Submission sent to ICO

 This is my submission to the ICO sent on 21st December 2025. /i was given permission to publish it last week by the ICO. I will post news when I have some.


 

1 - Is it OK to copy my arguments below for why the information I seek be published on my blog?
 

2 -My attachments have new arguments (along with the earlier correspondence) for why Redbridge should release the information post the ICO preliminary decision.

 

3 -  The text in this email bellow has a first section providing my new common arguments for all five requests which is not in the attachments. 

 

4 -  The second section in this email below has new arguments (which are in my attachments) since the ICO preliminary decision relating to each request without all the earlier correspondence. 

 

5 - I have attached the ICO preliminary notice finding against the Redbridge's claim saying I was vexatious for your ease of convenience.
 

1st Section – Common Argument for all Five requests
 

I am unsure whether Redbridge is withdrawing their old arguments in favour of new arguments post the preliminary ICO decision notice dismissing their claims that I was vexatious. As a consequence of this uncertainty I am maintaining all of my previous arguments should Redbridge be relying on their old arguments too.


In the hope of making my arguments easier to understand I have made five submissions, one for each request, as well as these arguments common to all five requests. For two of my request arguments, I have attached a pdf of the correspondence on the "what do they know" website. 


If Freedom of Information laws fails to win the information I seek I also rely on the Aarhus treaty environmental regulations for all five requests.


All of my arguments for all five requests are supported by two cases, Case CO2888/2008 involving MPs expenses and an ICO decision FS50199197 which are attached for your ease of convenience. The MPs expenses case bears similarities to my requests because paragraph 7 of the decision states

 

Section 40 provides the House with the only exemption which arises for consideration in the present case. It concerns personal information. So far as material it provides: "40 - (1) Any information to which a request for information relates is exempt information if it constitutes personal data of which the applicant is the data subject.”


Redbridge also rely on section 40.


Paragraph 16 of the MPs judgement states:
 

None of the MPs personally made any such claim on their own behalf: the assertion was advanced by the Corporate Officer of the House.”


I wrote to Mr Athwal (copying in the ICO at the same time) earlier this month, asking if he objected to his data being published. He did not reply to me. I also attach an ICO decision FS50199197 which appears to support my argument that Mr Athwal's decision not to object may be relevant. 


The MP expenses judgement has a section about “reasonable expectations”. Councillors until recently had a reasonable expectation that their home address would be published on the council register of interests. Following the murder of two MPs, most Councillors do not list home addresses. I have no objection to Councillors not publishing their home addresses if they believe they may face violent attack as a consequence of publication. 


However, it seems untenable for the Council to argue (albeit implicitly, the Council do not give the threat of violence as a reason for a refusal) rental addresses are to be used by those who may wish Councillors harm. It should be noted that the land registry title deeds for rental properties does not have to list the home address of the Councillor on them. 

 

Redbridge have not made any arguments about how Jas Athwal's security would be compromised by publishing his rental addresses. 


The then Councillor Athwal would have known of the Nolan principles and that any breach of them could cause an investigation into his conduct. The Joe Pike article should have led to the council investigating Councillor Athwal. 


There have been investigations of breaches of the Nolan Code for Cllr Michael Situ, David Lammy MP, Rachel Reeves MP and Angela Rayer MP. It is inexplicable that Redbridge have not announced an investigation into Jas Athwal and so it seems reasonable for the Information Commissioner to order Redbridge to supply the information sought.


While I seek all the information requested, the ICO may have the power to order a partial disclosure. For example the number of rental properties in the borough and the first half of the postcode. A summary of any investigation could be ordered, rather than the full disclosure I seek. Should the ICO decide to make an order for less than all of the information I seek, I expect to appeal, but it would be preferable to very little information being supplied as now. 

======================================================================================================================================

 

2nd Section – Arguments for each request post the ICO preliminary decision


ICO ref: IC 374420-R7X2 / Council ref: 24456217 Managing Agents (My reference 1 of 5) 

 

Please note with five requests and numerous emails I have underlined and made bold my new arguments below in an effort to avoid confusion. 


Redbridge wrote back on the the 5th December 2025 to say the below:
 

London Borough of Redbridge 
 

Andy Walker Your reference:request-1185819-663d7b06@whatdotheyknow.com 

 

Dear Andy Walker 

 

Freedom of Information Act 2000 Thank you for your request for information received on 11 October 2024 This request is being handled under the Freedom of Information Act 2000. Lynton House 255-259 High Rd, Ilford IG1 1NN Resources Support Please reply to: Denise Mercer Business Improvement Manager 02087082118 icw.information@redbridge.gov.uk www.redbridge.gov.uk Our ref: 24456217

 

Date: 5 December 2025 Section 1 of the Freedom of Information Act 2000 provides two distinct but related rights of access to information which impose corresponding duties on public authorities. These are: • The duty to inform the applicant whether or not information is held by the authority and, if so, • The duty to communicate that information to the applicant. Section 17 of the Freedom of Information Act 2000 requires the London Borough of Redbridge, when refusing to provide such information (because the information is exempt within the provisions of the Act) to provide you, the applicant, with a Notice which: 1. a) 2. b) 3. c) states the fact that an exemption has been applied specifies the exemption in question, and states why the exemption applies (if that would not otherwise be apparent) I can confirm that London Borough of Redbridge holds the information you requested. 

