Common Corruption With Purpose

Common Corruption – with Purpose Below is given a redacted form of a formal audit into a council. Whilst the report may seek a damage limitation outcome, the findings are a devastating indictment of a corrupt and fake charity working within corrupt councils using corrupt personnel as part of nulabor’s change agenda. Because the formal audit looked solely at the council’s procedures, it is what is not reported that is equally important: - Common Purpose selected the applicants for training, and even then on the basis on their value to Common Purpose, not the ratepayer who was funding the alleged training. - There were no prior declarations of interest among the local authority officers who dealt with both the training arrangements and the FoI requests, and who were also ‘graduates’ of Common Purpose. - Both Common Purpose and graduates of Common Purpose who were local authority officers worked together in a futile attempt to unlawfully frustrate the FoIA, and also in doing so embarked upon a national campaign of defamation, slander and libel against requesters, and in doing so unlawfully releasing their personal details nationally, for which Common Purpose has been rebuked by the Information Commissioner - Decisions were being made that had financial impact upon the ratepayer using mechanisms that bypassed the local democratic processes, the statutory requirements, and mandatory scrutiny. There is much more that could be said not only with this case, but also about Common Purpose exercising power beyond legal authority within other local authorities, institutions, Eurofunding organizations, Quangos and Government Departments. Even the press is tainted by Common Purpose. Whilst the example below is but one example, the association of Common Purpose with ongoing fraud and corruption is actually ubiquitous throughout the country, throughout local authorities, across sectors, geographic borders, and in the EU. Sheffield, for a long time accurately labeled the corruption capital of Europe, is riddled with the influence of Common Purpose. Regular readers have seen how the council regularly and unlawfully shows contempt for the law whenever Common Purpose is involved. Frequently, it has been determined that when fraud and corruption were exposed, those involved were associated with Common Purpose. Readers have also seen what happens to those who raise questions about Common Purpose, or council corruption, or who simply expose this criminality. They are destroyed, publicly humiliated, lied to, lied about, harassed and abused, ruthlessly and relentlessly.

It has already been shown how, especially where control and power mechanisms are concerned, Common Purpose is to be found, i.e. with decision-making about money, who gets what, what for, and the blatant and illegal lack of monitoring. Elected members of Sheffield City Council have already received a list, at Full Council, of the council-associated organizations that are Common Purpose influenced, and work in partnership with council Common Purpose graduates. Despite this, elected members are being denied their right to know who these people are. The ratepayers are also being denied their rights to information. There have to be questions to ask about how it has come about that this corruption and Common Purpose activity has not been brought to the attention of the authorities with purview. ( Targeting of children ! ) As seen in the example below, the unacceptable behavior ( note that the audit findings would have been even harsher had the auditors been given the minutes of Common Purpose meetings – but these are supposed to be secret, as meetings are held under ‘Chatham House’ rules ) has been ongoing for years, yet not one of these incidents has ever been reported upon by the Audit Commission. The same applies not only to Sheffield, but nationally. The question must be, Why NOT? Perhaps the answer can only be surmised, but a quick look at the Common Purpose graduate member list among Audit Commission personnel, the expenditure of the Audit Commission on Common Purpose, the status of the most senior Audit Commission personnel within Common Purpose, and the defiance to publish who their graduates are, all add up to a definitive and undeniable conclusion. Again, we must ask, why have the police NOT acted, and the Crown Prosecution Service NOT prosecuted, when Eurofraud, corruption, and other criminal acts are reported to them, accompanied by objective evidence. As above, the answer is simple, all the institutions, such as South Yorkshire Police ( and other Constabularies ) and the CPS are themselves active supporters and sponsors of Common Purpose. It is highly unlikely therefore that they will embark upon any course of action against their corrupt Common Purpose colleagues within, for example, council departments, the European Secretariat, local devolution mechanisms, or regional partnerships. This non-action is in turn supported by one of the most lucrative supporters of Common Purpose, the Ministry of Justice ( sic ). In their turn, those who have acted corruptly, and / or viciously towards citizens, are amply rewarded with jobs, status, Honours, and of course, vast amounts of money. Below is a redacted version of the formal report. After the report are sample extracts from a few of the findings of the Information Commissioner. Yes, the absolute corruption of Sheffield City Council continues.

