Copy of Right Care, Right Person Equality Impact Assessment

Freedom of information request reference no: 01.FOI.23.033665

I note you seek access to the following information:

A copy of the equality impact assessment carried out ahead of the Met’s introduction of the Right Care, Right Person policy in relation to mental health callouts.

When a request for information is made under the Freedom of Information Act 2000 (the Act), a public authority is required to inform you, when permitted, whether the information requested is held. It must then communicate that information to you. If a public authority decides that it cannot comply with all or part of a request, it must cite the appropriate section or exemption of the Act and provide you with an explanation. It is important to note that 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, 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. Any information released under the Act is also published upon the MPS website.

Decision

I have disclosed the requested Right Care Right Person EIA to you alongside this notice. In disclosing this record to you, I have refused to provide the personal data of police employees that do not hold senior ranks within the MPS. Any information removed has been replaced with a series of asterisks (i.e. **********).

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 Information

Reason for decision

Section 40(2)&(3) - Personal Information - of the Act provides that any information to which a request for information relates, is exempt information if the first condition of Section 40(3A)(a) is satisfied. The first condition of Section 40(3A)(a) states that personal information is exempt if its disclosure would contravene any of the data protection principles. If the disclosure of the requested personal data would not contravene the data protection principles, the disclosure must also not contravene Sections 3A(b) and 3B of the Act.

There are six principles that are set out in Article 5(1)(a) of the General Data Protection Regulations (GDPR) that dictate when the processing of personal data is lawful. The first principle requires that any processing of personal data must be lawful, fair and transparent. Under Article 6(1)(f) of the GDPR, the disclosure of personal data is considered to be lawful if:

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

Names of MPS Members of Staff - The requested Right Care Right Person EIA contains the names of MPS employees holding the rank of Superintendent and below (for police officers) or Band A (including shadow band equivalents) and below (for members of police staff). Having considered the legitimate interest test in respect of this personal data, I have found that:

A. Employees holding the rank of Superintendent and below and/or Band A and below are unlikely to expect their names to be published in response to this Freedom of Information Act request. Given their roles and level of responsibility within the MPS, I have not identified a legitimate interest that would be satisfied in disclosing their personal data in response to this request for information.

Disclosure

Following receipt of your request, I have conducted searches to locate the Right Care Right Person Equality Impact Assessment (EIA). These searches located the requested information.

Please note that imbedded with the RCRP EIA were the following documents:

1. Right Care Right Person: Stakeholder Engagement Plan
2. Digital Policing Local Work Instructions: Application Accessibility

These documents have not been considered for release as whilst they informed the Right Care Right Person EIA, they do not form part of this document.

DUTY TO ADVISE AND ASSIST
Under Section 16 of the Act, there is a duty to advise and assist those that have made, or intend to make, a request for information. In accordance with this duty, I can confirm that the MPS publishes information about various types of crime on its website. I have provided a link to this information below.

MPS Website: Stats and Data

It may also assist you to note that the MPS proactively publishes all disclosures made in response to requests made under the Freedom of Information Act 2000 on its Publication Scheme. I have provided a link to this section of the MPS website below.

MPS Publication Scheme
The MPS Publication Scheme can be searched using keywords and may accordingly hold other information that is of interest to you.