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Benefit: Discretionary Housing Payments

We're waiting for Paul Cardin to read a recent response and update the status.

Dear Wirral Metropolitan Borough Council,

Subject: Benefit.

The benefit in question is Discretionary Housing Payments.

Please provide information as follows, taken from a time period between January 2015 and the present date:

1 ...to show the date WBC amended the appropriate policies and procedures to ensure compliance with Hardy V Sandwell case law re: DHP (March 2015).

2 ...to show the date of the last internal and external audit to ensure compliance with 3.9 of the DWP, DHP Guidance Manual and Local Authority Good Practice Guide.

3 ...to show what action the authority has taken / is taking to identify people who have been adversely affected by non-compliant DHP decisions.

4 ...to show the extent to which claimants were incorrectly assessed, including total numbers of people affected.

5 ...to show what the authority has done to recognise and acknowledge its failings / malpractice in order to show that it has learned lessons since the Martin Morton / DASS whistleblow re: proven unlawful charging / unlawful debiting of supported living tenants' bank accounts.

6 ...to show the extent to which the authority has put measures in place to ensure compliance, restore fairness and to ensure this kind of failure does not recur in the future.

7 ...to show what measures the authority has taken to reimburse those people who have been adversely affected re: DHP i.e. details of all action taken to restore each affected person to the position they would have been in, had the correct awards been made.

8 ...to show the figure for the total amount of DHP benefit unfairly withheld from qualifying claimants who would have received payments in DHP benefit had their applications been correctly and fairly assessed in accordance with the law.

9 Please also provide the full, unredacted outcome of all internal and external audits taken within the above time period.

Please only redact the above information where necessary, in accordance with the requirements of the Data Protection Act 1998,

Yours faithfully,

Paul Cardin

Paul Cardin left an annotation ()

I blogged on this FOI request, outlining to the public some related background material ...and how public suspicion has been alerted ...to an increasing feeling that all is not well...

https://wirralinittogether.blog/2017/02/...

Dear Wirral Metropolitan Borough Council,

Just as a quick follow-up to this request, this is to make you aware that in addressing this request you should be mindful of the recent ECtHR judgment MAGYAR HELSINKI BIZOTTSÁG v. HUNGARY

(Application no. 18030/11)

http://echrblog.blogspot.co.uk/2016/11/m...

Should this request be either refused or partially refused in response, I will invoke this case and use it to clarify my right as a "social watchdog" to seek, receive and impart information, and the 15 - 2 findings of the ECtHR panel will be used to support it, despite the UK's determined attempts to hinder and / or qualify European citizens', journalists' and social watchdogs' Article 10 rights.

Please add the text of this clarification to the main body of the "Benefit: Discretionary Housing Payments" FOI request and address as one,

Yours faithfully,

Paul Cardin

InfoMgr, FinDMT, Wirral Metropolitan Borough Council

1 Attachment

Dear Mr Cardin

 

Thank you for your Freedom of Information request regarding Discretionary
Housing Payments. Please see the Council's response to each of the points
raised below.

 

1 ...to show the date WBC amended the appropriate policies and procedures
to ensure compliance with Hardy V Sandwell case law re: DHP (March 2015).

Wirral Council akin to other Local Authorities, has developed its own DHP
policy, in accordance with the DWP’s DHP Guidance/ Good Practice Guide
(revised using May 2016 and December 2016), which states, in relation to
PIP/ DLA that;

“Local Authorities are obliged to consider each DHP application on a case
by case basis having regard to the purpose of those disability related
benefits and whether the money from those benefits has been committed to
other liabilities associated with disability”.  The guidance further
advises that ‘in establishing if the claimant requires further financial
assistance the Local Authority can decide how to treat any expenditure,
offsetting it against income intended to assist with such expenditure as
appropriate’ and this is the approach that Wirral Council takes when
considering DHP applications. Procedures and guidance are reviewed when
appropriate in accordance with DWP guidance manuals.

 

2 ...to show the date of the last internal and external audit to ensure
compliance with 3.9 of the DWP, DHP Guidance Manual and Local Authority
Good Practice Guide.

