Dear Customer Enabling Services,

Thank you for your response dated 13 March 2026 (ref: FOI_10599).

I am writing to request an internal review of the decision on three grounds.

1. Misapplication of s.22 exemption — Questions 1 and 3

The response withholds information responsive to Questions 1 and 3 under s.22 of the Freedom of Information Act 2000, on the basis that Together for Children Sunderland is currently reviewing its records management procedures and anticipates publishing updated versions by July 2026.

The s.22 exemption applies to information held with a view to its publication at some future date. It cannot lawfully be applied to information that already exists and is currently in operational use.

Together for Children Sunderland must currently be applying some form of retention schedule and disposal procedure in order to manage its records. Those existing, operative documents are separate from any updated versions being prepared for future publication. The existence of a planned update does not justify withholding the version currently in force. To apply s.22 in this way is to use the exemption as a means of concealing what the organisation is actually doing with records now, which is not its intended purpose.

I request that the authority discloses the retention schedule entries and disposal procedures currently in operational use, or identifies any other exemption(s) it relies upon to withhold that information, with reasons.

2. Redactions without cited exemption — attached SEND schedule

The SEND retention schedule attached to your response (RecordsRetentionSchedule_SEND) is substantially redacted. The majority of rows below the three visible entries (SEN Panel Minutes and Decisions, SEN Case Files, SEN Tribunal Files) are blacked out.

No exemption is cited for these redactions anywhere in the response letter. Under s.17 of the Freedom of Information Act, where a public authority refuses to communicate information it must give the applicant a notice specifying the exemption(s) relied upon. The response does not do this in relation to the redacted portions of the schedule.

Please either disclose the redacted entries or provide a proper s.17 refusal notice identifying the specific exemption(s) relied upon for each category of withheld information, with reasons.

3. Question 4 — council guidance to maintained schools

The response states that Together for Children Sunderland does not hold information about its role in ensuring maintained schools comply with records retention and information rights obligations, on the basis that schools are separate public authorities and data controllers.

My question was whether the council or TfCS holds any recorded guidance, communications, or circulars issued to maintained schools about these matters. The separate legal status of schools as data controllers does not mean the council has never communicated with them about records management or information rights. These would be council-held records regardless of schools' separate status.

Please confirm whether any such recorded guidance, communications, or circulars exist. If no such information is held, please confirm that explicitly.

Yours faithfully,
Jamie Halliday