Fire Doors Fitted In Properties Under Your Management
Can you detail how many fire doors have been installed in properties under your management that have been supplied by the following companies:
Specialist Building Products Limited, trading as Permadoor
Solar Windows Limited
Birtley Group Limited, trading as Bowater by Birtley
Have you taken any action to remove fire doors supplied by these companies since the Ministry for Housing, Communities and Local Government announced these five suppliers have now been identified as failing to meet requisite fire performance standards.
Have any doors supplied by these companies been removed before the announcement.
Dear Basia Cummings
FREEDOM OF INFORMATION ACT 2000 (FOIA) – REQUEST FOR INFORMATION
The City of London (CoL) acknowledges receipt of your request for information of 6 August 2018.
Public authorities are required to respond to requests within the statutory timescale of 20 working days beginning from the first working day after they receive a request. The Act does not always require public authorities to disclose the information which they hold.
The FOIA applies to the CoL as a local authority, police authority and port health authority. The CoL is the local and police authority for the “Square Mile”, ie the historic City of London, and not for London as a whole. Please see the following page containing a link to a map (‘Explore the City’), which shows the local authority area covered by the CoL:
The CoL does have some functions, including Port Health Authority functions, which extend beyond the City boundary. For further information please see: www.cityoflondon.gov.uk.
Comptroller & City Solicitor’s Department
City of London
Tel: 020-7332 1243
Dear Ms Cummings,
FREEDOM OF INFORMATION ACT 2000 (FOIA) - REQUEST FOR INFORMATION
Following your request for information of 6 August 2018 and our
acknowledgement of 7 August, the City of London (CoL) responds as follows.
Historically, the CoL Housing Department is unusual in that it has over
2,700 social housing properties situated in seven London boroughs
(Hackney, Islington, Lambeth, Lewisham, Southwark and Tower Hamlets). It
also has two social housing estates located within the City itself and
this is our specific borough.
This response below relates specifically to our social housing properties.
One of our project contractors has installed 6 Permador door sets as a
pilot scheme. These units were supplied with full assessment certification
from Exova Warringtonfire for 30 minutes rated and the assessment included
all parts of the door set including ironmongery and associated closers.
MHCLG has reported that it is the glazed version of Permador units that
have failed. The doors supplied by Permador in our blocks are non-glazed
The CoL also owns and manages the private Barbican Estate (within the City
borough) and this is a nil response to fire doors from any of the
companies listed in your question.
In regard to doors relating to our operational buildings, in accordance
with section 17 of the FOIA, this part of the response acts as a refusal
In accordance with section 1(1)(a) of the FOIA the CoL confirms that it
would hold information relevant to the request. However, it estimates that
to comply with the request would exceed the cost/time allowed for in the
Freedom of Information and Data Protection (Appropriate Limit and Fees)
Regulations 2004 (made under section 12 of the FOIA), called (as you may
know) the 'appropriate limit', of £450, representing 18 hours work by one
person equivalent. Public authorities are not required to comply with
requests free of charge which it is estimated may exceed the appropriate
limit. Where they do comply, they are allowed to charge the full permitted
cost, at the statutory chargeable rate of £25 an hour. For resource
reasons, it is the practice of the CoL not to comply with requests which
exceed the appropriate limit.
In accordance with the FOI Fees Regulations an authority is allowed to
take into account, in calculating the estimated compliance time, the time
taken in -
"(a) determining whether it holds the information,
(b) locating the information,
(c) retrieving the information, and
(d) extracting the information from a document containing it."
In accordance with the Information Tribunal’s Decision Notice ref:
EA/2006/0085, which makes reference to calculation of estimates and
compiling the information, the CoL also considers the description covers
compiling the information, in so far as it can be said that the
information does not technically exist until it is compiled.
The CoL estimates the time it would take to comply with the request would
be approximately 20 hours by one-person equivalent which, in accordance
with the rate allowed to be charged, would be the equivalent to a cost of
Please note that there is no centralised repository, in a database or hard
copy filing system, which holds and collates the information you have
requested. To provide the information that you have requested would
require searching the CoL's hard copy and electronic filing systems across
We note also the Commissioner's guidance as provided in his Decision
Notice (Ref: FS 50238979) as to what constitutes a significant burden to a
public authority in complying with a request, namely where "significant
involvement and coordination of staff across the public authority
extracting information from numerous sources" would be involved, as it
would in this instance.
Please also note that the Commissioner has stated (FS 50227557) with
regard to FOIA section 12, to which the above Fees Regulations relate,
that the purpose of the section "is to prevent the possibility of a
disproportionate level of search and that it is reasonable in these
circumstances to adjudicate on the basis of a reasonable estimate of the
worst case scenario". Nevertheless, we consider that our estimate is not a
worse case estimate but a conservative one.
In addition, the ICO’s guidance states that, as a matter of good practice,
public authorities should avoid providing some information while applying
section 12 to the remainder. The guidance states that it “is accepted that
this is often done with the intention of being helpful but it ultimately
denies the requestor the right to express a preference as to which part or
parts of the request they may wish to receive which can be provided under
the appropriate limit” (‘Requests where the cost of compliance with a
request exceeds the appropriate limit’, 9 Sept 2015). The Information
Tribunal has stated (EA/2006/0085) that: “We ... accept that the cost
limits do not mean that the request must be complied with up to the point
at which the limit has been reached”. This position was endorsed by the
Tribunal in its decision EA/2010/0113.
Finally, please note that the Commissioner has stated (FS 50353495) that
“Section 12 of the Act provides an exclusion from complying with a
request. It is not subject to a public interest test”. We note too that
the Commissioner has stated (FS 50279125) that it serves merely as the
costs threshold and does not provide any statement about the value of any
request for information.
In accordance with best practice guidance as described in the Information
Commissioner's decision notice ref FS 50203140, after applying the
appropriate limit a public authority is required to provide advice and
assistance, in so far as is possible, as to ways in which an applicant
could reduce his/her request so that it may fall within the appropriate
In this instance we can confirm that the CoL does not hold a register of
doors installed within our operational buildings so to obtain this
information we would need to send someone around to all of these
properties and check the make of the doors. Realistically this would take
a month to complete. Nevertheless, the CoL can confirm that all new builds
are design and build, which means we do not influence what doors are
installed as long as they meet the current building regulations.
If you wish to make a complaint about the way the CoL has managed your
enquiry, please make your complaint in writing to email address:
[email address]. For a link to the CoL’s FOI complaints
procedure, please visit the following page:
www.cityoflondon.gov.uk/Feedback, at the end of which is located the
FOI complaints procedure. If, having used the CoL’s FOI Complaints
Procedure, you are still dissatisfied, you may request the Information
Commissioner to investigate. Please contact: Information Commissioner,
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Telephone:
(01625) 545700. Website: http://www.ico.org.uk/.
The FOIA applies to the CoL as a local authority, police authority and
port health authority.
The CoL holds the copyright in this communication. Its supply does not
give a right to re-use in a way that would infringe that copyright, for
example, by making copies, publishing and issuing copies to the public or
to any other person. Brief extracts of any of the material may be
reproduced under the fair dealing provisions of the Copyright, Designs and
Patents Act 1988 (sections 29 and 30) for the purposes of research for
non-commercial purposes, private study, criticism, review and news
reporting, subject to an acknowledgement of the copyright owner.
Office Manager | Housing Services Division
City of London Corporation |Telephone 020 7332 3014|
We work to defend the right to FOI for everyone
Help us protect your right to hold public authorities to account. Donate and support our work.Donate Now