The last internal Audit was completed May 2016 and an external Audit is
currently being undertaken.

 

3 ...to show what action the authority has taken / is taking to identify
people who have been adversely affected by non-compliant DHP decisions.

An exercise has been undertaken to contact those claimants who are in
receipt of a disability related income and who may have under declared
their disability related expenditure on previous applications for DHP.

 

4 ...to show the extent to which claimants were incorrectly assessed,
including total numbers of people affected.

281 Claimants may have been affected and were identified and contacted in
relation to their expenditure.

Out of 281 contacted 126 responded, some of which provided additional
information that was not included on the original application.

From the 123 who contacted 22 claimants received either a partial or a
full award.

The total of DHP paid to date in relation to this exercise is £10,271.06.

 

5 ...to show what the authority has done to recognise and acknowledge its
failings / malpractice in order to show that it has learned lessons since
the Martin Morton / DASS whistleblow re: proven unlawful charging /
unlawful debiting of supported living tenants' bank accounts.

All relevant policies and procedures have been reviewed following DWP
guidance issued and consideration of relevant case law

 

6 ...to show the extent to which the authority has put measures in place
to ensure compliance, restore fairness and to ensure this kind of failure
does not recur in the future.

Procedures have been reviewed and guidance issued to the officers in
relation to claims for DHP. Workshops have been delivered to all staff and
compliance testing is ongoing to ensure that the procedures and   guidance
is followed. 

 

7 ...to show what measures the authority has taken to reimburse those
people who have been adversely affected re: DHP i.e. details of all action
taken to restore each affected person to the position they would have been
in, had the correct awards been made.

As detailed in point 4 those affected have been reviewed based on
information provided.

 

8 ...to show the figure for the total amount of DHP benefit unfairly
withheld from qualifying claimants who would have received payments in DHP
benefit had their applications been correctly and fairly assessed in
accordance with the law.

The total sum paid to date has been calculated (see para 4 above).

The remaining exercise is still ongoing (see para 4 above) and it is not
possible to confirm whether any further awards will be made at this time.

 

9…  Please also provide the full, unredacted outcome of all internal and
external audits taken within the above time period.

We consider that the information you have requested is exempt information
under Section 31(1)(g)  of the Freedom of Information Act 2000 (“FOIA”) in
that its disclosure would prejudice the exercise by the Council  of its
functions for any of the purposes specified in subsection (2). The
relevant purposes are ascertaining whether any person has failed to comply
with the law and whether any person is responsible for any conduct which
is improper (Section 31 (2)(a) and (b) of FOIA.)

 

We have had regard to the guidance issued by the Information
Commissioner’s Office, “Law enforcement (section 31), 20130529,
Version:1.0.” The function that the Council is exercising concerns the
administration of discretionary housing payment. Paragraph 14 of the
guidance provides that “Section 31 is subject to a test of prejudice. This
means that information can only be withheld if its disclosure would, or
would be likely to, prejudice one of the activities listed in either
subsection 31 (1) or (2). We consider that disclosure of the requested
information would prejudice the relevant purposes of ascertaining whether
any person has failed to comply with the law and whether any person is
responsible for any conduct which is improper.(Section 31 (2)(a) and (b)
of FOIA.) We consider that prejudice would occur if the requested
information was given to you as a member of the public.

Paragraph 99-101 of the guidance deals with prejudice to investigations.
Paragraph 99 provides that “Many of the activities protected by section 31
will involve the relevant public authority conducting investigations.
”Paragraph 101 states that “Investigators need private thinking space, or
safe space, if they are going to fully explore all aspects of a case
without fear that their half-formed opinions would be reported in the
press or enter the public domain. Such concerns would hinder the efficient
running of an investigation. Investigators may expect their findings to be
made public but at a later stage when they represent the fully considered
conclusions of the investigation” I consider that to provide you with the
full, unredacted outcome of all internal and external audits taken within
the above time period would prejudice the purposes referred to above.

 

Public interest test

Section 31 is subject to the public interest test.