 

However we are withholding that information since we consider that the following exemptions apply to it. Request The information is exempt from disclosure under Section 40(2) of the Freedom of Information Act (FoIA). The information is personal data as defined by the General Data Protection Regulation (GDPR). As it is information about someone else, I’m unable to give this to you; release of this information would constitute a breach of Principle a) of the GDPR. Principle a) states that personal data shall be processed (used) fairly, lawfully and transparently and that it shall not be used unless at least one of the conditions in Article 6 of the GDPR is met; in this case none of those conditions have been met. 
 

This response therefore acts as a refusal notice under section 17 of the FoIA. Please quote the reference number 24456217 in any future communications. If you are dissatisfied with the outcome or the handling of your request, you have the right to ask for an internal review. Internal review requests should be submitted within 20 working days of the date of receipt of the response to your original email or letter and should be addressed to: Information Officer, 7th Floor (front), Lynton House, High Road, Ilford, IG1 1NN or sent to icw.information@redbridge.gov.uk If you are still dissatisfied with the Council’s response after the internal review you have a right of appeal to the Information Commissioner at: The Information Commissioner's Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF. Telephone: 01625 545 700 Website: www.ico.gov.uk Although the London Borough of Redbridge has considered your request strictly in accordance with the Act, if any or all of the information provided is to be published or broadcast, we would like the opportunity to comment on the information provided, in so far as that publication or broadcast refers to, or in any way identifies, the London Borough of Redbridge before the information is published or broadcast. The London Borough of Redbridge’s Press Office can be contacted on pressoffice@redbridge.gov.uk


 

Yours faithfully
 

Information Governance and Compliance Lead ENDS COUNCIL EMAIL

 

I maintain all of my reasons mentioned before.

 

On the 20th November 2025 I wrote to the Redbridge Chief Executive, The Redbridge Council Leader and copied in the Redbridge monitoring officer and Jas Athwal MP

 

Dear Claire Hamilton and Councillor Rai

 

Recent developments suggest Redbridge should carry out and publish the outcome of any investigation into whether Jas Athwal MP should have been fined for not having a landlord licence and his sub-standard flats. I rely on breaches of the Nolan code which led to investigations into the conduct of David Lammy MP, Angela Rayner MP, Rachel Reeves MP and Cllr Michael Situ. 

 

Cllr Situ's lack of a licence has led to a report in the Evening Standard which stated - The matter has also been referred to the council’s Monitoring Officer for investigation.”


So far Redbridge is refusing to say if an investigation into Mr Athwal has taken place following the Joe Pike BBC story last year. 


This is unacceptable; there should have two investigations, one by the monitoring officer and another by your landlord enforcement team to make several inspections of the rental properties in question to determine what remedial works needed to be done followed by further inspections to check if the works had been carried out. Guidance on your site and court case involving Redbridge Council and Irene Ekweozoh reported in the Redbridge Guardian suggest Mr Athwal should have fined as a consequence of any investigations. 


The apparent lack of either being done leads to a reasonable suspicion of misconduct in public office. While I am pursuing documents at the Information Commissioners Office to discover if any offence may have been committed it must be right for this issue to be resolved as soon as possible.


I say this because Labour is in charge of the borough and controls planning, education housing etc. It must be reasonable for residents to be concerned that if Jas Athwal is getting preferential treatment because he is a Labour member, other Labour members and their friends may also be getting favourable treatment. It also follows that political opponents who are campaigning for an investigation into Jas Athwal will be unfairly targeted. 


I stand in elections against Labour and have been the subject of unfair and some arguably unlawful actions by Labour: examples are,
 

a- Being fined for leafleting outside the Town Hall. This was clearly politically motivated, the council regulations ban commercial not political leaflets. The video is at my YouTube channel andywalker679 on 25th June 2025. I have not paid the fine and got no decision on my appeal.
 

b- There was a nonsense vexatious claim made by the Council at the ICO recently which was overruled by Commissioner. For the Council to imply that I had around a hundred information requests about Jas Athwal brought the Council and the Labour Party into disrepute. The real figure was around 25 requests over 5 years and only a small number featured Jas Athwal. 


c – During the last General Election when I was a candidate, the Council broadcast was turned off when I was speaking at planning meeting. Purdah was the given purpose. This is a nonsense because Jas Athwal had no such restrictions put on him.

 

d- Restrictions on me and others being able to speak at council meetings. I am the only person to be banned from entering the Town Hall. I say the Human Right Act article 10 protects freedom of speech. While the public do not have a statutory right to address council meetings; should the Council give them that right, what they say is not constrained by the current restrictive standing orders. Instead the lawful restrictions are inciting violence, hate speech etc or the chair of the meeting stopping the member of the public speaking because he/she believes what they are saying is outside the Council's remit. 


Cllr Begum has also been a vocal supporter of the campaign to investigate Jas Arhwal and she has recently been the subject of show trial. How could Cllr Begum get a fair trial when a Labour Cllr was making the complaint and the panel had a majority of Labour Councillors?


During the hearing Cllr Khan made it clear that he had the support of the Labour Whip who was sitting behind him showing how corrupt the process was. I would be grateful if you could tell me by close of business on 27th November:


a – Has an investigation has taken place into Jas Athwal by the monitoring officer about the Joe Pike story? Especially since Mr Athwal relied upon a managing agent for not having a licence and the poor state of his properties. The Redbridge landlord register suggests he did not have an agent and so leads to the concern that he or his family managed the properties. 

