Details of Faithful & Gould contract relating to Princes Parade, Hythe

Dr G J Burrell made this Freedom of Information request to Folkestone & Hythe District Council

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The request was partially successful.

Dear Folkestone & Hythe District Council,
This request is for provision by email of following information relating to the proposed development of Princes Parade, Hythe:
1. Copy of the contract awarded to Faithful & Gould on 20/06/2019 under Purchase Order SD00462, valued at £1,132,309.50.
2. Specification for the work required.
3. Audit trail showing all the authorisations that led to placement of this contract, with names (or posts) of the authorising officers and dates.
4. Details of the Capital budget provision that is currently in place for the proposed development of Princes Parade, to include details of all commitments that have been entered into so far, and which includes cover for the above contract.

Yours faithfully,

Dr G J Burrell

Folkestone & Hythe District Council

Dear Dr G J Burrell,

Ref: LS-009480-CA - FOI - Development of Princes Parade, Hythe

Thank you for your request dated 12 June 2019. This is being processed under the Freedom of Information Act 2000.

We will endeavour to supply the information you have requested promptly and within the requisite 20 working days. If we think that it will take longer, we will contact you.

Please ensure you leave the subject line in any correspondence sent to us in relation to this request to enable us to locate your file. The reference number for your file is shown above in the Subject Line.

Kind regards,

Caroline Archer
Information Officer
Folkestone & Hythe District Council,
Civic Centre, Castle Hill Avenue,
Folkestone, Kent. CT20 2QY.
Tel: 01303 853244

Email: [Folkestone & Hythe District Council request email]
Website: www.folkestone-hythe.gov.uk
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Folkestone & Hythe District Council

2 Attachments

Dear Dr G J Burrell,

Ref: LS-009480-CA - FOI - Development of Princes Parade, Hythe

I am writing in respect of your information access enquiry dated 17 July 2019.This request has been handled under the Freedom of Information Act 2000.

Please find below/attached information in response to your request.
________________________________________

1. Copy of the contract awarded to Faithful & Gould on 20/06/2019 under Purchase Order SD00462, valued at £1,132,309.50.

Please see attached. Some of the elements of this document have been withheld on the following grounds:

s40(2) - Personal Information of a 3rd party:
The Council is withholding the requested information in part, because it considers that the exemption under Section 40(2) of the Freedom of Information Act 2000 applies to it. The withheld data pertains to

-Page 1: client and contractor contact details.
-Clause 3.1: key personnel details.
-Clause 3.4: personnel details.

Section 40(2) provides an exemption for information that is the personal data of an individual other than the requester and where the disclosure of that personal data would be in breach of data protection legislation. Personal data is defined in Article 4(1)(1) of the General Data Protection Regulations (GDPR).

We consider that to release the withheld information would be in breach of GDPR’s Article 5(1)(a), “processed lawfully, fairly and in a transparent manner in relation to the data subject” (‘lawfulness, fairness and transparency’). The withheld data is considered to be the personal data of a third party.

• Lawful basis for processing:
In order for the processing of personal data to be lawful, a data controller must have a lawful basis for processing, as defined by GDPR’s Article 6 (and Article 9 for sensitive personal data).

In respect of the s40(2) exemption, there are two lawful bases that are considered relevant for personal data:

1) Consent of the subject.
2) Legitimate interests in disclosure.

s40 does not permit the use of the ‘legal obligation’ lawful basis unless there is a non-FOI legislative obligation to disclose the requested information. There is no such obligation in this case. Due to this, the Council considers that disclosure must be considered under ‘legitimate interest’ in the absence of consent from the subject.

• Balance of Legitimate Interests in disclosure:
In considering a legitimate interest as a lawful basis for disclosure, the Council must have regard of a range of factors. These include the legitimate interest in disclosure (the purpose), the necessity of disclosure in meeting that purpose, and the balance of those factors against the rights of the subject and any potential harm or distress that could be caused to them.

The Council considers that there is a legitimate interest in scrutinising how the Council operates the contracts it enters into. In contrast, the Council also recognises that most data subjects will have an inherent and strong reasonable expectation of privacy, and that this should only be infringed when there are compelling mitigating circumstances or it is necessary to meet an otherwise legitimate interest.

