Reading Between The Lines

Following GreenSquareAccord’s Stage 2 response to my formal complaint, I’ve gone through the document line by line.

What follows isn’t opinion dressed as outrage; it’s a factual comparison between what GSA wrote and what the record shows.

The Stage 2 review, dated 3 October 2025 and signed by Alex Hicken, claims to have independently reassessed the issues first raised in August. In reality, many of the most serious points remain unanswered or have been reframed to avoid responsibility.

Each section below addresses a part of the Stage 2 letter. I set out what GSA said, what the evidence shows, and why their response falls short. This isn’t about scoring points — it’s about documenting how the organisation handles accountability when challenged by a resident armed with proof.

This document breaks down the sections as set out in GSA’s Stage 2 response.

Investigating officer and independence

What GSA said:
GSA assigned the Head of Legal Services (Natalie Sheer) to Stage 1 because the complaint involved legal issues. Stage 2 says this was done “in good faith,” adding that she was not involved in the original decision to pursue an injunction and could therefore “fairly and objectively” review the complaint.

What the record shows:
• While she may not have made the original injunction decision, Ms Sheer later took an active role in related proceedings, including attending the hearing where GSA sought to enforce alleged undertakings breaches.
• She also contacted my solicitor directly despite clear instructions that all correspondence should be handled through GreenSquareAccord’s appointed external legal representatives. This breached standard legal protocol, which requires that once parties are represented, communication must take place between solicitors rather than directly through an organisation’s in-house counsel. The purpose of this rule is to maintain fairness, prevent conflicts of interest, and ensure that all exchanges are properly documented within the agreed legal framework.

Why this falls short:
An officer personally involved in subsequent litigation steps and direct dealings with my legal counsel is not an impartial choice to adjudicate my Stage 1 complaint. Independence is central to a fair process; the conflict here isn’t about the initial injunction decision but her later involvement in the same dispute she was asked to judge.

Tenancy status and “non-resident” labelling

What GSA said:
In Stage 2, GSA says it is “standard practice” to include tenancy information in complaint responses. They note the lease at our home is in my wife’s name and say their comment was “factually correct in terms of the legal position.” They add they “accept that you are a resident of the property but note that our legal relationship is with your wife as the leaseholder.”

What the record shows:
While technically correct about the lease, GSA has repeatedly used this fact to diminish or deny my resident status. Internal emails and Home Ownership Team correspondence refer to me as a non-resident or unauthorised contact and this has been used to justify:
• Refusing to respond to Section 20 and Section 22 consultation or information requests.
• Delaying or denying access to the Fire Risk Assessment (FRA) and other safety documentation.
• Ignoring formal complaints or correspondence about our building’s management.

Why this matters:
The Stage 2 statement sidesteps the problem: staff routinely rely on the “non-resident” label to avoid communication, transparency, and accountability. The complaint wasn’t about legal ownership — it was about that technicality being weaponised to obstruct statutory rights and legitimate resident enquiries.

Harassment, bullying and defamation

What GSA said:
The Stage 2 reviewer says Appendix 1 — an intranet article — simply indicated “GSA’s formal position.” She adds that defamation is “a matter of law,” and that the 8 July 2024 email was sent by “a colleague below managerial level,” with wording “ill-chosen but not constituting bullying or harassment.” She also claims information on my website “could be seen as incomplete, inaccurate or potentially misleading,” without giving examples, and refers to “inferences” I make in a podcast (e.g. about Ruth Cooke being “cruel to old people” and “mean to children”).