RESTRICTED XXXXXXXX COUNCIL AUDIT REPORT REVIEW OF XXXXXXXX COUNCIL’S RELATIONSHIP WITH COMMON PURPOSE 2009/2010 FINAL

Prepared for: XXXXXXXX, Head of Legal. XXXXXXXX, Acting Strategic Director of Corporate Services. XXXXXXXX, Head of Audit & Risk Assurance. Prepared by: XXXXXXXX, Lead Auditor. XXXXXXXX, Internal Audit and Inspection Manager XXXXXXXX XXXXXXXX XXXXXXXX September 2009 Additional circulation list: 2009 Service finance manager XXXXXXXX Head of Finance XXXXXXXX Strategic Director XXXXXXXX Chairman of the Audit and Governance Committee XXXXXXXX Cabinet portfolio holder Chairman of the Corporate Management Select Committee, XXXXXXXX XXXXXXXX, Acting Head of Procurement, XXXXXXXX Procurement (if applicable) XXXXXXXX and XXXXXXXX Chief Executive XXXXXXXX Deputy Leader of the Council XXXXXXXX Prepared for: Audit & Risk Assurance Team Common Purpose - 2009/10 1. INTRODUCTION 1.1 Common Purpose is a registered charity providing training and networking events for leaders of the future. XXXXXXXX Council has used Common Purpose on a number of occasions to provide external training to select applicants. A number of Freedom of Information (FOI) requests have been made around the procurement of Common Purpose services and a potential conflict of interests.

1.2 A review of XXXXXXXX Council’s relationship with Common Purpose was made at the request of the Head of Audit & Risk Assurance and the Head of Legal and was undertaken following agreement of the Terms of Reference included at Appendix A. This report sets out the findings and recommendations of the review. 2. WORK UNDERTAKEN 2.1 The review sought to ensure that: - Any interests were declared in line with the Code of Conduct for staff. - The need for a leadership programme was formally identified prior to entering into a commitment with Common Purpose. - All potential providers were approached to demonstrate Value for Money. - Applicants for training were identified as part of the personal development programme through Step Ahead appraisals. - Training evaluation was completed following attendance to ensure training objectives were met. - The authority met its obligations when responding to subsequent FOI and Data Protection requests. 3. BACKGROUND 3.1 Common Purpose have been used on four separate occasions by XXXXXXXX Council. The table below summarises the expenditure. 3.2 The Navigator training course was arranged by the Democratic Service Lead Manager following discussions as part of the annual appraisal and continuing personal development (CPD) process. A search of potential training courses by the Democratic Service Lead Manager had identified the Navigator course as the most suitable. PO Number Value Date Description 45_93581 £6,050.00 03.09.07 Navigator Course 2-5 Nov 45_144511 £293.75 12.08.08 Leading Beyond Authority Masterclass 45_156428 £41,000.00 14.11.08 InsideOUT Leadership Development Programme Commenced 6 Nov 45_183616 £4,500.00 12.05.09 Meridian Programme commenced 17 June 3.3 Training with Common Purpose was arranged for the Head of XXXXXXXX Highways following development needs recognised through the appraisal process and discussions with the Interim Head of Human Resource (HR) and Interim Strategic Director for Highways and Transportation. The Common Purpose Meridian programme was recommended as the most appropriate. The 2009/10 Procurement Standing Orders require purchases over the value of £5,000 to request three quotes, consequently there was no need to approach alternative providers for the Meridian programme. 3.4 This review has focused on the payment of £41k for the InsideOUT programme.

