Dear Dan Ackroyd
 
Freedom of Information Act 2000
 
 
Thank you for your request for information that was received on 17
December 2024. It is being handled under reference 54399770.
 
We are dealing with your request and we aim to send a response within 20
working days from the date we received your request.
 
For further information regarding FOI requests, please visit
[1]https://ico.org.uk/your-data-matters/off...
 
If you have any further queries about your request please contact
[2][email address].
 
 
Yours sincerely
 
 
Disclosures Team
 
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Bristol City Council
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Dear Dan Ackroyd, 
 
Please accept our apologies for the missing information. Please find
attached the information that we can disclose to you.
 
Thank you, 
Bristol City Council 

══════════════════════════════════════════════════════════════════════════

From: [FOI #1216257 email]
Sent: Fri Jan 10 2025 18:19:48 GMT
To: [Bristol City Council request email]
Subject: Re: CRR60 (aka Failure of HRA stock to meet landlord statutory
obligations) (ref: 54399770) - password
(Attachments:) Email (original message) from [FOI #1216257 email] received
on 10/01/2025.eml, Email from [FOI #1216257 email] - Re: CRR60 (aka
Failure of HRA stock to meet landlord statutory obligations) .txt
 
Bristol City Council
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Dear Dan Ackroyd
 
Thank you for your request for an internal review received on 21 January
2025. I am sorry that you are unhappy with our response under the Freedom
of Information Act 2000.
I apologise for the delay in acknowledging your internal review request.

I can confirm that we are considering your concerns and we will aim to
provide you with a response by 18 February 2025.

Yours sincerely
 
 
A Pannett
Lead Disclosures Officer

 
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the use of this email or attachments.

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Dear Dan Ackroyd
 
Information requested by: Dan Ackroyd

Our ref 54399770 – internal review response

I am writing in response to your concerns about Bristol City Council’s
handling of your request for information received on 17 December 2024 and
which was responded to on 10 January 2025.  

I was appointed to carry out an independent review as I was not involved
in the original decision. 

In your request you asked for the following information: 

“Dear Bristol City Council, 
 
Please provide me with all record entries kept in BCC's "risk managed
system Risk (formerly Pentana Risk)" related to the risk that was
eventually published as CRR60 (aka Failure of HRA stock to meet landlord
statutory obligations) in the 'Corporate Risk Register Q1
2024-2025'54399770  
 
Please provide me with the records since the risk entry was created in
August 2021 until 19 July 2024. 
 
Hopefully it will be clear what CRR60 means. If not, please refer to
question 7 in the Public Forum for the Homes and Housing Delivery Policy
Committee 19 July 2024: 
 
https://democracy.bristol.gov.uk/documen...

Original decision  

Bristol City Council responded to your request on 10 January 2025 to
confirm that it held the information requested.  Some information was
disclosed to you under the Freedom of Information Act (FOI Act). 

Internal review request  

On 10 January 2025 you contacted Bristol City Council to request an
internal review as you were not satisfied with the original response to
the above request.  In your internal review request you outlined the
following.  

“Dear Bristol City Council, 

The documents provided are not entirely what I requested. You have given
me two documents that were already in the public domain. 

I asked "Please provide me with the records since the risk entry was
created in August 2021 until 19 July 2024." 

The response cover letter seems to indicate that my request was
understood. 

"The risk system contains loads of confidential information, but we will
be happy to show." 

Yes. Please show me the information from the risk system, as requested. 

If it helps expedite matters, please consider this a request for an
internal review.” 

I have treated your request for an internal review in line with the terms
of the FOI Act. 

Internal review  

I have assessed the overall handling of your request with consideration of
the FOI Code of Practice. 

I have also paid specific reference to these sections of the FOI Act: 

Section 21 – Information Accessible by Other Means  

Section 21 specifies that information is exempt from disclosure under the
FOI Act if it is accessible to the requestor by other means. 

Section 16 – Advice and Assistance  

Section 16 of the FOI Act provides that a public authority should give
advice and assistance to any person making an information request. 

Section 40(2) – Personal Data 

Section 40(2) of the FOI Act provides that information is exempt from
disclosure if it is the personal data of an individual other than the
requestor and where one of the conditions listed in section 40(3A), 40(3B)
or 40(4A) is satisfied. 

To undertake my internal review, my investigations included the
following:  

- Interrogating our case management system for the history of the request,
to help determine which council service had been involved in the original
response and which were likely to hold the information in the scope of
your request; and to assess the overall handling of your request. 

- Conferring at length with officers in the Risk & Insurance service
(which coordinated the original response and co-manages the type of
information you are interested in) and the Housing Repairs & Maintenance
service teams (which co-manages the type of information you are interested
in).  This included seeking greater clarity on the information held in the
scope of your request and directing further searches to be undertaken for
the type of information you are interested in. 

The first finding of my internal review is that the council’s original
response lacked clarity, falling short overall in directly addressing what
information is held in the scope of your request by the council.  I
apologise on behalf of Bristol City Council for this failure in accordance
with Section 16 of the FOI Act. 

