Subject: Re: Internal Review: FOI 2026-020 - Great House Farm, Llandough | Cardiff Castle Furniture
From: Sion Buckler
Direction: sent
Date: Tue, 08 Sep 2026 12:16 UTC
Institution: Amgueddfa Cymru - Museum Wales
Refs: none
Archive id: gm-1a080f30175eb85a
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Dear FOI Team,

Thank you for the internal review outcome dated 8 September 2026.

I note that the review upholds the original decision. I do not, however,
consider that the review has answered the substantive questions raised in
my request for internal review.

I am therefore putting the position on record, while also making a separate
new request for recorded information which your review confirms already
exists.

1. Records identified during the additional searches

On 14 August 2026, Amgueddfa Cymru stated that the additional enquiries had
identified:

"some information relating generally to Great House Farm and the
surrounding area".

The internal review now describes these as:

"a small number of records referring generally to Great House Farm,
Llandough".

The wording has therefore changed slightly, but the material fact has not:
the Museum confirms that records referring to Great House Farm were
identified.

My internal-review request specifically asked for those records to be
identified and, where not exempt, provided.

The review does not do so.

Simply stating that the records are considered to fall outside categories 1
to 9 does not identify what they are, where they are held, when they were
created, or their reference numbers.

2. Archived electronic systems

My request of 14 August specifically asked:

- which archived systems were searched;
- the approximate date ranges covered;
- whether historical email or correspondence archives were searched;
- whether legacy collections-management databases were searched; and
- whether any archived systems were unavailable, incomplete or incapable of
being searched.

The review answers none of these questions individually.

Instead, it states:

"archived electronic records reasonably capable of containing information
within scope were considered"

and:

"Any data stored within a system or database pre-dating the existing
Collections Management Systems, would have been migrated into the incumbent
solution, and therefore included in the search."

The first statement describes a conclusion, rather than identifying the
systems actually searched.

The second is an assumption about migration completeness. "Would have been
migrated" is not a search result and does not establish that the relevant
historical data was in fact migrated, completely migrated, retained,
searchable and included in the particular search undertaken.

3. Correspondence independent of accessioned objects

This is the most significant issue.

The original request expressly sought correspondence and administrative
records concerning, among other things:

- identification;
- recovery;
- ownership;
- location;
- the Buckler and Williams families;
- Cardiff Council;
- Cardiff Castle;
- the Bute Estate;
- museums; and
- other public authorities.

Those categories were deliberately not restricted to objects which had
subsequently been accessioned by the Museum.

The review states:

"As no such objects were identified as having been acquired by the Museum,
no associated acquisition, provenance, ownership, loan, disposal or related
correspondence concerning such objects was identified."

That reasoning addresses correspondence attached to an identified
accessioned object. It does not establish that correspondence was searched
for independently of an accession record.

For example, an enquiry concerning an item, a communication about possible
provenance, a request to identify an object, a discussion concerning
temporary custody, a disposal enquiry, a communication with another
institution, or correspondence about the contents of a property could exist
without the item ever becoming an accessioned Museum object.

Accordingly, the fact that no accessioned object was identified does not
itself establish that no such correspondence existed or was held.

The subsequent statement:

"The review did not identify evidence that the Museum holds correspondence
concerning the identification, ownership, recovery or location of Great
House Farm furniture or household effects."

still does not establish whether the relevant correspondence repositories
were actually searched.

4. Search terms

My internal-review request set out specific terms and variants and asked
the Museum to confirm whether those terms had been used.

The review now states only:

"appropriate search terms and variants were used"

and refers generally to:

"location names, property names, family names and associated variants".

That does not confirm whether the specific terms identified in my request
were searched.

In particular, the review does not say whether searches included
combinations or variants involving:

"Bute Estate", "Bute", "Cardiff Castle", "Cardiff Council", "household
effects", "contents", "dispersal", "recovery", "transfer", "demolition",
"provenance", "ownership"

and the other terms specifically identified in my 14 August correspondence.

The distinction matters because a search for a property name or family name
is not necessarily equivalent to a search for correspondence concerning the
dispersal, recovery, transfer or ownership of its contents.

5. Transfer, disposal and destruction

My request also asked what evidential basis existed for the earlier
statement that the Museum was not aware of relevant records having been
transferred to another institution or destroyed.

