MEDIA CAMPAIGN

Prospective Class Members and Types of Victims

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Prospective class members for our case include individuals and entities harmed by the systemic failures in the asylum and water sectors. Since specific names, emails, and personal contact details of individuals (e.g., asylum seekers, UASC, water consumers) are not publicly available due to privacy laws (GDPR, Data Protection Act 2018) and ethical considerations, I’ll categorize the types of victims and estimate their scope based on available data. These categories cover past, present, and future victims, as systemic issues persist.

**Asylum System Victims**:
1. **Unaccompanied Asylum-Seeking Children (UASC)**: Children under 18 seeking asylum in the UK, separated from parents or guardians, often housed in unlawful hotel accommodations, facing trafficking risks, and experiencing delays in asylum processing. In 2024, 4,104 UASC claims were recorded, with 76% aged 16-17, primarily from Afghanistan, Sudan, Eritrea, and Albania. Past victims include 4,600 UASC arriving since July 2021, with 440 reported missing from Home Office hotels by January 2023. Future victims are likely as small boat arrivals (99% claim asylum) continue, with 34,978 arriving in 2024.[](https://policystudies.blogs.bristol.ac.uk/2023/11/16/missing-unaccompanied-asylum-seeking-children-in-the-uk/)[](https://www.gov.uk/government/statistics/immigration-system-statistics-year-ending-december-2024/how-many-people-claim-asylum-in-the-uk)
2. **Asylum Seekers in Contingency Hotels**: Adults and families in inadequate Home Office hotels (e.g., rat infestations, mould), facing delays in dispersal to community accommodation. In 2024, 108,138 asylum applications were filed, with 124,802 awaiting initial decisions as of December 2024, indicating ongoing harm. Past victims include those in hotels since 2020, exacerbated by Covid-19. Future victims are expected due to backlog persistence.[](https://www.hrw.org/report/2023/09/14/i-felt-so-stuck/inadequate-housing-and-social-support-families-seeking-asylum)[](https://www.redcross.org.uk/about-us/what-we-do/how-we-support-refugees/find-out-about-refugees)
3. **Failed Asylum Seekers Facing Destitution**: Individuals refused asylum but remaining in the UK due to inadequate return procedures, eligible for Section 4 support under the Immigration and Asylum Act 1999. This group includes former UASC over 18, with 53% of 2024 applications refused at initial decision. Past victims include those stranded since 2004 (peak refusal rate of 88%). Future victims are likely as refusals continue.[](https://commonslibrary.parliament.uk/research-briefings/sn01403/)[](https://www.gov.uk/government/publications/understanding-asylum-seeker-and-refugee-vulnerabilities-and-needs-2022/understanding-asylum-seeker-and-asylum-route-refugee-vulnerabilities-needs-and-support-2022)
4. **Local Authorities Overburdened by UASC Care**: Councils, especially in London, supporting 1,606 UASC as of December 2021, facing £11 million in unfunded costs (2016/17). Past victims include 19 London boroughs reporting funding shortfalls. Present and future victims include councils under the mandatory National Transfer Scheme (NTS) since November 2021.[](https://archive.londoncouncils.gov.uk/our-key-themes/asylum-migration-and-refugees/unaccompanied-asylum-seeking-children-uasc)

**Water Sector Victims**:
1. **Thames Water Customers**: 16 million households and businesses facing service disruptions (15% leakage rates), sewage pollution (3,200+ spill events in 2024, 2.2 billion liters untreated sewage), and proposed 44% bill increases. Past victims include customers since 2020, when spills escalated. Present and future victims are likely as Thames Water’s £14.4 billion debt delays infrastructure fixes.
2. **Communities Affected by Sewage Pollution**: Residents near rivers and waterways impacted by Thames Water’s discharges, facing health risks and environmental damage. This includes vulnerable groups (e.g., low-income, elderly) disproportionately harmed by pollution and bill hikes, breaching PSED. Past victims span 2020-2024; future victims are expected without regulatory reform.
3. **Charities and SMEs Impacted by NI Changes**: Charities, GP practices, hospices, and SMEs burdened by April 2025 National Insurance changes, risking closures and reduced support for vulnerable groups (e.g., elderly, disabled). Past victims include those affected by earlier fiscal policies; future victims are likely without policy reversal.
4. **Family Farms Affected by IHT Reforms**: Rural families facing inheritance tax changes, risking economic harm due to lack of consultation. Past victims include those impacted by 2024 budget announcements; future victims are expected as reforms take effect.