4. MANAGEMENT SUMMARY 4.1 The review found that the services of Common Purpose were procured without a formally documented assessment of need or appraisal of alternative suppliers. Common Purpose operate leadership development networks and programmes across geographical areas and sought to establish such a network for the XXXXXXXX geographical area. In August 2008 a commitment was made by XXXXXXXX Council to provide £41k to subsidise such a programme in XXXXXXXX. 4.2 Without the formal identification of the need for the leadership training and a comprehensive explanation of the limited market in which Common Purpose operate, and the unique nature of the programme, it is difficult for the authority to demonstrate value for money on the spend of £41k. 4.3 Expressions of interest from XXXXXXXX Council staff were canvassed internally in October 2008 prior to a purchase order being raised and prior to PRG approval being requested in November 2008. When PRG refused approval pending further information a request to approve the Contract Standing Order waiver without further delay was made by Senior Officers and granted by Procurement. 4.4 The failure to follow Procurement Standing Orders and ensure transparency throughout the procurement process has exposed the authority to allegations of cronyism, however misguided. The review uncovered no evidence to suggest that any XXXXXXXX officer made personal gain from the relationship with Common Purpose nor that any officer was involved in the business operation of Common Purpose. 4.5 It is the opinion of internal audit that controls were inadequate to demonstrate value for money and procurement officers did not provide sufficient challenge to the direction of senior members of staff within the Council. 5. FINDINGS AND RECOMMENDATIONS 5.1 Need Assessment Finding 5.1.1 The requirement for a leadership programme had been discussed by the former Chief Executive, the then Interim Head of HR and former Acting Head of PAPA and it was acknowledged amongst the group that, following the Joint Area Review (JAR) and consultation with partners within XXXXXXXX borders, XXXXXXXX Council (XXXXXXXX) had been criticised for being inward focused, arrogant and aloof. It was felt that there was a need for a programme to promote networking opportunities with leaders across XXXXXXXX and that XXXXXXXX leaders should promote the council and take an active role in the community. However, it has not been possible to identify a formal report or correspondence that provides a brief specification or needs assessment for the programme, nor which officers and organisations should be targeted and would benefit the most from such a programme.

5.1.2 Following the above discussions XXXXXXXX committed £41k (excl VAT) to create a programme of leadership training in XXXXXXXX for participants from various public and private organisations. XXXXXXXX sent 4 managers on the programme and subsidised a further 10 places. Attendance at the InsideOUT training, run by Common Purpose, is charged at £3,500 per delegate. Consequently, XXXXXXXX subsidised the Common Purpose programme to create a leadership network in XXXXXXXX. From the invoice issued to XXXXXXXX there are 10 named delegates not employed by XXXXXXXX. 5.1.3 In an email to the former Acting Head of PAPA and Interim Head of HR the Chief Executive proposed that of the 14 places subsidised by XXXXXXXX two places would be from XXXXXXXX, 6/7 from the Voluntary and Community Sector and four from the private/smallmedium sized enterprise sector. 5.1.4 The applications for the programme were sifted by the Chief Executive and Alex Geldart from Common Purpose on the 22 September 2008. A second sift was undertaken on the 21 October. From the invoice issued to XXXXXXXX it has been possible to identify the delegates whose places were subsidised by XXXXXXXX. Chief Executive XXXXXXXX Council for Voluntary Youth Service Director XXXXXXXX Communications Head of Voluntary and Community Services XXXXXXXX Community Action Individual Conciliation Manager acas Director XXXXXXXX Enterprise Hub Managing Partner XXXXXXXX Training & Consultancy Operations Director / Deputy CE XXXXXXXX Housing Association Chief Executive XXXXXXXX Chambers of Commerce XXXXXXXX Diocese Department for Social Responsibility Chief Executive XXXXXXXX Law Society 5.1.5 It has not been possible to determine whether any of these individuals made a contribution to Common Purpose for their attendance fees. 5.1.6 The commitment to support the InsideOUT scheme was acknowledged in August 2008 in email correspondence between Common Purpose and the former Acting Head of PAPA and was conditional on sufficient partner interest being secured. This was two months prior to seeking approval from PRG to commit to the bursary funding, in November 2008. 5.1.7 In October 2008 an email was circulated to the Council Performance Team (CPT), comprising Strategic Directors and Heads of Service, requesting expressions of interest for two delegates on the programme. Four officers replied expressing an interest in the programme and rather than select two candidates from the four it was decided to send all four. After some initial reluctance, Common Purpose agreed to accept all four delegates from XXXXXXXX.