The review now says:

"The statement that the Museum is not aware of relevant records having been
transferred or destroyed reflects the outcome of the searches undertaken
and the knowledge of relevant collections staff."

This combines two different things: documentary searches and institutional
recollection.

It does not tell me whether the Museum searched:

- transfer or accession-out records;
- disposal records;
- retention and destruction records;
- archival transfer documentation; or
- other records capable of establishing whether material had previously
been transferred or destroyed.

There is an important distinction between:

"no record of transfer or destruction was identified in the records
searched"

and:

"there is no evidence that any transfer or destruction occurred".

The review does not make that distinction sufficiently clear.

6. Searches concerning external institutions

The original request expressly contemplated records concerning Cardiff
Council, Cardiff Castle, the Bute Estate and other external bodies.

The review states:

"Searches were not limited solely to object catalogue records."

That is helpful, but it still does not identify what non-catalogue
repositories were searched.

For example, it does not identify whether searches were made of curator
correspondence, departmental files, donor correspondence,
acquisition/disposal correspondence, provenance files, loan files,
institutional correspondence indexes, or other historical administrative
records in which communications with external institutions might have been
recorded.

Again, the issue is not whether the Museum considers the search reasonable.
It is whether the relevant classes of records were actually searched.

7. The significance of the "balance of probabilities" conclusion

I note the review's conclusion that, "on the balance of probabilities", the
Museum does not hold recorded information within the scope of the request.

I do not dispute that a negative FOI determination may ultimately be
reached on that basis.

However, the balance-of-probabilities conclusion necessarily depends upon
the quality, scope and rigour of the searches on which it is based. The
ICO's guidance states that, where a requester disputes whether relevant
information has been located, the authority should be able to provide a
reasoned and detailed account of how it determined that further information
was not held, including the areas searched, staff consulted and, for
electronic searches, the keywords, accounts and time parameters used.

My concern remains that the review repeatedly substitutes statements such
as "we are satisfied", "appropriate", "reasonably capable" and "on the
balance of probabilities" for the underlying factual information about what
was actually searched.

I therefore consider the review outcome insufficiently informative on the
specific search methodology raised in my review request.

I reserve my right to refer the handling of FOI 2026-020 and the internal
review to the Information Commissioner's Office.

Separate new FOI request

Separately from the above, I am now making a new request under the Freedom
of Information Act 2000.

This new request is deliberately limited to recorded information which your
own correspondence confirms was identified or generated in connection with
the searches already undertaken.

Please provide:

A. Records identified

The "small number of records referring generally to Great House Farm,
Llandough" identified during the additional enquiries referred to in your
email of 14 August 2026 and the internal review outcome of 8 September 2026.

For each record, please provide, where recorded:

- title or description;
- date;
- collection, series or department;
- system or repository;
- reference, accession or record number; and
- a copy of the record, subject to any applicable exemption.

If any part of a record is exempt, please identify the exemption relied
upon and provide the remainder where reasonably practicable.

Limb A is confined to the records your 14 August and 8 September letters
say were identified in the FOI 2026-020 additional enquiries. It is not a
new collection-wide search. If any of those records are also in scope of
FOI 2026-032 or FOI 2026-036, please schedule them once and cross-refer.
Please do not refuse this request as a duplicate.

B. Existing search records

Any recorded information already held concerning the searches undertaken
for FOI 2026-020 or its internal review, including any existing:

- search notes;
- search logs;
- search checklists;
- system lists;
- search-term lists;
- IT tickets or instructions;
- archived-system enquiries;
- staff search records; or
- other contemporaneous records documenting the searches undertaken.

I am asking only for recorded information already held. I am not asking the
Museum to create a new narrative or retrospective report.

If no such search records are held, please state that expressly.

Please register this as a new FOI request and provide it with its own
reference number. It is not a further internal review of FOI 2026-020, nor
is it a request to reopen or amend FOI 2026-032 or FOI 2026-036.

I would therefore be grateful if this request could be processed separately
and not treated as a clarification or continuation of those matters.

Regards,

Sion Buckler (Ret'd Sergeant)
Royal Signals Cyber and Electronic Warfare Professional and Life Member