ESCC - FOIA DISCLOSURE
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Data Subject Access Reqeust & Freedom Of Information Act (F.O.I.A.) DISCLOSURE
⭐ TECHNICAL REPORT
Documentary Inconsistencies, GDPR/FOIA Breaches, and Procedural Irregularities in ESCC’s Publication of the Press Release Concerning Mr Riccardo Gresta
1. Purpose of the Report
This report examines the normative, documentary, and procedural inconsistencies arising from East Sussex County Council’s (ESCC) publication of the press release titled “Faked letter lands Blue Badge applicant in court”, its subsequent removal, and the responses provided through FOIA and SAR mechanisms.
The analysis identifies:
- FOIA‑redacted data that had previously been published online;
- breaches of GDPR principles;
- inconsistencies in the dates of the sentencing hearing;
- metadata demonstrating the impossibility of relying on a formally notified sentence;
- improper use of FOIA redactions to conceal names of public officials;
- persistence of derivative copies online;
- suspicious use of the FOIA formula “exemption when information is not held”.
2. Legal Framework
2.1 Freedom of Information Act 2000 (FOIA)
FOIA requires:
- redaction of personal data (Section 40(2));
- transparency regarding public officials acting in an official capacity;
- disclosure of names and roles of officials involved in public acts;
- the simple response “information not held” where information does not exist.
2.2 GDPR / UK GDPR
GDPR requires:
- data minimisation (Art. 5(1)(c));
- proportionality (Art. 5(1)(a));
- accuracy (Art. 5(1)(d));
- integrity and confidentiality (Art. 5(1)(f));
- accountability (Art. 5(2));
- protection of health data (Art. 9);
- protection of criminal offence data (Art. 10).
3. Documented Facts
3.1 FOIA Draft
In the FOIA document “Approval Email Chain_merge.pdf”, ESCC redacted:
- the data subject’s name;
- age;
- address;
- health details;
- criminal offence details;
- judicial quotations;
- names of public officials.
ESCC stated:
“We consider this information to be personal data… exempt from disclosure by section 40(2) FOIA.”
3.2 Original Online Publication
The press release published by ESCC contained:
- full name (“01234567891011”);
- age (“01234567891011”);
- address (“01234567891011);
- health data;
- criminal offence data;
- unnecessary identifying details.
3.3 Persistence of Derivative Copies
Despite removal in 2025, at least three derivative copies remain accessible via direct URL, containing the same personal data visible (public domain) that ESCC now redacts under FOIA.
4. FOIA/GDPR Inconsistency: FOIA‑Redacted Data Previously Published Online
4.1 FOIA acknowledges the data as “non-disclosable”
By redacting the data, ESCC acknowledges that:
- it is personal data;
- it is sensitive;
- it cannot be disclosed publicly.
4.2 Yet ESCC published the same data online
The online publication made public:
- name, age, address;
- health data;
- criminal offence data.
Conclusion
⭐ FOIA redactions prove that the original online publication was unlawful.
5. Inconsistencies in Sentencing Dates
Four different dates appear in official documents:
- 22 November 2022 (ESCC Legal Services);
- 22 December 2022 (press release);
- 23 December 2022 (publication date);
- 24 December 2022 (CCRC documentation).
Conclusion
⭐ If even the sentencing date is inconsistent, the entire documentary chain is unreliable.
6. Metadata: Impossibility of Relying on a Formally Notified Sentence
Metadata of the Word file show:
- Created: 22/12/2022 – 14:11
- Last Modified: 23/12/2022 – 11:25
6.1 The press release was drafted before the alleged sentencing
The press release claims:
“Sentencing on Thursday, December 22…”
Yet the file was created at 14:11 on the same day, when no written sentencing note, transcript, or court order could possibly have been available.
6.2 No written sentence was ever notified
Both CCRC and ESCC confirm:
- no written sentence exists;
- no sentencing note exists;
- no transcript exists;
- no court order exists.
Conclusion
⭐ The press release was drafted without any judicial documentation.
7. Improper FOIA Redactions Concealing Names of Public Officials
ESCC states:
“We do not disclose details of Council officers below Head of Service level.”