Factors in favour of disclosure:

•             Disclosing information that increases transparency about how
public authorities perform their function factors in favour of maintaining
the exemption

•             Protecting the ability of the Council to carry out
investigations and to enforce the law.

•             The effect of premature disclosure of information to a
member of the public when such investigations are being carried out.

•             Undermining future investigations if it is known that
information will be disclosed to the public before all relevant
investigations both internal and external are completed.

 

We also consider that the information that has already been supplied to
you in connection with your earlier queries can be construed as satisfying
the public interest. We are therefore refusing this part of your request
for information on the basis that the exemption contained in Section
31(2)(g) of FOIA  applies. You have the right to ask for an internal
review in connection with this refusal of part of your request for
information, which should be addressed in the first instance to Jane
Corrin, Records and Information Manager at
[1][Wirral Borough Council request email]

 

You also have the right to complain to the Information Commissioner in
respect of the refusal of part of your request for information under
Section 17 of FOIA but would be expected to exhaust first the internal
review process.

The address is:

The Information Commissioner’s Office,

Wycliffe House,

Water Lane,

Wilmslow,

Cheshire SK9 5AF

[2]https://ico.org.uk/global/contact-us/

Tel -0303 123 113

 

 

Yours sincerely

 

 

 

Lynette Paterson

Senior Information Management Officer

Business Services - Digital

 

Treasury Building

Cleveland Street
Birkenhead
Wirral
CH41 6BL

[3]Tel: 0151 691 8201

[4][Wirral Borough Council request email]

 

 

[5]LGC Awards15_Winner_MIP

 

 

This information supplied to you is copyrighted and continues to be
protected by the Copyright, Designs and Patents Act 1988.   You are free
to use it for your own purposes, including any non commercial research you
are doing and for the purposes of news reporting. Any other reuse, for
example commercial publication, would require our specific permission, may
involve licensing and the application of a charge

 

 

 

 

 

show quoted sections

References

Visible links
1. mailto:[Wirral Borough Council request email]
2. https://ico.org.uk/global/contact-us/
3. file:///tmp/Tel:0151
4. mailto:[Wirral Borough Council request email]

Dear InfoMgr, FinDMT,

I am disappointed with your response because it has fallen down in several areas. Your reply is, I believe, not simply a breach of the spirit of the Act but also its terms and your statutory obligations as a data controller.

I have come to this conclusion because more than one of my questions has not been responded to directly or adequately. Moreover, despite your use of the Section 31 exemption, I believe the response is strongly indicative of an attempt to conceal wrongdoing.

In accordance with the Act, please ask a more senior person to carry out an internal review, and to be mindful of the following clarifications when doing so.

I will list my concerns relating to each question sequentially:

[Please provide information...]

1. ...to show the date WBC amended the appropriate policies and procedures
to ensure compliance with Hardy V Sandwell case law re: DHP (March 2015).

*The requested date is not clearly stated and the written language used is very poor, bordering on indecipherable.*

2. ...to show the date of the last internal and external audit to ensure
compliance with 3.9 of the DWP, DHP Guidance Manual and Local Authority
Good Practice Guide.

*The leaked email (below) sent by Monitoring Officer Surjit Tour dated 31st October 2016 indicates that following an internal audit investigation, the Department had not been and was not compliant with 3.9 of the DWP, DHP Guidance Manual and Local Authority Good Practice Guide:

https://wirralinittogether.files.wordpre...

The point regarding 'external audit' was not answered clearly and raised further questions i.e. Had an external audit ever been done? If so, the date was not provided. Was the current external audit the only external audit ever undertaken? If so, this needs to be clarified to me in order to answer this part of the request.*

3. ...to show what action the authority has taken / is taking to identify
people who have been adversely affected by non-compliant DHP decisions.

*The central point here was not addressed. I did not ask for 'persons who had under declared'. I distinctly asked for 'Action...to identify people who [had] been adversely affected by non-compliant DHP decisions'.*

4. ...to show the extent to which claimants were incorrectly assessed,
including total numbers of people affected.

