details contained in the attached application form,
I am instructed that public liabilities insurance would not have been
required. The application form stated that the event would be a private
party of up to 50 people, and no public liabilities insurance would be
required for such an event. The attached document labelled Big Lunch
Street Party FAQ, sets out the relevant guidelines regarding public
liabilities insurance.
Question 6. Please provide a copy of the Temporary Event Notice and a copy
of the receipted invoice showing the fee being paid.
Response: Based on the details contained in the attached application form,
I am instructed that a Temporary Event Notice would not have been
required. The application form stated the event would be a private party
of up to 50 people, and a Temporary Event Notice would not be required for
such an event.
Question 7. Please provide copies of any correspondence saying the event
would not include the setting up of bouncy castles, or alternatively,
copies of any correspondence saying the event would not include the
setting up of bouncy castles.
Response: The attached application form did not indicate that the event
would include bouncy castles/inflatables.
Question 8. Please provide copies of any correspondence saying the event
would not include using a BBQ, or alternatively, copies of any
correspondence saying the event would NOT include the use of a BBQ.
Response: The attached application form states the event would be
self-catering and does not mention a BBQ.
Question 10. Please provide correspondence and documents showing that the
organisers were required to collect and remove all refuse and litter from
Thornton Heath Recreation Ground.
Response: I confirm that the Council holds an email confirming that the
applicant should leave the park in the way it was found. We are preparing
a copy of this email for disclosure to you in the final response.
Question 14. Please provide a copy of the Permit to serve food. A copy of
the application to use a BBQ and the permission issued by Croydon Council
to use a BBQ
Response: I am instructed that no permit was granted to serve food. Nor
was any application made for a BBQ. The application form stated the event
would be self-catering and would not include a BBQ.
Question 15. Please provide copies of any correspondence and documents
showing whether a music licence was required. If a music licence was
required and issued, please provide a copy.
Response: I am instructed that no music licence was required, since the
application form indicated this was a small, private event. No permits or
licenses would be required for an event of this size with self-catering.
Question 16. Please provide copies of the correspondence and documents
relating to the provision of toilet facilities. Please provide copies of
the correspondence from the organisers where they set out the toilet
facilities which were to be available.
Response: There is no request for toilet provision on the event
application form. If a park has toilets available, these would be open for
use.
Question 18. Please provide details of the number of complaints received
about the event.
Response: There were seven complaints about the event.
Question 19. Please provide copies of correspondence, or documents which
clearly show whether any other Council Officers attended apart from the
ones mentioned above. For example, Noise Control etc.
Response: It is understood that no other officers, other than
Neighbourhood Safety Officers (NSO) attended the event in response to a
noise complaint; during which the music volume is understood to have been
turned down following a request from the NSO’s.
Redaction of Personal Data
As set out above, some information which consists of personal data, has
been withheld from the information disclosed in response to Questions 1
and 2. The withheld items are clearly personal data regarding the event
applicant, and a junior council officer.
I have decided these items should be withheld under regulations 12(3) and
13 of the EIR. These regulations exempt personal information from
disclosure if that information relates to someone other than the
requester, and if disclosure of that information would breach any of the
data protection principles in Article 5(1) of the General Data Protection
Regulation (GDPR). We consider disclosure of this information is likely to
breach the first data protection principle, which provides that personal
data must be processed lawfully, fairly, and in a transparent manner. A
response to an EIR request is not just to the requestor, but enters the
wider public domain. For this reason we consider that disclosure would not
constitute fair processing of this personal data because the junior staff
member and applicant would not reasonably expect their names and contact
details to be disclosed in relation to a request for information under the
EIR.
On this basis, the council is withholding this personal data under
regulations 12(3) and 13, and this letter acts as a refusal notice in
respect of this information.
Further Extension of Deadline for Response
I apologise that this response does not provide a full response to the
questions in your EIR Request. Unfortunately we will require further time
to collate and prepare the information which should be included in the
final response, and to conclude our discussions with the relevant
departments. We are likely to need a further 10 working days to complete
the final response, therefore I am extending the deadline to issue the
response to Friday, 18 October 2019. I can only apologise for this further
delay in sending you the internal review response, and for any
inconvenience this may cause you.
