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← Back to Western House Academy Parent Audit · Part 1

We asked five questions. Here is what came back.

In July 2026 one parent sent five statutory requests to Western House Academy and The Park Federation Academy Trust — one for their own child’s records, four for information the public is entitled to. We have checked every reply, line by line, against the law that governs it.

18 failures identified · audit complete
5Requests sent
0Answered in full
18Failures identified
2Records “not held” then disclosed
3Points the school got right

How we did this

We are not going to tell you they got everything wrong.

Because they didn’t. On three points the school and the Trust are correct in law, and we say so below, clearly marked in green. We do that because it is true — and because it is what makes the other eighteen findings impossible to wave away.

Every finding on this page is anchored to the school’s or the Trust’s own written words. Nothing here is our summary of what we think they meant. It is what they wrote, quoted directly, with the law that applies to it set alongside.

We have also removed the names of individual members of staff. This is about how an institution behaved, not about any one person’s conduct.

  • Fail
    A legal duty was not metAn identifiable breach of freedom of information or data protection procedure.
  • Serious
    A governance failureSomething that leaves children less protected, or leaves nobody able to check.
  • Clash
    They contradict themselvesTwo statements that cannot both be true, often in the same letter.
  • Fair
    They are rightA point where the school or Trust is correct and we say so.

Part one · Our own child’s records

A legal deadline, paused by a rule that does not exist.

A Subject Access Request is how any parent asks what an organisation has written down about their child. The law gives it one month.

Finding 01 · Subject Access RequestSerious

The clock was stopped for the summer holidays

The response period will therefore be paused during the school closure period and will resume when the school reopens on 1 September 2026.

There is no provision in data protection law that pauses a subject access request because an organisation is closed. The clock can be paused for two reasons: while identity is being verified, and while a reasonable question about scope is outstanding. Holidays, closures and staff absence are not on that list.

The Trust already had both of those grounds available to it. It did not need a third. It used one anyway.

Why this finding matters more than the others

In three of the four freedom of information replies, the same author correctly explains that school closure rules affect FOI deadlines. That rule is real — for freedom of information. There is no equivalent for a parent asking to see their own child’s records.

So the rule was known. It was applied in a place where it does not exist, and the person it disadvantaged was the parent.

Look at what it adds up to. A request made on 7 July. Paused for roughly six weeks of closure. A further two-month extension already flagged in the same letter. That is a request made in July being answered in November.

Finding 02 · Subject Access RequestFail

Prove who you are — to the school that has been emailing you

The Trust held the request pending proof of identity and parental responsibility.

The parent was already in live email correspondence with the school. They are addressed by name in every letter. The request concerns a referral the school itself made about their child, six days earlier.

Identity checks exist for genuine doubt, and they are supposed to be proportionate. There was no doubt here. What the demand produced was delay.

Finding 03 · Subject Access RequestFair

Asking us to narrow the request was reasonable

The request did cover a great deal of ground. Asking a parent to focus it — and saying plainly what the school will assume if they don’t reply — is exactly how this is meant to work.

Credit where it is due. That part was done properly.

Part two · The money

£6,832.31 raised. £2,641 accounted for.

Bake sales, book fairs, ticketed events. Money given by parents, at a school, on school premises.

Finding 04 · FOI Request 1Clash

“We do not hold that” — and then they held it

The school does not hold a recorded breakdown showing the total funds raised through each school event, school sale or fundraising activity…

Three paragraphs later, in the same letter:

I can confirm that for the accounting period the total raised was £6832.31. Of which £2,641 was provided to Action Aid.

A figure stated to the penny is a figure somebody looked up. The records exist, and they were interrogated to produce that number.

“Not held” and “£6,832.31” cannot both be true of the same accounts — and “not held” is the answer this Trust reaches for more than any other.

Finding 05 · FOI Request 1Fail

Where did the other £4,191.31 go?

£6,832.31 was raised. £2,641 went to ActionAid — 38.7 per cent of it.

The letter says nothing at all about the remaining £4,191.31. Not where it went, not what it bought, not who decided.

That is not a refusal. A refusal would at least name a reason and give us something to appeal. This is silence, and it is the simplest unanswered question on this page.

Finding 06 · FOI Request 1Fail

Sent to documents that do not contain the answer

The Trust relied on the exemption for information “reasonably accessible by other means”, pointing the parent towards Companies House and Get Information About Schools.