In this case, the Council’s view is that the provision of the non-exempted elements of the contract enables the broader public to scrutinise it without undue prejudice. The disclosure of named individuals associated with its operation is not a necessary component of this activity. Consequently, the Council considers it appropriate to withhold this data.

s43(2) – Prejudicial to commercial interests
The Council is withholding the requested information in part, because it considers that the exemption under Section 43(2) of the Freedom of Information Act 2000 applies to it. The withheld data pertains to:

-Clause 1.3: fees.
-Clause 2.3: insurance details.
-Appendix 3: pricing schedule.

• Commercial Interests:
The requested document is a contract pertaining to commercial development activities. The Council considers that this document constitutes commercial information of the type encompassed by the exemption. The withheld data examines the specific breakdown of costs and insurance liabilities associated with the contract. This information is particularly commercial, as its disclosure would provide a competitive edge to industry

• 3rd Party Interests:
The Council considers that the above commercial interests are those of both the Council and Faithful+Gould. In applying the exemption contained within s43(2) on behalf of a 3rd party, the Council should not assume their position. The genuinely held stance of any 3rd parties should be established through a direct consultation or in reliance on prior evidence of their position. In this case, a consultation response was provided by F+G setting out the elements of the contract they felt would prejudice their commercial interests.

• Prejudice test:
The Council believes that the disclosure of the withheld elements of data would prejudice the above commercial interests. Disclosure of key pricing information would directly prejudice F+G’s commercial interests by providing their competitors with detailed tendering information. This would undermine their ability to effectively bid on wider contract.

The Council considers that this would also indirectly undermine its own commercial interests. A public authority that routinely damages the commercial interests of its contractors without a compelling reason to do so will face trouble procuring high quality specialists moving forward. This would degrade the Council’s ability to provide the best possible value for money when procuring services.

• Public interest test:
The exemption is subject to the public interest test; the Council has considered the public interest in disclosing the information and the public interest in maintaining the exemption.

In all the circumstances of the case, we consider that the public interest in maintaining the exemption outweighs the public interest in disclosing the information. The disclosure of the total value of the contract and the remaining clauses provide a great deal of information about how the contract functions. This allows the public to effectively scrutinise the work being carried out, without causing commercial damage to any of the involved bodies.

Whilst we recognise that there may be a public interest in this information in this case we consider that the public interest in maintaining the exemption outweighs the public interest in disclosing the information (Section 2(2)(b)).

2. Specification for the work required.

This is contained within the attached document.

3. Audit trail showing all the authorisations that led to placement of this contract, with names (or posts) of the authorising officers and dates.

13/2/19 Cabinet approved report C/18/69 Princes Parade Business Case. Sections 2.16 - 2.24 outlined the procurement strategy for the project.
14/4/19 Call Off Contract with Faithful and Gould signed by A Jarrett, Chief Officer Strategic Projects.
17/419 Purchase Order raised authorised by F Witwit, Project Manager.

4. Details of the Capital budget provision that is currently in place for the proposed development of Princes Parade

Please see attached. The Full Council approved the capital budget of £29.065m for the whole project at its meeting on 20 February 2019 as part of report A/18/19 – Update to the General Fund Medium Term Capital Programme and Budget Monitoring 2018/19 (minute 78 refers).

The capital budget reflects the approved business plan and, therefore, includes the costs associated with this contract. Please note that the profiled expenditure was calculated over a three year period from 2020/21 to 2022/23, but the Council approved the relevant budget as part of the MTCP. The capital spend can be reprofiled without the need for specific Council approval.

________________________________________

Should you require any further information, or if you are not satisfied with our response, please do not hesitate to contact me. You may also request an internal review by writing to the following address:

Freedom of Information Appeals Officer
Compliance & Information Governance
Folkestone & Hythe District Council
Castle Hill Avenue
Folkestone
Kent, CT20 2QY

Alternatively you can use our Customer Comment Form which can be accessed at our website www.folkestone-hythe.gov.uk

In addition, if you are not satisfied with our response you may apply to the Information Commissioner for an independent review at the following address:

The Information Commissioner
Wyncliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
Telephone 0303 123 1113 (local rate) or 01625 545 745 (national rate)
www.ico.org.uk

There is no charge for making an appeal.

