Let’s Dance Again CIO: Current Status of the Governance Record
A comprehensive Master Foundation Document (“MFD”) has now been consolidated in relation to Let’s Dance Again CIO.
This document is not a social media argument, not a personality clash, and not a campaign against community activity. It is a structured governance record bringing together correspondence, witness material, public posts, regulatory issues, data protection concerns, exclusion evidence, and Freedom of Information disclosures concerning the charity’s operation and oversight.
At its core, the issue remains simple: trustees of a registered charity have been asked clear and repeated questions about governance, financial oversight, safeguarding, conflicts of interest, data handling, and procedural fairness. Those questions have not been substantively answered.
The Trustees
The Charity Commission record shows the trustees as:
- Elaine Costigan
- Debora Dawn Price
- Janet Clarke
These individuals carry the legal responsibility for the governance and conduct of the charity.
That responsibility cannot be delegated away. It cannot be answered by supporters. It cannot be replaced by slogans, public outrage, or moral grandstanding on social media.
What the MFD Now Contains
The current MFD brings together, in one working record:
- Charity Commission status and trustee details
- Published financial summaries and comparator concerns
- Formal governance questions sent to trustees
- A formal data protection complaint
- A Subject Access Request and subsequent non-response
- Exclusion material affecting older beneficiaries
- Witness statements and contemporaneous accounts
- Public posts and comments by non-trustees acting in defence of the charity
- Evidence of trustee acquiescence in that conduct
- FOI disclosures from Sandwell Council concerning Wednesbury Town Hall
- An internal review request challenging the adequacy of that FOI response
- A chronology of escalation and unanswered issues
The purpose of the MFD is not theatrical. It is evidential.
The Core Governance Issues
The present record raises serious questions in the following areas.
1. Trustee Non-Response
Formal written questions have been sent to trustees on multiple occasions covering governance, safeguarding, data handling, exclusions, financial oversight, conflicts of interest, and public statements made on behalf of or in defence of the charity.
No substantive written response has been provided addressing the totality of those issues.
Silence, in these circumstances, is not neutral. It becomes part of the governance record.
2. Exclusion and Procedural Fairness
The record includes evidence of an exclusion letter issued to an older beneficiary, stating that the decision was final and not subject to appeal.
That raises obvious concerns about:
- natural justice,
- proportionality,
- consistency,
- and whether proper procedures were followed.
Where a charity serving older people excludes individuals without transparent process or review, scrutiny is not optional. It is necessary.
3. Data Protection and Special Category Data
Serious questions were raised regarding the collection and handling of personal data, including health-related information and emergency contact details.
Those questions included:
- who is the data controller,
- what lawful basis is relied upon,
- how forms are stored,
- who has access,
- and what safeguards exist where vulnerable people are involved.
Those concerns were not trivial and were put formally.
A later Subject Access Request was also submitted. As matters stand, the apparent failure to respond within time materially aggravates the data-protection picture.
4. Financial Transparency
The published income and expenditure figures do not obviously sit comfortably with the visible scale of activity carried on by the charity.
That is not an accusation of proven wrongdoing. It is a legitimate transparency concern.
Where there are:
- weekly activities,
- regular events,
- frequent use of public venues,
- and multiple streams of visible community operation,
it is reasonable to ask whether the published financial record fully reflects the operational reality, and whether trustees have exercised adequate financial oversight.
5. Conflict of Interest and USP Steels
A further unresolved issue concerns the public association between the charity and USP Steels, a company connected to the Chair’s son.
Questions were asked about:
- the nature and value of any support,
- what the company receives in return,
- whether any conflict was formally declared,
- whether trustee meetings approved the arrangement,
- and whether any branding or public association with Wednesbury Town Hall was known to or accepted by the council.
These are standard conflict-of-interest questions. They remain unanswered.
The Role of Non-Trustees
One of the clearest patterns in the record is that a non-trustee has repeatedly acted as the public voice of attack and retaliation while trustees themselves have remained substantively silent.
That conduct has included:
- personal attacks,
- legal-threat rhetoric,
- repeated public escalation,
- attempts to drag in third-party venues and organisations,
- and efforts to reframe governance scrutiny as harassment or hate.
That is not a proper substitute for trustee accountability.
A charity’s governance cannot lawfully be outsourced to an unofficial attack dog.
What the FOI Has Added
The FOI response from Sandwell Council materially strengthened the record.
It confirmed:
- extensive and repeated use of Wednesbury Town Hall,
- a period of free-use arrangements for community groups,
- a real funding relationship between council and charity,
- council awareness of complaints,
- and, strikingly, the apparent absence of written policy, criteria or guidance governing free use or preferential access during the relevant period.
That matters.
Where a charity is making repeated use of a public building, supported by public grant funding, and concerns are later raised about exclusion, fairness and safety, the expectation of proper governance is stronger, not weaker.
An internal review has now been requested because parts of the FOI response appear incomplete or overly reliant on applicant-supplied documents rather than independent council due diligence.
What This Is Not
This is not an attempt to shut down community activity.
It is not an attack on older people attending events.
It is not an attack on volunteers acting lawfully and properly.
It is not a hate campaign.
It is a documented effort to ensure that a registered charity serving older and potentially vulnerable beneficiaries is run:
- lawfully,
- transparently,
- fairly,
- and in accordance with trustee duties.
The Current Status
As matters stand, the position is this:
- The MFD has been consolidated into a structured evidential record.
- Trustees remain the central decision-makers and legal officeholders.
- Formal governance questions remain unanswered.
- Exclusion and fairness concerns remain live.
- Data protection concerns remain unresolved.
- The SAR issue remains serious.
- FOI disclosures have strengthened the public-interest case for scrutiny.
- The internal review process is now engaged.
- The conflict-of-interest strand remains unanswered.
- Public attacks by non-trustees have not displaced trustee responsibility.
Final Position
This matter is not becoming more trivial with time. It is becoming more defined.
The longer trustees do not answer clear governance questions, the more the absence of answers becomes evidential in itself.
The issue is no longer whether scrutiny was justified.
It plainly was.
The issue is whether the trustees of Let’s Dance Again CIO intend to discharge their duties properly, transparently, and on the record.
Until then, the MFD stands as the clearest available account of the present governance position.
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