This policy is unlawful, because:
- names of public officials acting in an official capacity are not personal data under FOIA;
- such names must be disclosed;
- these names were already publicly available in the original press release.
Conclusion
⭐ FOIA redactions were improperly used to conceal institutional responsibility.
8. Suspicious FOIA Formula: “Exemption when information is not held”
In response to the request for communications with Italian authorities, ESCC stated:
“Information is not held. Under Section 3(2) FOIA there is an exemption when the information is not held.”
Forensic Observation
The correct FOIA response is simply:
“Information not held.”
The additional formula:
- is unnecessary;
- is defensive;
- is atypical;
- suggests reluctance to state plainly that no action was taken;
- reads more as “we do not declare” than “we do not possess”.
Conclusion
⭐ The phrasing suggests an attempt to avoid a direct admission of inaction.
9. Resulting GDPR Breaches
✔ Data minimisation (Art. 5(1)(c))
✔ Proportionality (Art. 5(1)(a))
✔ Accuracy (Art. 5(1)(d))
✔ Integrity and confidentiality (Art. 5(1)(f))
✔ Accountability (Art. 5(2))
✔ Health data (Art. 9)
✔ Criminal offence data (Art. 10)
10. Overall Conclusion
ESCC’s conduct exhibits systemic and structural inconsistencies:
- FOIA redacts data that ESCC itself published online;
- FOIA redacts names of officials that are not personal data;
- press release drafted without any judicial documentation;
- press release created before the alleged sentencing;
- contradictory sentencing dates;
- derivative copies still online;
- defensive FOIA phrasing suggesting reluctance to declare inaction.
In summary:
⭐ FOIA proves the online publication was unlawful.
⭐ Metadata proves the narrative was not based on any sentence.
⭐ FOIA redactions conceal responsibility rather than protect privacy.
⭐ The FOIA formula “exemption when information is not held” is suspicious and defensive.
⭐ The entire documentary chain is inconsistent, unverifiable, and non‑compliant with GDPR.
The original ESCC press release appears to have been authored under the internal CMS username “karenb”, as visible in the
<author> tag of the page source prior to its removal. Based on ESCC’s internal naming conventions (“first name + initial of surname”), and on the pattern of authorship across multiple ESCC press releases, the username “karenb” is technically compatible with the name Karen Bowles, who has historically appeared in ESCC’s communications and press‑office structures.EAST SUSSEX COUNTY COUNCIL (ESCC)
Individual Mapping – Structure, Roles and Responsibilities (2022–2026)
Bullet‑Point Format
1. Executive Leadership (Top‑Level Command Chain)
• Becky Shaw
– Chief Executive, Head of Paid Service
– Confirmed active in 2022–23; likely active in 2026
– Overall responsibility for governance, communications and organisational oversight
• Rupert Clubb
– Director of Communities, Economy and Transport (CET)
– Confirmed active in 2022–23; likely active in 2026
– Direct oversight of Blue Badge operations and CET enforcement cluster
1bis – Identified December 2025 / Active August 2026
• Saffron Phillips
– Media and Content Officer
– Confirmed active in 2026
– Operational content production and media handling
• Natalie Anderson
– Head of Customer, Library and Registration Service
– Confirmed active in 2026
– Senior management within customer‑facing services
2. Communications & ESCC Newsroom (Content Production and Institutional Messaging)
• Warwick Smith
– Head of Communications & Marketing
– Confirmed active in 2022–23; likely active in 2026
– Direct supervision of Newsroom, press output and institutional messaging
• Karen Bowles
– Press Office – Media Enquiries
– Confirmed active in 2022–23; probably active in 2026
– Press release handling, media enquiries, publication and removal workflow
• Paul Crompton
– Marketing & Content Officer
– Confirmed active in 2022–23; active in 2026
– Editorial content production and web materials
• Ollie Bowen
– Strategic Planning & Communications Manager
– Confirmed active in 2022–23; active in 2026
– Strategic coordination of communications and planning
• Vanessa Souto‑Axell
– Campaigns & Project Manager
