Who runs Bognor?

Executive Summary: Formal Representation regarding the Arun Community Governance Review

This representation formally challenges the procedural status of the current Community Governance Review (CGR). It asserts that the process, as currently managed, fails to meet the statutory requirement for "inclusive engagement" under the Local Government and Public Involvement in Health Act 2007. Following protracted and unproductive communications with council officers, it is clear that the review is prioritising administrative convenience over the genuine preservation of community identity in Bognor Regis..

A primary concern is that ADC is overlooking the "Bournemouth Warning." The BCP (Bournemouth, Christchurch, and Poole) reorganisation demonstrated that failing to secure distinct community identities during governance shifts leads to "identity erasure" and increased tax burdens without improved local representation. This representation argues that the current ADC proposals risk repeating these failures, leaving Bognor residents with a diminished voice in a diluted democratic structure.

Furthermore, the timing of this review is procedurally premature. Finalising local ward and parish boundaries while the high-level Strategic Unitary Review for West Sussex remains undecided (closing 15 June) risks creating a contradictory and obsolete governance framework. I am requesting an immediate pause of the CGR to allow for a comprehensive impact assessment that ensures the final order is legally robust and truly reflective of the community's interests.

Tue 19 May 26

To: * Dawn Hudd (Chief Executive): dawn.hudd@arun.gov.uk

CC:

Subject: FORMAL REPRESENTATION: Statutory Failure & Data Risk | Community Governance Review 2026

Dear Ms Hudd,

I am writing to you as the guardian of Creative Bognor (www.creativebognor.com) to submit a formal representation concerning the current Community Governance Review (CGR). I wish to record a formal objection to the narrowness of the current Terms of Reference, which I believe fail to satisfy the "effective and convenient" test mandated by Section 93 of the Local Government and Public Involvement in Health Act 2007.

  1. Unconditional Offer of Community Intelligence

As the Council is aware, I have previously provided a progressive Community Blueprint (31 August 2025) and pointed towards The Locality Manifesto (7 August 2025) as a framework for modern engagement. I have offered the resources of the Creative Bognor platform—including our structured SHARE Agenda (Security, Health, Accessibility, Resilience, and Evaluation)—unconditionally for the Council’s use.

Our platform had over 16,000 verified views in the last year, serving as a statistically significant hub for community identity and engagement in Bognor Regis. To ignore such a resource while claiming to conduct a comprehensive review of community governance is a breach of the 'Duty of Inquiry' (Tameside Principle).

Furthermore, I point to the Bournemouth, Christchurch and Poole Council Statutory Governance Review of 2025 as an example of a more inclusive approach to community identity. Why is it that a more progressive approach to community engagement such as this is not possible here, and have the benefits and costs to our communities been properly assessed and evaluated?

  1. Data Governance Risk under the Data (Use and Access) Act 2025

Under Section 103 of the Data (Use and Access) Act 2025, public bodies have an enhanced statutory duty to ensure that data used for constitutional decisions is accurate and representative.

By bypassing an established digital engagement hub and a proactive community blueprint, the Council is relying on a "passive" data sample that creates a documented Data Bias Risk. The Council is knowingly ignoring an "informed" dataset that is far more representative of Bognor’s active social and digital landscape than traditional methods.

Please accept this as a formal notification of a data accuracy concern. Under the 2025 Act, I expect a formal acknowledgement of how this blueprint and dataset will be weighted in the review's evidence base within 30 days.

  1. Political & Financial Oversight

I am copying this representation to my Member of Parliament and the Chair of the Policy and Resources Committee. Given the Deputy Leader's prior support in principle for our heritage initiatives, I trust the Council recognises the 'Resource Efficiency' of utilising our established digital infrastructure. Proceeding with a narrow review that ignores these unconditionally offered assets would be procedurally flawed and represents a significant missed opportunity for cost-effective, modern engagement.

Procedural Accountability

To prevent this representation from being neutralised via a generic acknowledgement or relegated to a passive background note, let me be clear: any attempt to decouple this data from the formal evidence base by citing rigid statutory boundaries will be viewed as a conscious decision to proceed with a structurally flawed and unrepresentative review.

Given the Monitoring Officer's presence on this correspondence, I expect the Council's formal response to explicitly address the weight allocated to this informed dataset, rather than merely noting its existence.

Refusing to integrate this unconditionally offered digital infrastructure—while simultaneously spending public funds on passive, low-yield consultation methods—will be treated as a documented failure under the Tameside Principle and a deliberate acceptance of Data Bias Risk under the 2025 Act.