5.1.8 From the above it can be reasoned that the specific need was not formally identified and communicated prior to forming an agreement to commit to the programme. There is no evidence available that formally supports the requirement for the scheme in XXXXXXXX or that identifies the training need for XXXXXXXX managers to attend an external leadership programme. 5.2 Supplier Evaluation Finding 5.2.1 The 2008/091 Procurement Standing Orders (PSOs) required all expenditure over £3,000 to seek three quotes to ensure that the authority had reviewed potential suppliers and could demonstrate value for money and knowledge of the market if challenged. A waiver request was submitted by HR to avoid the need for 3 quotes and to adopt Common Purpose as the chosen provider. The waiver request stated that Common Purpose is a “highly specialist organisation focussing on leadership development in bringing together key leaders across geographical regions”. 5.2.2 The PSO waiver request offers little further explanation of the merits and unique nature of the Common Purpose programmes and there is no evidence to support the requirement that alternative organisations were considered. Neither did the case make explicit mention of the subsidised places XXXXXXXX would be supporting. Therefore, whilst there was no breach of the formal procurement process threshold, the failure to provide a thorough and detailed business case undermined the PRG process. 5.2.3 A number of senior officers interviewed have offered vociferous support for the programmes offered by Common Purpose and stated that there are no direct market comparisons with the leadership training provided by Common Purpose. It was also apparent throughout the investigation that the use of Common Purpose programmes is prevalent across the local government sector, with many senior XXXXXXXX officers having previously attended training whilst working at other authorities. 5.2.4 However, the failure to fully explain the unique nature of the programme offered by Common Purpose and what distinguishes the course from all other leadership training has exposed the authority to the subsequent allegations of cronyism. As innocent as the waiver request may have been, the form submitted to PRG does not provide sufficient evidence to refute such allegations. 5.3 PRG Approval Finding 5.3.1 A contract standing order waiver request was submitted to PRG to avoid the requirement to secure three quotations, necessary for all purchases over £3,000 in the 2008-09 Contract Standing Orders. A request to waive the contract standing orders was heard at PRG on the 5 November 2008, chaired by the Procurement and Commercial Manager.

( 1 The Procurement Standing Orders were changed in 2009/10 to exempt all expenditure under £5,000 from sourcing three quotations. Prior to 2009/10 all expenditure over £3,000 was required to seek 3 quotations. ) The request did not appear on the agenda sent out prior to the meeting as the request was submitted at short notice. This was not untypical. The request was submitted by HR and presented by the HR Practice Manager, as the expenditure would be charged to the central HR training budget. PRG did not give approval to the request and required further information to be provided that could support the request for CSO waiver. 5.3.2 Following the PRG meeting the Procurement and Commercial Manager was challenged by the former Acting Head of PAPA to explain why approval had not been granted. It was reasoned that the programme had the support of the Chief Executive and that Common Purpose were a unique provider in this field. The urgency of the request was also emphasised. Following the discussion approval was given outside of formal PRG discussion by the Procurement and Commercial Manager and sign off was sought from Finance and Legal by email. Approval was granted by the Financial Accounting & Analysis Manager and Contracts and Property Group Manager on the 7 November without further discussions. 5.3.3 This route was not untypical and was seen as an ‘emergency procedure’ for PRG approval. However, the decision to conduct discussion outside of a formal forum and the failure to formally record the reasons for PRG approval has unnecessarily protracted FOI correspondence. 5.3.4 One of the reasons cited for the delay in seeking PRG approval was the difficulty in arranging a meeting between the former Chief Executive and the former Leader of the Council. As a result it was not possible to present the waiver request to PRG before approval had been sought. 5.3.5 When interviewed the former Leader of the Council could not recall any briefing on the topic and expressed the view that it would be unusual for him to be consulted by the Chief Executive for a relatively small amount of expenditure. 5.4 PO Timescale Finding 5.4.1 It is unclear why the request for CSO waiver was made in such expedient circumstances. The funding of the programme had been agreed with Common Purpose in August 2008 (as evidenced in email correspondence between the former Acting Head of PAPA and Common Purpose) and dates for the programme were circulated in October to CPT two weeks before formal procurement approval was sought in November.