– Active from 2024; confirmed active in 2026
– Operational support for campaigns and project‑based communications
• Gavin Gadsby
– Media Relations Manager
– Not confirmed in 2022–23; not determinable in 2026
– No verifiable presence
• Claire Lee
– Media Officer
– Not confirmed in 2022–23; not determinable in 2026
– No verifiable presence
• Becca Durrant
– Press Office
– Not confirmed in 2022–23; not determinable in 2026
– No verifiable presence
• Laura Gooch
– Marketing & Content Officer → Comms Account Manager
– Confirmed active in 2022–23; no longer in ESCC by 2026
– Not involved in 2026 events
3. Governance & Information Team (Data Governance / Legal Information Governance)
• Bridget Osazuwa
– Information Governance Officer
– Confirmed active in 2022–23; no longer in ESCC by 2026
– Active during 2023–24 (PCS management)
• Kate Richmond
– Information Governance Officer
– Confirmed active in 2022–23; no longer in ESCC by 2026
– Active 2023–26 (Jannuary), absent in 2026
4. Blue Badge Office (Operational Line – Investigative Phase)
• Mark Jobling
– Investigations Officer – Blue Badge Fraud Unit
– Confirmed active in 2022–23; likely departed by 2026
– Operational figure during 2022–24
• Ann Longden
– Mobility Assessment Officer
– Confirmed active in 2022–23; not determinable in 2026
– Mobility assessments
• Stephany Thuoy
– Blue Badge Office Staff
– Confirmed active in 2022–23; not determinable in 2026
– Administrative/operational staff
5. Trading Standards / Public Protection
• Wendy Scott
– Senior Trading Standards Officer
– Confirmed active in 2022–23; likely active in 2026
– Enforcement parallel to CET operations
6. ICT & Digital Services (Infrastructure, CMS, Hosting)
Senior Leadership
• Phil Hall
– Chief Operating Officer
– Confirmed active in 2022–23; likely active in 2026
– Oversight of digital infrastructure, CMS processes and service delivery
• Matt Scott
– Assistant Director ICT / CDIO Orbis
– Confirmed active in 2022–23; no longer in ESCC by 2026
– Not involved in 2026 events
• Rosalyn Parker
– Chief Operating Officer (RocketReach profile)
– Confirmed historically; not determinable in 2026
– General service oversight
Operational Structure (Non‑Named Personnel)
• Schools ICT / Orbis ICT – approx. 75 staff
– Web/CMS administration
– Hosting and infrastructure
– Service desk
– Network & systems engineering
Forensic note:
Individual names are not publicly listed, but the structure was fully active in 2026.
7. Forensic Summary (2022–2026)
Executive Responsibility
• Becky Shaw
• Rupert Clubb
Communications Responsibility (Newsroom)
• Warwick Smith
• Karen Bowles
• Paul Crompton
• Ollie Bowen
• Vanessa Souto‑Axell
Technical Responsibility (ICT / CMS)
• Phil Hall
• Schools ICT / Orbis ICT team
Figures No Longer in Service (2026)
• Matt Scott
• Laura Gooch
• Bridget Osazuwa
• Kate Richmond
• Likely: Mark Jobling
8. Forensic Dossier Summary
The management of ESCC content during 2022–2026—including publication, persistence, and the hard removal of material on 15 April 2026—falls across three active functional clusters:
1. Executive Leadership
• Becky Shaw
• Rupert Clubb
2. Institutional Communications (Newsroom)
• Warwick Smith
• Karen Bowles
• Paul Crompton
• Ollie Bowen
• Vanessa Souto‑Axell
3. Digital Infrastructure (ICT / CMS)
• Phil Hall
• Schools ICT / Orbis ICT team
Information Governance and Blue Badge investigative personnel active in 2022–2024 were no longer in service in 2026 and played no role in the removal process.
Requests for rectification, correction or clarification may be submitted through this correspondence channel for proper consideration within the applicable procedural framework here.
Procedural Closure – Status Recorded
This notification was formally issued to all relevant entities, who were offered the opportunity to provide clarifications or counter‑documentation. As of the present date 30/08/2026, no objections, corrections, or alternative factual reconstructions have been submitted. The notification phase is therefore considered procedurally closed. A right of reply remains available, but any late submissions will not alter the factual framework established during the notification period.