Trust-level statutory accounts do not record what a school bake sale took. Sending a parent to a document that cannot answer their question is not accessibility. It is a redirection, and the exemption does not stretch that far.

Finding 07 · FOI Requests 1–4Fail

Nobody offered to help us ask a better question

The real objection is effort. The money is recorded by ledger code and cost centre, not event by event. Fine — that is a normal problem, and there is a proper route for it: refuse on cost, then help the requester reshape the request into something the school would answer.

That duty to advise and assist is a legal obligation, not a courtesy.

Across four freedom of information replies, not one narrower alternative was ever offered. Not once, on any of the requests, on any point.

Finding 08 · FOI Request 1Fair

The PTA really is outside these rules

A PTA is a separate body with its own bank account, and it is not covered by freedom of information law. The Trust is right about that, and we are not going to pretend otherwise.

But look at what it means in practice. Money raised from parents, at a school, on school premises, at school events, sits in a space where no parent has any right to ask where it went.

That is a hole in the law rather than something this school did. It is worth naming as exactly that.

Part three · Safeguarding

One hundred per cent trained, and no way to check.

We asked how the school protects children: the escalation route, the thresholds, the training, the audits.

Finding 09 · FOI Request 2Fail

The claim was given. The proof was withheld.

The school confirms that 100% of current teaching and pupil-facing staff have completed up-to-date safeguarding training.

In the very next section of the same letter, the training matrix and the compliance logs — the only records that could show whether that is true — were refused as staff personal data.

Data protection protects personal information. It does not protect whole filing cabinets. A table of roles, required courses and completion dates, with the names taken out, is not anybody’s personal data.

Redaction was available and straightforward. Blanket refusal was chosen instead, and the figure stays unverifiable by design.

Finding 10 · FOI Request 2Fail

An answer that answers nothing

If the school does not hold a separate internal version of this document, then no further recorded information is held by the school for this part of the request.

The law requires a public body to say whether it holds something. That is the first duty in the Act, before any question of disclosure arises.

“If we do not have it, then we do not have it” is a circle, not a reply. It reads like a sentence written by somebody who never went and looked.

Finding 11 · FOI Request 2Serious

There is no safeguarding records audit. At all.

The school does not hold a standalone document titled “Safeguarding Records Audit”.

Safeguarding, we are told, is “subject to monitoring and review through internal school and Trust safeguarding oversight arrangements”.

But that monitoring leaves behind no dated document, no recorded outcome, nothing anyone can point at.

If there is no record that a safeguarding audit happened, then no governor, no parent and no inspector can confirm one ever did. Oversight that leaves no trace cannot be checked, cannot be challenged, and cannot be relied on when it matters most.

And it does not sit well beside what they told us next

In the fourth reply, the Trust states that the safeguarding policy is subject to annual review.

Reviewed annually — against what, and evidenced how? If the review produces no record either, the word “annual” is doing a great deal of work on its own.

Part four · The numbers

Refused — including the one number that identifies nobody.

We asked how many safeguarding concerns were raised, and how many went to children’s social care, over four academic years.

Finding 12 · FOI Request 3Serious

A warning shot, for asking four questions

…where requests are repeated, overlapping, excessive, or impose a disproportionate burden, the school may consider the relevant provisions of the Freedom of Information Act 2000.

The Trust did not use the vexatious-request provisions. It mentioned them. Then it mentioned them again, almost word for word, in the next reply.

The threshold for calling a request vexatious is high, and it is meant to be about the request, not about a parent’s persistence. Four questions in six days, from a parent whose child had just been referred to social care, is not a campaign of harassment. It is a frightened parent using the rights Parliament gave them.

Putting that sentence in a letter to that parent does one thing. It makes them think twice before sending a fifth.

Of everything on this page, that is the sentence that tells you what they think of parents.

Finding 13 · FOI Request 3Clash

It does not exist — and we are withholding it

The Trust said the data was not held. It then withheld the same data under two separate exemptions.

You cannot keep back something that does not exist. Claiming both at once is what an authority does when it wants the answer to be no whichever way you push — and it is a pattern the Information Commissioner has criticised before.

