Legal FOI Request Deadlines Ignored, Internal Procedural Failures Excused, Investigating Their Staff Rejected- Here's Evidence on The Accountability Vacuum Inside NHS Thames Valley ICB Under CEO Nick Broughton's Leadership
TL;DR
After NHS Thames Valley ICB admitted that it had breached the statutory deadline for my Freedom of Information request, I asked the organisation to investigate something different from the FOI itself:
How had its own controls failed? Who was responsible? Why had senior leadership not intervened? What happened to its escalation procedures? Why had disputed redactions appeared in responsive records? And what accountability or corrective action would follow?
I took those questions to the Public & Patient Experience Team (PPET), the part of NHS Thames Valley ICB responsible for complaints and patient experience.
Lorri Josey, Complaints Manager in PPET, refused to register and investigate my corporate governance complaint. Her position was that because the problems arose from a Freedom of Information request, the appropriate route was the Information Commissioner's Office.
I repeatedly explained that I was not asking PPET to decide my FOIA rights. That question was already with the ICO. I was asking NHS Thames Valley ICB to investigate its own staff conduct, management failures, failed internal controls, executive oversight and organisational accountability.
No internal investigator was identified.
No alternative governance route was identified.
No investigation was opened.
Instead, on 28 August 2026, PPET declared the matter closed and warned that further correspondence might be read but not answered. (repeating the pattern)
By 3 September 2026, I had run out of patience and closed the correspondence myself.
For me, this was no longer one bad complaint response. It was another example of the same behaviour I had now experienced through the original complaints process, Chief Executive Dr Nick Broughton, Chair Dr Priya Singh, Information Governance, the FOI Internal Review and now PPET:
I raise evidence → I ask for accountability → substantive questions remain unanswered → the ICB eventually declares the conversation over.
In my opinion, that is not a series of isolated mistakes. It looks like culture.
The complete correspondence is available in my Evidence Folder.
What is PPET — and why did I expect it to investigate?
PPET stands for Public & Patient Experience Team.
Within NHS Thames Valley ICB, this is the function dealing with complaints and patient experience. The person corresponding with me was Lorri Josey, Complaints Manager, Public & Patient Experience Team, NHS Thames Valley ICB.
This distinction matters because I was not simply sending another email to the Freedom of Information team.
I deliberately went to the complaints function because what had happened was no longer only a question of whether my information request had been answered within the Freedom of Information Act.
The ICB's own Internal Review had already admitted that the statutory deadline had been breached.
The problems I wanted investigated were now organisational:
- why the statutory process had failed;
- why the ICB's own internal escalation safeguards had apparently failed;
- why the failure continued after it became known;
- how staff had handled the matter;
- how the Internal Review itself had been conducted;
- why disputed redactions had appeared in responsive records;
- why senior executives did not appear to intervene despite being directly notified;
- and who, if anyone, would be held accountable.
Those are not simply questions about whether section 10 of FOIA was breached.
They are questions about people, management, governance and organisational culture.
Why did I involve PPET before the FOI Internal Review had even finished?
On 23 July 2026, after the FOI team had repeatedly failed to respond properly to me, I requested a formal Internal Review.
But I copied PPET into the correspondence as well.
I explicitly separated the two issues.
The Information Governance team needed to examine the handling of my statutory FOI request.
PPET, I argued, should separately look at the repeated non-response, failure to remedy an acknowledged breach, lack of identifiable accountability and wider administrative and governance failures.
I was already seeing two different questions:
Question one: Did NHS Thames Valley ICB comply with Freedom of Information law?
Question two: How did NHS Thames Valley ICB allow this to happen, who failed to do what, why did nobody correct it, and what accountability follows?
The first belongs to information-law processes and ultimately the ICO.
The second, in my view, belongs squarely inside the organisation's own governance and accountability systems.
Why did Lorri Josey initially say an Internal Review made a separate complaint unnecessary?
On 27 July 2026, Lorri Josey responded.