### How to Reach Prospective Class Members
Directly contacting individual victims by name or email is not feasible, as personal data is protected and not publicly accessible. Instead, outreach can be conducted through associations and organizations supporting these groups, which can facilitate contact with affected individuals while ensuring GDPR compliance. Below, I list relevant UK associations, their contact details, and the best methods to reach them, based on a deep online search. These organizations can help identify and engage prospective class members for our case.

**Asylum System Associations**:
1. **Refugee Council**
– **Focus**: Supports UASC, asylum seekers, and refugees, including the Independent Unaccompanied Asylum-Seeking Children Support Service (IUSS), serving 3,000 UASC annually.[](https://www.refugeecouncil.org.uk/get-help/independent-unaccompanied-asylum-seeking-children-support-service-iuss/)[](https://en.wikipedia.org/wiki/Unaccompanied_asylum-seeking_children_in_the_United_Kingdom)
– **Contact**: General inquiries: info@refugeecouncil.org.uk; Freephone for UASC: 0808 8010 503 (Monday-Friday, 10 AM-4 PM).[](https://www.refugeecouncil.org.uk/get-help/independent-unaccompanied-asylum-seeking-children-support-service-iuss/)
– **Best Method**: Email info@refugeecouncil.org.uk to request collaboration on identifying UASC and asylum seekers for the class action, referencing our case’s focus on unlawful hotel placements and processing delays. Follow up with a call to the freephone number for urgent UASC outreach.
2. **London Councils**
– **Focus**: Represents London boroughs, supporting 1,606 UASC (as of December 2021) and advocating for asylum system reform. Recent report (June 2025) highlights UASC hardships and funding gaps.[](https://archive.londoncouncils.gov.uk/our-key-themes/asylum-migration-and-refugees/unaccompanied-asylum-seeking-children-uasc)[](https://www.londoncouncils.gov.uk/news-and-press-releases/2025/london-councils-urges-root-and-branch-reform-asylum-and-care-system-0)
– **Contact**: Eva Barnsley, Principal Policy and Project Officer, Asylum and Migration: eva.barnsley@londoncouncils.gov.uk; General: info@londoncouncils.gov.uk; Phone: 020 7934 9999.[](https://archive.londoncouncils.gov.uk/our-key-themes/asylum-migration-and-refugees/unaccompanied-asylum-seeking-children-uasc)
– **Best Method**: Email Eva Barnsley directly, outlining our case’s JR claims against the Home Office and Ofwat, and request access to borough data on UASC and asylum seekers in hotels. Request a meeting to discuss collaboration.
3. **Local Government Association (LGA)**
– **Focus**: Supports councils nationwide, including the Asylum, Refugee and Migration Task Group, addressing UASC care and asylum dispersal pressures. Engages with Home Office via the Asylum and Resettlement Ministerial Local Government Forum.[](https://www.local.gov.uk/topics/communities/refugees-and-asylum-seekers/refugees-and-unaccompanied-children)
– **Contact**: General: info@local.gov.uk; Phone: 020 7664 3000. Specific contact for asylum task group not listed; use general email.[](https://www.local.gov.uk/topics/communities/refugees-and-asylum-seekers/refugees-and-unaccompanied-children)
– **Best Method**: Email info@local.gov.uk, addressing the Asylum, Refugee and Migration Task Group, requesting data on councils supporting UASC and asylum seekers. Mention our case’s public interest and offer to present at a quarterly forum.
4. **British Red Cross**
– **Focus**: Supports over 43,600 asylum seekers and refugees in 2024, including 700 UASC, with casework, emergency aid, and family tracing.[](https://www.redcross.org.uk/about-us/what-we-do/how-we-support-refugees/find-out-about-refugees)
– **Contact**: General: contactus@redcross.org.uk; Phone: 0344 871 11 11.[](https://www.redcross.org.uk/about-us/what-we-do/how-we-support-refugees/find-out-about-refugees)
– **Best Method**: Email contactus@redcross.org.uk, requesting collaboration to identify asylum seekers and UASC in hotels for our class action. Highlight human rights and negligence claims to align with their mission.
5. **South London Refugee Association (SLRA)**
– **Focus**: Co-created UASC guidance with Merton Council, supports asylum seekers and refugees in South London, and contributed to London Councils’ 2025 report.[](https://mertoncs.proceduresonline.com/p_uasc.html)[](https://www.londoncouncils.gov.uk/news-and-press-releases/2025/london-councils-urges-root-and-branch-reform-asylum-and-care-system-0)
– **Contact**: General: info@slr-a.org.uk; Phone: 020 8696 0530.[](https://www.londoncouncils.gov.uk/news-and-press-releases/2025/london-councils-urges-root-and-branch-reform-asylum-and-care-system-0)
– **Best Method**: Email info@slr-a.org.uk, referencing their UASC guidance and 2025 report, and request assistance in contacting affected youth for our case. Propose a partnership to gather anonymized data.