Finding 14 · FOI Requests 3 & 4Fail

Exemptions used with no reason given

Two of the exemptions relied on are conditional. The Trust has to weigh them against the public interest and explain why secrecy wins. That explanation is not optional; a refusal notice is legally required to contain it.

No public interest test appears anywhere, in any of the four replies.

The exemptions are hedged, too — “where applicable”, “to the extent applicable”, “may rely on”. A refusal has to say which exemption covers which information. Gesturing at a list of them is not a refusal at all.

Finding 15 · FOI Request 3Fail

Even one number a year was too much

We accept part of this one, and we want to be plain about it. In a single primary school, safeguarding figures broken down by year, category, gender and ethnicity really could point at individual children. Small numbers identify people. That objection is real and we are not going to argue with it.

It has nothing whatever to do with the total number of referrals to Slough Children First each year. One figure. Several hundred pupils. It identifies nobody.

That was refused too — the strongest possible objection applied to the weakest possible case.

Why that refusal is a finding in itself

Schools report exactly this figure to their own governing body as a matter of routine. It is one of the basic numbers a governor needs in order to ask whether safeguarding is working.

So either the number exists, and it was withheld from a parent for no good reason — or it does not exist, and the governors have never been told either.

There is no third option, and both of them are worth knowing.

Part five · Who signed it off

One person approved the child protection policy. There is no record of it.

We asked a simple governance question: who approved the safeguarding policy, when, and where is that written down?

Finding 16 · FOI Request 4Serious

A signature nobody wrote down

…the Board of Directors had allocated the responsibility for approving this policy to the CEO… the Trust does not hold a separate voting record, resolution, chair’s action, or electronic approval record.

The child protection policy governing every school in the Trust was approved by one person, with:

  • no vote
  • no board resolution
  • no chair’s action record
  • no electronic approval record
  • and no involvement from the local governing body — published governor minutes are the formal record, the Trust says, “but not applicable in this case”

A trust may lawfully delegate that decision to its chief executive. Nobody is disputing that. What it cannot do is leave behind no evidence that the decision was ever taken.

A decision with no record of being made is not governance. It is an assertion.

Finding 17 · FOI Request 4Clash

No audit trail — followed immediately by the audit trail

The Trust does not hold a standalone tracking log, policy control schedule, or audit trail document of the type requested.

The next paragraph:

25th July 25, new policy drafted including changes from KCSIE 2025. 07 August 25, CEO approval for circulation to all DSLs and Principals.

Two dated events, produced seconds after declaring there was no trail to produce.

That is the second time in four letters that something “not held” turned out to be held. Once is an oversight. Twice is how they answer questions.

And “approval for circulation” is not adoption

Read what the 7 August entry actually records: approval to send the policy out to safeguarding leads and principals.

Approving a document for distribution is not the same as formally adopting it as the policy the school runs on. They are different decisions and they happen at different moments.

On the Trust’s own timeline, no record of formal adoption exists at all.

Finding 18 · FOI Requests 2 & 4Clash

Two letters, two different stories

Asked how staff escalate a child protection concern, the school pointed to its Child Protection and Safeguarding Policy as its own held document — the school’s answer, the school’s procedures.

Asked who approved that policy, the Trust explained it is a central document, signed off by one person, which the school’s own governors never considered.

So the school’s answer on how it protects children rests entirely on a document that no governor at that school has ever approved or scrutinised.

Finding 19 · FOI Request 4Fail

“The Trust will consider disclosure” is not an answer

If any relevant Board, committee, or approval minutes are held but are not already publicly available, the Trust will consider disclosure of the recorded information held.

A public body has twenty working days and two options: hand the information over, or refuse it and say which exemption applies and why.

“We will consider it” is neither. The request was left formally unanswered while appearing, to anyone skimming, to have been answered.

Finding 20 · FOI Request 4Fail

“Have inserted the link”

https://www.westernhouse.academy/attachments/download.asp?file=645&type=pdf
Have inserted the link

Somebody’s note to themselves, left inside a formal legal response about child protection governance, and sent to a parent.

It is a small thing and we nearly left it out. We have kept it because it says the same thing the rest of this page has been saying: nobody read it back before it went out.

The pattern

Read one letter and you see a busy office. Read all five and you see a method.

Eight things happen again and again. Each one appears in at least two separate replies.