She told me PPET had checked with NHS Thames Valley ICB colleagues and had been advised that the concerns fell within the FOIA Internal Review process rather than the NHS complaints process.
Importantly, she explained that the ICB complaints process was intended for issues including:
"staff conduct, or other organisational matters"
but said that my concerns could instead:
"be fully considered and remedied, where appropriate, through the FOIA internal review process."
That was the basis on which PPET declined to investigate separately.
Fine.
So I waited for the Internal Review.
Then the Internal Review happened - and I've already written about the Internal Review in this website.
And the premise of that refusal fell apart.
What happened when the Internal Review did not actually resolve the governance failures?
By 17 August 2026, the Internal Review had concluded.
It had admitted the statutory failure.
But it had not answered many of the organisational questions I had raised.
The FOI disclosure was still outstanding.
Questions remained about the ICB's failed escalation procedures.
Questions remained about disputed redactions.
Questions remained about who was responsible.
Questions remained about executive oversight.
And Mark Gittins had now told me that he would provide no further response to my substantive challenges.
So I went back to PPET.
This time I made the distinction impossible to miss.
I told Lorri Josey:
I am not asking PPET to conduct another FOI Internal Review or determine my statutory entitlement to information. That matter is already going to the ICO.
I am asking NHS Thames Valley ICB to investigate the conduct, governance, accountability and organisational failures exposed by what happened.
What exactly did I ask NHS Thames Valley ICB to investigate?
My formal corporate complaint on 17 August 2026 was structured around seven areas.
- Failure of the ICB's statutory and internal FOI controls.
- Adequacy and conduct of the Internal Review.
- The continuing statutory breach without an identified legal justification.
- Handling and unexplained redaction of responsive records.
- The conduct of the Internal Reviewer after I challenged him.
- Executive accountability and failure to intervene.
- The persistent absence of accountability across the organisation.
I asked PPET to register a formal corporate complaint and allocate it to a sufficiently senior and independent investigator.
I wanted the investigation to examine the people and systems involved, including Information Governance and Mark Gittins.
I also specifically asked it to establish what action had been taken by:
- Dr Nick Broughton, Chief Executive and Accountable Officer;
- Dr Priya Singh, Chair;
- and Hannah Iqbal, Chief Strategy and Commissioning Officer.
All three had been directly notified about the continuing failures.
I wanted to know what they actually did.
That is a governance investigation.
It is not an FOI appeal.
Why did Lorri Josey send me back to the ICO anyway?
On 19 August 2026, Lorri Josey replied.
She said she had "double-checked" her previous advice and received confirmation that it was correct.
The correct escalation route, she said, was the Information Commissioner's Office.
But she did not initially tell me what legislation, regulation, ICB policy or formal complaints rule she was relying upon.
I found that unacceptable.
"I have double-checked and been told I am correct" is not a transparent reason for denying somebody access to an accountability process.
Who checked?
Against what?
What provision applies?
Why?
If a public body is refusing to investigate a formal complaint, it should be able to explain the basis for doing so.
Why did I challenge the ICB's reliance on Regulation 8?
On 19 August 2026, I wrote back.
I recognised that Lorri Josey appeared to be relying on Regulation 8(1)(g) of the Local Authority Social Services and National Health Service Complaints (England) Regulations 2009.
That provision is relevant where a complaint relates to a person's right of access to information under the Freedom of Information Act.
I was not disputing the basic point that the ICO should deal with my statutory information-rights dispute.
I had already sent that part to the ICO.
My challenge was that the ICB was treating everything connected with the FOI failure as though it automatically became an information-law question.
I specifically asked the ICB to address Regulation 8(3) and explain why the separate organisational and conduct issues I had identified should also be excluded rather than dealt with through an appropriate internal process.
I did not receive a substantive answer to that point.
Why couldn't the ICO simply investigate the people and governance failures for them?
Because the ICO is not NHS Thames Valley ICB's HR department.
It is not its disciplinary function.