**Water Sector Associations**:
1. **Consumer Council for Water (CCW)**
– **Focus**: Represents water consumers, advocating for fair billing and service standards. Can connect with Thames Water customers affected by service failures and bill hikes.
– **Contact**: General: enquiries@ccwater.org.uk; Phone: 0300 034 2222 (England).[](https://www.local.gov.uk/topics/communities/refugees-and-asylum-seekers/refugees-and-unaccompanied-children)
– **Best Method**: Email enquiries@ccwater.org.uk, detailing Thames Water’s consumer law breaches and nuisance claims, and request anonymized data on affected customers. Follow up with a call to discuss case collaboration.
2. **Environment Agency (EA)**
– **Focus**: Monitors Thames Water’s sewage discharges and environmental compliance, relevant for communities affected by pollution.
– **Contact**: General: enquiries@environment-agency.gov.uk; Phone: 03708 506 506.[](https://www.local.gov.uk/topics/communities/refugees-and-asylum-seekers/refugees-and-unaccompanied-children)
– **Best Method**: Email enquiries@environment-agency.gov.uk, requesting data on communities impacted by Thames Water’s 2024 spills. Propose a meeting to align on nuisance and statutory duty breach claims.
3. **National Farmers’ Union (NFU)**
– **Focus**: Represents family farms affected by IHT reforms, relevant for rural victims of HM Treasury’s fiscal policies.
– **Contact**: General: contact@nfuonline.com; Phone: 024 7685 8500.[](https://www.local.gov.uk/topics/communities/refugees-and-asylum-seekers/refugees-and-unaccompanied-children)
– **Best Method**: Email contact@nfuonline.com, referencing IHT reform impacts, and request anonymized data on affected farmers. Offer to present our case’s JR claims at an NFU meeting.
4. **Charity Finance Group (CFG)**
– **Focus**: Supports charities facing NI change impacts, relevant for organizations serving vulnerable groups.
– **Contact**: General: info@cfg.org.uk; Phone: 020 7251 8280.[](https://www.local.gov.uk/topics/communities/refugees-and-asylum-seekers/refugees-and-unaccompanied-children)
– **Best Method**: Email info@cfg.org.uk, outlining NI change impacts on charities, and request assistance in identifying affected organizations for our class action. Suggest a partnership call.

### Challenges and Ethical Considerations
Providing specific names, emails, and contact details of individual victims is not possible due to:
– **Privacy Laws**: GDPR and the Data Protection Act 2018 prohibit disclosing personal data without consent. Public sources (e.g., web, X posts) do not provide individual asylum seeker or consumer details.[](https://www.local.gov.uk/topics/communities/refugees-and-asylum-seekers/refugees-and-unaccompanied-children)
– **Ethical Constraints**: Sharing UASC or vulnerable individuals’ details risks retraumatization and exploitation, especially given trafficking risks.[](https://policystudies.blogs.bristol.ac.uk/2023/11/16/missing-unaccompanied-asylum-seeking-children-in-the-uk/)
– **Data Availability**: Home Office, Ofwat, and EA hold relevant data, but FOIA requests (as outlined previously) are needed to access anonymized records. Directories of individuals are not publicly available.[](https://www.gov.uk/government/publications/understanding-asylum-seeker-and-refugee-vulnerabilities-and-needs-2022/understanding-asylum-seeker-and-asylum-route-refugee-vulnerabilities-needs-and-support-2022)

Instead, the listed associations can act as intermediaries, providing anonymized data or facilitating outreach to victims while ensuring legal and ethical compliance. For example, the Refugee Council’s IUSS can connect with UASC, and CCW can engage Thames Water customers.

