Data Protection complaints to the ICO about the Land Registry and outcomes /last five years

The request was successful.

Dear Information Commissioner’s Office,
Request Title/summary within scope.



I am writing to make an open government request for all the 
information to which I am entitled under the Freedom of Information 
Act 2000.

Please send me original recorded information, which includes information held on computers, in emails and in printed or handwritten documents as well as images, video and audio recordings.

If this request is too wide or unclear, and you require a 
clarification, I would be grateful if you could contact me as I 
understand that under the Act, you are required, as a duty,  to advise and assist requesters.(Section 16 / Regulation 9).

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If my request is denied in whole or in part, I ask that you justify 
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I will also expect you to release all non-exempt material. I reserve 
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charge excessive fees.

If any of this information is already in the public domain, please 
can you direct me to it, with page references and URLs if 
necessary.

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copies of the confidentiality agreement and remind you that 
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agreement has not been signed.

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The information should be immediately readable - and, as a freedom of Information request,  not put in a PDF or any closed form, which some readers may not be able to access.



I understand that you are required to respond to my request within 
the 20 working days after you receive this letter. I would be 
grateful if you could confirm in writing that you have received 
this request.

::::::::

Please consider  the ICO's Decision on the provision original documents on file....rather than newly written letters of response,which did not exist at the time of request.

https://ico.org.uk/media/action-weve-tak...

50. However, if the requester expresses a preference to inspect the original documents (or copies of those documents) then we would expect the authority to provide them with a reasonable opportunity to view the originals (or copies), where practicable. 

https://ico.org.uk/media/for-organisatio...

Nb This request does not require a letter, drafted by the External Affairs department, or any other written input by reputational defence employees - and purporting to be the response to a FOIA request.

::


Please note: 
Section 77 FOIA 

77.—(1) Where—
(a) a request for information has been made to a public
authority, and
(b) under section 1 of this Act or section 7 of the Data Protection Act 1998, the applicant would have been entitled (subject to payment of any fee) to communication of any information in accordance with that section,
any person to whom this subsection applies is guilty of an offence if he alters, defaces, blocks, erases, destroys or conceals any record held by the public authority, with the intention of preventing the disclosure by that authority of all, or any part, of the information to the communication of which the applicant would have been entitled.
(2) Subsection (1) applies to the public authority and to any person who is employed by, is an officer of, or is subject to the direction of, the public authority. 

::::

The request:

Time period - The last five years.

I would like to read:

1. The number of DPA complaints about the Land Registry made to the ICO.
2. The dates of these complaints
3. Whether or not the complaints were investigated.
4. The reasoning for acceptance, or refusal
5. Correspondence between the ICO and Land Registry ( redacted) on these complaints, including any warnings and subsequent information which may not have been divulged to complainant.(redacted)
6 The outcome of complaints accepted
7. The closing dates of complaints cases.
8 Any follow ups the ICO undertook after breaches.
9. If the Land Registry has been placed on the 'watch list' after breaches.

Yours faithfully,

Jt Oakley

AccessICOinformation, Information Commissioner’s Office

Thank you for contacting the Information Commissioner’s Office. We confirm
that we have received your correspondence.

 

If you have made a request for information held by the ICO we will contact
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more information please visit [1]http://ico.org.uk/about_us/how_we_comply

 

If you have raised a new information rights concern - we aim to send you
an initial response and case reference number within 30 days.

 

If you are concerned about the way an organisation is handling your
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The Information Commissioner’s Office

 

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Information Commissioner’s Office

6 April 2017

 

Case Reference Number IRQ0675742

 

Dear J Oakley

Request for Information
 
Thank you for your email which we received on 3 April, in which you have
made a request for information held by the Information Commissioner's
Office (ICO). 
 
Your request has been passed to the ICO’s Information Access Team, and is
being dealt with in accordance with the Freedom of Information Act 2000
under the reference number shown above. 
 
We will therefore respond to your request promptly, and no later than 4
May which is 20 working days from the day after we received your request.
 
Should you wish to reply to this email please be careful not to amend the
information in the ‘subject’ field. This will ensure that your reply is
added directly to your case.
 