It is not its executive-governance function.
It is not responsible for deciding whether Dr Nick Broughton exercised appropriate leadership after being notified of a continuing statutory failure.
It is not responsible for asking why managers failed to operate the ICB's internal escalation controls.
It is not responsible for determining whether staff complied with their internal organisational duties.
It is not responsible for deciding what management action, disciplinary action, governance action or FPPT consideration should follow.
I told Lorri Josey this directly.
The ICO can investigate the information-law failure. It cannot run NHS Thames Valley ICB for NHS Thames Valley ICB.
If the ICB's systems failed, somebody inside the NHS still has to ask why.
If PPET was not the right team, why didn't it send the complaint to whoever was?
This was perhaps the simplest question I asked.
I told Lorri Josey:
If PPET cannot investigate this, tell me who can.
Refer it.
Escalate it.
Identify the appropriate internal governance mechanism.
If the concerns involve senior executives and that creates an independence problem, send them somewhere with sufficient independence to investigate.
I identified possible routes myself, including senior independent oversight and NHS England regional governance structures.
What I would not accept was an accountability vacuum in which:
because the conduct happened around an FOI request, apparently nobody inside NHS Thames Valley ICB had to examine the conduct at all.
That makes no sense to me.
What do the NHS's own Complaint Standards say should happen when things go wrong?
The Parliamentary and Health Service Ombudsman's NHS Complaint Standards are supposed to create an NHS complaints culture that is open, honest and accountable.
They describe effective complaint handling as thorough and fair.
They expect organisations to give accountable responses, identify mistakes, learn from them and take action to prevent recurrence.
Guidance for senior NHS leaders says they should ensure appropriate structures exist for fair and robust complaint investigations and that learning from complaints is used to improve services.
That is the opposite of what I felt I was experiencing.
I was not seeing curiosity about how the organisation had failed.
I was seeing a hunt for the next reason why somebody else should deal with it.
Why did the ICB close the complaint instead of identifying an accountability route?
On 28 August 2026, PPET sent its next response.
This time it explicitly cited Regulation 8(1)(g).
The ICB said my outstanding concerns arose from the handling of my FOI request and therefore would not be investigated through its complaints process.
Again, my Regulation 8(3) challenge was not substantively addressed.
No alternative internal investigator was identified.
No HR route was identified.
No governance route was identified.
No independent executive route was identified.
No one was named as responsible for examining the conduct issues.
Instead, I was told:
"The ICB considers this matter is now closed."
And I was warned that if I sent further correspondence about the FOI complaint, it might be read but not responded to.
There it was again.
The same ending.
Why did this start looking like a pattern rather than coincidence?
On 29 August 2026, I wrote back and laid out the history.
This was no longer the first time I had encountered this behaviour.
Years earlier, I had challenged the original female sterilisation policy through the ICB's complaints process.
The substantive questions about evidence, equality, clinical guidance, bodily autonomy, consultation and decision-making were not properly answered.
Dr Nick Broughton, Chief Executive, eventually issued his final response and closed the internal complaint route.
I went to the Ombudsman.
The Ombudsman subsequently found that the ICB had indeed failed to properly understand and engage with key aspects of my complaint.
Then I challenged Dr Priya Singh, Chair of NHS Thames Valley ICB, about the replacement female sterilisation policy and leadership accountability.
Again, I did not get direct answers to central questions.
Eventually, she declared further correspondence closed.
Then came FOI-TV-2606-105.
The statutory deadline was missed.
I challenged the Internal Review.
Mark Gittins eventually told me that further correspondence on those questions would receive no response.
Then I went to PPET.
Lorri Josey eventually told me the matter was closed, and future emails might not be answered.
The sequence had become painfully familiar:
I raise substantive concerns → the ICB answers around them → I challenge the lack of accountability → scrutiny continues → somebody declares the correspondence finished.
Once might be poor complaint handling.
Twice starts to concern me.
