Disclosure escalation map
Disclosure escalation map · Status: working map, our case, not a finding of any court · Version 1.0.0 · Prepared 19 Oct 2026 by Tab (for Sion Buckler)
For each body: what was asked, what came back, which exemption or refusal was used, which deadlines are passed or due, and the next lawful lever. Free routes first. Every request, reply and date is on the Disclosure Rings dartboard; this page adds the next step. Anything sent to a regulator, ombudsman or court is Sion’s decision.
| Body | Asked | What came back / refusal | Deadlines | Next lawful lever | When |
|---|---|---|---|---|---|
| Welsh Government / Cadw | ATISN 27021 (1988 listing records): two 29 Jul 1988 photos released, rest “not held”, reviewed 2 Jul. ATISN 26-0010: “No files were found” (19 Oct). ATISN 27589: refused 19 Oct (ref qA2496208). | FOIA s.14(2) (“substantially similar … no new information”); considered under FOIA, not the EIR | ATISN 26-0009 due 6 Nov. 26-0010 review deadline 14 Dec. Combined reply already sent 19 Oct 23:13. | EIR reg 11 representations on 27589 (no repeat-request rule in the EIR; refusal needs reg 12(4)(b) + public interest test), s.16 / reg 9 advice, preservation (draft ready) | Wed 21 Oct 10:00; then ICO complaint if 27589 stays refused (Sion decides) |
| Vale of Glamorgan Council (FOI) | EIR 00210772 answered 7 Jul (reg 6(1)(b), planning register). Internal review asked 7 Jul. | No decision. 11 Sep: “further historical documentation has been found”, still “sifting”. | EIR reg 11(4) 40 working days passed about 2 Sep 2026. Sion gave until 30 Oct (18 Oct chase). Requests 00211557 / 00211484 / 00211483 / 00211027 pending. | ICO complaint (s.50 via EIR reg 18) for breach of reg 11(4) (draft ready, needs Sion’s OK) | Not before Sat 31 Oct |
| Vale of Glamorgan Council (complaints) | Corporate complaint (failure to respond) July–Aug 2026, acknowledged. | No stage-two outcome found in this pass. | Council timescale passed (dartboard: 18 Sep). | Public Services Ombudsman for Wales (free), once the council’s process is exhausted or overdue | Option for Sion |
| Llandough Community Council | FOIA/EIR request 28 Sep. | Refused 11 Oct under FOIA s.12 (cost). | Review asked; due about 8 Dec. SAR due 13 Nov. | In the review: the EIR have no cost limit (s.12 cannot apply to environmental information; only reg 12(4)(b)); s.16 advice on narrowing. Then ICO. | After the review outcome |
| HM Land Registry | FOI/EIR answered in part; ICR/090/26 decided. | SAR pending. | SAR due 28 Oct. | Combined SAR + EIR email (draft, Tue 20 Oct 09:45); ICO SAR complaint if late (draft held to 29 Oct, needs Sion’s OK) | 20 Oct; 29 Oct |
| Ministry of Justice / HMCTS | Admin records FOIs; SAR (extended); preservation notice. | Court records exempt (FOIA s.32). | FOI due 23 Oct; review due 29 Oct. | Wait. Court-file routes (CPR 5.4C access; CPR 31.17 non-party disclosure) cost money and carry costs risk: listed, not filed | 23 Oct |
| South Wales Police | FOI 1264/26; review of 719/26; SAR. | Earlier “no records held” (719/26). | SAR due 29 Oct; FOI due about 6–9 Nov; review due about 20 Nov. | Wait; ICO if late. Follow-up draft held to 9 Nov | 29 Oct; 9 Nov |
| The National Archives | CAS-359317 and CAS-347296; FOI on location only. | Location answers; one “not held”. | FOI due 6 Nov; review due 20 Nov. | Wait. Then free location-and-content asks for OS 35/2503, IR 90/51/58, IR 94/51/58, MAF 11/55/5333 (found 19 Oct) | After 6 Nov |