Yours sincerely
 
 
 
 

Danny Langley
Lead Information Access Officer
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire SK9 5AF
T. 01625 545784  F. 01625 524510  [1]ico.org.uk  [2]twitter.com/iconews
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Information Commissioner’s Office

2 Attachments

2 May 2017

 

Case Reference Number IRQ0675742

 

Dear J Oakley

 

Request for Information
 
Further to our acknowledgement of 6 April we can now respond to your
request for information of 3 April.
 
We have dealt with your request in accordance with your ‘right to know’
under section 1(1) of the Freedom of Information Act 2000 (FOIA).
 
Request
 
In your message, sent through whatdotheyknow.com, you asked:
 
“Time period - The last five years. I would like to read:
 
1. The number of DPA complaints about the Land Registry made to the ICO.
2. The dates of these complaints
3. Whether or not the complaints were investigated.
4. The reasoning for acceptance, or refusal
5. Correspondence between the ICO and Land Registry ( redacted) on these
complaints, including any warnings and subsequent information which may
not have been divulged to complainant.(redacted)
6 The outcome of complaints accepted
7. The closing dates of complaints cases.
8 Any follow ups the ICO undertook after breaches.
9. If the Land Registry has been placed on the 'watch list' after
breaches.”
 
Our response
 
Information within the scope of your request predating April 2014 is not
held as we have not retained complete casework records relating to DPA
complaints from beyond that date. For the period April 2014 to the date
you made your request our answers are therefore:
 
1. Fifteen
2, 6, 7. Please find below a table with the date each of the fifteen cases
referred to above were created, completed, and with a description for the
outcome of each case. I have attached a note explaining each case outcome
description in more detail.
 
 

+-----------------------------------------------------------------------+
|Case |Date created |Date reported |Case outcome |
|------+-----------------+----------------+-----------------------------|
|539247|25 April 2014 |3 June 2014 |No action for DC |
|------+-----------------+----------------+-----------------------------|
|545190|19 June 2014 |13 March 2015 |DC action required |
|------+-----------------+----------------+-----------------------------|
|568583|22 January 2015 |25 February 2015|No action for DC |
|------+-----------------+----------------+-----------------------------|
|572059|20 February 2015 |12 March 2015 |Not DPA |
|------+-----------------+----------------+-----------------------------|
|578748|16 April 2015 |8 May 2015 |Not DPA |
|------+-----------------+----------------+-----------------------------|
|579381|21 April 2015 |23 July 2015 |No action for DC |
|------+-----------------+----------------+-----------------------------|
|582329|15 May 2015 |21 July 2015 |Compliance advice given to DC|
|------+-----------------+----------------+-----------------------------|
|602164|21 October 2015 |21 January 2016 |General advice given to DC |
|------+-----------------+----------------+-----------------------------|
|602883|27 October 2015 |17 December 2015|Not DPA |
|------+-----------------+----------------+-----------------------------|
|613695|25 January 2016 |11 April 2016 |General advice given to DC |
|------+-----------------+----------------+-----------------------------|
|617037|17 February 2016 |20 June 2016 |Compliance advice given to DC|
|------+-----------------+----------------+-----------------------------|
|638627|20 July 2016 |29 July 2016 |DC action required |
|------+-----------------+----------------+-----------------------------|
|645969|12 September 2016|25 November 2016|No action for DC |
|------+-----------------+----------------+-----------------------------|
|647651|23 September 2016|5 November 2016 |Not DPA |
|------+-----------------+----------------+-----------------------------|
|652343|25 October 2016 |2 December 2016 |No action for DC |
+-----------------------------------------------------------------------+

 
3. In such cases our investigation will involve the case officer
contacting the data controller to explain that we have received a data
protection concern and to ask them to revisit the case. Whether this
happens or not is information not specifically recorded in our casework
management system, however it is possible to do a manual search of the
cases listed above and see in how many cases we made such enquiries of
Land Registry. I can confirm we made such enquiries in five of the above
cases. Sometimes it is not necessary to further investigate, if for
example it is evident from the information provided by the complainant as
to whether compliance with the DPA is likely.
 
4. In each case the reason for ‘accepting’ a data protection concern is
that the information provided suggests a breach of the Data Protection Act
1998 (DPA) may have taken place. The reasoning for not pursuing a concern
further is when no evidence of a breach of the DPA has been provided.
 