Procurement Standing Orders require that all purchasing must be: “…financially approved according to the Council’s Financial Regulations prior to issue to the supplier. Verbal Commitments or Retrospective Purchase Orders are not permitted in any circumstance.” 5.4.2 It is evident from the above that the procurement of the services of Common Purpose in the above instance did not comply with Procurement Standing Orders. 5.5 Training Evaluation Finding 5.5.1 The InsideOUT programme run by Common Purpose promises to use ‘proven leadership techniques developed by Common Purpose over nearly 20 years… to deepen their understanding, broaden their perspectives and expand their leadership capabilities’. The programme focuses on developing individuals’ personal leadership skills and their understanding of networks and relationships with senior leaders. 5.5.2 If challenged, it would be difficult for XXXXXXXX to prove value for money on a large subsidy to an external party that sought to establish a network that focused on the personal development of individuals’ leadership needs, rather than implementing or promoting a programme of leadership training within the authority where the benefit would be aimed at strengthening the organisation’s leadership culture. 5.5.3 Following attendance the programme did offer a valuable learning experience and delegates learnt techniques that would improve their leadership skills and decision making. It should be noted though, delegates from XXXXXXXX felt there would have been greater focus on leadership techniques as opposed to the presentation / seminar style learning that was provided. There was also disappointment that there was not greater representation of delegates from the private sector and that many public sector delegates were already acquainted. 5.5.4 The programme offers delegates an online forum to use to further develop personal contacts following the completion of the training. However, the forum in XXXXXXXX does not appear to be active and has not been used by XXXXXXXX delegates. Whilst the objective of XXXXXXXX was to establish a leadership network in XXXXXXXX between partner organisations, there is little evidence of the network being active and XXXXXXXX delegates have played no further role in the XXXXXXXX forum. 5.5.5 Consequently based on discussion with attendees from XXXXXXXX it is reasonable to question whether the best use of resources was achieved from a leadership and networking programme when there had been no formal or specific acknowledgment of the need for such a programme and where the network would not appear to be active.

5.6 Declaration of Interests Finding 5.6.1 Following a number of FOI requests a member of the public made allegations that the former Chief Executive was associated with Common Purpose as a Director. Company details obtained from Company House provide no evidence to support the allegation that the former Chief Executive was a director of Common Purpose. Whilst there would appear to be a high turnover of Directors there is no mention of the former Chief Executive. 5.6.2 From documents submitted to the authority it is evident that the former Chief Executive was a member of the Common Purpose XXXXXXXX Advisory Group and Local Forum in 2004. At this time he was Chief Executive of XXXXXXXX Council. 5.6.3 The arrangement between XXXXXXXX and Common Purpose in 2008 sought to establish a Common Purpose network in XXXXXXXX, in the former Chief Executive’s email to CPT requesting volunteers for the scheme, he commented: “it has been a regret of mine that no programme existed here (XXXXXXXX). Now we have the opportunity to run a programme for XXXXXXXX that I hope will become a permanent feature in the XXXXXXXX.” 5.6.4 The review could find no evidence of any undisclosed motives to establishing a network in XXXXXXXX, other than previous positive experiences with Common Purpose programmes. 5.6.5 Further to the former Chief Executive’s experience with Common Purpose, it is evident that the former Acting Head of PAPA has attended Common Purpose programmes as a delegate whilst an employee of XXXXXXXX Council. The Interim Head of HR has had previous involvement in establishing a Common Purpose network whilst at XXXXXXXX Council. 5.6.6 There was no evidence found during the review to support any council officer’s direct involvement with Common Purpose or that any XXXXXXXX employees benefited financially from the relationship with Common Purpose. Common Purpose are a legitimate leadership training provider who are used widely across the public sector. However, the unique programmes offered by Common Purpose and officers’ previous association and experience with the organisation’s programmes have muddied the waters of impartiality in the public eye and resulted in the allegations of cronyism. Greater clarity and closer adherence to the authority’s procurement procedures would have provided a more robust defence against the allegations of a conflict of interest that have subsequently arisen.