Kind regards,

Jamie Naylor
Senior Information Officer
Tel: 01303 853252
Folkestone & Hythe District Council,
Civic Centre, Castle Hill Avenue,
Folkestone, Kent. CT20 2QY.
Email: [Folkestone & Hythe District Council request email]
Website: Home | FOI and Data | Privacy
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Any correspondence with the Council may be subject to disclosure into the public domain, in line with relevant transparency legislation.

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Dear Folkestone & Hythe District Council,

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

I am writing to request an internal review of Folkestone & Hythe District Council's handling of my FOI request 'Details of Faithful & Gould contract relating to Princes Parade, Hythe'.

Ref: LS-009480-CA - FOI - Development of Princes Parade, Hythe
In your response to my FOI request you have failed to provide a large proportion of the information I requested even though much of the omitted information clearly does not fall within your stated exemptions. I therefore ask that you conduct an Internal Review with a view to providing certain of the omitted information as identified below.
This Internal Review request, which now seeks the release of specific, limited information only, is submitted without prejudice to any subsequent challenge regarding some of your claimed exemptions. The specific information being sought should not however be in conflict with the claimed exemptions and so the latter are not being challenged unless the authority withholds the requested information on such grounds.

1. Copy of the contract awarded to Faithful & Gould on 20/06/2019 under Purchase Order SD00462, valued at £1,132,309.50.
The Call-Off contract provided is clearly not the version issued to the Contractor but is an incomplete template derived from the pre-existing Framework Agreement with South Hunsley School and Sixth Form College, and within which this contract now falls. It is therefore an incomplete response and this therefore needs to be rectified.
(a) The Awarded Contracts page on the Kent Business Portal is in the public domain and shows some of the key current information about this contract, namely: Awarded date - 20/06/2019, Start date – 29/04/2019, Review date – 06/06/2022 , End date - 05/12/2022, Estimated value - £1,132,309.50. That data has not been disclosed in your response but should have been, together with other key information.
(b) If a “letter of intent” (or equivalent) was issued to the contractor prior to the execution of the formal contract, please provide a copy since this binds the parties into a contractual arrangement.
(c) The Order Form sets out the ‘call-off’ Services to be supplied since this has been omitted. Please therefore provide a fully completed copy of this (or its equivalent), including all approvals, with dates and all supporting documentation provided by the contractor in defining the Services and their duration; all of which are key parts of the contract.
(d) Para (1.3) of the Call-Off Contract blanks out the Price Payable (with crosses) but in the absence of Appendix 3 (which is said to stipulate the fees and invoice payment schedule) the meaning of that figure cannot be placed in context. By implication it is the same as the Estimated value already published on the Kent Business Portal, which would mean it should not have been redacted. There can be no obvious reason for withholding ALL the information contained in Appendix 3 and its release is therefore requested, subject if necessary to any restrictions regarding personal data as prescribed by the GDPR.

2. Specification for the work required.
You have provided in Appendix 2 a Specification and Scope of Service for the overall project, but have failed to include a specification, or statement, of the Services that had been demanded at the time of my request. I have however requested this in item (c) of section 1 above and assume therefore that this information will be provided under that heading.

3. Audit trail showing all the authorisations that led to placement of this contract, with names (or posts) of the authorising officers and dates.
(a) The information provided is not an audit trail of the authorisations that led to this contract. The authorisations that led to the placement of this contract (of which the Purchase Order and any Waivers would form part) should include supporting documents that stem from prior exchanges with Pagabo and the Contractor in which an offer to sell the Services will have been proposed by the Contractor and then accepted by the council under contract (possibly initially by Letter of Intent). Those documents will therefore have become essential parts of the council’s authorisation process and need to be included in your response.
(b) For avoidance of doubt, the authorisations within the audit trail are expected to include those for the following individual (principally separate) items:
i. The re-assignment of the Framework Agreement to FHDC
ii. Approvals for the Services to be undertaken (as stated in the Order Form, or equivalent)
iii. Authorisation in respect of the irregular nature of this procurements (e.g. capital expenditure on a council development prior to the grant of planning permission)
iv. Approval/Signing of the Letter of Intent (or its equivalent).
v. Approval/Signing of the Contract awarded as a Deed.
Note that some of the above would normally be expected to be authorised by the S151 Officer and/or the Monitoring Officer.

A full history of my FOI request and all correspondence is available on the Internet at this address: https://www.whatdotheyknow.com/request/d...