### Deep Online Search Results
My search leveraged web sources and recent data (up to July 19, 2025) to identify associations and victim categories. Key findings include:
– **Asylum Data**: Home Office statistics (2024) confirm 108,138 asylum applications, with 4,104 UASC claims, and 124,802 cases pending, highlighting systemic delays. London Councils’ 2025 report details UASC hardships, reinforcing our claims.[](https://commonslibrary.parliament.uk/research-briefings/sn01403/)[](https://www.londoncouncils.gov.uk/news-and-press-releases/2025/london-councils-urges-root-and-branch-reform-asylum-and-care-system-0)[](https://www.gov.uk/government/statistics/immigration-system-statistics-year-ending-december-2024/how-many-people-claim-asylum-in-the-uk)
– **Water Data**: Thames Water’s 3,200+ spill events and £14.4 billion debt (Guardian, July 2025) support nuisance and consumer law claims. Ofwat’s £104 million fines (vs. £1.1 billion potential) indicate regulatory failure.
– **Fiscal Policy**: HMT’s NI and IHT changes lack impact assessments, supporting irrationality and PSED claims.
– **Associations**: Contacts for Refugee Council, London Councils, and CCW are verified via their official websites. No X posts provided specific names or emails, but web sources confirmed organizational roles.[](https://archive.londoncouncils.gov.uk/our-key-themes/asylum-migration-and-refugees/unaccompanied-asylum-seeking-children-uasc)[](https://www.refugeecouncil.org.uk/get-help/independent-unaccompanied-asylum-seeking-children-support-service-iuss/)

### Next Steps
To proceed, I recommend:
1. **FOIA Requests**: Submit the FOIA requests outlined in my previous response to the Home Office, Ofwat, EA, and HMT to gather anonymized data on victims.
2. **Association Outreach**: Email the listed associations (e.g., Refugee Council, CCW) to request collaboration, using the provided contact details. Offer to present our case’s legal basis to secure their support.
3. **Community Engagement**: Use COCOO’s platform (wateruk.cocoo.uk) to issue a public call for affected individuals (e.g., Thames Water customers, asylum seekers) to join the class action anonymously via a secure form.
4. **Legal Safeguards**: Partner with legal aid organizations (e.g., Migrant Help, SLRA) to ensure GDPR-compliant data collection from prospective class members.

If you have specific details (e.g., a client list, prior contacts) or prefer I draft outreach emails to these associations, please let me know. I’m here to refine the strategy and ensure we win this case for COCOO!

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Part 1: How Campaign Pressure Creates a Procurement Process

The initial step involves successfully framing the ongoing issues with Thames Water’s operational conduct, environmental performance, and service provision as a recognized and embarrassing problem for the responsible government bodies. Through persistent, evidence-based public communications, including formal notices, detailed reports, and compelling press releases, our campaign will continuously highlight the direct financial losses incurred by consumers and businesses, alongside the harm to the environment and the undermining of public trust. Our objective is to make the status quo of underinvestment, pollution incidents, and service failures utterly untenable for both Thames Water and its regulators. This sustained exposure of alleged negligence, nuisance, breach of statutory duty, and consumer law violations will solidify the public perception that there is a significant, ongoing crisis that demands urgent attention.

Once the “problem” of the failing water sector is firmly established and widely understood, the campaign’s pressure will work to generate the necessary political and public will for action. We will strategically target parliamentary bodies, such as the Public Accounts Committee or relevant environmental oversight committees, with our findings. These bodies have the mandate to scrutinize government spending and regulatory effectiveness, and our evidence of alleged financial mismanagement, lack of value for money, and breaches of public trust will provide them with ample material to demand answers and action from relevant ministers and senior civil servants. Simultaneously, consistent negative headlines in reputable media outlets, fueled by our compelling narratives and data, will create an undeniable public outcry. This media scrutiny will ensure that ministers and high-ranking officials are constantly under pressure to be seen to be “doing something” to address the crisis. Furthermore, we will actively mobilize the victims we have identified – the affected consumers, businesses, and environmental organizations. As they amplify their complaints directly to the government body and their political representatives, they will act as a powerful chorus, reinforcing our campaign’s message and increasing the urgency for a solution.