 

b- Did your landlord licensing department investigate Jas Athwal's properties for the reasons given above and if so what was their conclusions? 

 

Regards


 

Andy Walker ENDS EMAIL


My additional grounds to the ICO are that: Redbridge is wrong to claim that the information must be withheld because it is personal data. I rely on the recent investigations of David Lammy MP, Angela Rayner MP, Rachel Reeves MP and Cllr Michael Situ. 

All four persons were investigated for an apparent breach of the Nolan code of conduct for elected representatives. Jas Athwal MP and at the time of the BBC story, Councillor Athwal should have faced a transparent investigation by the monitoring officer.

I made this clear to Claire Hamilton and Cllr Rai in the 20th November email copied above, but they still refuse to say if an investigation took place. I copy them into this email to give them another opportunity to say if an investigation took place.

When a public authority like Redbridge Council refuses to carry its legal obligations to carry out and publish an investigation into whether Jas Athwal should have been fined for not holding landlord licenses then the ICO should intervene to publish the information I request. This would allow me and others to judge whether a prosecution for misconduct in public office should be pursued. 

I say publication of the information I seek is in the public interest to maintain public confidence in the rule of law in Redbridge.

 

===========================================================================================================================================


ICO ref: IC 374451-T4B4 / Council ref: 24670698 Councillor Athwal Investigation (My reference 2 of 5)


 

Redbridge wrote on the 5th December 2025 per the below: 

 

 

Andy Walker‏
 

London Borough of Redbridge
Lynton House 
255-259 High Rd, 
Ilford IG1 1NN

 


 

 

Resources Support‏

 


Please reply to:

 

s‏

 

 ‎Information Governance and Compliance Lead‏

 

???

 

xxx.xxxxxxxxxxx@xxxxxxxxx.xxx.xx
www.redbridge.gov.uk

 

 

 

 Our ref: 24670698

 

 

 

Date: 5 December 2025

 

 

Your reference:xxxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxxxxx.xxx

 

Dear ‎Andy Walker‏

 

Freedom of Information Act 2000

 

Thank you for your request for information received on  26 October 2024

 

 

This request is being handled under the Freedom of Information Act 2000. 

Section 1 of the Freedom of Information Act 2000 provides two distinct but related rights of access to information which impose corresponding duties on public authorities. These are:

  • The duty to inform the applicant whether or not information is held by the authority and, if so,

  • The duty to communicate that information to the applicant.

Section 17 of the Freedom of Information Act 2000 requires the London Borough of Redbridge, when refusing to provide such information (because the information is exempt within the provisions of the Act) to provide you, the applicant, with a Notice which: 

  1. a)      states the fact that an exemption has been applied

  2. b)      specifies the exemption in question, and

  3. c)      states why the exemption applies (if that would not otherwise be apparent)

I can confirm that London Borough of Redbridge holds the information you requested. However we are withholding that information since we consider that the following exemptions apply to it.


Request 

 

The information is exempt from disclosure under Section 40(2) of the Freedom of Information Act (FoIA). The information is personal data as defined by the General Data Protection Regulation (GDPR). As it is information about someone else, I’m unable to give this to you; release of this information would constitute a breach of Principle a) of the GDPR. Principle a) states that personal data shall be processed (used) fairly, lawfully and transparently and that it shall not be used unless at least one of the conditions in Article 6 of the GDPR is met; in this case none of those conditions have been met. This response therefore acts as a refusal notice under section 17 of the FoIA. 

 

Please quote the reference number 24670698 in any future communications.

 

If you are dissatisfied with the outcome or the handling of your request, you have the right to ask for an internal review. Internal review requests should be submitted within 20 working days of the date of receipt of the response to your original email or letter and should be addressed to: Information Officer, 7th Floor (front), Lynton House, High Road, Ilford, IG1 1NN or sent to icw.information@redbridge.gov.uk If you are still dissatisfied with the Council’s response after the internal review you have a right of appeal to the Information Commissioner at: 

 

The Information Commissioner's Office

 Wycliffe House Water Lane 

Wilmslow 

Cheshire

 SK9 5AF. 

Telephone: 01625 545 700 

Website: www.ico.gov.uk 

 

Although the London Borough of Redbridge has considered your request strictly in accordance with the Act, if any or all of the information provided is to be published or broadcast, we would like the opportunity to comment on the information provided, in so far as that publication or broadcast refers to, or in any way identifies, the London Borough of Redbridge before the information is published or broadcast. The London Borough of Redbridge’s Press Office can be contacted on pressoffice@redbridge.gov.uk

 

Yours faithfully 

 


Information Governance and Compliance Lead

 

My Original Request Below of 26th October 2024

 

In an email dated 24th October your monitoring officer wrote to me concerning Cllr Athwal as follows:

"Thank you for your e-mail. The Council applies its policies and procedures appropriately and consistently, this includes the consistent application of residents’ general right to confidentiality. Your reference to an apparent offence of misconduct in public office is baseless and without merit and will not be commented on further." ENDS QUOTE

I seek all emails from senior staff about whether an investigation into whether Cllr Athwal should be commenced about him not holding a landlord licence as reported by the BBC earlier this year.

