In a letter to the Mayor and Deputy Mayor of Lydney and the Town Clerk of Lydney Town Council on 10 July 2021, Zac outlined the timeline he plans to work to with regards to severe concerns about the handling, security and lawful right of access to data the Council holds:
“I’m writing further to the correspondence received from the Town Clerk on 18 May 2021 and Cllr Harley on 28 May 2021 in which it was stated that arrangements had been made for the retrieval of and provision of access to personal data held by Lydney Town Council relating to myself. For memory, the email dated 18 May 2021 stated that time had been allocated on 25 May 2021 to ‘work through’ emails from TateTech with a view to providing me with the results by the end of that week, 28 May 2021. The latter email of 28 May 2021 stated that due to the volume of emails it could be expected to take longer commencing on 7 June 2021 when more resources were expected to be available.
“As I have made you aware I have been attempting to access this data since the summer of 2019, and, whilst I appreciate the scale of the data held and the limits on staffing resources, I am finding it increasingly tiresome that I do not have access to information that I needed urgently last year. The fact Cllr Harley’s email of 28 May describes the arduous process of isolating emails relating to myself suggests that this basic stage had not been started for 10 months after my initial request. I can understand delays in processing such a large volume of data but I struggle to understand why it took 10 months to send an email to TateTech asking them to gather the emails.
“I have also queried, which has yet to receive a response, that the Council understand that emails are not the only form of data included within this SAR. Other forms of data include but are not limited to: documents, digital files such as screenshots, data collected through direct notifications from Council social media channels, written notes, paper-copy files including those held by the Personnel Committee relating to my activities from 2018-2019 and ANY and ALL other data held by the Council relating to or mentioning myself. Could you please confirm that this point is understood?
“As all deadlines set by the Council so far have lapsed with little to no progress, I am informing you that I have set a deadline of 6pm on Monday 13 September 2021– the first Full Council meeting after Summer Recess – for my data to be supplied to me in full. This will provide for a grace period of approximately 4 months since Cllr Harley’s election as Mayor of Lydney. If this has not occurred, on Tuesday 14 September 2021 I will submit a formal complaint to the Information Commissioner’s Office relating to this matter alone and will supply a copy of this complaint to yourselves.
“Following this, as advised previously, there are other data matters to be dealt with. I will submit a preliminary complaint to Full Council on Friday 1 October 2021 as formal correspondence for the meeting to be held on Monday 11 October. This complaint will relate to the potentially unlawful and non-approved disclosure of extremely sensitive employment and other internal data between June 2020 and May 2021.
“This initial complaint is for information and comment only by the Council – not for review under Council complaints procedures. The Council will have until 6pm on Monday 8 November 2021 to provide comment on the substance of the complaint. Upon receiving comment I will decide whether, in my view, the matter can be resolved locally. If not, or if no comment is received, the complaint shall be submitted to the Information Commissioner’s Office on Monday 15 November 2021.
“My right of access to the information requested through this SAR is asserted under Article 15 of the General Data Protection Regulations 2018, I reserve my right to take formal action – through relevant watchdogs or legal action – to ensure I, and others, can access our data rights.
“Thank you in advance for your time and co-operation in this matter. I hope that you can agree that the above timetable is both extended enough to not overwhelm you and clear enough for us to see a way out of this issue in a way that upholds my rights and helps strengthen the Council’s data handling processes and security measures.”