Information on Operation Boxster

Freedom of information request reference no: 01.FOI.22.027745

I note you seek access to the following information:

I would like to submit a follow-up FOI as follows:
1. In the following December 2021 Met Police presentation slides to Haringey Council, it says the operational direction of Operation Boxster incudes: “IOM style evidence gathering on problem sex workers:

a. Please explain what IOM style evidence gathering is
b. Please explain what evidence is gathered
c. Please explain how evidence is gathered
d. Please provide the name(s) of any database(s) where this evidence is inputted
e. If there is a database (per 1d), please advise how many sex workers have been entered into it

NB. In Q2 of Internal Review 01-FOI-22-025612 you opted to neither confirm nor deny you held this information citing S31 exemption. But please note the Met Police has already publicly confirmed it is gathering this evidence.

1. Since the commencement of Operation Boxster until the present (date of sending this FOI or latest date you have information for), how many sex workers have been put on the Gang's Matrix or the IOM as a consequence of Operation Boxster?

Please break this information down by name of the database, month and year (or relevant period - e.g. if data is collected quarterly), age and nationality and/or ethnicity.

2. Since the commencement of Operation Boxster until the present (date of sending this FOI or latest date you have information for), how many sex workers have been put on managed cohort databases other than the ones listed in Q2? Please break this information down by name of the database, month and year (or relevant period - e.g. if data is collected quarterly), age and nationality and/or ethnicity.

3. Since the commencement of Operation Boxster until the present (date of sending this FOI or latest date you have information for), how many sex workers have been referred to the Home Office's National Command and Control Unit as a consequence of Operation Boxster? Please break this information down by month and year (or relevant period - e.g. if data is collected quarterly), age and nationality and/or ethnicity.

4. Since the commencement of Operation Boxster until the present (date of sending this FOI or latest date you have information for), how many sex workers have been referred to the National Referral Mechanism as a consequence of Operation Boxster?

Please break this information down by:
a. Month and year (or relevant period - e.g. if data is collected quarterly)
b. Age and nationality and/or ethnicity
c. The outcome of the referral (eg positive reasonable grounds, positive conclusive grounds, negative reasonable grounds, negative conclusive grounds)

5. Since the commencement of Operation Boxster until the present (date of sending this FOI or latest date you have information for), how many sex workers have been provided with safeguarding and/or diversionary programmes as a consequence of Operation Boxster? Please also state what safeguarding and/or diversionary programmes have been offered.

6. Since the commencement of Operation Boxster until the present (date of sending this FOI or latest date you have information for), how many sex workers have been given a:
a. CBO (Criminal Behaviour Order)
b. CPW (Community Protection Warning)
c. CPN (Community Protection Notice)

7. Please break this information down by month and year (or relevant period - e.g. if data is collected quarterly), age and nationality and/or ethnicity.

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) - Personal Information
Section 31(1)(a)(b) - Law enforcement

Reason for decision

A Freedom of Information Act request is not a private transaction. Both the request itself, and any information disclosed, are considered suitable for open publication. This is because, under Freedom of Information, any information disclosed is released into the wider public domain, effectively to the world and not just to one individual.

Q2 (partial disclosure), Q4 (exemption applied) and Q7 (partial disclosure). The risk of disclosing any data is high in relation to the possible identification, or misidentification, of individuals. Breaking down all of the information requested by age, nationality/ethnicity, month and year makes the chance of identifying these individuals and finding out additional, often sensitive, information about them even greater, which could place individual victims at risk of harm.

Section 40(2)(3A)(a) – Personal Information - Data disclosed in accordance with the Freedom of Information Act is disclosed to the world, and not just to the individual requesting the information.

You have requested specific record level data. This level of information is not suitable for public consumption. Should the MPS publish crime data at the level requested, it would be at a level that would make the identification of individuals extremely possible. To produce and publish crime related information at a level that would identify the involved parties would not be lawful, fair or in line with our processing commitments. Thus, disclosure of the information at record level is exempt in accordance with section 40(2)(3A)(a) of the Act.

Section 3 of the Data Protection Act 2018 confirms that information which relates to an identified or identifiable living individual is Personal Data. The Freedom of Information Act provides an exemption for Personal Data and this is known as the section 40 exemption.

The information sought under your Freedom of Information request is at such a level that, if disclosed, would provide enough detail (age, ethnicity, month, year) to identify the individuals involved.

Section 31(1)(a)(b) – Law Enforcement - In considering whether or not this information should be disclosed, we have considered the potential harm that could be caused by disclosure.