As previously outlined, should you wish to, you have the right to escalate
your concerns to the ICO ahead of completion of the review.
The ICO can be contacted as follows:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire, SK9 5AF
Telephone: 0303 123 1113
The ICO’s website is [1]www.ico.org.uk.
Yours sincerely
Howard Passman for Sarah Kelly,
020 8726 6000
Information Management and Governance Co-ordinator
cid:995D36CC-63D9-452C-921A-47E295D9BC0F
Resources Department
Legal Services
7th Floor Zone C
Bernard Weatherill House
8 Mint Walk
Croydon CR0 1EA
Council services, online, 24/7 www.croydon.gov.uk/myaccount.
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BY EMAIL ONLY
Internal Review Request under the Environmental Information Regulations
2004
Our reference: Internal Review 11596
Dear Norbury Brook,
I refer to the partial response issued by my colleague Mr Passman of 07
October 2019, regarding internal review ref. 11596.
This is a further partial response, attaching the email which we stated
the council would disclose to you, in response to Questions 2 and 10 of
your EIR request. Those questions are:
· Question 2. Please provide copies of correspondence, be it via
e-mail, conversation transcripts, text messages, or any other form of
communication between Croydon Council and the organisers concerning the
conditions the organisers must comply with relating to (a) the sale and
consumption of alcohol in Thornton Heath Recreation Ground (b) limiting
the number of attendees to 50, (c) conditions as to anti-social behaviour
(d) the instructions which were issued to the organiser re noise levels
and (e) that the event must close by 19:00.
· Question 10. Please provide correspondence and documents showing
that the organisers were required to collect and remove all refuse and
litter from Thornton Heath Recreation Ground.
The attached email was sent to the event applicant by the council’s
Community and Voluntary service, which initially receives Big Lunch
application forms. Please note that the email was sent to the applicant in
response to their original application to hold the Big Lunch event on 02
June 2019. The applicant subsequently submitted an identical event
application form to the council, to change the date of the event to 16
June 2019.
Please also note that some personal data which consists of the
names/contact information of the applicant and two junior council
officers, has been redacted from the attached email. This information is
being withheld from disclosure under regulations 12(3) and 13 of the EIR
for the reasons set out in our partial response of 07 October 2019, in
respect of redaction of applicant and junior officer names/contact
information. This email acts as a refusal notice in respect of this
information.
Unfortunately we will not be able to send you our response to the
remaining five questions covered by your EIR request today, as we are
still in the process of completing our discussions with the departments
required to finalise our response to those questions. As you are aware, I
have been on leave, and my colleagues in the Legal team have had limited
capacity to progress this matter in my absence. I can only apologise again
for this delay in sending you our final response.
We are likely to need a further five working days to complete the final
response, therefore I am extending the deadline to issue the final
response to next Friday (25 October 2019). I can only apologise for this
further delay in sending you our final response, and for any inconvenience
this may cause you. As previously outlined, should you wish to, you have
the right to escalate your concerns to the ICO ahead of completion of the
review.
The ICO can be contacted as follows:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire, SK9 5AF
Telephone: 0303 123 1113
The ICO’s website is [1]www.ico.org.uk.
Yours sincerely
Sarah Kelly
Corporate Solicitor
cid:image002.png@01D407E8.20701350
Legal Team
Resources Department
Floor 7 , Bernard Wetherill House, Mint Walk, Croydon, CR0 1EA
Council services, online, 24/7 www.croydon.gov.uk/myaccount.
Please use this web site address to view the council's e-mail disclaimer -
http://www.croydon.gov.uk/email-disclaimer
References
Visible links
1. http://www.ico.org.uk/
BY EMAIL ONLY
Internal Review Request under the Environmental Information Regulations
2004
Our reference: Internal Review 11596
Dear Norbury Brook,
I refer to my email of 18 October 2019, regarding internal review ref.
11596.
This is brief update to let you know that the Legal team has now completed
our discussions with the relevant departments, and are now completing the
final response to your internal review request. We expect to finalise the
response, and send this to you, next week. I am therefore extending the
deadline to send our response to you, by a further five working days, to
next Friday, 01 November 2019, although we hope to send the response to
you before that date. I apologise again for the delay in sending you the
final response.