I expect the staff to include the monitoring officer, the Chief Executive, the Leader of the Council and the Head of the selective landlord licencing department.

I say the Nolan principles in public life mean these emails should be published in the public interest. ENDS MY REQUEST

 

Council Response 

 

The information is exempt from disclosure under Section 40(2) of the Freedom of Information Act (FoIA).  The information is personal data as defined by the General Data Protection Regulation (GDPR). As it is information about someone else, I’m unable to give this to you; release of this information would constitute a breach of Principle a) of the GDPR. Principle a) states that personal data shall be processed (used) fairly, lawfully and transparently and that it shall not be used unless at least one of the conditions in Article 6 of the GDPR is met; in this case none of those conditions have been met. This response therefore acts as a refusal notice under section 17 of the FoIA. 

Please quote the reference number 24670698 in any future communications​.

 

As set out by the Information Commissioners Office in their Decision Notice if you are still dissatisfied with the Council’s response we will not delay matters with an internal review. You therefore have a right of appeal to the Information Commissioner at:

The Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF.
Telephone: 01625 545 700
Website: www.ico.gov.uk

  

Although the London Borough of Redbridge has considered your request strictly in accordance with the Act, if any or all of the information provided is to be published or broadcast, we would like the opportunity to comment on the information provided, in so far as that publication or broadcast refers to, or in any way identifies, the London Borough of Redbridge before the information is published or broadcast.   The London Borough of Redbridge’s Press Office can be contacted on xxxxxxxxxxx@xxxxxxxxx.xxx.xx.

Yours faithfully

‎‏


‎Information Governance and Compliance Lead ENDS COUNCIL EMAIL 

 

I maintain all of my reasons mentioned previously. 

 

On the 20th November 2025 I wrote to the Redbridge Chief Executive, The Redbridge Council Leader and copied in the Redbridge monitoring officer and Jas Athwal MP


Dear Claire Hamilton and Councillor Rai
 

Recent developments suggest Redbridge should carry out and publish the outcome of any investigation into whether Jas Athwal MP should have been fined for not having a landlord licence and his sub-standard flats. I rely on breaches of the Nolan code which led to investigations into the conduct of David Lammy MP, Angela Rayner MP, Rachel Reeves MP and Cllr Michael Situ. 

 

Cllr Situ's lack of a licence has led to a report in the Evening Standard which stated - The matter has also been referred to the council’s Monitoring Officer for investigation.”


So far Redbridge is refusing to say if an investigation into Mr Athwal has taken place following the Joe Pike BBC story last year. 


This is unacceptable; there should have two investigations, one by the monitoring officer and another by your landlord enforcement team to make several inspections of the rental properties in question to determine what remedial works needed to be done followed by further inspections to check if the works had been carried out. Guidance on your site and court case involving Redbridge Council and Irene Ekweozoh reported in the Redbridge Guardian suggest Mr Athwal should have fined as a consequence of any investigations. 


The apparent lack of either being done leads to a reasonable suspicion of misconduct in public office. While I am pursuing documents at the Information Commissioners Office to discover if any offence may have been committed it must be right for this issue to be resolved as soon as possible.


I say this because Labour is in charge of the borough and controls planning, education housing etc. It must be reasonable for residents to be concerned that if Jas Athwal is getting preferential treatment because he is a Labour member, other Labour members and their friends may also be getting favourable treatment. It also follows that political opponents who are campaigning for an investigation into Jas Athwal will be unfairly targeted. 


I stand in elections against Labour and have been the subject of unfair and some arguably unlawful actions by Labour: examples are,
 

a- Being fined for leafleting outside the Town Hall. This was clearly politically motivated, the council regulations ban commercial not political leaflets. The video is at my YouTube channel andywalker679 on 25th June 2025. I have not paid the fine and got no decision on my appeal.
 

b- There was a nonsense vexatious claim made by the Council at the ICO recently which was overruled by Commissioner. For the Council to imply that I had around a hundred information requests about Jas Athwal brought the Council and the Labour Party into disrepute. The real figure was around 25 requests over 5 years and only a small number featured Jas Athwal. 


c – During the last General Election when I was a candidate, the Council broadcast was turned off when I was speaking at planning meeting. Purdah was the given purpose. This is a nonsense because Jas Athwal had no such restrictions put on him.

 

d- Restrictions on me and others being able to speak at council meetings. I am the only person to be banned from entering the Town Hall. I say the Human Right Act article 10 protects freedom of speech. While the public do not have a statutory right to address council meetings; should the Council give them that right, what they say is not constrained by the current restrictive standing orders. Instead the lawful restrictions are inciting violence, hate speech etc or the chair of the meeting stopping the member of the public speaking because he/she believes what they are saying is outside the Council's remit. 


Cllr Begum has also been a vocal supporter of the campaign to investigate Jas Arhwal and she has recently been the subject of show trial. How could Cllr Begum get a fair trial when a Labour Cllr was making the complaint and the panel had a majority of Labour Councillors?


During the hearing Cllr Khan made it clear that he had the support of the Labour Whip who was sitting behind him showing how corrupt the process was. I would be grateful if you could tell me by close of business on 27th November:


a – Has an investigation has taken place into Jas Athwal by the monitoring officer about the Joe Pike story? Especially since Mr Athwal relied upon a managing agent for not having a licence and the poor state of his properties. The Redbridge landlord register suggests he did not have an agent and so leads to the concern that he or his family managed the properties. 

