Board minutes and agendas
Dear The Royal Parks,
Please share the agendas and minutes for any board meetings, or of any board sub-committees or related bodies, for the last five years.
Yours faithfully,
Tim Lennon
Dear Mr Lennon,
Thank you for your enquiry by email dated 27 June 2024 under The Freedom
of Information Act (FOIA) 2000.
Your enquiry is being dealt with and The Royal Parks will aim to reply to
your enquiry within 20 working days, commencing from 28 June 2024, the
next working day after receipt.
If you have any questions pertaining to this enquiry or require further
assistance, please do not hesitate to contact me. My contact details are
listed below.
Yours sincerely,
Gavin Gribbon | Records Manager | [1][The Royal Parks request email]
[2]www.royalparks.org.uk | The Old Police House | Hyde Park | London | W2
2UH
Disclaimer
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confidential. It is intended solely for use by the recipient and others
authorized to receive it. If you are not the recipient, you are hereby
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may be unlawful. This email has been scanned for viruses and malware, and
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References
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1. mailto:[The Royal Parks request email]
2. http://bit.ly/YL2eik
Dear Mr Lennon,
We would like, with your agreement, to contact you directly about aspects
of the response we are preparing for this request.
Could you send a direct contact address to the email address below?
Thank you.
Gavin Gribbon | Records Manager | [1][The Royal Parks request email]
[2]www.royalparks.org.uk | The Old Police House | Hyde Park | London | W2
2UH
Disclaimer
The information contained in this communication from the sender is
confidential. It is intended solely for use by the recipient and others
authorized to receive it. If you are not the recipient, you are hereby
notified that any disclosure, copying, distribution or taking action in
relation of the contents of this information is strictly prohibited and
may be unlawful. This email has been scanned for viruses and malware, and
may have been automatically archived by Mimecast Ltd
References
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1. mailto:[The Royal Parks request email]
2. http://bit.ly/YL2eik
Dear Mr Lennon,
Please find attached a covering letter in response to your FOI. Also
attached is a separate letter regarding the specific use of one of the
exemptions we have applied.
The size of the documents has meant that we have had to send them as
separate emails – these will be sent in Parts 2. 3 and 4.
Please also accept our apologies for the slight delay in response.
Gavin Gribbon | Records Manager | [1][The Royal Parks request email]
[2]www.royalparks.org.uk | The Old Police House | Hyde Park | London | W2
2UH
Disclaimer
The information contained in this communication from the sender is
confidential. It is intended solely for use by the recipient and others
authorized to receive it. If you are not the recipient, you are hereby
notified that any disclosure, copying, distribution or taking action in
relation of the contents of this information is strictly prohibited and
may be unlawful. This email has been scanned for viruses and malware, and
may have been automatically archived by Mimecast Ltd
References
Visible links
1. mailto:[The Royal Parks request email]
2. http://bit.ly/YL2eik
Dear Mr Lennon,
Attached is Part 2, featuring the first set of documents.
Gavin Gribbon | Records Manager | [1][The Royal Parks request email]
[2]www.royalparks.org.uk | The Old Police House | Hyde Park | London | W2
2UH
Disclaimer
The information contained in this communication from the sender is
confidential. It is intended solely for use by the recipient and others
authorized to receive it. If you are not the recipient, you are hereby
notified that any disclosure, copying, distribution or taking action in
relation of the contents of this information is strictly prohibited and
may be unlawful. This email has been scanned for viruses and malware, and
may have been automatically archived by Mimecast Ltd
References
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1. mailto:[The Royal Parks request email]
2. http://bit.ly/YL2eik
Gavin Gribbon would like to recall the message, "Your Freedom of
Information request - our ref: 24/43 - Board meetings - Part 3".