As previously outlined, should you wish to, you have the right to escalate
your concerns to the ICO ahead of completion of the review.
The ICO can be contacted as follows:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire, SK9 5AF
Telephone: 0303 123 1113
The ICO’s website is [1]www.ico.org.uk.
Yours sincerely
Sarah Kelly
Corporate Solicitor
cid:image002.png@01D407E8.20701350
Legal Team
Resources Department
Floor 7 , Bernard Wetherill House, Mint Walk, Croydon, CR0 1EA
Council services, online, 24/7 www.croydon.gov.uk/myaccount.
Please use this web site address to view the council's e-mail disclaimer -
http://www.croydon.gov.uk/email-disclaimer
References
Visible links
1. http://www.ico.org.uk/
BY EMAIL ONLY
Internal Review Request under the Environmental Information Regulations
2004
Our reference: Internal Review 11596
Dear Norbury Brook,
I refer to my email of 25 October 2019 regarding internal review ref.
11596.
I confirm that the Legal team has now completed the final response to your
internal review request. Unfortunately we will be unable to send the
response to you today, as we need additional time to check a final point
regarding the response documents with a staff member who has been out of
the office this week. We will be able to complete our discussions with
that staff member by close of play on Monday, and will then finalise and
send the response to you as early as possible on Tuesday (05 November
2019). I am therefore extending the deadline to send our response to you,
by a further two working days, to next Tuesday. I can only apologise again
for the delay in sending you the final response.
As previously outlined, should you wish to, you have the right to escalate
your concerns to the ICO ahead of completion of the review.
The ICO can be contacted as follows:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire, SK9 5AF
Telephone: 0303 123 1113
The ICO’s website is [1]www.ico.org.uk.
Yours sincerely
Sarah Kelly
Corporate Solicitor
cid:image002.png@01D407E8.20701350
Legal Team
Resources Department
Floor 7 , Bernard Wetherill House, Mint Walk, Croydon, CR0 1EA
Council services, online, 24/7 www.croydon.gov.uk/myaccount.
Please use this web site address to view the council's e-mail disclaimer -
http://www.croydon.gov.uk/email-disclaimer
References
Visible links
1. http://www.ico.org.uk/
BY EMAIL ONLY
Internal Review Request under the Environmental Information Regulations
2004
Our reference: Internal Review 11596
Dear Norbury Brook,
I write further to my email of 25 October 2019, in respect of your request
for information under the Environmental Information Regulations 2004
(‘EIR’), regarding the Big Lunch event in Thornton Heath Recreation Ground
on 16 June 2019.
We have already sent you our responses to 14 of the 19 questions covered
by your request for information. This final response covers the five
remaining questions, namely, Questions 9, 11, 12, 13, and 17. Those
questions are set out in bold italics below, together with our responses.
RESPONSES to QUESTIONS 9, 11, 12, 13, and 17
Question 9 – Please provide correspondence and documents that prove
conclusively that Council Officers attended at 19:00 to ensure that the
event closed on time.
Response: Please see the attached .pdf document labelled “Internal Review
11596 – REDACTED – Email Reports Regarding NSO Attendance”. This document
includes an email report regarding NSO attendance at the event just before
7pm.
Question 11 – Please provide copies of correspondence and documents
between departments showing arrangements being made for Council NSO’s and
officers from the Council’s Horticultural and Parks Event Teams to attend
the event.
Response: Please see the attached .pdf document labelled “Internal Review
11596 – REDACTED - Emails Regarding Council Staff Attendance and Police
Notification”. This document contains copies of emails regarding notifying
police, and arrangements for NSOs to attend the event (NSOs are employed
by Neighbourhood Operations). These emails consist of:
· emails sent by officers in the Events and Sports service to
Neighbourhood Operations at 09:38 on 13 June 2019; 16:13 on 13 June 2019;
and 18:46 on 15 June 2019.
· an email sent by a Neighbourhood Safety Manager to the Events and
Sports service at 21.53 on 13 June 2019.