The National Referral Mechanism (NRM) is a framework for identifying and referring potential victims of modern slavery and ensuring they receive the appropriate support.

Revealing the breakdown requested by victims’ age, nationality/ethnicity, month and year may result in victims not fully safeguarded by the NRM, putting them at risk of further exploitation.

Victim safety and security must always be the first priority of the MPS and any adverse disclosure effectively relating to the direct safety of victims (especially those specifically referred to in the media) would be detrimental to law enforcement and public safety.

Section 31(1)(a)(b) therefore applies to recorded information in all instances you refer to as disclosure would reveal information relating to vulnerable persons and their safeguarding. The exemption must be consistently applied to this request in full to safeguard information pertaining to victims.

Law enforcement tactics engaged to ensure victims are kept safe in connection with human trafficking and sexual exploitation would be undermined by disclosure, increasing the fear of crime by vulnerable individuals.

An adverse disclosure of this kind may lead to a lack of reporting among the public if FOIA disclosure makes it appear that we cannot handle sensitive crime related information in a sensitive and discrete manner. This in turn undermines the ability of the MPS to prevent and detect crime effectively where there is a loss of public trust and confidence.

Publicly disclosing information in connection with human trafficking and sexual exploitation cases may possibly lead the MPS to need to increase resources if those with ill intent use answers as ‘intelligence’ against vulnerable victims and try and undermine their safety and those of others.

If this same requested is lodged with the MPS over time in respect of many different operations, disclosures would lead to a mosaic effect of revealing whether certain operations resulted in a ‘lesser’ number of NRM’s or not. Over time this may allow an inference to be made by those with ill intent about how victims may or may not be fully safeguarded by the NRM. This risks putting individuals at risk of further exploitation, which is an outcome that is not in the public interest.

The strongest reason favouring disclosure is the furthering transparency and openness regarding the use of public funds.

The strongest reason favouring non-disclosure vulnerable individuals and victims are not put at risk of further exploitation, undermining the ability of the MPS to prevent and detect crime due to adverse FOIA disclosures.

I have determined that the disclosure of the requested information would not be in the public interest. I consider that the benefit that would result from the information being disclosed does not outweigh the considerations favouring non-disclosure

Disclosure

I would like to submit a follow-up FOI as follows:
Q1 - In the following December 2021 Met Police presentation slides to Haringey Council, it says the operational direction of Operation Boxster incudes: “IOM style evidence gathering on problem sex workers”:

a. Please explain what IOM style evidence gathering is
b. Please explain what evidence is gathered
c. Please explain how evidence is gathered
d. Please provide the name(s) of any database(s) where this evidence is inputted
e. If there is a database (per 1d), please advise how many sex workers have been entered into it

a.) The IOM style intelligence gathering relates to identifying vulnerable individuals who commit crime to fund their lifestyles and providing help and assistance to overcome barriers in the individual leaving the lifestyle. This could be help ion things such as homelessness, drug dependency and benefit entitlements.

This possible work was considered as part of the Operation Boxster’s approach to assisting individuals who wished to exit sex work. After consultation with the different outreach teams it was decided that this work is completed by numerous different agencies who have specialism in working with sex workers and their unique issues they face. As such this approach was not adopted and no database or evidence has been collected and the assistance provided to sex workers by the different outreach teams provides medical and pastoral needs of the sex workers without police guidance.

a.) No evidence is gathered by police as this method was not instigated.
b.) See above answer.
c.) See above answer.
d.) See above answer.

NB. In Q2 of Internal Review 01-FOI-22-025612 you opted to neither confirm nor deny you held this information citing S31 exemption. But please note the Met Police has already publicly confirmed it is gathering this evidence.

Q1 - Since the commencement of Operation Boxster until the present (date of sending this FOI or latest date you have information for), how many sex workers have been put on the Gang's Matrix or the IOM as a consequence of Operation Boxster?

Please break this information down by name of the database, month and year (or relevant period - e.g. if data is collected quarterly), age and nationality and/or ethnicity.

No sex workers have been placed on the IOM or gang matrix database.

Q2 - Since the commencement of Operation Boxster until the present (date of sending this FOI or latest date you have information for), how many sex workers have been put on managed cohort databases other than the ones listed in Q2? Please break this information down by name of the database, month and year (or relevant period - e.g. if data is collected quarterly), age and nationality and/or ethnicity.

