Open access land in Flintshire

siobhan grindley made this Freedom of Information request to Flintshire County Council

This request has been closed to new correspondence from the public body. Contact us if you think it ought be re-opened.

The request was successful.

siobhan grindley

Dear Flintshire County Council,

Can you please provide me with a list of all locations in Flintshire that have open access

Yours faithfully,

siobhan Grindley

Lavinia M Stockham, Flintshire County Council

Dear Ms Grindley,

I write to acknowledge receipt of your Freedom of Information request which has been given the reference number R016029. Your request has been forwarded to the Freedom of Information Act Contact Officer for Planning & Environment to process and this Officer will be in contact with you.

Should you send any further correspondence about this request, please include the reference number and either e.mail it to [Flintshire County Council request email], or post it to Freedom of Information, Flintshire County Council, Information Governance, County Hall, Mold, Flintshire, CH7 6NB.


FOI Contact Officer
FOI Contact Officer | Swyddog Cyswllt Rhyddid Gwybodaeth
Governance | Llywodraethu
Flintshire County Council | Cyngor Sir y Fflint
Tel | Ffôn | 01352 702121
Email | Ebost | [Flintshire County Council request email] | |

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siobhan grindley left an annotation ()


Dear Ms Grindley

Since November 2017, you have submitted 25 separate information requests to Flintshire County Council on the subject of Fixed Penalty Notices (FPNs) and/or services provided by Kingdom Security. Please be advised that as the information requested is ‘information on the environment’, we have dealt with these requests under the Environmental Information Regulations (2004) and not the Freedom of Information Act (2000).

Of the 25 requests submitted to the Council, 9 have already been answered and 16 are still “live”. Public authorities are allowed to aggregate multiple requests – and thus to consider them as a single request – when the requests are:
• made by the same requestor, or by a group of requestor's acting in concert;
• made at the same time; and,
• are concerned with the same broad information.
We believe that your requests clearly meet these tests, and so have decided that it is appropriate to aggregate them and consider them as a single request.

Responding to your requests, when considered together in this way, would place a very considerable burden on the Council and cause significant disruption to the Streetscene Department’s provision of other services. For example, answering the questions about FPNs would involve the relevant officer opening and searching through each of the 3586 database records individually. Allowing an average of one minute to open each record, to search through it, and, if applicable, to make notes on any representations received, this part of retrieving the information alone would take 3586 minutes, or around 59 hours. Given that representations might be in the form of longer letters, or more complex in nature, it is likely that it would take the officer in question even longer than this estimate. This is in addition to other parts of the request, and the burden they will place on the department is not negligible. We do not believe using the provisions of Regulation 7(1) of the Environmental Information Regulations (EIRs) to extend the time for compliance to a total of 40 working days would alleviate the disruption sufficiently to make the requests reasonably practicable for the Council to respond to.

We have therefore reluctantly decided to refuse your requests under Regulation 12(4)(b) of the EIRs. This states that ‘a public authority may refuse to disclose information to the extent that – the request for information is manifestly unreasonable.’ We believe that the very considerable disruption answering the requests would cause makes the requests obviously unreasonable to respond to. To apply this exception, we are required to carry out a public interest test. We have considered the following arguments in support of the public interest in disclosure:
• The requested information relates to services provided by Kingdom Security, which are currently a controversial issue in the local area and which have attracted local news coverage. Therefore there is some inherent value in the request as potentially informing public participation in local democracy.
• The public interest in local government’s transparency and accountability is arguably especially strong when more controversial issues are in question. It is important for the Council to be seen to be open and accountable in order to ensure public confidence.
However, despite the strength of these arguments, we believe they are outweighed by the public interest in maintaining the exception:
• The burden in complying with the requests is excessive in terms of staff time and cost, and would disrupt the provision of frontline services to the public.
• The value of the requests is not proportionate to the burden and disruption they would cause to the Streetscene Department. A significant amount of information on this issue is already publicly available, and the Council has already provided information in response to the first 9 of your requests. We believe that this information is sufficient to inform public debate: the main procedures have been outlined and statistics in relation to certain towns/areas have been provided. This provides a clear picture of how the FPNs are typically enforced and would allow informed representations to be made to the Council or to local elected representatives. It is difficult to see how the 16 further requests would further inform public debate in any meaningful way.
• The Council has already expended considerable time and resources in complying with 9 requests you have made on this subject. We will also answer a further request submitted through your MP, Mark Tami (reference number: R015715). This latter request is complex and voluminous, and will take several hours to answer.

While we believe that applying this exception is appropriate in this case, we would like to emphasise once again our reluctance in taking this action: as a Council, we are committed to ensuring transparency and facilitating public participation in decision-making wherever possible. With these principles in mind, we would like to invite you to submit what information you would like the Council to routinely make available in relation to FPNs and Kingdom Security. This will ensure your access to the information as far as is reasonable, while reducing the burden on the Council in handling such requests in the future. We will also use the requests we have already received in relation to Kingdom as a guide regarding what we should look to publish. Where we are able to publish the requested information, we will publish it on the Flintshire County Council website to ensure wider public access to it.

I look forward to hearing from you in due course.