What the record shows:
• Appendix 1 is not independent or factual; it was authored internally (by Steve Hayes and Sophie Atkinson) to brief staff against me. It should never have been relied on as evidence in a complaint response.
• The article contains demonstrable inaccuracies, presents opinion as fact, and portrays me as a threat — amplifying internal hostility.
• GSA says there is “no legal definition of bullying” but then applies improvised definitions to dismiss conduct that plainly meets ordinary understandings of targeted, reputationally damaging communication.
• I consistently offered GSA a right of reply; they ignored it.
• No examples of “false” or “misleading” content have ever been identified. Assertions were made without evidence.
• The “cruel to old people/mean to children” line was an analogy grounded in outcomes: elderly leaseholders overcharged for undelivered services and families left in unsafe, damp homes.
• I refer only to senior leadership — those responsible for decisions. I have not named junior or frontline staff.
• Contact with Julianne Britton’s number was invited by her due to emails being lost under the Contact Management Plan. After the judge advised against further use of that number, I complied immediately and have not used it since.
• GSA now concedes the “personal mobiles” claim should not have been plural.
• Claims of “negative impacts on colleagues’ wellbeing” remain unsupported: no statements, dates, or examples were produced.
• “Invasion of privacy” here refers to scrutiny of professional conduct by senior officers — a legitimate public-interest function.
• The criticism of my “manner and delivery” and use of “computer-generated images” is unsupported by any policy. I use generated images because GSA has tried to remove real photographs from blogs and videos.

Why this matters:
The Stage 2 analysis treats harassment and bullying as matters of tone rather than conduct. It ignores the clear organisational campaign of misinformation seen in Appendix 1 and in internal emails labelling me a “hate group.”

Appendix 1 has since been proven to be false — it claimed that I had been contacting staff on their personal phones, something GreenSquareAccord has now admitted did not occur. Despite this, the document was circulated internally and relied upon in the complaint response as evidence of alleged harassment.

No policies, standards, or definitions are cited to justify GSA’s judgments, and no apology or correction has been issued following these admissions. What should have been an investigation into conduct became, instead, a defence of GSA’s communications strategy — one built on misinformation, contradiction, and reputational management rather than accountability.

Misuse of legal processes

What GSA said:
Stage 2 says matters before the courts are “out of scope” of the complaints policy and many events are over 12 months old. It concludes that legal action was led by “concerns for colleague wellbeing.”

What the record shows:
• Misuse of legal processes is the core of this complaint. Excluding it on procedural grounds removes the very issue under investigation.
• The copyright claim, undertakings, breach allegations, and subsequent arrest form a continuing pattern of intimidation.
• No evidence is offered that litigation was genuinely led by colleague-safety concerns (no risk assessments, incident logs, or clinical evidence).
• Major hearings ended with findings critical of GSA’s conduct, including March 2024 when alleged breaches were dismissed and costs awarded. None of this is acknowledged.
• Rebranding reputational protection as “wellbeing” is unsupported by facts.

Why this matters:
Declaring legal conduct “out of scope” shields the organisation from scrutiny of how it used the courts to suppress criticism. A proper review would test proportionality, evidential basis, and necessity. Stage 2 repeats assertions and excludes the evidence that disproves them. All court costs were ordered by the judge to be borne by GreenSquareAccord, including full restitution of barristers’ fees and associated legal aid expenses. This direction serves as a clear indication that the court did not agree with the actions taken by GreenSquareAccord and sought to protect the integrity of the legal aid system from being misused through unnecessary or unjustified litigation.

Misuse of Contact Management Plans

What GSA said:
GSA says the Contact Management Plan is no longer in place. It is now a “position statement” that they will communicate only with my wife as leaseholder, except where there is a statutory obligation to reply to me (e.g., SARs). They say this protects colleague wellbeing and centralises communications. They concede wording could have been clearer and promise to correct internal system flags.

What the record shows:
• My wife has repeatedly instructed GSA in writing — including to Ruth Cooke — that I am to handle all communications on her behalf.
• Refusing to honour written authority is not discretionary; residents can appoint a representative. GSA also now accepts I am a resident.
• Limiting replies to “statutory obligations” lets GSA decide unilaterally what it will answer, effectively silencing one half of a household.
• In practice the CMP remains: my primary email is blocked and messages are diverted to “info@”, where they are delayed or ignored.
• The “position statement” is a rebrand of the same restriction.
• No evidence has been produced that colleague wellbeing was compromised.