 

b- Did your landlord licensing department investigate Jas Athwal's properties for the reasons given above and if so what was their conclusions? 

 

Regards


 

Andy Walker ENDS EMAIL

 

My additional grounds to the ICO are that:Redbridge is wrong to claim that the information must be withheld because it is personal data. I rely on the recent investigations of David Lammy MP, Angela Rayner MP, Rachel Reeves MP and Cllr Michael Situ. 
 

All four persons were investigated for an apparent breach of the Nolan code of conduct for elected representatives. Jas Athwal MP and at the time of the BBC story, Councillor Athwal should have faced a transparent investigation by the monitoring officer.

I made this clear to Claire Hamilton and Cllr Rai in the 20th November email copied above, but they still refuse to say if an investigation took place. I copy them into this email to give them another opportunity to say if an investigation took place. While I maintain my request in its entirety, I point out that every landlord is required to name their managing agent on the publicly available Redbridge register. Therefore, at the very least the ICO appears bound to release the name of Jas Athwal's agent. 

When a public authority like Redbridge Council refuses to carry its legal obligations to carry out and publish an investigation into whether Jas Athwal should have been fined for not holding landlord licenses then the ICO should intervene to publish the information I request.

This would allow me and others to judge whether a prosecution for misconduct in public office should be pursued. 

I say publication of the information I seek is in the public interest to maintain public confidence in the rule of law in Redbridge

 


====================================================================================================================================

 

CO ref: IC 356463-L5H6 / Council ref: 23837929 (My reference 3 of 5) Information regarding Councillor Athwal

 

I applied to the ICO, and the ICO issued a preliminary decision notice which is attached for your convenience.

 

Redbridge wrote back on the 5th December to say the below (cut and pasted from the What do you know site)


 

London Borough of Redbridge, Redbridge Borough Council 5 December 2025

WhatDoTheyKnow has identified Redbridge Borough Council may have refused all or part of your request under Section 40Get help to challenge it.

Information request
Our reference: 23837929
Your reference: [FOI #1169976 email]

Dear Andy Walker
 
Freedom of Information Act 2000
 

Further to the ICO's instruction within their Decision Notice issued 6th
November 2025 for us to reconsider your request, we have concluded that
the information you have requested is exempt under Section 40(2) of the
Freedom of Information Act 2000.  The information concerned constitutes
personal data of a third party(or parties) and is, as such, exempt from
disclosure.  This application is an absolute exemption and therefore there
is no requirement to conduct a Public Interest Test in this regard.

 

Should you be unsatisfied with this response, you will note the ICO
invites you to engage with them without the requirement for the local
authority to conduct an internal review.

 
 
Yours faithfully


Information Governance and Compliance Lead
London Borough of Redbridge ENDS REDBRIDGE EMAIL

 

t should be noted at the time of writing my original request Mr Athwal was a Councillor and an MP. My reply to Redbridge's response of 5th December is as follows;


 

1 - Redbridge previously relied upon the localism act re the rental addresses and  s40(5A) and (5B) FOIA. In their internal review copied in the attachment "Send 3..", Redbridge then changed their position to call me vexatious.

 

2 – The vexatious claim failed and now Redbridge have provided a third ground relying upon Section 40(2) which reads:

 

Any information to which a request for information relates is also exempt information if—

(a) it constitutes personal data which do not fall within subsection (1), and

(b) either the first or the second condition below is satisfied”

 

3 – I say Councillors have to declare their rental addresses on their register of interests. This is their duty under the Section 30 of the localism act 2011 copied below:


 

Disclosure of pecuniary interests on taking office 

(1) A member or co-opted member of a relevant authority must, before the end of 28 days beginning with the day on which the person becomes a member or co-opted member of the authority, notify the authority's monitoring officer of any disclosable pecuniary interests which the person has at the time when the notification is given.

And


 

  1. Where a member or co-opted member of a relevant authority gives a notification for the purposes of subsection (1), the authority's monitoring officer is to cause the interests notified to be entered in the authority's register (whether or not they are disclosable pecuniary interests).


 

4 - Councillors have the right to remove property addresses from the register. However, this is not an absolute right, Councillors have to show publication would lead to “violence or intimidation of them or their family” per the extract from a letter written by Simon Hoare MP to Council Chief Executives in England


 

Withholding details of councillors’ sensitive interests and home addresses 


 

18 March 2024


 

In response to recent concerns from elected members about intimidation in public life, I want to ensure that all councillors and elected mayors are aware of the sensitive provisions in Section 32 of the Localism Act 2011.1 The sensitive interests’ provisions provide for details about a registered interest to be excluded from versions of the Register of Interests available for public inspection (or published online) where a member and monitoring officer agree that the disclosure of that interest could lead to violence or intimidation of them or their family.

 

They provide for members to disclose that they have an interest but for the details to be withheld from the public register. On receipt of this letter, I would be grateful to you bringing the contents to the attention of all current members of your Council and your Council’s Monitoring Officer. 
 

The Government encourages monitoring officers to look sympathetically at accommodating requests for the withholding of home addresses from published versions of the register of interests where there are legitimate concerns of violence or intimidation. 