Yours faithfully,

Dr G J Burrell

Folkestone & Hythe District Council

Dear Dr G J Burrell,
 
I acknowledge receipt of your email of 12 September 2019 expressing
dissatisfaction with our response to your request for information (dated
17 July 2019). The original request was handled under the Freedom of
Information Act 2000. 
 
We will be addressing your concerns by way of an Internal Review.
Folkestone & Hythe District Council's approach to Internal Reviews is
subject to guidance produced by the Information Commissioner's Office in
line with Section 45 of the Freedom of Information Act 2000.
 
The Secretary of State for Constitutional Affairs’ Code of Practice on the
Discharge of Public Authorities’ Functions under Part 1 of the Freedom of
Information Act 2000, issued under Section 45 reads, in part, as follows:
 
“39. The complaints procedure should provide a fair and thorough review of
handling issues and of decisions taken pursuant to the Act, including
decisions taken about where the public interest lies in respect of exempt
information. It should enable a fresh decision to be taken on a
reconsideration of all the factors relevant to the issue…”
 
Consequently, the scope to be considered by a review is whether the
Council’s response on 12 August 2019 breached the Act or was otherwise
incorrect.
 
We anticipate that the internal review will be completed within 20 working
days of your application for review, however there may be mitigating
circumstances under which an extension is required. If this is the case
with your review, we will endeavour to notify you and explain why more
time is needed.
 
Yours sincerely,
 
 
Rachel Neville
Information Officer
Folkestone & Hythe District Council
Civic Centre, Castle Hill Avenue, Folkestone, Kent. CT20 2QY.
Office: 01303 853437
[mobile number]
Email: [1][Folkestone & Hythe District Council request email]
Website: [2]Home | [3]FOI and Data | [4]Privacy
Follow us on [5]Twitter and [6]Facebook
 
 
 
 
      
 
   
[7]www.folkestone-hythe.gov.uk
 
 

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Dear Folkestone & Hythe District Council Information Officer

I write to remind you that I am still awaiting your response to my request for an Internal Review, dated 12 Sept 2019.

In your most recent message you advised that you expected to respond within 20 working days, but you still have not done so after 28 clear days, neither have you suggested any mitigating circumstances for a delay.

Since it is possible that your ongoing delay might be arising from your incorrect application of one or more of the FOI Act Exemptions, it might be helpful for me to point out that you should have interpreted my original request under the Environmental Information Regulations, and that the officers from whom you are seeking disclosure may be attempting to withhold information under a non-applicable FOI Exemption. (As you are aware, Princes Parade is subject, for example, to the environmental emissions methane and carbon dioxide).

I now ask that you now provide within 48 hours the information requested, as was further clarified in my Internal Review request.

Yours faithfully,

Dr G J Burrell

Information Officer Case Management, Folkestone & Hythe District Council

2 Attachments

Dear Dr G J Burrell,

 

I refer to your application dated 12 September 2019 for an internal review
of the council’s decision on your information access request handled under
the Freedom of Information Act 2000.

 

Please accept our sincere apologies for the lengthy delay in this matter
and that on this occasion the way your request was handled fell below the
required standard in this respect.

 

In considering your request I have looked at case impartially and
reconsidered the relevant factors / Public Interest Test. In light of
this, I can confirm that I consider the original handling of the case to
be partially upheld.  I will address each point in sequence and explain my
rationale as follows.

 

1.        Copy of the contract awarded to Faithful & Gould on 20/06/2019
under Purchase Order SD00462, valued at £1,132,309.50.

The Call-Off contract provided is clearly not the version issued to the
Contractor but is an incomplete template derived from the pre-existing
Framework Agreement with South Hunsley School and Sixth Form College, and
within which this contract now falls.  It is therefore an incomplete
response and this therefore needs to be rectified.

 

The provided document is the call off contract issued to the contractor.
This is not an incomplete template; South Hunsley School and Sixth Form
College are referred to within the document due to their status as the
Contracting Authority for the procurement framework in question.

 

Throughout the document, Folkestone & Hythe District Council is correctly
identified as the Client Organisation, and Faithful+Gould Limited as the
contractor. The provided document is a copy of the contract that was
signed by the Council.  