5. We take the view that when an individual raises a data protection
concern with the ICO they do not expect details to be subsequently
released into the public domain. We consider correspondence held on such
cases to relate to a specific concern about an individual’s data rights,
and so constituting the personal data of the complainant. For this reason
the core of the correspondence within the scope of this part of your
request is being withheld pursuant to sections 40(2) and 44 of the FOIA.
We have attached a PDF containing the information falling within this part
of your request which we are able to disclose.
 
8. Please note that any further follow up enforcement work is published on
our website at: https://ico.org.uk/action-weve-taken/enf....
 
9. I can confirm we do not hold a data protection ‘watch list’ in this
context. We use the information gathered from the DPA concerns reported to
us to help us identify any trends in an organisations compliance with the
DPA. This, along with information from other sources, is monitored to help
us detect areas in which we can improve compliance with the DPA.
 
FOIA Section 40 (2)
 
Some of the information in the scope of your request which we are
withholding is the personal information of third parties. Section 40(2) of
FOIA allows a public authority to withhold information from a response to
a request under the FOIA when the information requested is personal data
relating to someone other than the requestor, and its disclosure would
contravene one of the Data Protection principles.
 
We consider that when individuals make complaints to the ICO they do not
anticipate or expect the details of their complaints, or specific any
actions taken by the data controller concerned or the Information
Commissioner in connection with their complaints, to be disclosed to the
wider world. Therefore, we consider that such a disclosure would be unfair
and in breach of the first Data Protection principle which states that –
“Personal data shall be processed fairly and lawfully …”
 
FOIA Section 44

Some of the information has also been withheld pursuant to FOIA section
44. This is information which was provided to us by the Land Registry
solely for investigation of the relevant data protection concerns and was
provided ‘in confidence’ for the purposes of our investigations. It is
therefore being withheld by the ICO under the provisions of section 44 of
the Act which places prohibitions on disclosure. 
 
Section 44(1)(a) of the FOIA states;
 
‘(1) Information is exempt information if its disclosure (otherwise than
under this Act) by the public authority holding it -
(a) is prohibited by or under any enactment’
 
The enactment in question is the DPA and specifically section 59 of that
Act. This states that neither the Commissioner nor her staff shall
disclose;
 
“any information which:
 
a.     has been obtained by, or furnished to, the Commissioner under or
for the purposes of the information Acts.
b.     relates to an identified or identifiable individual or business,
and
c.      is not at the time of disclosure, and has not been available to
the public from other sources, unless the disclosure is made with lawful
authority.”
 
This prevents us from disclosing the information which has been collected
in the course of our investigations unless we have lawful authority to do
so. We do not have lawful authority on the basis that this information was
provided to us 'in confidence'.
 
Review Procedure
 
I hope this provides you with some useful information. However, if you are
dissatisfied with this response and wish to request a review of our
decision or make a complaint about how your request has been handled you
should write to the Information Access Team at the address below or e-mail
[1][ICO request email].
 
Your request for internal review should be submitted to us within 40
working days of receipt by you of this response. Any such request received
after this time will only be considered at the discretion of the
Commissioner.
 
If having exhausted the review process you are not content that your
request or review has been dealt with correctly, you have a further right
of appeal to this office in our capacity as the statutory complaint
handler under the legislation. To make such an application, please write
to our Customer Contact Team at the address given or visit our website if
you wish to make a complaint under the Freedom of Information Act.
 
A copy of our review procedure can be accessed from our website.
[2]here.
 
Yours sincerely
 
 

Danny Langley
Lead Information Access Officer
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire SK9 5AF
T. 01625 545784  F. 01625 524510  [3]ico.org.uk  [4]twitter.com/iconews
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Jt Oakley left an annotation ()

Seemingly the Land Registry has broken the DPA on several occasions ( four times for me)

Yet nothing really seems to be done. Because it happily continues to do so.

Safe in the knowledge that the ICO will not chase consistent breaches the of the law.