Yours sincerely,

Lesley Matischok, FOI Contact Officer

siobhan grindley

Dear Lavinia M Stockham,

Thank you for your email, I have to say i am surprised to hear that so much work is involved in collecting the data related figures i requested. I have wrongly assumed that Flintshire CC had a more up to date data system installed and the figures requested were easily downloaded. I have also put in similar requests to other councils with no issues to date.

However as much as I understand and accept as true what you are saying, apart from these figure related requests I do think the others could and should be easily answered by a competent person.
My intention is not to make work for Someone and I understand if these things take longer than the 20 working days. I have in the past waited well over 40 days for a request to be answered as you are aware.
Before I proceed to the next level and request an internal review, which is not what Im about, I am just after some answers which I feel the public have a right to.
I am not out to cause unnecessary work for someone, and more spending of our councils money. Can I suggest that if I were to cancel some requests would it be possible to let the others proceed. The ones I’d cancel are all the data related ones and listed below. Please let me know your thoughts on this.

Thank you for your time

Siobhan Grindley


reference number R01598
Sent 27-4-2018

Open access land in Flintshire
reference number R016029
Sent 3-5-2018

FPNs Queensferry
reference number R015905
Sent 16- 4-2018

FPNs Mold
reference number R015904.
Sent 16- 4-2018

FPNs shotton
reference number R015902
Sent 16- 4-2018

FPNs Connah’s Quay
reference number R015903.
Sent 16- 4-2018

FPNs A55
reference number R015901
Sent 16- 4-2018

reference number R015900
Sent 16- 4-2018

types of litter
reference number R015921
Sent 18-4-2018

FPN by month 2018
Ref number R016050
Sent 6-5-2018

Open access land in Buckley elfed
Re: FOI Enquiry: R016012
Sent 2-5-2018

FPN Issued through non civil cctv footage
reference number R015984
Sent 26-4-2018

CCTV data protection
reference number R015983.

Income from FPNs for litter
reference number R015958
Sent 25-4-2018

Kingdom security Flintshrie complaints
reference number R015943 .
Sent 20-4-2018

Complaints missing paperwork
Re: FOI R015749
Sent 20-4-2018

FPNs 85%
reference number R015834

Yours sincerely,

siobhan grindley

Lesley Matischok, Flintshire County Council

Dear Ms. Grindley,


I am writing in relation to your recent request for information (reference
number: R016029), which we have dealt with under the Environmental
Information Regulations (EIRs).


Under Regulation 6(1)(b) of the EIRs, public authorities do not have to
make information directly available to applicants where it is already
publicly available and easily accessible to the applicant in another form
or format. Maps showing ‘Open Access Land’, as defined by the Countryside
and Rights of Way Act, can be found on the Natural Resources Wales or via
the following link:


If this is not the information you are requesting, please contact us and
describe more specifically what you mean by the terms ‘open’, ‘access’ and
‘locations’. This would greatly assist our officers.


Yours sincerely,


FOI Contact Officer





If you are dissatisfied with the Council’s handling of your request for
information, you can ask for an internal review within 2 months of the
date of this response. Where your complaint is a complex one it may not be
possible to deal with it within the above timescales. In such a situation
a progress report will be sent within the above timescales.


Requests for an internal review should be addressed to the Council’s
Information Governance Manager at:


Information Governance Team,

County Hall,




Or by emailing [2][email address]


Please remember to quote your original request’s reference number.


You also have the right to complain to the Information Commissioner. The
Information Commissioner can be contacted at the following address:


Information Commissioner’s Office,

Wycliffe House,

Water Lane,



SK9 5AF.


The contents of this communication and any enclosed documents may be
subject to copyright protection.  It has been sent to you for your
information and you may use it for any non-commercial research you may be
doing or undertaking.  Its contents can also be used for the purposes of
news reporting.  Any other re-use, for example, commercial publication or
publication on a website, requires the permission of this Council.  If you
wish to re-use this information please contact us, letting us know how you
wish to re-use it and what the intended audience will be so that we can
consider your request.  This information should be sent to:  The Records
Manager, Flintshire County Council, County Hall, Mold, Flintshire  CH7
6NB, or [3][email address].


We welcome correspondence in Welsh. We will respond to correspondence
received in Welsh without delay.

Opinions advice, conclusions and other information in this

message that do not relate to the official business of

Flintshire County Council shall be understood as neither

given nor endorsed by it or on its behalf, and consequently

Flintshire County Council shall bear no responsibility

whatsoever in respect thereof.

Rydym yn croesawu gohebiaeth Gymraeg. Ymatebwn yn ddi-oed i ohebiaeth a
dderbynnir drwy gyfrwng y Gymraeg.

Deellir na fydd unrhyw safbwyntiau, na chynghorion, na

chasgliadau nac unrhyw wybodaeth arall yn y neges hon,

nad ydynt yn berthnasol i waith swyddogol

Cyngor Sir y Fflint, yn cael eu cynnig na'u cadarnhau ganddo

nac ar ei ran, ac felly ni fydd Cyngor Sir y Fflint yn derbyn

unrhyw gyfrifoldeb am y rhannau hynny o'r neges.



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