 

Previously the Prime Minister, when Minister for Local Government in 2019, wrote to all Leaders of local authorities in England on this matter. I want to refresh awareness of the sensitive interests’ provisions among the current cohort of councillors in response to recently raised concerns about councillors’ personal safety. This letter will be published on gov.uk for guidance purposes. I remain grateful to all those who serve their communities as local council members. “ ENDS EXTRACT

 

5 Redbridge have not claimed the exemption available to them in my paragraph 4 of: 


 

disclosure of that interest could lead to violence or intimidation of them or their family.”


 

6 Therefore, I argue that the ICO is duty bound to order Redbridge to allow all of Mr Athwal's properties owned in Redbridge to be published with the exception of his home address.


 

7 It should be noted that as at 16th December 2025 Redbridge Councillor Muhammed Javed lists his rental properties on his register per the extract cut and pasted  below:
 

"Do you have any beneficial interest in land which is within the area of the Council.


 

Address/Description of Land

65 Woodland Road, IG1 (A,B,C)

Home Address withheld pursuant section 32(2) of the Localism Act 2011


8 The old landlord register attached shows Redbridge named Jas Athwal's rental property addresses. The new digital version only shows one of Mr Athwal's properties via a name search today on 16th December. It is not know why only one is listed at 16th December. 


 

9 – Even with only one property on the landlord public register for Mr Athwal, an inconsistency is shown in the Redbridge argument. Redbridge argues that Mr Athwal's council register of interests must not have his rental addresses, but it seems OK to have a rental address listed on the publicly available landlord register.


 

10 – ICO decision notice FS50199197 says at paragraph 46: 


 

Is disclosure fair and lawful?

 

  1. In considering whether disclosure would be fair and lawful the Commissioner has taken into account a number of criteria, including: 

• Whether the information relates to an individual’s public life (i.e. their work as a public official or employee) or their private life (i.e. their home, family, social life);

• The reasonable expectations of the individuals as to what would happen to their personal data;

• Whether the individuals have objected to disclosure. 


 

11 - I say the information regarding rental addresses clearly comes under the public official role because Mr Athwal knew he would have to disclose his rental addresses on the Councillor register of interests without a reasonable excuse of a threat to him or his family caused by disclosure of the addresses.

This would also meet the reasonable expectation test. I also wrote to Mr Athwal on the 10th December 2025 (which was copied to the ICO) saying 


 

I would be grateful if you could tell me if you object to your personal data being disclosed by close of business on Friday 12th December per the ICO preliminary notice dated References: IC-356463-L5H6, IC-364257-X2Q0, IC-374420-R7X2, IC-374451-T4B4 & IC-374441-Q4B6?I would be sympathetic to a reasonable extension should you wish to obtain legal advice.
 

If I do not hear from you I am minded to draw this to the attention of the ICO”


 

Mr Athwal did not reply to me. 


 

12 – If my arguments fail I also rely on environmental regulations based on the Aarhus Convention. In particular the three pillars.

 

13 – I say the fair implementation of the Redbridge Landlord Licensing scheme which my requests relate to is covered by Aarhus because it protects the built and natural environment. Energy performance certificates which are part of the Council scheme are designed to reduce CO2 emissions.


 

14 – If the ICO agrees that Mr Athwal and Redbridge Council does not have a reasonable excuse for non-disclosure of his rental addresses then I argue it follows that I should have access to “All correspondence between Redbridge Council and Councillor Athwal regarding landlord property licences for all the rental properties owned by Cllr Athwal in Redbridge” I clarified the dates for correspondence to be from between 1st January 2024 to the 1st September 2024. 


15 – I rely on the arguments I used before at the internal review stage which are cut and pasted below


 

Dear Redbridge Borough Council,

 

Please pass this on to the person who conducts Freedom of Information reviews.

I am writing to request an internal review of Redbridge Borough Council's handling of my FOI request 'Information regarding Councillor Athwal'.

Thank you for your reply. In short Redbridge claims Mr Athwal is a private individual, as well as an elected representative, and as such his right to privacy trumps the right for the public to know the information I seek.

Taking the first part of my request regarding the address of Mr Athwal's rental properties, it is a fact that these were previously disclosed. This disclosure allowed Andrew Boff AM to visit Mr Athwal's properties and found them to be sub-standard. A BBC investigation found Mr Athwal did not hold the selective landlord licences required by law.

The tests for a successful prosecution were set out in a court case reported by the Wanstead Guardian dated 9th August 2021 titled “Landlord wins court battle with Redbridge Council over fine”

Judge Martin Rodger QC scrapped the initial £2500 fine for the landlord for these reasons:

1 The landlord only had one property for rent.

2 The landlord had been absent from the UK for ten years.

3 An officer inspection found the rental flat in good condition.

None of these three tests apply to Jas Athwal, suggesting a clear duty on Redbridge to pursue a prosecution.

The Nolan principles and the Aarhus environmental regulations compel Redbridge to disclose the rental agreements. Nolan puts higher standards of transparency and accountability on elected representatives . Without the publication of the rental addresses, the BBC story would not have run and the public would not have known the poor state of his rental properties.