 

(a)   The Awarded Contracts page on the Kent Business Portal is in the
public domain and shows some of the key current information about this
contract, namely: Awarded date - 20/06/2019, Start date – 29/04/2019,
Review date – 06/06/2022 , End date - 05/12/2022, Estimated value -
£1,132,309.50.  That data has not been disclosed in your response but
should have been, together with other key information.

 

The commencement date and end date are defined within the contract itself
(1.2 and 1.4 respectively). The review date is not recorded within the
contract, as this date is not contractually defined. Review periods are
instead a procedural element of the Council’s procurement policies.

 

A review is undertaken a set period prior to the end of a contract. This
is to evaluate whether the contract has satisfactorily concluded, and
whether the works involved will need to be extended or re-tendered. On
this basis I do not consider that any relevant dates have been withheld
from the contract document.  

 

Upon review, I have concluded that the top level pricing figure contained
within 1.3 should not have been redacted. The unredacted figure is the
contract value stated on the Kent Business Portal:  £1,132,309.50.

 

(b)  If a “letter of intent” (or equivalent) was issued to the contractor
prior to the execution of the formal contract, please provide a copy since
this binds the parties into a contractual arrangement.

 

A letter of intent was not utilised for this project and is therefore not
held.

 

(c)  The Order Form sets out the ‘call-off’ Services to be supplied since
this has been omitted. Please therefore provide a fully completed copy of
this (or its equivalent), including all approvals, with dates and all
supporting documentation provided by the contractor in defining the
Services and their duration; all of which are key parts of the contract.

 

The services to be supplied are documented within the Order Form (1.1) and
the works specification / role definitions (appendix 2).

 

(d)  Para (1.3) of the Call-Off Contract blanks out the Price Payable
(with crosses) but in the absence of Appendix 3 (which is said to
stipulate the fees and invoice payment schedule) the meaning of that
figure cannot be placed in context.  By implication it is the same as the
Estimated value already published on the Kent Business Portal, which would
mean it should not have been redacted. There can be no obvious reason for
withholding ALL the information contained in Appendix 3 and its release is
therefore requested, subject if necessary to any restrictions regarding
personal data as prescribed by the GDPR.

 

In respect of 1.3, please see above.

 

Upon reviewing appendix 3, the decision has been made to disclose the bulk
of the document with the exception of the commercially sensitive aspects,
ie the table giving the fee breakdown (page 54) and the construction value
figure in paragraph 24 (page 55).  This commercially sensitive information
has been withheld for the reasons which were set out in the original
response and remain the same.

 

The redacted version removes the figure from the paragraph stated and also
removed the table with the fee breakdown on the previous page. We do not
provide breakdowns of pricing.

 

2.        Specification for the work required.

You have provided in Appendix 2 a Specification and Scope of Service for
the overall project, but have failed to include a specification, or
statement, of the Services that had been demanded at the time of my
request.  I have however requested this in item (c) of section 1 above and
assume therefore that this information will be provided under that
heading.

 

Appendix 2 contains the specification for works that was issued to the
contractor. This specification also contains contextual information and a
matrix table clearly defining which elements are applicable to the
contractor.

 

3.        Audit trail showing all the authorisations that led to placement
of this contract, with names (or posts) of the authorising officers and
dates.

(a)  The information provided is not an audit trail of the authorisations
that led to this contract.  The authorisations that led to the placement
of this contract (of which the Purchase Order and any Waivers would form
part) should include supporting documents that stem from prior exchanges
with Pagabo and the Contractor in which an offer to sell the Services will
have been proposed by the Contractor and then accepted by the council
under contract (possibly initially by Letter of Intent). Those documents
will therefore have become essential parts of the council’s authorisation
process and need to be included in your response.

 

In order to gain access to a contracting framework, the Council must apply
to the Contracting Authority. An application is not made for access in
respect of a specific contract, but for general access that the Council
can make use of at any point in the future for whichever tendering
exercise is considered appropriate.

 

Consequently, the Council considers the client access agreement and F+G
contract to be two entirely separate (albeit linked) matters. The Council
is willing to separately disclose the client access agreement should you
wish to review this document.

 

The Council does not consider that the access agreement for the tendering
framework forms part of the audit trail for this particular contract, and
thus falls outside of the scope of your original request.