Information on sex workers is collected on Operation Boxster’s Master Work Return Database. This is registered on the MPS Assets register- Spreadsheet identify individual sex workers in BCU, their active days and associated individuals arrested for soliciting sex workers and other associated activities.

Age range	British	Romanian	Bulgarian	Irish	Other
18 to 20	0	2	0	0	2
21 to 30	13	5	11	0	2
31 to 40	12	8	7	5	1
41 to 50	11	1	1	0	2
51 to 60	5	0	0	0	0
Totals	41	16	19	5	7

This data is taken from August 2021 till the present day (30.12.2022). A total of 88 sex workers have been identified as working in the area deployed by Operation Boxster. We are unable provide month / year that the individual is placed on this database as this information is not recorded separately from the sightings sheets.

Q3 - Since the commencement of Operation Boxster until the present (date of sending this FOI or latest date you have information for), how many sex workers have been referred to the Home Office's National Command and Control Unit as a consequence of Operation Boxster? Please break this information down by month and year (or relevant period - e.g. if data is collected quarterly), age and nationality and/or ethnicity.

The data regarding referrals to the Home Office Command and Control is not collected and as such we are only able to state that since May 2020 no referrals have been made by Operation Boxster to any immigration officials. Prior to May 2020 we are unable to state if any or how many were conducted.

Q4 - Since the commencement of Operation Boxster until the present (date of sending this FOI or latest date you have information for), how many sex workers have been referred to the National Referral Mechanism as a consequence of Operation Boxster?

Please break this information down by:
a. Month and year (or relevant period - e.g. if data is collected quarterly)
b. Age and nationality and/or ethnicity
c. The outcome of the referral (eg positive reasonable grounds, positive conclusive grounds, negative reasonable grounds, negative conclusive grounds)

See FOI Exemption Section 31

Q5 - Since the commencement of Operation Boxster until the present (date of sending this FOI or latest date you have information for), how many sex workers have been provided with safeguarding and/or diversionary programmes as a consequence of Operation Boxster? Please also state what safeguarding and/or diversionary programmes have been offered.

The types of help and assistance offered by the outreach teams include medical, homelessness, benefits and emergency exit routes. There is no data relating the amount of safeguarding or diversionary programmes provided to sex workers by Operation Boxster. As previously explained several different outreach organisations work in the area which Operation Boxster works in. These include:

The Salvation Army
Street lights UK
Clash and SHOC
Enable – NHS Find and Treat Team.

Each organisation has a dedicated time and day which they conduct their work during the week. It has been agreed that during the time these outreach teams are out that Operation Boxster removes officers from the area which they conduct their outreach.

Officers engage with sex workers when deployed and will check on their welfare, identify new sex workers, ask safeguarding questions around exploitation or coercion, provide information details of all outreach teams, pass on messages for individuals to contact outreach members wishing to make contact, provide safety advice to sex workers and respond to all concerns they have around possible dangerous clients or concerns they have. We also make sex workers aware of complaints about types of behaviour or areas where residents have made complaints.

Q6 - Since the commencement of Operation Boxster until the present (date of sending this FOI or latest date you have information for), how many sex workers have been given a:
a. CBO (Criminal Behaviour Order)
b. CPW (Community Protection Warning)
c. CPN (Community Protection Notice)

Q7 - Please break this information down by month and year (or relevant period - e.g. if data is collected quarterly), age and nationality and/or ethnicity.

No CBO’s have been issued by Operation Boxster.

All CPW’s and CPN’s relate to complaints of specific areas by residents where sex workers have been asked not to work or take clients. These are only issued after engagement by officers with the individual sex workers explaining about the complaints and after informing all outreach teams of the areas of concern so reinforce the message.

Any restrictions placed on the sex worker after numerous contacts and warnings, are restrictions of behaviours in a small area linked to the compliant. Operation Boxster does not ban sex workers from large areas or restrict their access to outreach teams. It is recognised that large scale bans causes displacement and places sex workers in potential danger moving them to areas that they are unfamiliar with.

CPW issued	CPN issued
23/09/2022	24/09/2022
23/09/2022	05/10/2022
13/10/2022	19/10/2022
23/09/2022	05/10/2022
25/11/2022
30/01/2022
30/05/2021	05/11/2021
05/07/2021	01/10/2021
29/05/2021
02/06/2021
27/02/2022
02/06/2021

 

Age range
20 – 26	8
31 – 37	4

 

Nationality

Bulgarian

Czech

Romanian

Irish

The above table where two dates are shown identifies a single sex worker who has received both a CPW and progressed to a CPN.