When I see the same behaviour through the Chief Executive, the Chair, Information Governance, an Internal Reviewer and the complaints function, I start asking whether this is how the organisation itself operates.
What happened when I gave PPET one final opportunity to identify an investigator?
On 29 August 2026, I gave the ICB one final opportunity.
I asked PPET to address Regulation 8(3) and answer one simple question:
Who within NHS Thames Valley ICB will investigate the staff conduct, failed internal controls, management response and leadership-accountability issues I have raised?
If nobody would investigate them, I asked the ICB to say so clearly and identify the legal, regulatory or policy basis for that position.
I gave a deadline of 31 August 2026.
That date passed without the substantive answer I had requested.
Why was "in due course" no longer good enough?
On 2 September 2026, Lorri Josey wrote again.
She said she would share my email with ICB colleagues, seek further confirmation and respond:
"in due course."
At another stage of this battle, perhaps I would have waited.
By September 2026, I was done.
I had already spent years chasing this organisation.
I had repeatedly been given vague timeframes.
I had watched legal deadlines expire.
I had watched people promise answers and then fail to provide them.
I had watched correspondence get closed while substantive questions remained unresolved.
"In due course" is not a timeframe.
And I was no longer prepared to keep my life permanently open-ended around whenever NHS Thames Valley ICB might eventually decide to answer questions about its own accountability.
Why did I finally close the correspondence myself?
On 3 September 2026, I wrote to Lorri Josey for the final time.
I told her I was done waiting for NHS Thames Valley ICB to get its own accountability processes in order.
I had asked repeatedly.
I had explained the distinction between the ICO's responsibility and the ICB's responsibility.
I had identified the legislation I believed was relevant.
I had suggested alternative accountability routes.
I had given them a deadline.
I had given them another opportunity.
I had still not been told who inside the organisation would investigate what had happened.
So this time I closed the correspondence.
There is an important difference.
I was not ending scrutiny because I did not want to answer it.
I was ending an internal exchange because I had exhausted reasonable attempts to make the organisation scrutinise itself.
I would pursue the issues externally instead.
What does this repeated behaviour say about NHS Thames Valley ICB's culture?
This is where my concern has moved beyond individual emails.
Organisational culture is not what an institution writes on its website.
It is what people repeatedly do.
NHS organisations can write that they value:
- transparency;
- openness;
- accountability;
- learning;
- patient involvement;
- equality;
- and continuous improvement.
Those words are cheap.
The test comes when somebody turns up with evidence that something may have gone wrong.
Do you investigate?
Do you answer?
Do you identify who was responsible?
Do you look honestly at leadership?
Do you correct the failure?
Or do you redirect, delay, reframe, deflect and eventually stop responding?
From my experience, the behaviour I have seen across NHS Thames Valley ICB tells a very different story from the values written in its policies.
Is this what top-down resistance to accountability looks like?
In my opinion, yes.
When the same behaviour appears at multiple levels of one organisation, I stop believing that every example is an unrelated mistake.
I saw it from the Chief Executive.
I saw it from the Chair.
I saw it through Information Governance.
I saw it through the Internal Review.
I saw it through PPET.
Different people.
Different functions.
Same endpoint.
Scrutiny is tolerated until it becomes uncomfortable. Then communication is shut down.
That is my interpretation of the documentary record.
Please read it and form your own.
What happens when nobody inside an NHS organisation will investigate the NHS organisation?
You create an accountability vacuum.
And that is dangerous.
Because healthcare organisations exercise enormous power.
They decide what treatment gets commissioned.
They decide what pathways patients have to navigate.
They decide what evidence is sufficient.
They decide how equality duties are interpreted.
They decide how complaints are investigated.
They decide whether senior leadership needs scrutiny.
They handle statutory information requests about their own decisions.
If the same organisation can make the decision, investigate the decision, investigate the complaint about the decision, review its own investigation and then decide that nobody needs to investigate the governance failures exposed along the way, that starts looking frighteningly close to institutional self-policing without meaningful accountability.