Diana Smith left an annotation ()

Hi JT Oakley,
my DPA(SAR) was lodged in March 2009 after two years of evasion by Land Registry to questions lodged under the FOIA.
Gill Miles as their then Information Officer resigned her post while not providing me with the information she stated in writing to me she would comply with within the timeframe of the DPA.
I lobbied the ICO from July 2009 until they finally came on board in November 2010.
The written advice of the ICO was to put in my DPA(SAR) again to Land Regiatry and to word it exactly as l had with my first request.
This would more than suggest l had worded it correctly.
Land Registry continued to ignore my requests up until my attending their offices for a pre -booked appointment , where they summoned Humberside Police on a 999 call to have me and a fully trained CAB Generalist and my other helper ( a man of 86 years old) removed on the 1st February 2011.
The later findings of the ICO were that the Land Registry had breached the DPA as of the 21 st January 2011.
In other words they were in breach when they had me removed.
The removal was a personal attack on me as a disabled person with limited mobility and the twelve staff laughed their socks off while we were escorted out.
The person who had made the 999 call was already on record for her conduct to me for my DPA(SAR) and her previous conduct acting outside of the remits of Land Registry by her telephoning my acting solicitors to arrange non-disclosure of the very paperless documents that was the sole basis for theft of my already confirmed and recorded to be registered land..
Also this person published defamation about me to other Land Registry Staff regarding personal information contained within a statement l had been directed to make in October 2007 to the Kingston upon Hull Office.
This " customer services manager " stated in communications that " she owed God one" for the Direct Lightning Strike to my home that terrified me and my 75 year old mother when it split the house at 1 am in the morning.
When the information for my DPA(SAR) was sent on the 26 th September 2011 with the usually offered Internal Review by Gurmale Sondh , l replied quickly on the 9 th October 2011 requesting such.
It never came .
Now Gurmale Sondh having offered me Internal Review recently is again typically denying me it.
I view Land Registry as completely out of control and complete liars when it comes to fronting it out with the ICO.
Land Registry lied in 2009 to The Home Office stating the land was unregistered when their own forms record it as my registered title.
In the real world producing the original documented evidence would be all that was needed, but this is not the real world and Land Registry except totally paperless claims without any lodged fee being paid , which in my book makes a complete mockery of the whole registration process.
Heads should roll for their bad behaviour and a panel needs setting up to completely overhaul how the ICO perceives they can continue to twin their behaviour along the realms of fantasy of refusing to view obvious criminal behaviour in highly profitable property / land thefts,

Diana Smith.

Jt Oakley left an annotation ()

Duane Smith.

I agree. It's extraordinary given its record, that the Land Registry continues to get away with it.
The insult that you read about yourself in record is appalling - and the following treatment extremely substandard for any Public Authority,

From my point of view, being told that the LR was 'not subject to Foia' ......to having my personal information - and that of others- put in the internet.

So I can verify what you say -It has a cavalier and dismissive attitude to the public.

In addition, the relationship with the ICO is extremely suspect.

Four DPA breaches of my information alone and nothing done?
It appears that the last two breaches were never investigated.

When it wasn't busily trawling for gossip stared as 'digging' about me in the internet,( from DPA internal documents) the LR employees were misinforming the ICO about data on my personal files. Which is even more infuriating.

:::

However, before I made the request I knew the requested information existed.
And that it should be available under FOIA.

The Land Registry stated categorically it didn't exist.

:::

The most incredible thing was, due to the complaint time lag, ( it took ages to investigate as the caseworker didn't seem to entirely grasp the complex Land Registry procedures * ) my complaint to the ICO was described as frivolous -vexatious...By the same ICO caseworker

*Apart from telling me about her ill health problems - at length - and her complaint that the ICO had not given her the ability of sending me anything from her home.

But mindbendingly, her wrongful accusation about me was made AFTER the Land Registry had finally produced the requested data to me - in a private email. How could be 'frivolous' if I was proved right?

I've asked the ICO - but received no explanation.

So no apology from the ICO, of course.... Even though I produced incontrovertible proof - by sending the email of my requested LR data.

So now I'm banned from writing to the Land Registry on an entirely false premise ....and a wrongful piece of information.

:::

On this issue alone, - and there are many - the Land Registry said 'jump'... and the ICO not only jumped in its favour- on no evidence - but decided that I was to blame ......for evidencing the fact that the ICO that the Land Registry had made a completely false statement.

Shocking really! And, on this basis, I believe every accusation you have made above.