Disclaimer
The information contained in this communication from the sender is
confidential. It is intended solely for use by the recipient and others
authorized to receive it. If you are not the recipient, you are hereby
notified that any disclosure, copying, distribution or taking action in
relation of the contents of this information is strictly prohibited and
may be unlawful. This email has been scanned for viruses and malware, and
may have been automatically archived by Mimecast Ltd
Dear Mr Lennon,
Attached is Part 3, featuring the second set of documents.
Gavin Gribbon | Records Manager | [1][The Royal Parks request email]
[2]www.royalparks.org.uk | The Old Police House | Hyde Park | London | W2
2UH
Disclaimer
The information contained in this communication from the sender is
confidential. It is intended solely for use by the recipient and others
authorized to receive it. If you are not the recipient, you are hereby
notified that any disclosure, copying, distribution or taking action in
relation of the contents of this information is strictly prohibited and
may be unlawful. This email has been scanned for viruses and malware, and
may have been automatically archived by Mimecast Ltd
References
Visible links
1. mailto:[The Royal Parks request email]
2. http://bit.ly/YL2eik
Dear Mr Lennon,
Attached is Part 3, featuring the second set of documents.
Gavin Gribbon | Records Manager | [1][The Royal Parks request email]
[2]www.royalparks.org.uk | The Old Police House | Hyde Park | London | W2
2UH
Disclaimer
The information contained in this communication from the sender is
confidential. It is intended solely for use by the recipient and others
authorized to receive it. If you are not the recipient, you are hereby
notified that any disclosure, copying, distribution or taking action in
relation of the contents of this information is strictly prohibited and
may be unlawful. This email has been scanned for viruses and malware, and
may have been automatically archived by Mimecast Ltd
References
Visible links
1. mailto:[The Royal Parks request email]
2. http://bit.ly/YL2eik
Dear Mr Lennon,
Attached is Part 4, featuring the third and fourth sets of documents.
Gavin Gribbon | Records Manager | [1][The Royal Parks request email]
[2]www.royalparks.org.uk | The Old Police House | Hyde Park | London | W2
2UH
Disclaimer
The information contained in this communication from the sender is
confidential. It is intended solely for use by the recipient and others
authorized to receive it. If you are not the recipient, you are hereby
notified that any disclosure, copying, distribution or taking action in
relation of the contents of this information is strictly prohibited and
may be unlawful. This email has been scanned for viruses and malware, and
may have been automatically archived by Mimecast Ltd
References
Visible links
1. mailto:[The Royal Parks request email]
2. http://bit.ly/YL2eik
Dear The Royal Parks,
Thank you for sharing these papers. Unfortunately a number of the documents appear to have entirely blank pages. Could you please review these?
Yours faithfully,
Tim Lennon
Dear Mr Lennon,
We have now checked through the documentation which was provided.
The blank pages appear in the materials as a result of putting documents
through a scanner; the scanner has copied both sides of each page and so
the blank pages are actually blank in the originals.
Regards,
Gavin Gribbon | Records Manager | [1][The Royal Parks request email]
[2]www.royalparks.org.uk | The Old Police House | Hyde Park | London | W2
2UH
Dear The Royal Parks FOI team,
Thank you for your response to my information request ref: FOI 24/43 (https://www.whatdotheyknow.com/request/b...)
I am dissatisfied with the handling of this FOI query, and am writing to formally request you carry out an internal review of its handling.
What follows is an explanation of my concerns. I have highlighted the points that I request are specifically addressed in your review.
Nature of redactions
The redactions you have made appear broad, untargeted, and overreaching.
Whole sections of board minutes are missing in their entirety; either excluded (e.g. of the first 16 pages of “Combined Board Minutes June 2019 June 2024 Redacted Part 1.pdf”, 12 are blank) or manually redacted (e.g. section 4.3.1 to section 8.3 from “Minutes of a Meeting of the Board of Directors held on 12 June 2024” is redacted back-to-back, comprising 6.5 pages of a 9 page document, 70%+ redacted). This style of ‘blanket redaction’ appears throughout all four.pdf files I received from you.