Why this falls short:
Renaming a Contact Management Plan doesn’t change its substance. Refusing to correspond with a nominated representative is a misuse of process and a barrier to accountability. The continuing email blocks show the CMP still operates whatever it’s called.

Whilst GSA’s Stage 2 response claims that the Contact Management Plan is no longer in use, Appendix 1 (the internal intranet article) explicitly refers to an updated plan and instructs staff not to engage with me. This directly contradicts their formal complaint response and demonstrates that restrictive measures remain active in practice despite their denial.

The April 2023 CMP letter also repeated serious and inflammatory claims — including allegations that junior female colleagues had felt “vulnerable” or “unsafe” — yet, as later correspondence and Subject Access Request results confirm, no supporting evidence was ever provided. Those accusations were quietly dropped from later correspondence, proving they were unfounded.

Equally troubling, GSA staff were advised internally to contact the police if they “felt unsafe,” effectively institutionalising suspicion rather than encouraging dialogue. This directive, combined with the persistence of blocked emails and the existence of an intranet post explicitly maintaining the CMP, shows that the plan remains active in both culture and practice — not as a safeguarding tool, but as a means of isolation and control.

In short, GSA’s Stage 2 explanation collapses under its own evidence: the Contact Management Plan never truly ended; it was simply renamed, reworded, and repurposed to continue silencing legitimate scrutiny.

Police involvement

What GSA said:
Stage 2 maintains that Stage 1 was accurate. GSA says the police referral was made by Steve Hayes personally in response to my “sustained focus” on him, and that GSA was not involved. They also say there is “no evidence” the words violent or dangerous were used, pointing to the charge “harassment without violence.”

What the record shows:
• The arrest followed an internal directive (from the former Director of Customer Services, supported by Sophie Atkinson) advising staff to go to the police if they “felt threatened.”
• This was part of a broader strategy to build a harassment narrative after litigation failed. No evidence of harassment existed; none has been produced.
• Hayes became a focus because, as Director of Communications, he fronted public messaging. Scrutinising a senior comms lead is accountability, not harassment.
• I complied with undertakings; there was no prohibited contact.
• Timeline: a court case was dismissed and costs awarded on 6 August 2024; shortly afterwards Hayes reported me; I was arrested in the early hours of 20 August 2024. The sequence looks retaliatory, not protective.
• Police took no further action. Officers told me Hayes described me as potentially violent, leading to six officers at 1 a.m. The charge label doesn’t alter that trigger.
• GSA cannot both say Hayes acted privately and also assert what was or wasn’t in the police report unless the organisation was involved or informed.
• Sophie Atkinson then publicly stated: “As an Executive Director of GSA – we 100% support Steve Hayes...” That contradicts the “personal capacity” claim and shows organisational backing.

Why this falls short:
The Stage 2 review downplays what was a coordinated organisational use of police powers, recasting it as a private complaint by one employee. The internal directive to staff, the public endorsement, and the timing following GSA’s courtroom defeat all point to a systemic misuse of authority aimed at silencing lawful criticism.

The bail conditions imposed after my arrest went far beyond what would be expected from a personal complaint. I made clear to officers at the time that I would not comply with them, as they amounted to an attempt to silence lawful expression.

The first bail condition stated that I must not contact, mention, or post about Steve Hayes in any capacity — including online articles, social media, or other communications. The second bail condition replicated these restrictions in full but applied them to GreenSquareAccord as an organisation.

Together, these conditions prohibited me from communicating with, referring to, or even discussing GreenSquareAccord or its Communications Director publicly. Their scope makes clear this was not the action of a single individual but an organisation-led effort to suppress public scrutiny through the use of police powers.

Narrative control, public misinformation and sector exclusion

What GSA said:
GSA claims contacts with external bodies/media were limited to exercising a right of reply, managing event clashes, and keeping discussions on-topic. They deny unusual aggression with ITV and say YouTube/SquareSpace reports were legitimate privacy concerns.

