To the Legal Team,
East Sussex County Council
County Hall, St Anne’s Crescent
Lewes, BN7 1UE

Subject: Response to Communication Restriction under Unreasonable Customer Behaviour Policy

Dear Legal Team,

I am writing in response to the letter dated 18 November 2024, regarding the restriction placed on my communications with East Sussex County Council under the Unreasonable Customer Behaviour Policy.

Your justification for enacting this policy appears to be flawed as you have not processed or addressed my complaints in accordance with your own terms of business or in compliance with Data Protection legislation.

Key Concerns:

1. No Evidence of Complaint Handling:
   To date, no formal acknowledgment, investigation, or resolution of the issues I have raised has been provided. Under your complaints procedure, you are obligated to process complaints and communicate outcomes in a timely and transparent manner. Without this, the application of the Unreasonable Customer Behaviour Policy is premature and unjustified.
2. Data Protection Non-Compliance:
   My communications relate to substantive concerns about breaches of Data Protection laws. You have neither acknowledged nor investigated these concerns, which is a statutory obligation under the UK GDPR and Data Protection Act 2018. This failure directly impacts the legitimacy of your decision to restrict my communications.
3. Inadequate Application of Policy:
   The policy you refer to cannot reasonably be applied when there has been no fair attempt to engage with or resolve my concerns. Additionally, citing Public Sector Equality Duty without providing evidence of how this has been assessed undermines the credibility of your claim.

Request for Clarification:

I request the following:

• Confirmation that my complaints will be processed under your official complaints procedure, including acknowledgment of the specific data protection concerns I have raised.
• A detailed explanation of how your decision to restrict communication complies with Data Protection law and your internal complaints policy.
• Reassessment of the restriction, given your failure to engage meaningfully with my complaints.

If I do not receive a satisfactory response, I will escalate this matter to the Information Commissioner’s Office (ICO) and the Local Government and Social Care Ombudsman (LGSCO) for review of both the data protection breaches and the council’s failure to follow its own policies.

I trust you will address these points urgently to ensure compliance with your legal obligations and maintain public confidence in the council’s processes.

Yours faithfully,
Martin Newbold

On Tue, Nov 19, 2024 at 5:07 PM East Sussex County Council <inforequests-icw@eastsussex.gov.uk> wrote:

Subject access request
Our reference: 19567481

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Dear Mr Newbold

Please see my attached correspondence. 

Yours sincerely

Anita Cundall

Customer Services Manager

Customer Services Team, Communities, Economy and Transport

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