Section headings are redacted alongside their underlying content. An example of this can again be seen between sections 4.3.1 and 8.3 of “Minutes of a Meeting of the Board of Directors held on 12 June 2024”; sections 5, 6, 7 and 8 are missing both content and heading; zero information is provided about 4 out of 8 (50%) scheduled discussion points. This wholesale removal of content does not suggest a targeted approach of ‘redacting only what is strictly necessary’.
The ICO’s guidance for publication of board minutes (https://ico.org.uk/media/for-organisatio..., version 2.1, page 4) states:
“When a meeting or part of a meeting is dealing with sensitive or potentially confidential issues, it is good practice to state this at the meeting. This will ensure that all attendees have the same understanding about whether the meeting or certain parts of it are private”
Your redaction of entire pages/sections would suggest highly sensitive information that would have been sensitive at the time. However, there is no record or acknowledgement of this in the minutes; this suggests retroactive ‘blanket redaction’ of content that was not genuinely sensitive at the time.
Justification given for redactions
You rely on five sections of the FOI act to justify your redactions. These sections cover:
1) Communications with the former Sovereign/current Monarch (“s37”)
2) Personal information relating to internal staff (“s40”)
3) Legal professional privilege (“s42”)
4) Commercial interests (noted in your letter dated 02/08/24 as relating to “a small number of sections” (“s43”)
5) Material which may be considered to prejudice the effective conduct of public affairs (“s36”)
When redacting content, you have not provided notes on which specific section you have relied on. This lack of clarity makes it difficult to understand the reasoning you have applied and whether redaction is in fact justifiable.
Sections 37, 40, 42 and 43 relate to redactions that are inherently limited in ‘raw volume’ of content. They cannot justify your removal of entire pages/sections/headings. I can therefore only conclude that your widespread ‘redact entire sections’ approach has relied exclusively on the application of “s36”.
This raises three specific procedural issues:
1) Your qualified person (Andrew Scattergood, CEO) was present in the meetings being minuted and subsequently redacted; could you review what process was followed to ensure impartiality of his decision-making process (so as to mitigate any conflict of interest between his roles as “speaking in the meetings” and “determining whether s36 was justified”), and how it was documented
2) The ICO has historically taken issue with “s36” being used to enact ‘blanket exemptions’, i.e. the Qualified Person needs specific, justifiable reasons for targeted redaction; could you review the process by which your Qualified Person personally approved every individual redaction (including entire pages, sections, section headings as outlined above), and how it was documented
3) Whilst “s36” covers a broad range of content, the ICO expects public bodies to provide clear explanations and justifications for why it has been used; could you review the process by which it was deemed appropriate to rely on “s36” without providing any accompanying explanation, context or rationale, and how it was documented
I understand that you should respond to this request for Internal Review within 20 working days, as outlined in the Information Commissioner’s guidance:
“The Information Commissioner’s Office recommends that public authorities carry out internal reviews within 20 working days. Under Environmental Information Regulations there is a legal requirement that internal reviews must be carried out as soon as possible and within 40 working days.”
Thank you,
Tim Lennon
Dear Tim,
Thank you for your your request for internal review sent by email dated
24/09/2024.
Your enquiry is being dealt with and The Royal Parks will aim to reply to
your enquiry within 20 working days, commencing from 25/09/2024, the next
working day after receipt.
If you have any questions pertaining to this enquiry or require further
assistance, please do not hesitate to contact us again on this email
address.
Yours sincerely, Amy
The Royal Parks are:
Bushy Park | The Green Park | Greenwich Park | Hyde Park | Kensington
Gardens | The Regent’s Park & Primrose Hill | Richmond Park | St. James’s
Park | plus Brompton Cemetery & Victoria Tower Gardens
The Royal Parks is registered in England and Wales: Company Registration
No: 10016100
Registered Charity No: 1172042. Registered Offices: The Old Police House,
Hyde Park, London, W2 2UH
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