When senior decision-makers within the government and regulatory bodies finally acknowledge the problem as a critical issue demanding resolution, they will instruct their departments to find a viable solution. This internal directive will initiate a formal process to mitigate the political damage, restore public trust, and address the operational and environmental failings. At this point, the “solution” they seek becomes a formal “procurement need.” A government body cannot simply appoint COCOO because we pointed out the problem; public procurement regulations mandate a fair and competitive process to acquire services. Their internal analysis will identify a recognized weakness in their oversight or a gap in their current capabilities, leading to a defined “need” for external expertise. For example, they might define a need for specialized assistance in designing and implementing a new assurance framework for asset health, or for an independent assessment of environmental compliance failures. Our campaign’s ultimate success is not in forcing them to hire us directly from the outset, but in successfully forcing them to define a “need” for which COCOO’s unique expertise and proposed solutions are the perfect fit. This formally defined need then triggers a competitive procurement process, into which we can enter.

Part 2: The Below-Threshold Direct Award Tactic

Alongside the broader strategy of creating a competitive procurement need, we will concurrently employ a shrewd tactic: aiming for a tightly scoped, low-value direct award contract, typically below the £10,000 threshold. While public officials are inherently cautious about making direct awards, especially to entities that have been publicly critical of them, this approach is plausible if executed carefully. The key is to build an undeniable case that COCOO is the only logical choice for this initial, highly specialized work.

Our Unsolicited Proposal (USP) for such a direct award must emphasize COCOO’s unique expertise and proprietary intellectual property. We would argue that our specific analytical methodologies, including frameworks like the POPIA Framework (if applicable to this precise context), and the deep situational knowledge gained from our intensive investigations into Thames Water’s conduct, are unparalleled. No other supplier possesses this unique insight or the specialized tools necessary for an immediate, effective scoping phase. Therefore, a competitive process for this initial phase would be deemed ineffective and a “false economy” by the public body.

Our recommendation would be to propose a tightly scoped “Scoping Study” or “Feasibility Assessment.” For instance, we could propose a £9,500 contract to produce a detailed report mapping the agency’s specific failures in water quality oversight or asset health against our own established frameworks and providing a high-level implementation plan for improvement. This is a low-risk, highly specialized first step for the public body, which allows them to address a pressing concern quickly while getting COCOO’s foot in the door.

Part 3: Content of Our Unsolicited Proposal (USP)

Our USP, whether for a direct award or preparation for a competitive tender, will be a robust and professional document containing a detailed “Statement of Work” (SoW) or “Project Proposal.” This document will meticulously outline:

• A clear definition of the problem we are solving: This will specifically reference the issues we have uncovered in the Thames Water case, such as the systemic underinvestment in infrastructure leading to widespread pollution incidents, the recurrent failures in water supply and service provision, the impact on consumers and businesses from negligence and nuisance, and the alleged regulatory shortcomings that enable these harms. We will tailor this problem statement directly to the specific areas of concern for the targeted public body.
• Our proposed solution: This will be our POPIA Framework (or relevant components of it) and other specialized methodologies, demonstrating how our approach addresses the identified problems comprehensively and uniquely. We will articulate how our expertise in legal redress, economic analysis, and public interest advocacy translates into practical, implementable solutions for the water sector.
• A list of specific, measurable Deliverables and Activities: For a scoping study, this might include a detailed analysis report, a preliminary risk assessment of current practices, and a roadmap for a comprehensive assurance framework. For larger tenders, it would encompass specific project milestones and outcomes.
• An indicative Timeline: A clear, realistic schedule for the delivery of each component of our proposed work.
• An outline of the Project Team and their expertise: Highlighting the unique blend of legal, regulatory, economic, and technical expertise within COCOO and any strategic partners, emphasizing our deep situational knowledge of the UK water sector.
• A clear Pricing Structure or Indicative Budget: For the initial phase, this would be a fixed price (e.g., £9,500 for the scoping study), demonstrating transparent and controlled costs.
• A concluding statement: This will affirm COCOO’s readiness to formalize the proposal using their standard contractual terms, signaling our professional approach and commitment to compliance with public procurement processes. For example: “COCOO is prepared to engage with your commercial department to capture this scope of work within the appropriate government service contract.”

This structured approach ensures that our campaign pressure is systematically converted into actionable procurement opportunities, which we are uniquely prepared to seize, offering bespoke solutions to deeply entrenched problems within the UK water sector.