• an email sent by a Neighbourhood Safety Manager to Neighbourhood
Operations staff at 20:58 on 15 June 2019.
Question 12 – Please provide copies of correspondence and documents
between the Council NSO’s, the Council’s Horticultural and Parks Events
Team and the department responsible for authorising the event, confirming
that arrangements had been made for officers to attend.
Response: Please see the attached .pdf document labelled “Internal Review
11596 – REDACTED - Emails Regarding Council Staff Attendance and Police
Notification”.
Question 13 – Please provide correspondence and documents showing that
Council NSO’s and Officers from the Horticultural and Parks Events Teams
attended the event. The correspondence should show the times the various
NSO’s and officers were in attendance.
Response: Please see the attached .pdf document labelled “Internal Review
11596 – REDACTED – Email Reports Regarding NSO Attendance”. This document
contains copies of email reports from Neighbourhood Operations staff
regarding NSO attendance at the event.
Question 17 – Please provide correspondence and documents showing
conclusively that the local Police were advised of the event taking place.
If the local Police acknowledged this correspondence and documentation,
please provide copies of the acknowledgement.
Response: Please see the attached .pdf document labelled “Internal Review
11596 – REDACTED - “Emails Regarding Council Staff Attendance and Police
Notification”, and the attached copy of an email from police to the
council dated 27 June 2019, which confirms police were aware of the event.
Redacted Information
Please note that some information has been redacted from the attached .pdf
documents. The redacted material consists of (a) internal communications
which fall outside the scope of this request for information, and (b)
personal data.
The following personal data has been redacted from the emails contained in
the document labelled “Internal Review 11596 – REDACTED – Email Reports
Regarding NSO Attendance”:
· names and contact details of junior council officers from the
council’s Neighbourhood Operations service, namely NSOs and a
Neighbourhood Safety Manager.
· photographs of members of the public.
· details of complaints about the event including name and address
of those making the complaints.
The following personal data has been redacted from the emails contained in
the document labelled “Internal Review 11596 – REDACTED - Emails Regarding
Council Staff Attendance and Police Notification”:
· names and contact details of junior council officers from the
council’s Neighbourhood Operations service, namely NSOs and a
Neighbourhood Safety Manager.
· names and contact details of junior council officers from other
service areas including the Events and Sports service.
The following personal data has been redacted from the email from police
to the council:
• police officer name and contact details.
• the name and contact details of a junior council officer from the
Events and Sports service.
The withheld personal data items listed above are clearly personal data
regarding members of the public, the police officer, and junior council
officers. I have decided these personal data items should be withheld
under regulations 12(3) and 13 of the EIR. These regulations exempt
personal information from disclosure if that information relates to
someone other than the requester, and if disclosure of that information
would breach any of the data protection principles in Article 5(1) of the
General Data Protection Regulation. I consider disclosure of this
information is likely to breach the first data protection principle, which
provides that personal data must be processed lawfully, fairly, and in a
transparent manner. A response to an EIR request is not just to the
requestor, but enters the wider public domain. For this reason I consider
that disclosure would not constitute fair processing of this personal data
because these members of the public, the police officer, and junior staff
members would not reasonably expect their names and contact details to be
disclosed in relation to a request for information under the EIR.
On this basis, the council is withholding this personal data under
regulations 12(3) and 13, and this email acts as a refusal notice in
respect of this information.
If you are not happy with the outcome of this internal review, you have
the right to apply directly to the Information Commissioner for a
decision. The Information Commissioner can be contacted at:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire, SK9 5AF
Telephone: 0303 123 1113
The ICO’s website is [1]www.ico.org.uk.
Yours sincerely
Sarah Kelly
Corporate Solicitor
cid:image002.png@01D407E8.20701350
Legal Team
Resources Department
Floor 7, Bernard Wetherill House, Mint Walk, Croydon, CR0 1EA
Council services, online, 24/7 www.croydon.gov.uk/myaccount.
Please use this web site address to view the council's e-mail disclaimer -
http://www.croydon.gov.uk/email-disclaimer
References
Visible links
1. http://www.ico.org.uk/
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