Penalty notices issued on the A20 east-bound between Sandy Lane to Cookham Road

Freedom of information request reference no: 01.FOI.24.035242

I note you seek access to the following information:

The A20 east-bound between Sandy Lane to Cookham Road has recently been subject to a significant reduction in the speed limit - from 70mph to 40mph. I am unsure as to when this scheme actually became active (can you please confirm?), however, I am aware that many road users have been issued with multiple penalty notices.

Therefore, can you please confirm:
1. the number of penalty notices issued since the scheme became active; and
2. the number of penalty notices issued for the same stretch of road during the 12 months prior to this.

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 38 – Health & Safety

Reason for decision

I have exempted the information requested in your 2nd and 3rd questions.

To expand on this further, your second question ‘the number of penalty notices issued since the scheme became active’

We are not required by Statute to release information on camera detections/activations. We have therefore exempted this part of your request under Section 31 & 38 of the Act.

To provide the number of violations/detections and NIP’s issued by this site specific speed camera, would cause operational harm to the MPS.

Further to the above, in regard to your 3rd question ‘2. the number of penalty notices issued for the same stretch of road during the 12 months prior’

Section 31 – Law Enforcement & Section 38 – Health & Safety - Information released under the Freedom of Information Act is released into the public domain, and not just to the individual requesting the information. While some individual requests for site specific safety-camera data may pose no threat to the prevention or detection of crime or to public safety, it is possible that subsequent requests of a similar nature could enable camera deployment and enforcement patterns to be plotted.

In these circumstances the information requested would, enable individuals to draw conclusions about the likelihood of being caught on camera at specific locations. If numbers of offence detection were released, it may enable the public to predict likely camera deployment patterns. This could potentially lead to individuals making decisions about where it is and is not “safe” to speed or jump the lights.

In addition, there is documented evidence that the release of information relating to safety cameras which generate the most offences has resulted in those camera sites being subject to criminal damage (section 38 of the Act).

The Mosaic Effect - FOIA disclosures are placed into the public domain. Disclosures which appear harmless, pieced together with other disclosures can be used in a ‘mosaic effect’ to give a fuller picture to those wishing to disrupt operational policing challenges in London. This ‘cumulative prejudice’ or the ‘mosaic effect’ whereby the information requested may be of increased significance when combined with other information obtained through other means and/or at a later date. Combining the items illuminates their interrelationships and breeds analytic synergies, so that the resulting mosaic of information is worth more than the sum of its parts.

The information would provide a national picture of where work is being undertaken, creating a mosaic effect on data disclosure and allowing criminals to map together information to target identified weaknesses. This would clearly hinder the Met’s effectiveness to enforce the law and place risk on public safety.

To disclose information in relation to NIPs issued would therefore reveal tactical capability and would place the MPS at a tactical disadvantage. The MPS has a duty to protect the public from harm and that duty of care to all involved must be the overriding consideration. It cannot be in the public interest to disclose information which would undermine our ability to detect crime and bring offenders to justice. Specific information would reveal resource information and intelligence that would be extremely valuable to those wishing to carry out such infractions.

As detailed within the 'harm', the disclosure of any information that provides information in relation to the deployment and use of police resources would be a valuable asset to individuals and/or organisations wishing to commit crimes. In addition, more crimes would be committed which would place the safety of the general public at risk.

Whilst there is public interest in the transparency of policing resources and providing reassurance that the MPS is appropriately and effectively ensuring that their resources are used effectively and appropriately, there is also a strong public interest in knowing that policing activity with regard to the delivery of law enforcement is operationally effective.

Public safety is of paramount importance and any information which would undermine policing tactics and consequently place individuals at risk is not in the public interest. The effective delivery of operational law enforcement is crucial and of paramount importance to the MPS.

Disclosure of information that would undermine the operational integrity of effective law enforcement and will undoubtedly adversely affect public safety as more crimes would be committed.

We are therefore unable to disclose the NIP data by the location requested, as we believe that there is a stronger public interest in ensuring that the overall effectiveness of speed cameras is not undermined or compromised.

Disclosure

In regard to your first question, ‘I am unsure as to when this scheme actually became active (can you please confirm?)’

The new 40 mph speed limit came in to force on 18 October 2023