What the record shows:
• SAR disclosures show proactive outreach by Steve Hayes to sector bodies (including CIH and Four Million Homes) to have me removed from events, including before publication.
• ITV staff told me Hayes’s response to a right-of-reply request was personal and unusually aggressive, including a 1 a.m. email.
• Internal emails show monitoring of invitations I received and behind-the-scenes steps to have them withdrawn, unrelated to any live litigation.
• Multiple takedown requests to YouTube and Squarespace alleging harassment/copyright/privacy were not upheld; content remained online.
• Independent platforms found no breach; GSA’s own documentation frames these efforts as part of an organised comms strategy.

Why this falls short:
Calling this “right of reply” is misleading when the contact preceded stories or targeted organisers who had never sought GSA’s input. GSA didn’t simply respond to media coverage — they proactively contacted external organisations, including the Chartered Institute of Housing and the government-funded Four Million Homes programme, to have me excluded from events, panels, and discussions.

They did so while promoting unsubstantiated claims that certain colleagues had “felt harassed” by my behaviour — allegations that were never evidenced. GSA also asserted that I had contacted staff on their personal mobile phones, a claim they have since had to correct. The only instance involved a former senior manager, Julianne Britton, who had explicitly given consent for contact her via a mobile number as emails were lost due to CMP used by GSA.

These false and exaggerated claims were used to mislead third parties, framing me as a threat rather than as a resident raising legitimate concerns. Internal emails obtained through my Subject Access Request — showing Steve Hayes’s direct contact with the Chartered Institute of Housing and Four Million Homes — confirm that these interventions occurred, yet none of this evidence was reviewed or referenced in the Stage 2 investigation.

Ongoing failures in communication

What GSA said:
Stage 2 acknowledges communication failures are recurring (the second-highest reason for complaints). It apologises for a missed email to the Data Protection Team, saying internal restrictions blocked emails not sent via “info@”.

What the record shows:
• The problem is systemic and long-standing, as the Housing Ombudsman has already recognised.
• GSA’s own explanation shows scale: even the Data Protection Team didn’t know my direct emails were blocked. Lawful requests were delayed or lost.
• I copy multiple recipients so correspondence is actually received — that’s necessity, not duplication.
• On the Fire Risk Assessment (FRA), internal emails debated whether they were obliged to provide it, and the document was only released after remedial actions — identified a year earlier — were finally carried out. The delay appears to have bought time, not served residents.
• “Seven days is a standard service timescale” misses the point. This was a statutory health and safety disclosure.

Why this falls short:
Admitting failures while maintaining the systems that cause them is not improvement; it’s confirmation of dysfunction. Communication blocks compromise safety and transparency.

Subject Access Request (SAR) failures

What GSA said:
GSA says “full searches” were carried out across systems, including nicknames/initials I provided; they “do not use Zoom” and “do not have a GSA WhatsApp group”; withheld information was based on legal privilege or colleague confidentiality; they apologised for the missed email and will cooperate with the ICO.

What the record shows:
• Only GSA knows which nicknames or shorthand were used internally; expecting me to supply them reverses the burden and guarantees gaps.
• I did not ask for a “WhatsApp group” — I asked for WhatsApp messages on work devices where staff discussed me. Those are my personal data and must be searched.
• Saying “we don’t use Zoom” dodges the real question: do they use Microsoft Teams or other platforms, and were those properly searched?
• My SAR expressly requested “records from all communication platforms, including but not limited to Microsoft Teams, Zoom, WhatsApp, SMS/text, internal chat systems, and any other tools.”
• The response indicates they limited searches to Zoom (which they say they don’t use) and an invalid WhatsApp group, rather than searching company-issued phones/devices.
• “Colleague confidentiality” is misapplied: names can be redacted; content discussing me is still my personal data.
• The email-blocking that prevented the Data Protection Team from receiving my reply shows internal dysfunction in the very team responsible for compliance.
• Referring me to the ICO while declining to fix search scope in-house is not meaningful engagement.