Aarhus is designed to empower individuals to protect the environment from governments who are damaging our planet. The landlord licence scheme protects our environment by monitoring landlords, especially by making sure landlords comply with energy performance certificate regulations. For Aarhus to work with regard landlord licencing the whole register should be published, as it has be done in the past by Redbridge.

Taking the second part of my request, it appears the senior officers of the council may have committed the offence of misconduct in public office. To investigate if this claim is credible I require the emails about Mr Athwal to discover if any reasonable person would have investigated Mr Athwal and or his agent for not holding a licence.

A full history of my FOI request and all correspondence is available on the Internet at this address: https://www.whatdotheyknow.com/request/i...

Yours faithfully,

Andy Walker

 

===========================================================================================================================================

 

CO ref: IC 364257-X2Q0 / Council ref: 24558362 (my reference 4 of 5) 

Dates of Cllr Athwal's landlord inspections


 

1 -This is part 2 of my reply to Redbridge's refusal to my request dated 5th December 2025.


2 - Part one attached is a copy of the history of the request taken from the What do they know website.


My original request dated 18th October 2024 said:


Dear Redbridge Borough Council,

I seek the dates of when Cllr Jas Athwal 15 rental properties located in Redbridge were inspected under the Redbridge Council landlord licensing scheme.

To be clear, I only seek the dates of the inspections not the contents of the inspection reports.

The period I seek is from the inception of the scheme until 17th October 2024.

Yours faithfully,

Andy Walker


3 – The initial Redbridge refusal was 


The Council can neither confirm nor deny that it holds the information relevant to your request as the duty in section 1(1)(a) of the Freedom of Information Act 2000 (“FOIA”) does not apply by virtue of the following exemptions upon which this Council relies: Section 30 FOIA; and Section 30(3). “ dated 22nd November 2024.

 

4 – I can find no reply to my request for an internal review from Redbridge. Following an ICO preliminary notice, which is attached for your ease of convenience, Redbridge have written back to me with new grounds for refusal dated 5th December 2025 as follows:

 

Dear Andy Walker
 
Freedom of Information Act 2000
 
Further to the ICO's instruction within their Decision Notice issued 6th
November 2025 for us to reconsider your request, we have concluded that
the information you have requested is exempt under Section 40(2) of the
Freedom of Information Act 2000.  The information concerned constitutes
personal data of a third party(or parties) and is, as such, exempt from
disclosure.  This application is an absolute exemption and therefore there
is no requirement to conduct a Public Interest Test in this regard.

Should you be unsatisfied with this response, you will note the ICO
invites you to engage with them without the requirement for the local
authority to conduct an internal review.

 
Yours faithfully


Information Governance and Compliance Lead
London Borough of Redbridge

5 – It seems Redbridge have abandoned their earlier position. However, I stand by earlier arguments contained in part 1 attached. 

 

6 – If Redbridge are now relying exclusively on Section 40(2) of the
Freedom of Information Act 2000 then similar arguments for disclosure are used per my 3 of 5 attachment ICO ref: IC 356463-L5H6 / Council ref: 23837929. 

 

 

7 - IC 356463-L5H6 is about (i)Councillor Athwal's rental addresses and (ii) internal Redbridge Council emails regarding landlord property licences for all the rental properties owned by Cllr Athwal. Similar arguments will be made here because landlord inspections, if any took place, fall under the Council emails regarding landlord property licences for all the rental properties owned by Cllr Athwal
 

8 – The purpose of this request is to discover how many inspections of Cllr Athwal's properties took place and when they took place to see if Cllr Athwal has received favourable treatment due to his status as a Councillor and MP.


9 – If the ICO agrees with me that Councillor Athwal's rental addresses should be disclosed then I argue then the public should have access to records such as the date of the inspections of these rental properties took place.


10 – The arguments made in IC 356463-L5H6 are amended slightly below


– If the ICO agrees that Mr Athwal and Redbridge Council does not have a reasonable excuse for non-disclosure of his rental addresses then I argue it follows that I should have access to the council inspections of his rental properties.

 

11 – I rely on the arguments I used before at the internal review stage which are cut and pasted below with some deletions and additions.


Dear Redbridge Borough Council,

Please pass this on to the person who conducts Freedom of Information reviews.

I am writing to request an internal review of Redbridge Borough Council's handling of my FOI request 'Information regarding Councillor Athwal'.

Thank you for your reply. In short Redbridge claims Mr Athwal is a private individual, as well as an elected representative, and as such his right to privacy trumps the right for the public to know the information I seek.

Taking the first part of my request regarding the address of Mr Athwal's rental properties, it is a fact that these were previously disclosed. This disclosure allowed Andrew Boff AM to visit Mr Athwal's properties and found them to be sub-standard. A BBC investigation found Mr Athwal did not hold the selective landlord licences required by law.

The tests for a successful prosecution were set out in a court case reported by the Wanstead Guardian dated 9th August 2021 titled “Landlord wins court battle with Redbridge Council over fine”

Judge Martin Rodger QC scrapped the initial £2500 fine for the landlord for these reasons:

1 The landlord only had one property for rent.

2 The landlord had been absent from the UK for ten years.

3 An officer inspection found the rental flat in good condition.

None of these three tests apply to Jas Athwal, suggesting a clear duty on Redbridge to pursue a prosecution.