That is how you create the Wild West in healthcare.
Policies can be created badly.
Legal deadlines can be missed.
Internal controls can fail.
Senior leaders can be notified and apparently do nothing.
Complaints can expose further failures.
And then, instead of somebody asking who is accountable, every internal route can eventually point somewhere else.
Why does this matter far beyond one FOI request?
Because healthcare governance is not paperwork.
The quality of governance affects what care people can access, how quickly failures are corrected and whether dangerous decisions are caught before they hurt people.
Weak accountability creates space for poor decisions to survive.
Poor decisions can restrict treatment.
They can create inequality.
They can leave patients without care they need.
And in healthcare, failures that remain unexamined can ultimately contribute to real harm.
This is why I become angry when accountability is treated like an administrative inconvenience.
These organisations are not selling shoes.
They make decisions about people's bodies, health and sometimes their survival.
The standard should be higher, not lower.
Is the NHS good at talking about values but bad at proving them?
That is increasingly my view.
NHS documents are full of commitments.
Openness.
Transparency.
Patient-centred care.
Learning culture.
Equality.
Accountability.
Governance.
But when I ask for evidence showing those principles being applied to an actual failure, I repeatedly find something else.
I find missing records.
I find unanswered questions.
I find delays.
I find people sending responsibility elsewhere.
I find nobody apparently willing to examine the people at the top.
And eventually I find another email telling me that communication is finished.
Values are not what an organisation says about itself. Values are what it repeatedly does when following them becomes inconvenient.
Do I think this organisational culture is rotten?
Yes.
In my opinion, this is rotten.
I am not saying that every person working at NHS Thames Valley ICB is incompetent or acting badly.
I am saying that the accountability structure I have experienced appears rotten.
A healthy organisation should be able to examine itself.
A healthy organisation should not be frightened of evidence.
A healthy organisation should not make a member of the public fight through five different internal functions simply to find somebody willing to ask, "How did we fail and who needs to fix it?"
And a healthy organisation certainly should not keep ending conversations when those questions refuse to go away.
If this can happen here, how widespread is the problem across the NHS?
I cannot prove from my case that every NHS organisation behaves like this.
But I would be deeply surprised if this culture exists nowhere else.
That is exactly why external oversight matters.
NHS England.
The Care Quality Commission.
The Parliamentary and Health Service Ombudsman.
The Information Commissioner's Office.
Health scrutiny committees.
Boards.
Audit and governance functions.
All of them should be asking whether organisations are merely publishing accountability frameworks or actually living by them.
If one NHS commissioning organisation can repeatedly close down internal scrutiny across different departments and levels of leadership, that should make every external body responsible for NHS oversight extremely curious about what happens when nobody as persistent as me is watching.
Why am I now pursuing accountability outside NHS Thames Valley ICB?
Because I have tried the internal routes.
I complained.
I challenged the Chief Executive.
I challenged the Chair.
I used Freedom of Information law.
I requested an Internal Review.
I challenged the Internal Review.
I asked PPET to investigate the governance failures.
I explicitly separated those failures from the ICO's information-law role.
I asked for an alternative internal route.
I asked for somebody — anybody — inside the organisation to take ownership of investigating what had happened.
I did not get one.
So I am no longer spending endless weeks trying to convince NHS Thames Valley ICB that it should investigate itself.
I will take the evidence to organisations whose job is to scrutinise it from the outside.
And I will continue publishing the documentary record here.
Where can I read the correspondence with Lorri Josey and PPET?
You can read my correspondence with Lorri Josey, Complaints Manager in the Public & Patient Experience Team at NHS Thames Valley ICB, together with the FOI Internal Review, leadership correspondence and wider evidence trail in my Evidence Folder.
I encourage you to read it rather than simply taking my interpretation at face value.
This is my opinion. Read what I asked. Read what they answered. Read where they stopped answering. Then decide for yourself what kind of accountability culture the evidence shows.
Sources and further reading
