Information on uniforms for Sir Mark Rowley

Freedom of information request reference no: 01.FOI.22.027548

I note you seek access to the following information:

A) Since the announcement of his selection as Commissioner in July 2022, how much have the provision of and/or alteration of uniforms for Sir Mark Rowley cost?

B) A list of which uniforms have been provided and/or altered and what the alterations were.

C) how the above was funded.

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)&(3A)(a) - Personal Data

Reason for decision

The answers to your questions are provided below in the section titled Information disclosed. In relation to Question B, I have not indicated which items have been altered and what the alterations were.

Section 40(2)(3) - Personal Information - When this exemption is claimed, it is accepted that harm would result from disclosure. Section 40(3A)(a) states that public authorities will not disclose information which constitutes personal data and if the disclosure would contravene any of the Data Protection principles.

To disclose the alterations made to the Commissioner’s uniform would publicly reveal information about an individual which would contravene Data Protection principles. The Data Protection Act 2018 defines personal data as any information relating to an identified or identifiable living individual. There are six data protection principles set out in section 34 of the DPA 2018 and under Article 5(1)(a) of the General Data Protection Regulations (GDPR). The first principle requires personal data to be processed in a ‘lawful and fair’ manner. The basis for determining what constitutes lawful and fair is outlined under section 35 of the DPA. Under section 35(2) it states:

• the data subject has given consent to the processing for that purpose, or
• the processing is necessary for the performance of a task carried out for that purpose by a competent authority.

It is important to note that the release of the data will not be used for a law enforcement process.

Under Article 6(1)(f) of the GDPR, the disclosure of personal data is considered to be lawful if:

• There is a legitimate interest in the disclosure of that personal data.
• The disclosure of the personal data is necessary to meet that legitimate interest.
• The disclosure would not cause unwarranted harm to the data subject.

Having considered your request, I have found that alterations made to the Commissioner’s uniform would disclose special category data. By means of a legitimate interest test I have considered the release of the personal data, and I have found that:

Commissioner alterations

• Disclosing the alterations made to the Commissioner’s uniform would provide information which falls under special category data. The ICO states that ‘Special category data is personal data that needs more protection because it is sensitive’. I have not identified a legitimate interest that would be fulfilled through disclosing this data.

• As the head of London's Metropolitan Police Service the Commissioner would expect that certain types of information in relation to his role will be requested and disclosed. The role of Commissioner is both a senior and a public facing role in which the Commissioner in part, is responsible for explaining and defending policies, and delivering this to the public at large, therefore the disclosure of certain information is considered reasonable. However, the Commissioner would have a legitimate expectation that the MPS would not publicly release and publish his information that would fall under special category data in response to a Freedom of Information request. The MPS must consider how we process personal data, even when this data is in relation to the Commissioner who is in a public facing role.

• Alterations have occurred in relation to some of the Commissioner’s uniform. Including this data could provide health data about the Commissioner. You may ask how this is possible? If I disclose that an alteration has been made to the Commissioner’s jacket for example, and then specify what this was, and in 6 months’ time I then receive another FOIA request asking the same questions that you have posed, I would be divulging health data. If the jacket has been altered then this could indicate the Commissioner has lost or gained weight, or that his weight has remained the same. If I then receive another FOIA asking about alterations 4 months later, again I would be providing an update on any changes. This is health information which falls under special category data which could be harmful, if released. Accordingly, I have provided a section 40 exemption in respect to alterations made.

CONTEXT
Please note that as Commissioner of one of the country’s largest Police force, covering the capital, he is required to attend Ceremonial events, such as The State Funeral of Queen Elizabeth II or the forthcoming coronation. Therefore, it is essential that the Commissioner is provided with a special uniform for such State events or other ceremonial duties. To ensure value for money when such uniforms are prepared, the MPS use a regular supplier.

Disclosure

QA - Since the announcement of his selection as Commissioner in July 2022, how much have the provision of and/or alteration of uniforms for Sir Mark Rowley cost?

The majority of the Commissioner’s uniform has been supplied from existing Uniform Services stock, as it would be for any serving officer, funded through the Met’s annual uniform budget and alterations undertaken in-house at no additional cost. A small number of uniform items are specific to the Commissioner, to enable him to undertake a number of official and ceremonial duties as the most senior police officer in the country.

The cost of the Commissioner’s uniform provision overall is approximately £6071.18

QB - A list of which uniforms have been provided and/or altered and what the alterations were.

Jackets/Tops/Fleece
Coat/Tunic
Shirts
Trousers
Ceremonial dress
Accessories (including hat, belt, cravat, gloves, epaulettes)

Please note I have not indicated which items have been altered, nor what the alterations were. This data is exempt by virtue of section 40(2)(3) – Personal Information.

QC - How the above was funded ?

The Commissioner’s uniform is funded through the uniform services budget, as it is for all officers. Any necessary alterations to uniform would have been undertaken in-house by Uniform Services, and as such there is no additional cost.