Operational, Tactical and Strategic (Bronze, Silver, Gold) Commanders of Operation London Bridges in the MPS

Freedom of information request reference no: 01.FOI.22.026584

I note you seek access to the following information:

I am requesting the roles, rank and, if possible, the names of the Operational, Tactical and Strategic (Bronze, Silver, Gold) Commanders of Operation London Bridge in the MPS.

In using Operation London Bridge, I mean the events surrounding the death of Her Majesty Queen Elizabeth II, including the processions and the funerals. Specifically, the period beginning on the 8 September 2022 to the 19 September 2022.

Decision

I have today decided to disclose some of the requested information. Some data has been withheld as it is exempt from disclosure and therefore this response serves as a Refusal Notice under Section 17 of the Freedom of Information Act 2000 (the Act) by virtue of the following exemptions:

Section 40(2)&(3) – Personal Information

Reason for decision

I consider that Section 40(2) and 40(3A)(a) is applicable in this case, as any further disclosure at this level of detail (names of officers below Chief Superintendent), would breach the 1st data protection principle that requires personal data to be processed lawfully, fairly and in a transparent manner in relation to individuals.

There is no presumption of disclosure in relation to ‘personal data’ which is defined as: ‘any information relating to an identified or identifiable living individual’

“Identifiable living individual” means a living individual who can be identified, directly or indirectly, in particular by reference to—

(a) An identifier such as a name, an identification number, location data or an online identifier, or
(b) One or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the individual.’

For such disclosure to be lawful, it would be necessary to satisfy a condition within Article 6 of the GDPR. Article 6 sets out the six lawful bases, applying to all processing; one of which must be in place in every case of disclosure of personal data, in accordance with the first data protection principle. The Information Commissioner’s Office (ICO) guidance provides:

‘In all circumstances, you must have an Article 6 lawful basis for processing.

There are six lawful bases for processing in Article 6, but only (a) consent or (f) legitimate interest are relevant to disclosure under FOIA or EIR.

In order to assess whether this lawful basis is engaged you need to consider three key questions:

(i) Purpose: what is the legitimate interest in disclosure of the information?
(ii) Necessity: is disclosure necessary for that purpose?
(iii) Balancing test: does the legitimate interest outweigh the interests and rights of the individual?’

Here, we need to balance the rights and freedoms of the individuals involved with any legitimate public interest in disclosure. Any further disclosure of the requested information under FOIA legislation is not necessary to meet a legitimate interest.

With this in mind, the data subjects in the circumstances of your request would have a legitimate expectation that this type of personal data would not be used for non-policing purposes (i.e. FOIA requests – disclosures for which are also placed on the MPS website Publication Scheme).

Any further disclosure in the circumstances of your request would be unlawful and would therefore contravene the first data protection principle. I have therefore applied the exemption provided under Section 40(2) of the Freedom of Information Act to this information as the first condition, defined in subsection (3A)(a) of Section 40 has been satisfied. This therefore, becomes an absolute exemption.

Disclosure

Please find below information pursuant to your above request:

Position	Holder	Officer Name
Gold MPS	DAC Jane Connors	DAC Jane Connors
Silver MPS	T/Cmdr. Karen Finlay	T/Cmdr. Karen Finlay
Bronze 1	Superintendent
Bronze 2	Chief Supt Chief	Supt Claire Clark
Bronze 3	Superintendent
Bronze 4	Superintendent
Bronze 5	Superintendent
Bronze 6	Superintendent
Bronze 7	Superintendent
Bronze 8	Superintendent
Bronze 9	Superintendent
Bronze 10	Superintendent
Bronze 11	Not used
Bronze 12	Superintendent
Bronze 13	Superintendent
Bronze 14	C/Insp
Bronze 15	Chief Supt	Chief Supt Stuart Bell
Bronze 16	City of London	Commander Dai Evans (CoLP)
Bronze 17	City of London	Commander Dai Evans (CoLP)
Bronze 18	Superintendent
Bronze 19	C/Insp
Bronze 20	C/Insp
Bronze Marine	Inspector
Bronze Mounted	Inspector
Bronze Engagement	Commander Helen Harper	Cmdr Helen Harper
Bronze CTC	Detective Chief Supt	D/Chief Supt David McGillicuddy
Bronze Crime	Detective Chief Supt	D/Chief Supt Simon Messinger
Bronze Firearms	Superintendent
Bronze Protection	C/Insp
Bronze Escort	C/Insp
Bronze Command & Control	Chief Supt	Chief Supt Kris Wright
Bronze Support	Superintendent