*If the exercise was undertaken simply to address claimants' 'under declarations' (see response to Point 3) it will have failed to identify the presumably larger number of persons adversely impacted by non-compliant [see Surjit Tour email dated 31st October 2016] Wirral Council DHP decisions dating back to the Hardy V Sandwell High Court decision (30th March 2015).

In light of this, your response does not and cannot accurately address the point regarding "incorrectly assessed" and "numbers of people affected".*

5. ...to show what the authority has done to recognise and acknowledge its
failings / malpractice in order to show that it has learned lessons since
the Martin Morton / DASS whistleblow re: proven unlawful charging /
unlawful debiting of supported living tenants' bank accounts.

*Although sub-sections of FOIA Section 31 have been quoted to justify non-disclosure, no indication has been given in response to point 5. that any disciplinary investigation or civil / criminal action is categorically underway. Such moves towards a measure of accountability, stated publicly, would indicate that lessons have been learned since the Martin Morton case.*

6. ...to show the extent to which the authority has put measures in place
to ensure compliance, restore fairness and to ensure this kind of failure
does not recur in the future.

*See Point 3. and Point 4.*

7. ...to show what measures the authority has taken to reimburse those
people who have been adversely affected re: DHP i.e. details of all action
taken to restore each affected person to the position they would have been
in, had the correct awards been made.

*See Point 3. and Point 4.*

8. ...to show the figure for the total amount of DHP benefit unfairly
withheld from qualifying claimants who would have received payments in DHP
benefit had their applications been correctly and fairly assessed in
accordance with the law.

*See Point 3. and Point 4.*

9. … Please also provide the full, unredacted outcome of all internal and
external audits taken within the above time period.

*Please note…

Under the Section 31 exemption, you appear to have made an error when listing the "Factors in favour of disclosure". If I read it correctly, there is just one factor in favour of disclosure and three factors against disclosure, however these are all listed together wrongly under the "Factors in favour of disclosure" heading. Please confirm and restate these.*

Due to the extremely poor response to this initial request, I believe there is a strong indication of an attempt to conceal wrongdoing. I am therefore appealing your response to Point 9 on these grounds under the public interest test.

I believe your reliance upon a Section 31 exemption is weakened by a failure to be clear and comprehensive in your response. I would therefore request your public confirmation that appropriate moves towards accountability and an investigation into potential wrongdoing are either planned or underway.

Finally, despite a clear subsequent request, you have failed to acknowledge the reference to:

MAGYAR HELSINKI BIZOTTSÁG v. HUNGARY
(Application no. 18030/11)
http://echrblog.blogspot.co.uk/2016/11/m...
Please do so in your response to internal review,

Yours sincerely,

Paul Cardin

Paul Cardin left an annotation ()

Link to leaked internal email.

Shows Wirral Council Monitoring Officer's acceptance that the council's treatment of DHP applications had been unlawful for 18 months following the Hardy V Sandwell case:

https://wirralinittogether.files.wordpre...

InfoMgr, FinDMT, Wirral Metropolitan Borough Council

1 Attachment

Dear Mr Cardin

 

I write further to your request for Internal Review dated 4 April 2017.

 

Please accept my apologies for the delay in replying, it is taking longer
than expected to prepare a comprehensive response to all of the points
raised in your email. The Council requires a further 10 working days in
order to address all of your concerns thoroughly and to finalise its
position before responding.

 

I would anticipate the Internal Review being completed by Friday 19 May
2017.  Your understanding and patience in this matter is appreciated.

 

Yours sincerely

 

 

 

Lynette Paterson

Senior Information Management Officer

Business Services - Digital

 

Treasury Building

Cleveland Street
Birkenhead
Wirral
CH41 6BL

[1]Tel: 0151 691 8201

[2][Wirral Borough Council request email]

 

 

[3]LGC Awards15_Winner_MIP

 

 

This information supplied to you is copyrighted and continues to be
protected by the Copyright, Designs and Patents Act 1988.   You are free
to use it for your own purposes, including any non commercial research you
are doing and for the purposes of news reporting. Any other reuse, for
example commercial publication, would require our specific permission, may
involve licensing and the application of a charge

 

 

 

 

show quoted sections

References

Visible links
1. file:///tmp/Tel:0151
2. mailto:[Wirral Borough Council request email]

Dear Wirral Council, FAO Surjit Tour, Director of Law,

After attempting to fob me off, and failing to correctly address several valid points I made initially, you have only succeeded in creating a large burden of extra work for your hard-pressed staff.