Why this falls short:
The SAR process is neither comprehensive nor transparent. Narrowing “WhatsApp messages” to a “WhatsApp group,” and “video calls” to “Zoom,” looks like scope-avoidance, not compliance. Omissions around Teams and other platforms suggest no full search was undertaken. Escalation to the ICO is now the appropriate next step.

Conflicts of interest and professional conduct

What GSA said:
GSA thanks me for “feedback,” points to published Tenant Satisfaction Measures (TSMs) and annual reports, says the absence of 2023/24 TSMs online is a “data update,” and promises to discuss restoring historic data. They cite the Chair’s foreword to the 2025 Complaints and Service Improvement Report and deny pursuing me to protect reputation. They also point to a 19 September 2023 letter offering a meeting, conditional on an undertaking about acceptable behaviour.

What the record shows:
• Removing historic TSMs is a transparency issue. If GSA holds the data, it should publish it; “data update” is not an explanation.
• The Chair’s forewords repeat the same promises year after year while performance issues persist.
• GSA’s actions towards me are reputationally driven; the “harm” they allege is reputational.
• The meeting was required by the Housing Ombudsman to rebuild the relationship; GSA delayed and then imposed conditions via the customer service desk, not a senior decision-maker.
• I have never used offensive or intimidating language; there was no basis for requiring undertakings as a precondition to dialogue.
• Recording meetings is a basic accountability measure where accurate minutes are not reliably provided.

Why this falls short:
Stage 2 ends as it begins: with platitudes about improvement and selective memory about evidence. Transparency, engagement, and accountability remain absent. Withheld TSM data, recycled language, and conditional invitations reinforce a pattern: protecting image over integrity.

An Unchanging Culture

This has been a long and difficult journey stretching back to 2016, when I first began raising issues with GreenSquareAccord — then GreenSquare. Water leaks, faulty lifts, poor security, excessive service charges, unanswered complaints — the same problems persist. When I first spoke up, I hoped that by going through this process, both I and the organisation would evolve. I have.

Over that time, I’ve grown as a person — in my marriage, in resilience, and as a campaigner for better housing. I created a resident-support site that continues to flourish despite everything thrown at it. I built the Housing Sector platform — a space for tools, conversations, and education across the wider housing world. Through discussions with residents, leaseholders, campaigners, and professionals, I’ve learned, connected, and built a following. I’m now seen by many inside the sector as a threat to the status quo, but that’s fine — growth always unsettles those committed to standing still.

What’s clear from the first complaint I ever made to this most recent one is that GreenSquareAccord hasn’t grown. My tenancy almost spans Ruth Cooke’s entire tenure as CEO, and yet the lack of progress — in culture, accountability, and transparency — is tangible. The Stage 2 complaint response proves it. It demonstrates neither fairness nor independence. Instead, it exposes an organisation still hiding its true culture while promoting a polished version that happens to align neatly with the values expected of a National Housing Federation board member — which Ruth Cooke is.

Across every stage of this process, a pattern of evasion runs through GSA’s conduct. They reframe, minimise, or exclude key issues. They rely on recurring justifications — “colleague wellbeing,” “out of scope,” “privacy” — not to protect staff but to deflect accountability. It’s narrative control: using the language of improvement while practising the behaviour of avoidance. The result is predictable — a continuing erosion of trust between residents and their landlord.

That loss of trust explains why so many residents and groups now turn to public forums and social media to make their voices heard. It isn’t just me — it’s a symptom of a wider culture where GreenSquareAccord’s words no longer carry credibility. We’ve all heard the same tired promises and excuses repeated for years.

The difference between residents and staff is simple: we’re here for the long haul. Our homes are permanent; our lives are rooted in these communities. Staff, especially at senior level, come and go. More than half of GSA’s leadership team are on interim contracts. The churn is constant, but the culture remains. Ruth Cooke’s time will end soon enough, and someone new will arrive with the same promises of reform — only for the same behaviour to continue. Ten years on, very little has changed.