Diana Smith left an annotation ()

Hi JT Oakley ,
after eighteen court hearings where l was denied the information of my stolen conveyance document or Land Registry Office copy of it for my DPA(SAR) , at the nineteenth hearing on the 3 rd February 2012 , l got the result l needed.
However Land Registry are ignoring HH Justice Peter Smith stating in his decision that if a miscarriage of justice has occurred then it must be put right.
Legal Advice and Police Advice is NO ONE HAD THE RIGHT TO HAVE MY CONVEYANCE DOCUMENT and this is certainly the miscarriage of justice the Judge refers to.
I caught Land Registry's Corporate Lawyer red- handed with my stolen conveyance document and even through Lincolnshire Economic Crime Unit said they must return it , this lawyer refused.
This Land Registry Lawyer provided a certified copy of the document and gave his word and legal advice that the judge at Grimsby Courts would accept it as if it was the original document itself.
Then he failed to come forward when the Judge at Grimsby Court refused to consider the certified copy.

CEO Mr Newbold (Account suspended) left an annotation ()

JT Oakley, If as you say you have been banned from writing to Land Registry have they given you a referral to a different person who will deal with this matter?

Jt Oakley left an annotation ()

I cannot make any FOIA requests. Because, according to the ICO, I made a 'frivolous' complaint.
The fact that the ICO put my personal information on WDTK FOUR times doesn't count.
The fact that the frivolity if asking why the Land Registry denied the information that I later obtained and added to the WDTK request didn't count.

The data didn't exist ...and therefore I was frivolous to complain about its existence...even when I had sent it to the ICO!

It is the worst ICO decision that I've ever seen.

If you complain, and the person you are complaining about is part of a certain team, the supervisor of the team automatically backs the person up..... even though they are CLEARLY and patently illogically in the wrong.

.....

It was the same situation in the PHSO ...until I got the complaint out to an independent advisor, who came down on my side.

The PHSO has now ditched the people who knew anything about the complaint subjects, the external advisors, so I would presume it would go back to the supervisor.

And supervisors clearly won't admit their staff are botching stuff up badly...because it reflects on their OWN management.

You have no proof of what's said in phone calls... as phone calls to both the PHSO and ICO are not recorded.

So if it's your word against theirs- it's Always theirs which is believed.

However, the old trick of the supervisor saying ' I was in the next desk and I heard everything' is alive and well at the ICO.
So your complaint is never upheld if it's about a phone incident.

Knowing what I know, having been through this corrupt system ( and won thee times, once with the Welsh Ombudsnan, once with the external advisor and once in court vs ICO protecting the PHSO ) I'd say -don't bother. The ICO is so supportive if Public Authorities it's not worth complaining because they are almost always believed,
Even when there are consustent complaints about Authorities nothing hapoens because the ICO prefers to chase commercial companies, which it can fine. It can't find Public Authorities and there is very little point of saying Tut
to them.

And don't expect any improvement via the Ombudsman. I found that even with an upheld Decision, The NHS just ignored it.

Advice...Get yourself to a lawyer if you can.

Jt Oakley left an annotation ()

If you disbelieve me..here's the proof.

LR process was requested .
I knew it existed so knew what to ask for- Land Registry wouldn't give it to me
I complained to ICO ..which did nothing just agred with Land Registry.
The Land Registry then sent me the data -the process - which I put it on the WDTK request for other people to read

Then the ICO and stated that MY complaint that the Land Registry was frivolous..vexatious for insisting the data ( now on WDTK) existed.

You really couldn't make it up!

https://www.whatdotheyknow.com/request/l...

CEO Mr Newbold (Account suspended) left an annotation ()

JT Oakley; Are you aware that it is a legal requirement for them to provide a steer to someone else that can deal with your complaint?

Jt Oakley left an annotation ()

No.. please provide.

Because even if you write to the ICO, fairly explaining what went wrong, you don't get a response ....other than one from the supervisor of the person who botched up. If there's a way round that I'd like to know it.