This foreseeable and avoidable burden created the need for you to then request an extra 10 days in which to deal with the points you'd left unanswered. You have failed to deal with the self-inflicted additional work and it is time to politely and courteously inform you that I will be approaching the Information Commissioner today to report this failure, and to inform them that your organisation was in breach of statutory law for an 18 month period, during which it would be entirely plausible to assume that vulnerable people and their families will have been targeted for detrimental treatment or even evicted from their homes,

Yours sincerely,

Paul Cardin

Paul Cardin left an annotation ()

Following Wirral Council's latest failure and its inability to respond, this serious case will be appealed to the ICO.

Here's the latest update to the Wirral In It Together blog:

https://wirralinittogether.blog/2017/05/...

Corrin, Jane, Wirral Metropolitan Borough Council

Dear Mr. Cardin,

This response is in reply to the complaint you have made to the ICO, in
relation to your request for an Internal Review ref FOI1127411.  I have
copied your specific questions below and have answered each in turn.

 

[Please provide information...]

 

1.  ...to show the date WBC amended the appropriate policies and
procedures to ensure compliance with Hardy V Sandwell case law re: DHP
(March 2015).

Answer -  The DHP Policy review was concluded in February 2017 and is
available on our website, this is a policy statement and not specifically
in relation to disability related cases.  Procedures in relation to DHP
were reviewed, revised and issued to Officers in July 2016 including
Customer Services staff and Assessment Officers.  In December 2016 the
procedures were reviewed in line with DWP guidance. All amendments made
have been agreed with the Audit Team.

 

2.  ...to show the date of the last internal and external audit to ensure
compliance with 3.9 of the DWP, DHP Guidance Manual and Local Authority
Good Practice Guide.

Answer - An Internal audit was completed in May 2016 and a recent external
review was conducted by LA Directory Limited on 20^th -23^rd  February
2017.  The report from this review was received 30^th March 2017. An
action plan has been drawn up in accordance with recommendations made and
is currently underway.

 

3.  ...to show what action the authority has taken/is taking to identify
people who have been adversely affected by non-compliant DHP decisions.

Answer - The Council undertook an exercise commencing Tuesday 3^rd
January, inviting 281 previous DHP claimants to contact us to discuss any
disability related expenditure associated with a DHP claim during the
period of April 2015 to September 2016. The 281 claimants were those who
may have been affected and those who responded had a full review for that
application.

 

·         281 invitations to contact were issues

·         126 responded and were taken through the review process

·         22 of the 126 received either a partial or full award based on
evidence or information provided

·         The total cash value of the 22 awards was £10,271.06

 

In relation to new claims received, Assessment Officers have a structured,
consistent approach to all awards and have the required procedures and
work instructions available.  Detailed briefing sessions have also taken
place and mandatory electronic work flow processes are now operational to
support the decision making process and to ensure full audit trails are
available.

 

The Council undertakes quality assurance testing to ensure procedures are
followed and understood and results are fed back to the Head of Service.

The Council continues to review this area and to offer support and
training as required to Officers who may wish to discuss areas of
discretion.

 

4.  ...to show the extent to which claimants were incorrectly assessed,
including total numbers of people affected.

Answer – All DHP claims made between April 2015 and September 2016 were
the claimant/partner or child was in receipt of a disability related
benefit.  The Council wrote to all those who may have been affected, where
there was either a short award period or the full shortfall had not been
met by an earlier award.   The review project was undertaken by dedicated
officers, in addition a dedicated customer phone line/email which was put
in place to ensure the customers could contact an officer directly.   A
reminder exercise was also undertaken to contact those who had failed to
respond to the initial invitation for review. The reminder process
commenced Friday 26^th January giving a further 7 days to make contact. 