I’ve said before: what GSA class as stock, residents call homes. That remains the fundamental gulf between us.

With this Stage 2 process now closed, the next step is escalation.

Housing Ombudsman

The Housing Ombudsman must be made aware of how GreenSquareAccord’s leadership under Ruth Cooke have handled residents, complaints, and the use of legal intimidation. Many of the issues I’ve raised echo findings already made in other Ombudsman determinations. This is not an isolated failure but a persistent pattern.

I doubt the Housing Ombudsman will have many powers or opportunities to intervene in the harassment and misuse of legal processes that I have experienced, but it remains my duty to make them aware of the culture and behaviours that exist within GreenSquareAccord — a culture shaped by the leadership of CEO Ruth Cooke and Head of Governance Sophie Atkinson, and carefully concealed by their Head of Communications, Steve Hayes.

Information Commissioner’s Office (ICO)

As set out throughout this analysis, GSA deliberately narrowed and distorted my Subject Access Requests — hiding behind selective interpretations, omitting data, and refusing to conduct full searches. That is a data-protection failure that demands regulatory review.

Regulator of Social Housing

The Regulator must now consider whether GSA’s governance arrangements are fit for purpose. The behaviour seen in this complaint goes beyond poor communication — it exposes systemic weaknesses in leadership oversight and resident accountability.

Solicitors Regulation Authority (SRA) – Sophie Atkinson

Finally, I will be referring Sophie Atkinson, Executive Director of Governance and a registered solicitor, to the Solicitors Regulation Authority. This is not something I do lightly, but her conduct demands scrutiny.

The referral will cover, but not limited to:

• Misuse of copyright law at county-court level, where a judge described the action as a back-door prosecution and criticised the inclusion of unreasonable clauses such as prohibiting me from doing anything “annoying.”

• The use of SLAPP-style legal tactics to suppress public-interest reporting and lawful criticism.

• Misleading affidavit evidence, where statements filed under oath misrepresented facts and overstated the nature of alleged risk.

• Improper court action alleging breaches of undertakings, where GSA pursued me for supposedly failing to remove historic web pages that were never part of the undertakings I agreed to.

• Failures under data-protection law, where Subject Access Request responses were incomplete, filtered, and obstructed by email blocking.

• Endorsement of defamatory internal communications portraying me as a threat to the organisation.

• Governance failures under the Landlord and Tenant Act 1985, including the late response to statutory information requests and the back-dating of Section 20 costs that pushed expenditure beyond the £250 per-home threshold — effectively bypassing the legal consultation requirement.

• In addition, GreenSquareAccord deleted comments I made during a Section 22 consultation process, removing legitimate resident input from the record in direct contravention of their statutory and governance obligations.

• External defamation and misuse of authority, where GreenSquareAccord, under Ms Atkinson’s governance oversight, went beyond its own organisational boundaries to spread false or misleading information to outside bodies — including the police, the Chartered Institute of Housing, and the government-funded Four Million Homes programme — in an effort to damage my credibility and reputation.

• And finally, her role in enabling the misuse of police involvement, supporting an internal culture that encouraged staff to report alleged “harassment” without evidence and publicly backing a senior colleague whose complaint led to my unlawful arrest.

Together, these actions raise serious concerns about professional conduct, governance, and adherence to the legal standards expected of a solicitor

I take no enjoyment in any of this, but I have no choice. Accountability matters.

If this decade-long experience has shown me anything, it’s that silence in the housing sector isn’t accidental — it’s cultivated. The only way to change that is to challenge it head-on and leave a record that cannot be quietly deleted or rewritten.

So yes, this may be the end of my complaint with GreenSquareAccord, but it isn’t the end of the matter. I will take this forward with every relevant body, because others deserve better than what I’ve been put through. I have to tread a path so others have one to follow.

If you have any questions, advice, guidance, or would like to offer support, please get in touch.