Diana Smith left an annotation ()

Dear J T Oakley,
I hold record from Helen Grant as the then under secretary of state for Justice stating how understanding the judiciary are if a document has not been available for a hearing and how reasonable they are about allowing appeals in such cases .
Record reveals after many years of my efforts including involving two judges in 2002/ 2003 over errors of my information and that of my registered title, no correction was made.
So after some twelve years of such negligence , once again in February 2007 , l had cause to contact Land Registry again.
Whereupon l was lied to that the errors would be corrected .
A PROPERTY AND FIFTY ACRES OF LAND WAS REMOVED FROM MY TITLE THE VERY NEXT DAY.
When investigated Land Registry relied on a Statute that was not in place for the date they relied on it for.
Land Registry later said they knew it was coming in.
The Advertising Standards Authority provided their adjudicator ruling of the 30 th May 2007, where Land Registry stated that NO ONE can claim registered land by adverse land possession.
So ignoring that twelve years had not passed and the fact Land Registry had confirmed their holding of copy of the paperwork for the land being already registered to me, and their own declaration on the ASA ruling, goal posts were insanely moved .
My neighbours solicitors made contact with Land Registry in May 2007 , two months after l had recieved confirmation of it being my registered land.
A FIRST REGISTRATION FORM was filed for my neighbours claim to my already registered land on the 26 th July 2007, exactly a day after the second adjudication of the ASA against Land Registry, where the ASA stated LAND REGISTRY HAD MISLED THE UK PUBLIC OVER OVER-RIDING INTERESTS.
Gurmale Sondh as information officer for Land Registry has admitted over 6,500 cases were referred by Land Registry for judicial involvement without the crucial information of this ruling.
Gurmale Sondh then blocked my request made to The Land Registry Rules Committee , that was for the statistics / numbers of members of the public that had received misleading literature from The Adjudicator to HM Land Registry.
I already have confirmation from Kevin Sadler of the AHMLR dated late October 2009 that the information was misleading information and mirrored the same wrong information on their website for the same period.
So cases passed by Land Registry without the much needed information , were then subject to even more misleading literature on their arrival wIth the procedures of the AHMLR?
Worse still the correct AHMLR literature was published in February 2009 but was not the literature handed out to members of the public.
During the months between February 2009 - October 2009 , TWENTY- TWO CASES that Land Registry had passed to the AHMLR were investigated by The Independent Complaints Review as to why these cases had been referred in the first place.
My case for this window was told to me by the ICR in March 2009 to take up with the PHSO who were over the AHMLR for complaints against them.
The PHSO when alerted by me through my elected MP that the upcoming case before the AHMLR was related to the previous issues l had had and were once again with Land Registry and Legal Service Commissions involvement , was ignored and a commissioner with LSC who had a perceived conflict of interest , was allowed to sit as a deputy adjudicator in breach of his oath as a barrister.
This commissioner / adjudicator / barrister , then ignored a written request by the other sides solicitors for the issuing of a certificate to enable them billing direct solicitors who had timed me out.
This was for £21,400.00p that l was not deemed liable to pay.
Then this commissioner / adjudicator / barrister , ignored the directions of his chief adjudicator , in refusing my appeal that my then acting solicitor had recieved an extension in order to present.
I was then chastised in writing by this chief adjudicator becaquse he thought l just could not be bothered to put in to appeal.
And the appeal was all because of the existence of the actual owner of the land , that this commissioner / adjudicator / barrister agreed with me in his published decision , was the correct owner of the land , but was thought to have died.
That's right after TWO YEARS of Land Registry and my neighbours attempts to file to allow a claim against already acknowledged registered land , Land Registry failed to request a stay on the decision because of the existence of the owner, which was entirely their responsibility to do.
Neither Land Registry or this commissioner / adjudicator / barrister for the AHMLR would reply to if they had considered the evidence of the existence of the excepted owner of the land .
I sent this information twice as did my then appointed legal advisor .
To prevent me sucessfully approaching the civil courts to this day Land Registry and the First Tier Land Tribunal still do not respond.
The procedure rules do state that Land Registry cannot refer a case for judicial involvement if a known caution is in play.
I had reported the incorrect information held in Kingston upon Hull Land Registry caution register , back in March 2000 and was able to supply the proof of the LSC forms of a legal aid charge for this person worded as if she resided at my home .
Police paperwork had not been correctly filed in October 1999 as if to hide on behalf of the solicitors l was using at the time , which then turned out to be my neighbours solicitors.
The head doctor ( being the doctor who was meant to examine me for the police statement l was making) at my own doctors appears to also have profited property / land for the postcode of the properties / land , with the registered title l purchased and confirmed by Inland Revenue , l had l had paid full stamp duty land tax for.
The level of orcastrations across all UK based agencies makes your head spin....

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