| Glamorgan Archives | Bute and land-tax location requests; County Treasures enquiry (sent 19 Oct). | Partly answered; fees quoted for copies. | FOI due 6 Nov; chase draft held to 29 Oct. | In the 29 Oct chase: ask what accession Acc 2002/96 (“Llandough parish, records”) is, and for the list of P35/11–29 (Community Council minutes 1982–2000) | 29 Oct |
| Amgueddfa Cymru – Museum Wales | FOI 2026-024 / 032 / 036. | Review answered 22 Sep; “not held” on outstanding items (12 and 16 Oct). | FOI due 23 Oct. | ICO complaint on the reviewed answers (ICO expects complaints within about 6 weeks of the final reply; that would be early Nov). Sion decides | Decide by about 3 Nov |
| National Library of Wales | Bute estate research enquiries; FOI/2026/09. | Review: “not held” (30 Sep). | FOI due 23 Oct. | Wait | 23 Oct |
| RCAHMW | RC26-0375. | Answered 29 Sep and 13 Oct. | None open. | Written confirmation draft (free). Scan order is paid: hold | Free route only |
| Heneb (formerly GGAT) / HER | HER searches; EIR request. | Refused 16 Oct; Heneb says it is not FOIA-covered and EIR coverage is “a matter of legal determination”. | Complaint target about 3 Nov. | ICO complaint asking the Commissioner to decide whether Heneb is a public authority under EIR reg 2(2) for its HER work. Sion decides | After the complaint answer |
| Dŵr Cymru Welsh Water | EIR of 7 Jun. | Answered about six weeks late (13 Aug): no records. SAR refused 3 Sep. | New EIR/3106/2026 due about 11 Nov. | Wait for 3106, then reg 11 representations; ICO if late | 11 Nov |
| BP / successor | BP Archive records enquiry (sent 19 Oct); preservation. | Earlier “not held” (25 Aug). | None statutory (BP is not a public authority). | BP Properties Ltd (00699446) is still active: its Companies House filings are free to search. No CPR route while there is no live claim | Free search |
| Ordnance Survey | Map-naming request 27 Jun. | Treated as routine business, passed to Customer Services; no reply since. | FOIA s.10 would have expired about 24 Jul if it had been logged as FOI. | Re-frame as FOIA/EIR; confirm or deny; s.16 advice (draft ready) | Tue 20 Oct 12:00 |
| Ministry of Defence | FOI2026/23272; SAR DPR2026/46503. | Logged. | Due about 9–13 Nov. | Wait | 9 Nov |
| Wales Office | 26FOI 103 answered 22 Sep. | Pointed to Welsh Government. | Review due 23 Nov. | Wait | 23 Nov |
| Prime Minister’s Office / Cabinet Office | FOI via WhatDoTheyKnow, Oct 2025. | No reply found in the mailbox (the WhatDoTheyKnow page could not be checked from here). | Long overdue. | Check the WhatDoTheyKnow thread first; an ICO complaint may now be out of time | SOURCE PENDING |
| Loosemores → Hugh James (solicitors) | Not on the dartboard; no correspondence found in this pass. | — | — | SOURCE PENDING: establish which party Loosemores acted for before any approach | — |
| MPs, Senedd and watchdogs | MP casework; Senedd Committee declined 22 Sep. | — | MP draft Tue 20 Oct 10:30. | Senedd Member or MP written question: option only, needs Sion’s OK. Senedd draft stays on HOLD | Sion decides |
Free catalogue finds, 19 Oct 2026: EV-0249 (Western Ground Rents Ltd wound up in 1996 as a dormant BP company), EV-0250 (Welsh Office stopping-up order, Old Barry Road, Llandough, 1992), EV-0251 (BP Properties Ltd, 00699446, still active), EV-0252 (OS object name book OS 35/2503), EV-0253 (tithe redemption IR 90/51/58, IR 94/51/58), EV-0254 (1879 exchange of lands, MAF 11/55/5333). Catalogue-only entries are marked SOURCE PENDING.
Rules: one email per body per day; no cc/bcc; nothing re-asked that is answered or pending; exact quotes; no accusation stated as fact; no paid archive visits or copies before the free routes are used.