Equalities Impact Assessment report for the Project Alpha Social Media Hub

Freedom of information request reference no: 01.FOI.21.021572

I note you seek access to the following information:

I would like to request the Equalities Impact Assessment report for the Project Alpha Social Media Hub.

The equalities impact assessment is mentioned here:

MOPAC - Project Alpha Social Media Hub

"This business case has undergone a full Equalities Impact Assessment. Due regard has been taken to the Equality Act’s Public Sector Equality Duty under Sec 149 of the Equality Act 2010. Consideration has been taken to assess equality impact caused by the proposed business change including effective engagement and analysing relevant equality information. As a result, no negative impact has been identified to any individual at this stage."

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 31(1)(a)(b)– Law enforcement
Section 40(2)(3A) – Personal Information

Reason for decision

Before I explain the decisions that I have made in relation to your request, I thought that it would be helpful to outline the parameters set out by the Freedom of Information Act 2000 (the Act), within which a request for information can be answered. The Act creates a statutory right of access to information held by public authorities. A public authority in respect of a request must, if permitted, state under Section 1(a) of the Act, whether it holds the requested information and, if held, then communicate that information to the applicant under Section 1(b) of the Act.

The right of access to information is not without exception and is subject to a number of exemptions which are designed to enable public authorities to withhold information that is unsuitable for release. Importantly, the Act is designed to place information into the public domain, that is, once access to information is granted to one person under the Act, it is then considered public information and must be communicated to any individual should a request be received.

Section 31(1)(a)(b) LAW ENFORCEMENT - Disclosure of any further information in regards to your request would cause operational harm to the MPS and affect our ability to fulfil our core function of law enforcement. The release of such information would reveal tactical operational information which would be to the detriment of providing an efficient policing service and a failure in providing a duty of care to all members of the public.

Disclosure of any further information would hinder the ability of the MPS to police effectively in preventing crime and harm to others involving potentially serious violence if the public become aware of the tactics, resources and capabilities available to the MPS. This is particularly so if the public are aware of what type of tactics, intelligence and resources the MPS are likely to have available and use, as it also indicates what capabilities and resources they do not have and decisions they may take to overcome the violence used or threatened, by those wishing to cause harm.

It is not in the public interest to disclose any further information as it would in effect, reveal law enforcement tactics and resources used to respond to such policing matters. Such a disclosure would also have an adverse effect, by assisting those planning to commit acts of violence.

Disclosure of the type of capabilities available to the police at a specific point in time would enable those individuals intent on committing criminal activity to circumvent methods used to prevent crime and apprehend offenders. This in turn hinders the ability of the MPS to carry out its core functions in law enforcement.

Disclosure of any further information would also place the public at greater risk of harm, if would-be criminals were provided with such information which is clearly related to policing capabilities.

Section 40(2)&(3) - PERSONAL INFORMATION - I consider that Section 40(2) and 40(3A)(a) is applicable in this case, as disclosure of the names of individuals, as would be contained within the documents being requested, 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 under FOIA, in accordance with the First Data Protection Principle.

Disclosure

Please see below a document which has been redacted in part by virtue of section 31(1)(a)(b)– Law enforcement and section 40(2)(3A) – Personal Information.

Please note that the first redaction refers to the Protective Marking of the document, which is deemed not relevant to this request.