Three Confirmations

Governance failures of the type documented in this investigation do not usually announce themselves. They accumulate in the gaps: the declaration that was not made, the framework that was not written, the assessment that was not required. What makes the Southport record unusual is that the council has confirmed each of these absences directly, in writing, in response to formal Freedom of Information requests.

Three confirmations are now on the public record.

The first: no declaration

FOI request SP-04 asked for any entry in Sefton Council's register of officers' interests relating to Mark Catherall's directorship of Southport BID Company Limited. The response was signed by Catherall himself. It confirmed that no register entry exists. The stated reason was that his appointment to the BID board was approved by Cabinet, and that Cabinet approval removes the obligation to declare.

The internal review of this response was decided by Fiona Townsend, Senior Lawyer. Four grounds were submitted. None were addressed. The decision read in full: “The information provided is factual and your request has been answered.”

Catherall's job description, disclosed in a related response, lists his BID directorship as Principal Responsibility 12 of his role. The directorship is a named and numbered job function. It is not declared in the register of interests. The council's position is that no declaration is required.

The second: no framework

VisitSouthport.com is a publicly funded tourism platform operated directly by Sefton Council. It promotes businesses in the town. The same officer who runs it sits on the board of the BID that represents those businesses. FOI request SP-09 asked for any logs, audit trails, or editorial records showing how decisions were made about which businesses to promote.

The response confirmed that no such records are held. The internal review found the same. The council's Stage 1 response to a formal complaint acknowledged that no documented editorial framework currently exists for the platform and committed to reviewing whether one “is required and beneficial.” That phrasing is itself the confirmation: a platform that has operated for over a decade has no documented basis for its editorial decisions.

A further FOI request asking specifically whether a documented editorial framework exists is currently outstanding, due mid-June 2026.

The third: no assessment

FOI request SP-13 asked whether the council had assessed the interaction between Catherall's BID board seat (Principal Responsibility 12) and his oversight of the council's operator agreement for the Marine Lake Events Centre (Principal Responsibility 18). The MLEC is a £73 million public venue projected to generate 60,000 additional hotel overnight stays in Southport annually. The primary commercial beneficiary of that footfall is the dominant hotel operator in the town. The Commercial Director of that operator is the BID Treasurer.

On 11 June 2026, the council issued a supplementary response. On the question of whether any assessment of this structural overlap exists, the answer was:

“An assessment does not exist nor is required.”

Sefton Borough Council, Information Governance Team, 11 June 2026

That is not a refusal to disclose. It is a declaration of policy. The council has formally stated, in writing, that examining the conflict between these two responsibilities is not something it considers necessary.

What the three confirmations mean together

None of these responses allege misconduct. None identify a rule that was broken. Each one confirms that a governance mechanism that a reasonable organisation would have in place does not exist.

The register of interests exists to make conflicts visible. It does not contain the BID directorship. The editorial framework for a publicly funded tourism platform exists to ensure decisions about who is promoted are accountable. It does not exist. The conflict assessment exists to identify where an officer's overlapping responsibilities require management. It was not conducted and, in the council's view, was not required.

The three gaps share a structural logic. The same post that holds the directorship also runs the platform and oversees the venue agreement. The governance mechanisms that would normally constrain each of those functions independently are absent across all three simultaneously. The council has confirmed each absence in response to a direct question. The record does not require interpretation. It requires reading.

Eleven ICO complaints are currently active against Sefton Council arising from this investigation. The findings above are documented in the FOI tracker and sourced to their primary documents.