Secondly, I can clarify that some of the information you have requested
has previously been extracted from the council’s risk management system,
Ideagen Risk, covering the period of your request within reports for
publication via the ‘Meetings, agendas and minutes’ pages of the council’s
website.   

I can also clarify that these reports contain direct extracts of the
records held in the risk management system at the point that they were
created.  No additional documents are attached to the risk record entries
themselves, due to the way the system operates.  Furthermore, I can advise
that the Ideagen Risk system is a ‘dynamic’ database, which means that
when an entry is updated, the previous recorded information is
overwritten/superseded. 

The council should therefore have applied have Section 21 of the FOI Act
to this part of the information you requested, that I consider is
reasonably accessible to you publicly, with advice on how to locate it on
the council website.  I apologise on behalf of Bristol City Council for
this failure to apply Section 21 of the FOI Act in its original response. 

I can advise from my investigations that the information held by the
council for the date range specified in your request is accessible to you
publicly within these reports at the following direct links:- 

Homes and Housing Delivery Committee on 30 July 2024:  

[1](Public Pack)Agenda Document for Audit Committee, 30/05/2024 14:00 

Homes and Housing Delivery Committee on 19 July 2024 (Pages 12 – 26):  
[2](Public Pack)Agenda Document for Homes and Housing Delivery Policy
Committee, 19/07/2024 10:00 

Additional Advice and Assistance 

Whilst it is outside the date range of your request, in recognising your
interest in this type of information, you can also find further published
reports containing more recent extracts from the CRR60 risk register
record on the council website at these direct links:- 

Homes and Housing Delivery Committee on 13 December 2024 (Pages 337 –
350): 
[3](Public Pack)Agenda Document for Homes and Housing Delivery Policy
Committee, 13/12/2024 10:00 

Homes and Housing Delivery Committee on 14 February 2025 (Pages 252 –
268): 
[4](Public Pack)Agenda Document for Homes and Housing Delivery Policy
Committee, 14/02/2025 10:00 

This part of my internal review response therefore acts as a refusal
notice under Section 17 of the FOI Act.

Thirdly, from investigations, additional ‘deactivated’ records (known as
‘sub-risks’) that informed CRR60 risk entry, before it was created on
Corporate Risk Register, have been identified and extracted from the
Ideagen Risk system.

I can advise that these were the versions of these records at the date of
their deactivation on 3 April 2024, that were held at the date of your
request.

I apologise on behalf of Bristol City Council that these now disclosed
records were not previously identified and accounted for in the council’s
original response.

These records are provided as the attached ‘CRR Sub Risks’ PDF.

Due to the way the information has been extracted and presented from
Ideagen Risk system to be accessible to you as part of this internal
review response, you may need to use to the zoom function of Adobe Reader
(or equivalent PDF viewing software) to view the full extent of the
document.

For context, the acronym ‘DRR’ as shown within the extracted information
stands for ‘Directorate Risk Register’.

Please note that the personal data of non-senior council officers and
officers no longer working for the council has been redacted from these
extracted records, in accordance with Section 40(2) of the FOI Act.

Section 40(2) – Personal Data

We consider that parts of this additional information otherwise disclosed
to be personal data that falls to be exempt under Section 40(2) of the FOI
Act, which prohibits us from disclosing third party personal data if this
would contravene data protection principles as set out in the Data
Protection Act 2018 (DPA) and the UK General Data Protection Regulation
(UK GDPR).

The individuals involved (council officers beneath senior management level
and other no longer working for the council) would have a reasonable
expectation that their personal information and any details that would
identify them would not be released to the public, and disclosure would
therefore put us in breach of the DPA 2018 and the UK GDPR.

This part of my internal review response therefore acts as a refusal
notice under Section 17 of the FOI Act.

Decision

The final decision of this internal review is that it upholds your
complaint.

The council’s original response lacked clarity overall, falling short of
its advice and assistance duties under Section 16 of the FOI Act.  I
apologise on behalf of Bristol City Council for this failure.

The council’s original response should have applied the exemption at
Section 21 of the FOI Act for some of the information held in the scope of
your request, that is considered reasonably accessible to you via
publicly.  I have now applied this exemption as part of this internal
review response with detail on how to access this information held in the
scope of your request.  I apologise on behalf of Bristol City Council for
this failure.

The council’s original response should also have identified and accounted
for relevant additional records information held on in risk management
system.  I apologise on behalf of Bristol City Council for this failure. 
These additional records have now been disclosed to you now with this
response subject to redactions for personal data in accordance with
Section 40(2) of the FOI Act.

If you are not content with the outcome of this Internal Review you have
the right to apply directly to the Information Commissioner’s Office for a
further decision. The Information Commissioner can be contacted at:

Information Commissioner’s Office

Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
 
[5]www.ico.org.uk 
 
Helpline on 0303 123 1113
 
Yours faithfully
 
 
A Pannett
Disclosures Team
 
NOTE: Please do not edit the subject line when replying to this email.
 
Bristol City Council
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This email has been scanned for all viruses and all reasonable precautions
have been taken to ensure that no viruses are present. Bristol City
Council cannot accept responsibility for any loss or damage arising from
the use of this email or attachments.

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