Every pattern below is evidenced by the numbered findings on this page.
 What happensWhere
01“Not held” — then disclosed anyway, in the same letter04, 17
02Exemptions used with no public interest reason given14
03Hedged, conditional refusals — “where applicable”, “if not held, then not held”10, 14
04Sent to documents that do not contain the answer06
05Never once offered a narrower question they would answer07
06Vexatious-request provisions raised pre-emptively at a parent12
07A statutory deadline paused with no statutory basis01
08Every decision through one officer and one chief executive — governors absent throughout16, 18

Measured against the standard

The Nolan Principles are not optional for academy trusts.

The Seven Principles of Public Life apply to everyone holding public office, trustees and school leaders included. Four of them are directly engaged by what is on this page. We have used four rather than seven, because stretching to the weak ones would only dilute the strong ones.

Principle · Openness

Openness

“Holders of public office should act and take decisions in an open and transparent manner.”

Exemptions used to deflect rather than to direct. Blanket refusals where redaction was plainly available. A statutory deadline paused with no basis in law. Across five replies, the default setting is to find a reason not to say.

Principle · Accountability

Accountability

“Holders of public office are accountable to the public for their decisions and actions and must submit themselves to the scrutiny necessary to ensure this.”

A child protection policy approved by one person with no record of the approval. No local governing body involvement. No safeguarding records audit in existence. And a warning issued to the parent attempting the scrutiny.

Principle · Honesty

Honesty

“Holders of public office should be truthful.”

Records declared not held, and then produced, twice in four letters. A one hundred per cent training figure asserted while the only evidence capable of supporting it is refused.

Principle · Leadership

Leadership

“Holders of public office should exhibit these principles in their own behaviour and treat others with respect.”

Proof of identity demanded from a parent already known by name. A statutory response sent out with an internal note still sitting in it. A parent warned about vexatious requests for asking four questions in six days.

What you can do

None of this needs a solicitor. All of it is free.

If you are in the same position, this is the order to do things in. It is the order we are following.

  1. 1

    Complain to the ICO about the paused request — now

    A subject access request complaint does not need an internal review first. This is the fastest test of the Trust’s position, and it is the finding most likely to be upheld.

    Free
  2. 2

    Ask for an internal review of each reply, within 40 working days

    Send them separately, one per request, and name the specific defect rather than simply saying you are dissatisfied. The numbered findings above give you the wording for each one.

    Free
  3. 3

    Escalate to the ICO on any review that does not fix it

    The Information Commissioner can order disclosure. Most authorities settle before it gets that far, which is rather the point.

    Free
  4. 4

    Ask again — smaller

    Request only the total number of referrals to Slough Children First for each academic year. One number per year, no breakdowns at all. That removes the identification objection completely and forces a plain answer on whether the figure exists.

    Free
  5. 5

    Take the governance failures to the Trust Board and the Department for Education

    A trust-wide child protection policy approved with no record, and no safeguarding records audit in existence, are not freedom of information problems. They will not be fixed by the freedom of information process and they should not be sent there.

    Free

Use our FOI request template Use our SAR template

Right of reply

Western House Academy and The Park Federation Academy Trust are invited to respond.

Our standing offer

Every school profile on WeTheParents carries the same promise, and this audit is no exception. The school and the Trust are welcome to reply to anything on this page, and we will publish that reply here in full and unedited.

If we have got a fact wrong, tell us and we will correct it and say that we have. If a record we have described as not held does in fact exist, send it and we will publish it.

help@wetheparents.co.uk

Coming next

Part two — the Safeguarding Policy itself

This audit was about how the school answers questions. The next part is about what those answers revealed: a child protection policy with no recorded approval, no governor scrutiny, and no audit standing behind it.

We are working through the policy line by line now, and we will publish it here.

Sources and anonymisation

Every quotation on this page is taken verbatim from written responses issued by Western House Academy and The Park Federation Academy Trust between 7 July and 31 August 2026, in reply to one Subject Access Request and four Freedom of Information requests made by a parent at the school.

The names of individual members of staff, the requesting parent and their child, along with all personal details and direct contact addresses, have been removed. This audit is about how an institution behaved, not about any individual. The full anonymised correspondence is available to any parent, journalist or regulator who asks for it.

Nothing on this page is legal advice. Where the law is summarised it is summarised plainly, and where a point turns on how a statute should be read we say so in the finding itself.

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