5.7 Response to FOI requests Finding 5.7.1 The review considered responses to enquiries from members of the public to have been handled fairly and in a timely fashion. However, failure to ensure transparency throughout the procurement process has exposed the authority to accusations of cronyism that, though false, are difficult to refute. Consequently the correspondence between the authority and members of the public has become protracted to the point where it is now a drain on officer time that could have been avoided. 5.8 Value For Money Finding 5.8.1 It is the opinion of the auditor that value for money could not be demonstrated on the subsidy of 10 places on the XXXXXXXX InsideOUT programme. The programme was funded from the central training budget for the authority and was not linked to any of the council’s improvement priorities. Funding secured from the XXXXXXXX Strategic Partnership would have been a more appropriate source for a programme that sought to encourage closer networking across organisations within XXXXXXXX. 5.8.2 Whilst the programme was procured in reaction to criticism of the authority being isolated and aloof, there is neither documented evidence of an appraisal of the organisations to be subsidised nor any criteria that would demonstrate the justification for those delegates chosen. 5.9 Recommendations 5.9.1 The process for submitting late requests to PRG should only occur in exceptional circumstances with good reason. Requests should be recorded in full with supporting documentation where required. Discussion and decisions for granting or refusing PRG approval should be documented to ensure transparency can be demonstrated if challenged at a later date. 5.9.2 Training spend should be linked to the Council's objectives / values / priorities and individuals’ development plans. 5.9.3 An official statement should be released clarifying XXXXXXXX Council’s relationship with Common Purpose and the status of the leadership network within XXXXXXXX. 6. ACKNOWLEDGEMENT 6.1 The assistance and co-operation of all the staff involved was greatly appreciated.

APPENDIX A TERMS OF REFERENCE Common Purpose 2010 BACKGROUND Common Purpose is a registered charity providing training and networking events for leaders of the future. XXXXXXXX Council has used Common Purpose on a number of occasions to provide external training to select applicants. A number of Freedom of Information (FOI) requests have been made around the procurement of Common Purpose services and a potential conflict of interests. PURPOSE OF THE AUDIT The audit will review compliance with the arrangements, as defined within the Council’s Procurement Standing Orders, and draw conclusions and recommendations based on the findings. WORK TO BE UNDERTAKEN The review will seek to ensure that: • Any interests were declared in line with the Code of Conduct for staff. • The need for a leadership programme was formally identified prior to entering into a commitment with Common Purpose. • All potential providers were approached to demonstrate Value for Money. • Applicants for training were identified as part of the personal development programme through Step Ahead appraisals. • Training evaluation was completed following attendance to ensure training objectives were met. • The authority met its obligations when responding to subsequent FOI and Data Protection requests. OUTCOMES The following outcomes will result: • Verbal summary of findings at the end of fieldwork for discussion with key officers; • Draft report of the findings and recommendations for factual accuracy, to include an opinion on the adequacy of controls in operation and whether value for money is being achieved; • Final report with a Management Action Plan (MAP) of recommendations for the service to respond to and implement within agreed timescales. REPORTING ARRANGEMENTS Auditor: XXXXXXXX, Lead Auditor Supervisor: XXXXXXXX, Internal Audit and Inspection Manager Reporting to: XXXXXXXX, Chief Executive Audit Ref: XXXXXXXX / XXXXXXXX

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Comment

Even with the very narrow remit of the audit, and the absence of consideration of external documents, the conclusions are damning.

Please note that even The Law Society has been infiltrated. Corruption within the Solicitors Regulation Authority has already been demonstrated by this citizen in a previous publication, and there is a further SRA corruption report to be published in the next few days.