 

(b)  For avoidance of doubt, the authorisations within the audit trail are
expected to include those for the following individual (principally
separate) items:

 

i.   The re-assignment of the Framework Agreement to FHDC

ii.  Approvals for the Services to be undertaken (as stated in the Order
Form, or equivalent)

iii. Authorisation in respect of the irregular nature of this procurements
(e.g. capital expenditure on a council development prior to the grant of
planning permission) 

iv. Approval/Signing of the Letter of Intent (or its equivalent).

v.  Approval/Signing of the Contract awarded as a Deed.

 

Note that some of the above  would normally be expected to be authorised
by the S151 Officer and/or the Monitoring Officer.

 

i.              Please see above for details regarding the client access
agreement.

ii.            The provided call-off contract provides all relevant
details of services to be undertaken.

iii.           The question of “irregularity” has since been presented to
the Council at the public meeting held on 25^th September 2019. This was
answered by the Council Leader. For clarity, the question and response are
reproduced below:

 

Q: Will the Leader please explain how and why a £1.132m Call-Off contract
could rightfully have been awarded to Faithfull & Gould (F&G) and why this
was done without the recorded authorisation of the s151 officer or anyone
more senior in the council than level K.  F&G were appointed lead project
management consultant for the Princes Parade development and commenced
work 3 months prior to planning consent being granted on 18 July 2019. 
The Pagabo Framework Agreement, under which F&G were the single
pre-nominated consultant, did not provide the opportunity for competitive
tendering for either the contract nor the Framework.  In all respects this
was an irregular commitment from an already insufficient Capital budget
that should not have occurred and I ask that this should be explained.

 

A: The use of framework agreements by district councils for procurement is
commonplace and often recommended for large and complex projects. The use
of framework agreements is allowed under UK and EU procurement law and the
council’s contract standing orders. The benefits of using framework
agreements are that they streamline administration, reduce the procurement
risk and allow councils access wider economies of scale. Companies listed
on framework agreements will have already gone through a competitive
process and depending on how the framework is set up, it is possible to
make a direct award to a supplier.

 

With reference to the Princes Parade Project, the business case (C/18/69)
reported to cabinet on 13/2/19 set out the procurement strategy for the
project. This was covered in sections 2.16 to 2.26 of the cabinet and was
further expanded on in Appendix 1 of the report, which set outs in detail
the frameworks considered for the appointment of the main project
consultant and main points for consideration. Several frameworks were
considered for the appointment of the project consultancy team and the
eventual decision was to use the PAGABO National Framework for
Professional Services in Construction and Premises mainly due to the
flexibility offered by the agreement and the track record and experience
of the companies listed within each professional discipline on the
framework, many of whom had good local experience having been involved in
the design of the new leisure centre in Dover. This includes the main
project consultants Faithful & Gould.

 

In answer to the question around budget authorisation this is
straightforward. The Chief Strategic Projects Officer, as the budget
holder and responsible officer for the project has the delegated authority
to award contracts for the project. This is position as set out in the
Council’s contract standing orders and there was no requirement for
authorisation by the Council’s S151 Officer. The budget is sufficient to
cover the project. I consider therefore that the decision was taken
correctly and in accordance with the council’s procedures.

 

iv.           As noted above, a letter of intent was not utilised.

v.            A copy of the signed deed page for the contract has been
attached. Please note that the deed page is not dated because the
commencement date is recorded elsewhere in the document.

 

The contents of this request are subject to re-use under the terms of the
[1]Open Government Licence unless otherwise specified. Publications
relying on this data must be attributed accordingly. Where released
materials are subject to 3^rd party copyright or intellectual property
rights, rights to attribution and re-use remain vested in the holder.

 

Personal data disclosed in conjunction with an information access request
is provided in compliance with the Council’s legal obligations. This
disclosure does not constitute consent for direct marketing under the
Privacy and Electronic Communications Regulations (PECR), and should not
be construed as such.

 

If you are not satisfied with our response you may apply to the
Information Commissioner for an independent review at the following
address:

 

The Information Commissioner

Wyncliffe House

Water Lane

Wilmslow

Cheshire SK9 5AF

Telephone 0303 123 1113 (local rate) or 01625 545 745 (national rate)

[2]www.ico.org.uk

 

Kind regards,

 

Case Management (Support Services)

Information Governance

Folkestone & Hythe District Council.

Email: [3][Folkestone & Hythe District Council request email]

Website: [4]Home | [5]FOI and Data | [6]Privacy

Follow us on [7]Twitter and [8]Facebook

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