 

For those customers who responded, the Council considered their income,
expenses and  their  personal circumstances - for example the ability to
move to suitable alternative accommodation.   The number of cases were the
award was reviewed and a payment made is detailed in point 8

 

5.  ...to show what the authority has done to recognise and acknowledge
its failings/malpractice in order to show that it has learned lessons
since the Martin Morton/DASS whistleblowing re: proven unlawful
charging/unlawful debiting of supported living tenants' bank accounts.

Answer - The Council strives always to improve working practices and put
amended procedures in place across any service area where we believe this
will improve the level of service provided. In respect of DHP, once the
issue/error had been drawn to our attention, we responded fully and
positively so as to correct any inaccurate assessments and to ensure all
future application were assessed accurately and consistently with revised
guidelines. One of the improvements to ensure a full audit trail, was that
with immediate affect ALL cases have a comprehensive and detailed
explanation for the decision made.

 

6.  ...to show the extent to which the authority has put measures in place
to ensure compliance, restore fairness and to ensure this kind of failure
does not recur in the future.

Answer – Actions completed:-

 

·         Devised a review process and managed as a project by dedicated
officers

·         Implemented a dedicated email and telephone number for direct
contact from claimants

·         Implemented increased quality checking volumes during and after
the review until 100% accuracy was consistent – this has been achieved
however the 100% QA continues for the immediate as instructed by Head of
Service

·         Policy, procedures and training documentation and aides
reviewed, amended and strengthened accordingly

·         External audit undertaken for further assurances as detailed in
point 2

·         All Assessment Officers provided with refresher training and
updated guidance including FAQ documents

·         Contact made with neighbouring authorities to establish best
practice and controls (Sefton/Knowsley/Liverpool/St Helens

·         On Line form/hyperlinking directly to guidance currently under
review – in discussions with system provider Capita – new form expected
during June 2017

 

7.  ...to show what measures the authority has taken to reimburse those
people who have been adversely affected re: DHP i.e. details of all action
taken to restore each affected person to the position they would have been
in, had the correct awards been made.

Answer - Claimants whose DHP awards were reviewed (details provided below)
were considered for retrospective awards.  Any award  paid was paid
directly to the claimant unless they requested the payment  be paid to
their Landlord. The figures have been provided in point 8 below.

 

8.  ...to show the figure for the total amount of DHP benefit unfairly
withheld from qualifying claimants who would have received payments in DHP
benefit had their applications been correctly and fairly assessed in
accordance with the law.

Answer -  

 

·         281 invitations to contact were issues

·         126 responded and were taken through the review process

·         22 of the 126 received either a partial or full award based on
evidence or information provided

·         The total cash value of the 22 awards was £10,271.06

 

9.  …  Please also provide the full, unredacted outcome of all internal
and external audits taken within the above time period.

Answer - The Internal reviewer upholds the original response from the
Council which is detailed below:

 

I consider that the information you have requested is exempt information 
under Section 31(1)(g)  of the Freedom of Information Act 2000 (“FOIA”)
in  that its disclosure would prejudice the exercise by the Council  of
its  functions for any of the purposes specified in subsection (2). The 
relevant purposes are ascertaining whether any person has failed to
comply  with the law and whether any person is responsible for any conduct
which  is improper (Section 31 (2)(a) and (b) of FOIA.)

 

I have had regard to the guidance issued by the ICO -  “Law enforcement
(section 31), 20130529,  Version:1.0.”  The function in this case is the
administration of discretionary housing payment.   As previously
mentioned, Paragraph 14 of the  guidance states that “Section 31 is
subject to a test of prejudice".  This test means that information can
only be withheld if its disclosure would, or  would be likely to,
prejudice one of the activities listed in either  subsection 31 (1) or
(2).   

