Guidance on VRMs

Freedom of information request reference no: 01.FOI.22.027616

I note you seek access to the following information:

You state the MPS only publishes the first 4 characters of a VRM. This is in keeping with current National Police Chief’s (NPCC) guidance on the subject.

1. It would have bene helpful for you to provide me with a copy of the guidance. Please do so.

2. Does the MPS register their total loss vehicles with MIAFTR2 i.e., whether through an intermediary or directly, place their total loss records in the central database of write-offs that is available to the public?
a. If ‘yes’, why will you not provide them to me if they are available via another source
b. If ‘no’, why not – the register is ‘anti-fraud’

3. What manages your total loss Claims

4. What is your disposal route for total losses i.e. auction – if so which one?

Decision

I have today decided to disclose the located information to you in full.

Please find below information pursuant to your request above.

You state the MPS only publishes the first 4 characters of a VRM. This is in keeping with current National Police Chief’s (NPCC) guidance on the subject.

Q1 - It would have bene helpful for you to provide me with a copy of the guidance. Please do so.

We only publish the first 4 characters of the VRN. The last 3 characters are a unique identifier and do not add anything meaningful into the public domain that would mitigate the harm in disclosure. We don’t publish any VRN data relating to sensitive assets.

ICO decision notice FS50308040 relates to a request to West Yorkshire Fire and Rescue Service (WYFRS) for the details of its fleet of vehicles. FOIA Section 24 (National Security) was applied on the basis that disclosure could enable someone to clone their vehicles and compromise security. Arguably, police vehicles would be easier to clone as cars of the relevant make and model are easy to obtain.

ICO - Reference: FS50308040 Freedom of Information Act 2000 (Section 50) Decision Notice.pdf

The ICO’s guidance on information in the public domain states:

‘Fragmented or buried information

35. Information can be in the public domain even if it would have to be collated from multiple sources, or if it is buried within a much larger collection of information, as long as an interested member of the public could realistically access it without specialist skills or knowledge. This will depend on the facts of the case and the public authority must make a judgement in all the circumstances.

36. However, even if we accept the information is all in the public domain, disclosure in a ready-collated and more easily understandable form could increase the risk of prejudice and/or increase the public interest benefits from disclosure.’

‘42. However, there will still always be some weight to general transparency and full picture arguments in favour of disclosure.
Therefore, as a general rule, there is likely to be little justification for withholding the information.

43. Nonetheless, any arguments that disclosure would still be harmful because it would draw more attention to a sensitive issue or reopen a debate at a particularly sensitive time should be considered.

44. Care should also always be taken to consider whether the FOI disclosure might actually reveal anything new. For example, the withheld information could be more detailed than the information in the public domain, could corroborate a previously unreliable source or leak, or could confirm that the public authority did not have any additional information’

I would argue that ‘new’ information could include any disclosure relating to covert or non-liveried vehicles in addition to the potential elimination of vehicles suspected of being related to police functions. The harm in providing ‘ready-collated’ information is applicable to many types of information that are visible or disclosed on limited basis such as officer names and identifiers, staff contact details, protection officers, incident details witnessed by bystanders and could also be applied to disparate information relating to national security. This is also analogous to the difference between homes and buildings being visible to the public at the relevant location vs pictures and satellite images being easily accessible from anywhere in the world via the Internet e.g. Google street view and Google Earth.

The DVLA guidance linked below also provides a useful explanation of the meaning and format of VRNs.

DVLA - INF104 Vehicle Services Vehicle registration numbers and number plate.pdf

Q2 - Does the MPS register their total loss vehicles with MIAFTR2 i.e., whether through an intermediary or directly, place their total loss records in the central database of write-offs that is available to the public?

The MPS does register its total loss vehicles directly with MIAFTR. MIAFTR access is limited to specific industry related subscribers – not the public. Some of the information kept within the MIAFTR records is disseminated to records that can be accessed by the public via portals such as HPI but none of these specifically identify the vehicles as “police” vehicles.

Q3 - What manages your total loss Claims

The MPS is self-insured and therefore pays for its own repairs. The MPS has its own Insurance and Claims section that manages claims against and by 3rd party’s.

Q4 - What is your disposal route for total losses i.e. auction – if so which one?

MPS vehicles are sold via a company called Synetiq, this is an online auction.