Requested Action

I request that the Council:

  1. Demonstrates that the benefits and costs of a more progressive approach have been properly assessed and evaluated.
  2. Formally adopts the provided Community Blueprint as a core consultative document for the CGR.
  3. Amends the CGR scope to reflect the principles of community power outlined in the Locality Manifesto.
  4. Confirms how the 16,000+ digital engagements via Creative Bognor will be accounted for in the Council's final report.

I look forward to your substantive, legally reasoned response within 30 days.

Yours sincerely,

John Parsons, Guardian, Creative Bognor

www.creativebognor.com

The response

Wed 3 Jun 36

Dear Ms. Fairs-Browning

Thank you for your comprehensive and informative response, which is well received.

I shall consult with colleagues and provide a substantive response to your request for further information within the next seven days.

Yours sincerely 

John Parsons

Curator and owner of www.creativebognor.com  (held in trust on behalf of Bognorians)

Dear Mr Parsons,

 Thank you for your email and for setting out your representation in relation to the Community Governance Review (CGR). Your submission, including the materials referenced, has been noted and will be recorded as part of the review process.

I address your points in turn below.

  1. Scope of the Community Governance Review
    The Terms of Reference for the CGR were agreed in accordance with the statutory framework set out in the Local Government and Public Involvement in Health Act 2007. The Council ensure that any review has regard to the statutory criteria of reflecting the identities and interests of the community and securing effective and convenient local governance. All representations received during the consultation period are recorded upon receipt and incorporated into the Council’s evidence base, with officers reviewing and analysing all submissions after the consultation closes and before any recommendations are finalised. The timing of submissions does not affect their consideration, as established processes ensure that all material is assessed in a consistent and proportionate manner, and we ensure that the process is fair, transparent and procedurally robust for all participants. The consultation remains at a formative stage, with no decisions taken, and all representations will be taken into account in preparing the final report and recommendations. Any CGR outcome will be rational, and evidence based. The Council takes into account relevant considerations and can exclude irrelevant considerations.

Your suggestions regarding broader approaches to engagement, including the Creative Bognor platform and the Locality Manifesto, are acknowledged. There is however ambiguity around the contents of your email, and I would be grateful if you could address the following points, so that the contents of your email can be given further consideration:

  1. What is Bognor Creative, is it a reliable source?
  2. Can you evidence how many people have used the website to communicate about matters relating to governance?
  3. Are the visitors to the site residing within the district? Can that be evidenced?
  4. Please clarify what you are proposing? That the platform be used for consultation purposes in future governance reviews? Or otherwise?
  5. Do you have authority to act for Bognor Creative? Please provide evidence.
  6. Does Bognor Creative give authority for its digital infrastructure to be used in the manner that you propose? Please provide evidence of this.
  1. Reference to the Data (Use and Access) Act 2025
    In respect of point 2 of your email, Section 103 of the Data Use and Access Act can be read here. In essence, Section 103 is about a data subject’s right to make a complaint to the controller (the council) in connection with their own personal data. There is no correlation to Community Governance Reviews or constitutional decision-making. Therefore, it is my view that this legislation has been cited in a context to which it does not apply.

Notwithstanding this, I can confirm that the Council remains committed to ensuring that information used to inform the CGR is handled appropriately and that consultation responses are considered in a fair and balanced manner under UK GDPR, ensuring that the consultation responses are processed lawfully.

 

  1. Use of External Platforms and Submitted Material
    The Council is under no statutory obligation to adopt external documents or platforms as core consultative materials within the CGR. However, your Community Blueprint and associated information will be treated as a formal representation and considered as part of the evidence base alongside all other consultation responses.

With regard to your query on how digital engagement figures will be accounted for, the Council will summarise and report consultation responses in accordance with its standard procedures. This includes qualitative and quantitative feedback received through the Council’s formal consultation channels.

  1. Assessment of Options and Resource Considerations
    The Council will consider the benefits and impacts of proposals arising from the CGR as part of its decision-making process, taking into account representations received and assessing them against statutory guidance and practical deliverability.

Conclusion

Your representation has been formally recorded and will be considered as part of the review. The Council will publish its findings and recommendations in due course following completion of the consultation process.

My response addresses the points raised in your correspondence.

Yours sincerely,

Lauren Fairs-Browning

On behalf of Dawn Hudd

Lauren Fairs-Browning AEA Cert

Electoral Services Manager, Electoral Services Department