Current fleet list and list of all sold vehicles

Freedom of information request reference no: 01.FOI.22.027342

I note you seek access to the following information:

Registration number:
Make:
Model:
of all vehicles currently on your fleet list and all vehicles sold between 27/11/2021 and 13/11/2022.

Decision

I have today decided to disclose the majority of the requested information. A lot of what you have requested is already in the public domain and a link to it has been provided below. Data about sold vehicles has been provided partially, as some of the data is exempt from disclosure. Therefore this response serves as a partial Refusal Notice under Section 17(1) of the Freedom of Information Act 2000 (the Act) by virtue of the following exemptions:

Section 21 - information requested has been identified as being accessible via other means
Section 31(1)(a)(b) – Law Enforcement
Section 40(2)(3A)(a) – Personal Information

Reason for decision

You have asked for information in relation to vehicles currently on our fleet list and those recently sold, to be broken down by make, model and registration plate. Unfortunately, disclosing the information you are seeking to the level of granularity you have requested would be likely to provide enough information for individuals (or groups of individuals) with criminal or malicious intent to disrupt our ability to deploy resources safely and efficiently which would hinder our ability to fulfil our basic law enforcement functions. Therefore, full registration plate details cannot be provided.

In additional, vehicles sold by us are now no longer an organisational asset and instead private property. Releasing the make, model and full registration could lead to the identification of the new owners, which would be their personal information. Therefore, redactions have been made in accordance with the Act to anonymise this data.

Section 21(1) - information requested has been identified as being accessible via other means - Information which is reasonably accessible to the applicant otherwise than under section 1 is exempt information.

Some of the information requested has been identified as being accessible via other means as it is already published. Where information is already in the public domain we are not required to re-publish the data; instead public authorities are required to direct you to the information, which we have done in this instance.

Section 31(1)(a)(b) – Law Enforcement - Any information that identifies specific vehicles (for example, disclosing their make, model and registration plate in full) would identify specific operational vehicles and therefore influence our tactical capability. If we were to disclose the above information to the level of granularity you have requested this would readily identify specific, and specialist, units whilst on patrol or responding to incidents. If this information was obtained by individuals with criminal intent they could use it to disrupt local policing. For example, any individual with access to this information could use the information to commit crime and avoid detection which would negatively affect the MPS law enforcement function. This knowledge could additionally provide sufficient information for individuals with malicious intent to form some form of attack on an operational unit.

Clearly it would not be in the best interests of the public to publish such information as it would also be likely to reduce the effectiveness of policing deterrents as a source for preventing and detecting crime. If criminals were to have full details of MPS fleet registration numbers and vehicle makes and models, they could use this information to create databases to exploit the absence of police in particular areas at specific times. Should any weaknesses of police vehicles deployment be exploited, there is a strong possibility criminality would result causing disruption and/or harm to members of the public and subsequently a loss of confidence in the MP.S

To disclose the information you have requested in full would therefore reveal our capability and would place the MPS at a tactical disadvantage as outlined in the harm above. It cannot be in the public interest to disclose information which would undermine our ability to detect crime, and bring offenders to justice, and ultimately, to reduce crime in London.

The majority of fleet data is already published by the MPS, in a way in which to avoid any potential harm. I consider that the benefit that would result from further information being disclosed does not outweigh the considerations favouring non-disclosure. This decision is based on the understanding that the public interest is not what interests the public, but what would be of greater good to the community as a whole.

Section 40(2)(3A)(a) – Personal Information - Under FOIA, it would be unfair and unlawful to disclose personal information relating to third parties. To disclose the full registration plate numbers of vehicles now no longer in our possession would essentially be the release of third party information. To disclose information by way of a FOIA disclosure would therefore be in contravention of the first data protection principle, which is that of fair, lawful and transparent processing.

When considering whether the processing of personal information is fair and lawful, we must balance the rights of data subjects and the legitimate interests in disclosure.

There is always generally some sort of legitimate interest in information requested under FOI, unless for personal interest. In this instance, the legitimate interest is extremely slight, and must be balanced against the unwarranted harm to the interests of the individuals who fall within the scope of the respect (either directly or indirectly).

In light of the nature of the information and reasonable expectations of individuals, I do not believe there these individuals would expect that the personal information the MPS holds about them would be publicly disclosed under the Act. The subjects of this request would have no reasonable expectation that the MPS would place their personal information into the public domain as this could lead to unsolicited contact.

As articulated above, the processing of personal data is governed by legislation and as such, the MPS has a legal obligation to take appropriate steps to protect personal data. Disclosing VRMs in full would require disclosing personal data and would impair the ability of the MPS to fulfil its legal obligations.

This matter was discussed in ICO Decision Notice FS507933731 which related to a request to Sunderland Council for information relating to vehicles licensed, or formerly licensed, as hackney carriage licences or Private Hire Vehicles (PHV’s). That stated that “a disclosure of the VRM’s of vehicles which are now being used for private purposes potentially discloses personal data relating to individuals”. It then went on to state,xx

“The Commissioner has previously considered the status of VRM’s under the DPA 1998 and decided that where the VRM belongs to a vehicle which is owned by a living individual the VRM itself will be personal data without associated information being disclosed with it. This is because information identifying the owner of the vehicle is obtainable simply from having access to the VRM. However the Commissioner notes that where the owner of a vehicle is a corporate body or an organisation rather than a living identifiable individual then VRM information cannot be personal data.”

With this in mind, a disclosure of any VRM data which refers to vehicles which have since been sold on to private individuals would also be a disclosure of personal data, relating to the new owner of the vehicle. A motivated individual with access to the VRM number of a vehicle would be able to take steps to identify the current owner of that vehicle.

Section 40 exemption is therefore appropriate with regards to your request for information under FOIA and that the public interest in this matter is met by the MPS publishing fleet data in a manner which does not pose harm to private individuals.

Disclosure

Please be advised that MPS Fleet Data is published every six months by the MPS. Any further breakdown than that published would significantly impact on law enforcement. Please access the link below for the most recent published data: MPS Fleet Data – July 2022:

Fleet list data – July 2022 | Metropolitan Police

Please find attached details relating to sold vehicles, subject to redactions for vehicle registrations (for the reasons outlined above).