The Nolan principles and the Aarhus environmental regulations compel Redbridge to disclose the rental agreements. Nolan puts higher standards of transparency and accountability on elected representatives . Without the publication of the rental addresses, the BBC story would not have run and the public would not have known the poor state of his rental properties.

Aarhus is designed to empower individuals to protect the environment from governments who are damaging our planet. The landlord licence scheme protects our environment by monitoring landlords, especially by making sure landlords comply with energy performance certificate regulations. For Aarhus to work with regard landlord licencing the whole register should be published, as it has be done in the past by Redbridge.

It appears the senior officers of the council may have committed the offence of misconduct in public office. To investigate if this claim is credible I require the emails about the dates of any inspections of Cllr Athwals rental properties to discover if any reasonable person would have investigated Mr Athwal and or his agent for not holding a licence.

A full history of my FOI request and all correspondence is available on the Internet at this address: https://www.whatdotheyknow.com/request/i...

Yours faithfully,

Andy Walker

==============================================================


 

ICO ref: IC 374441-Q4B6 / Council ref: 25167709 


 

Notices to landlord

 

1 – This is part two of my reply to Redbridge's refusal to my request 5th December 2025. Part one is a copy of the history of the request taken from the What do they know website.

2 My original request dated 2nd December 2024 said :

Dear Redbridge Borough Council,

An article at https://propertyindustryeye.com/fines-fo... entitled "Fines for non-compliant landlords exceeds £10m in London
April 10, 2024 in Property Industry Eye| Marc da Silva" writes

"Redbridge Council have also revealed the results of their enforcement efforts from recent licensing measures, with 3,000 notices served..."

I seek under the environmental regulations or freedom of information law.

1) How many notices were issued to selective licence landlords for the period 1st July 2024 to 1st December 2024 including their dates of issue.

2) The names of the landlords or their managing agents.

3) The contents of the notice.

The grounds for issuing notices are set out in the Redbridge "Private Sector Housing Enforcement Policy" 2023.

If you feel you you cannot release all the information, then please send what you believe your duty is to disclose.

Yours faithfully,

Andy Walker


 

3 – On 9th January 2025, Redbridge provided the answer to my point one which is “148 notices were issued to selective licence landlords between the 1st July and 1st December 2024.” Redbridge refused my points 2 and 3 listed above in (2).


 

4 I sought an internal review per the below on the 22nd January 2025 stating:

 

Dear Redbridge Borough Council,

Please pass this on to the person who conducts Freedom of Information reviews. I am writing to request an internal review of Redbridge Borough Council's handling of my FOI request 'Notices to landlord'.

Thank you for your reply in which you state:
"148 notices were issued to selective licence landlords between the 1st July and 1st December
2024."

I note you refuse to supply the names of the landlords, how are potential tenants to know if landlords are complying with their duties if their names are not published? It must be in the public interest for these landlords to be named as part of the drive to improve rental standards in the private sector.

Naming the landlords and the contents of the notice will also hold the authority to account as it would provide an incentive the Council to keep on top of repairs required in a timely manor. Should the data I seek be published periodically it would help encourage competition between London Boroughs to who has the best quality private rental stock.

I expect Cllr Jas Athwal MP to have got a notice within this period, if not it may be helpful to the gathering evidence for a misconduct in public office charge.

I hope you will grant my appeal in due course.

A full history of my FOI request and all correspondence is available on the Internet at this address: https://www.whatdotheyknow.com/request/n...

Yours faithfully,

Andy Walker


5 – The Council replied, I was unable to cut and paste their reply, however should the Commissioner wish to go to my part one pdf, the link there should provide the review.

 

6 – I made an appeal to the ICO, the decision notice is attached for your convenience.
 

7 – The latest Redbridge reply is below dated 5th December; 2025

Dear Andy Walker
 
Freedom of Information Act 2000
 
Further to the ICO's instruction within their Decision Notice issued 6th
November 2025 for us to reconsider your request, we have concluded that the information you have requested is exempt under Section 40(2) of the Freedom of Information Act 2000.  The information concerned constitutes personal data of a third party(or parties) and is, as such, exempt from disclosure.  This application is an absolute exemption and therefore there is no requirement to conduct a Public Interest Test in this regard.  We have already provided a response to the first of this particular request.
 
Should you be unsatisfied with this response, you will note the ICO
invites you to engage with them without the requirement for the local
authority to conduct an internal review.
 
Yours faithfully


Information Governance and Compliance Lead
London Borough of Redbridge



8 - I argue:
 

a) In addition to my arguments above which I maintain: Mr Athwal was a Councillor at tine of the BBC report in 2024 and as such under greater scrutiny than others. Should my argument win that Mr Athwal has to disclose the addresses of his rental properties because they should have been on the Councillor register of interests it follows that reasonable scrutiny of his properties should take place. This includes how many notices were served on him in the period sought.


 

b) I also say that Landlords are under greater scrutiny than others. This includes how many notices were served on them in the period sought.

Regards


 

Andy Walker


 

My Attachments

 

High Court Case CO2888/2008

ICO decision Reference: FS50199197 

ICO Preliminary Decision  


Comments

Popular posts from this blog

Jas Athwal MP and the Rogue Landlord Allegations: A Year On, Still No Transparency

David Lammy MP, Angela Rayner MP, Rachel Reeves MP and Cllr Michael Situ were all investigated: Why not Jas Athwal MP?

Report from 10 Downing trip