But one of the most disturbing features is the selection of potential future leaders, by Common Purpose, from among our children. As has been seen in Sheffield, young people are targeted for Common Purpose training and activities, either through the council or via a Housing Association or other third party ( ‘YourTurn’ ) , with absolutely no evidence whatsoever of there having been any of the statutory CRB checks by the local police upon those in contact with the children at these Common Purpose events. Is there still anyone left in the country that doubts whether Sheffield City Council is absolutely corrupt?

It was mentioned before the audit report that Common Purpose had been rebuked by the Information Commissioner. Here are a few examples, as indicated to the complainant. Please note that these are only a few examples from a single citizen, there are literally dozens of similar instances, from over 150 citizens, where the same is happening throughout the country, as part of a national campaign by Common Purpose to not only destroy those who ask legitimate questions of local authorities and institutions about their involvement with Common Purpose, but to criminally show contempt for the law, in this case the FoIA and DPA. Note that the false allegation of vexatiousness also occurs in local, unlawful refusal notices.

· Assessment letter for your complaint against the Ministry of Justice (Reference: RFA0225283); “"Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data." From the information you have provided it appears likely that the MoJ has failed to comply with the seventh principle in this case. This is because steps were not taken to ensure that your personal data was held securely and not passed to Common Purpose.” · Assessment letter for your complaint against London Councils (Reference: RFA0225285); "Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data." From the information you have provided it appears likely that London Councils has failed to comply with the seventh principle in this case. This is because London Councils did not take steps to ensure that your personal data was withheld from Common Purpose when they were approached about your FOIA request. In light of this it is my assessment that it is unlikely that London Councils has complied with the DPA in this case.” · Assessment letter for your complaint against South Gloucestershire County Council (Reference: RFA0225278); “Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data." From the information you have provided it appears likely that the Council has failed to comply with the seventh principle in this case. This is because adequate steps were not taken to ensure that your personal data was held securely and not passed to Common Purpose. In light of this it is my assessment that it is unlikely that the Council has complied with the DPA in this case.” · Assessment letter for your complaint against The Leadership Centre which is now part of the Local Government Association. (Reference: RFA0220083); "Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data." In light of this it is my assessment that it is unlikely that the Leadership Centre has complied with the DPA in this case. This is because they should have taken adequate steps to ensure that your personal data was not provided to a

third party during the course of responding to your FOIA request.” · Assessment letter for your complaint against Common Purpose (Reference: RFA0246793) “You have complained that Common Purpose have obtained information from public authorities about freedom of information requests which have been made to them about the relationship between the public authority and Common Purpose.

This information has been complied into a list which contains details of the request and also personal data such as names and addresses of the requester. This list has then been provided to other public authorities as a way for Common Purpose to demonstrate their view that the requests are vexatious. The first principle states: "Personal data shall be processed fairly and lawfully." From the information you have provided it appears likely that Common Purpose has failed to comply with the first principle in this case. This is because an individual would not reasonably expect Common Purpose to use information which was provided to one public authority in order to deal with a specific request to be passed onto multiple other public authorities. The processing was not therefore fair. In light of this it is my assessment that it is unlikely that Common Purpose has complied with the DPA in this case.” · Assessment letter for your complaint against Cumbria County Council (Reference: RFA0248670) "Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data." From the information you have provided it appears likely that Cumbria County Council has failed to comply with the seventh principle in this case. This is because they did not take adequate steps to ensure that your personal data was separated from the FOIA request before contacting Common Purpose about the information which had been requested. In light of this it is my assessment that it is unlikely that Cumbria County Council has complied with the DPA in this case.”

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Thank you to all those who have worked so hard in providing material for this publication. Throughout the country, fraud and corruption continues to be exposed, and those involved with this corruption are definitely seeking a way out of their predicament. Such is futile. With the death of nulabor, nobody shall be able to avoid being held to account. Given that the Charity Commission has proved itself to be an institutionally corrupt nulabor sycophant ( not least about how it encouraged the use of another local corrupt fake charity, Lowedges Forum, to not only operate without legitimacy, but to launder fraudulently acquired Eurofunds ), Common Purpose has no future.

Best regards

martin