“No Records. No Decisions. No Problem.” – Sandwell’s Invisible Governance Model

“No Records. No Decisions. No Problem.” – Sandwell’s Invisible Governance Model

There’s a phrase often used in public life:

“If it isn’t written down, it didn’t happen.”

Well, according to Sandwell Metropolitan Borough Council, the opposite now appears to be true:

If it isn’t written down… it’s probably how we run things.

Let’s start with the basics: fishing

Fishing on Sandwell Council land is technically controlled by byelaws.

Those byelaws clearly say:
👉 Fishing is prohibited unless authorised by the Council

So naturally, you’d expect:

• A policy

• A decision

• A record

• A system

Something… anything… that shows how that authorisation actually works

Instead, after months of FOIs, Internal Reviews, and chasing:

There is no documented authorisation framework.

No policy.
No decision notice.
No delegated authority.
No site-level approvals.

Just this:

“It’s generally authorised.”

Ah yes. The “trust us, it’s fine” model of governance.

The policy that disappeared into thin air

It gets better.

The Council:

• Drafted a Fishing Policy

• Consulted on it

• Then… quietly dropped it

So naturally, you’d expect:

• A report explaining why

• A decision record

• A consultation outcome

Nope.

None exist.

Not “withheld.”
Not “exempt.”

Just… not held.

So we now have a public consultation process that:

• started

• ran

• and then apparently vanished without a single recorded conclusion

That’s not policy-making.

That’s policy evaporating.

Wildlife protection? Don’t be silly

Now here’s the bit that should genuinely concern people.

The Council has confirmed:

There are no ecological assessments,
no wildlife risk analyses,
and no site evaluations
relating to angling activity.

Let that sink in.

Activities affecting:

• fish

• birds

• habitats

• water quality

…are taking place on public land without any recorded environmental assessment.

Not “we did one but can’t share it.”

Just:

“We don’t have any.”

Enforcement: if you don’t record it, it didn’t happen

Want to know how many incidents linked to fishing have been recorded?

👉 One.

Across years.

And enforcement action?

👉 Zero.

But here’s the catch (no pun intended):

The Council only records incidents via its online portal.

So:

• Ranger observations? ❌ Not recorded

• Officer notes? ❌ Not recorded

• Verbal reports? ❌ Not recorded

Which means:

If it wasn’t logged online… it effectively never existed.

A perfect system — if your goal is not finding problems.

Pollution, water quality, and “case-by-case” everything

Water quality monitoring?

Not really done.

Formal protocols?

Don’t exist.

Environmental incidents?

Minimal records.

Instead, the approach appears to be:

“We’ll deal with it when it happens.”

Which is comforting… right up until something actually goes wrong.

And the grand finale…

After all of this — every question, every challenge, every Internal Review — the Council has now formally confirmed:

This is their final position
and no further records exist

Not delayed.
Not pending.
Not being reviewed.

Finished.

Locked in.

So what are we left with?

Let’s summarise the “Sandwell Model”:

• Policies started but never concluded

• Activities authorised without documentation

• Environmental safeguards not recorded

• Enforcement not meaningfully tracked

• Governance decisions with no audit trail

All confirmed. In writing.

This isn’t about fishing

This is about something much bigger:

👉 How decisions are made
👉 What gets recorded (and what doesn’t)
👉 Whether public assets are properly governed

Because if this is how one area operates…

where else is the same thing happening?

Next steps

This matter has now been formally referred to the
Information Commissioner's Office.

Not out of choice — but because:

You cannot have transparency without records
and you cannot have accountability without transparency

Final thought

“Sunlight is the best disinfectant.”

But in Sandwell right now…

There’s not much to shine it on.

#Sandwell #FOI #Transparency #Accountability #LocalGovernment #Governance #WildlifeProtection #EnvironmentalProtection #PublicAccountability #OpenGovernment #FOIUK #ICO #Byelaws #FishingPolicy #CouncilFail #TruthMatters #FollowTheEvidence #RecordKeeping #Scrutiny #PublicInterest