The Council considered this and was of the belief that disclosure of the
requested  information would prejudice the relevant purposes of
ascertaining whether  any person has failed to comply with the law and
whether any person is  responsible for any conduct which is improper.  I
uphold this belief and also consider that prejudice would occur if the
requested  information was disclosed to you, as a member of the public.

 

Paragraph 99 of the guidance states that “Many of the activities protected
by section 31  will involve the relevant public authority conducting
investigations."  In addition para 101 states “Investigators need private
thinking space, or  safe space, if they are going to fully explore all
aspects of a case  without fear that their half-formed opinions would be
reported in the  press or enter the public domain. Such concerns would
hinder the efficient  running of an investigation. Investigators may
expect their findings to be  made public but at a later stage when they
represent the fully considered  conclusions of the investigation”

 

I uphold the original decision that providing you with the full unredacted
outcome of all internal and external audits would prejudice the purposes
referred to above.

 

Section 31 is subject to the public interest test and the factors relied
on are detailed below.

 

The Factor in favour of disclosure is - Disclosing information increases
transparency about how  public authorities perform their function

 

Factors in favour of maintaining  the exemption are: -

1.            Protecting the ability of the Council to carry out 
investigations and to enforce the law

2.            The effect of premature disclosure of information to a 
member of the public when such investigations are being carried out

3.            Undermining future investigations if it is known that 
information will be disclosed to the public, before all relevant
investigations are completed

 

As stated in our previous reply - The Council considers that the
information that has already been supplied to you in connection with your
earlier queries can be construed as satisfying the public interest.  

 

You have the right to complain to the Information Commissioner if you are
dissatisfied with this Internal review. 
[1]https://ico.org.uk/global/contact-us/

 

Finally, despite a clear subsequent request, you have failed to
acknowledge the reference to:  MAGYAR HELSINKI BIZOTTSÁG v. HUNGARY 
(Application no. 18030/11)  [2]http://echrblog.blogspot.co.uk/2016/11/m...

Answer - I have raised this with the ICO and have sought advice from
them.  Their verbal response is that the Council does not have to take
MAGYAR HELSINKI BIZOTTSÁG v. HUNGARY  (Application no. 18030/11) into
consideration when answering your enquiry.  The ICO is happy to discuss
this in more detail with you if you wish to contact them.

 

Yours sincerely

Jane Corrin

Records and Information Manager

Business Services - Digital

 

The information supplied to you is copyrighted and continues to be 
protected by the Copyright, Designs and Patents Act 1988.   You are free 
to use it for your own purposes, including any non commercial research
you  are doing and for the purposes of news reporting. Any other reuse,
for  example commercial publication, would require our specific
permission, may  involve licensing and the application of a charge

 

 

 

 

 

 

 

 

 

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References

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1. https://ico.org.uk/global/contact-us/
2. http://echrblog.blogspot.co.uk/2016/11/m

Dear Corrin, Jane,

As there was no apology forthcoming, I assume you were not aware that your response is way overdue.

I have therefore already referred this case to the ICO,

Yours sincerely,

Paul Cardin

Corrin, Jane, Wirral Metropolitan Borough Council

Dear Mr. Cardin,
Thank you for your email below. I copied my response to the ICO and advised you that my reply was to the ICO complaint you had raised, in relation to your Internal Review.
The ICO had asked us to respond to you by 3 July 2017, so my response was therefore well within this timeframe. However, you are correct that the Council did not respond to your Internal Review in a timely fashion and I apologise for any inconvenience this has caused you.
Yours sincerely

Jane Corrin
Records and Information Manager
Business Services - Digital
0151 691 8645

Wirral Council
[email address]

Visit our website: www.wirral.gov.uk
from: Paul Cardin [mailto:[FOI #389024 email]]
Sent: 15 June 2017 18:41
To: Corrin, Jane
Subject: Re: ICO Complaint FS50684466 (Internal review FOI 1127411) - Paul Cardin - Discretionary Housing Payments

Dear Corrin, Jane,
As there was no apology forthcoming, I assume you were not aware that your response is way overdue.
I have therefore already referred this case to the ICO,
Yours sincerely,
Paul Cardin

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