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Freedom of information request reference no: 01.FOI.24.034533
I note you seek access to the following information:
Print Management & Energy Consumption - I would be very grateful if you would provide me with answers for the following questions regarding your carbon goals and printer agreements through the organisation:
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 43(2) – Commercial Interests
Section 40(2) Personal Information
Reason for decision
The MPS is required to exempt information held for Question Ten (10) by virtue of the following exemption:
Section 43(2) Commercial Interests - Information is exempt information if its disclosure under this Act would, or would likely to, prejudice commercial interests of any person (including the public authority holding it).
In order to apply section 43(2), the MPS must satisfy itself that disclosure of the information would, or would be likely to, prejudice the commercial interests of any person, including the public authority holding it. In this case the MPS consider that disclosure of any specific financial details, would be likely to have an adverse effect on the MPS’s ability to negotiate with other organisations/individuals.
Disclosure of the requested information, including financial details would prejudice the commercial interests of the MPS because the disclosure of this information would set a 'benchmark', which potential service providers could use to compare their proposed responses to. This would therefore have a negative impact on the competitive nature of the tendering process and could also provide competitors with an unfair advantage.
There is a public interest in ensuring that companies are able to compete fairly and such a disclosure would weaken the position of the MPS in a competitive environment by revealing market-sensitive information. This would as a consequence have a harmful effect on future partnerships when entering into commercial activities with the MPS.
The public interest in transparency is met by the routine disclosure of MPS expenditure invoices of spends over £250. You can find that information here in each invoice:
Published items - 250 | Metropolitan Police
Any further breakdown as per this request on Canon UK is commercially sensitive and would damage the MPS commercial interests.
This decision is based on the understanding that the public interest is not what interests the public, but what would be of greater good to the community as a whole.
The MPS is required to exempt information held for Question Twenty Two (22) by virtue of the following exemption:
Section 40(2)(3A)(a) (Personal Information) of the Act - 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 includes the following which we consider to be the Personal Data of the individuals that could be identified through the release of this information/ Personal information requested within this FOIA request includes:
Where the request is seeking access to third party personal data the Section 40(2) exemption may be engaged. In order to apply the Section 40(2) exemption, the disclosure of the requested information must satisfy either the first, second or third conditions as defined by subsections 3(A), 3(B) and 4(A) of the Data Protection Act 2018.
The first condition ensures that the exemption would apply in circumstances where the disclosure of the information would breach any of the Data Protection Act 2018 principles. There are six Data Protection principles specified within Article 5(1) of the General Data Protection Regulation (GDPR).
In this instance we have decided that the disclosure of the Personal Data would be incompatible with the first Data Protection principle which requires that personal data shall be: ‘processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’);
Under the Data Protection Act 2018, 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.
Here, we need to balance the rights and freedoms of the individuals involved with any legitimate public interest in disclosure. Having considered the release of the identified personal data, the MPS has found, having considered the legitimate interest test, that, whilst there is an element of public interest in the recorded information, the information requested is uniquely personal to individuals in the context of their personal and working lives in connection to their occupation.
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. Recently the General Data Protection Regulation (GDPR) was been introduced across the European Union (EU) and the European Economic Area (EEA).
In respect of the United Kingdom, GDPR was enshrined in UK law through the Data Protection Act 2018. The MPS, like all UK public authorities are obliged to comply with the Data Protection Act 2018 and this includes the protection of personal data. Information captured by your request, can fairly be considered "personal data" and sensitive, with a clear identifiable link.
In most cases, personal data is exempt from disclosure under the remit of the Freedom of Information Act. Where an individual is requesting third party personal data the MPS must ensure that any action taken adheres to the principles of GDPR/ the Data Protection Act 2018.
To clarify, the Freedom of Information Act only allows disclosure of personal data if that disclosure would be compliant with that law. The disclosure of the information you have requested must be carefully managed in order to ensure that there is no prejudice to any person in any possible way, however remote.
Disclosure
I have today decided to disclose the located information to you.
Please find below information pursuant to your request above.
Q1 - What is the current average energy charge within the organisation (kW hour)?
This question isn’t clear, however in the last complete financial year (April 2022 to March 2023), we consumed 100.7 GWh of electricity at a total cost of £18.5m averaging 18.3 p/kWh. Electricity is purchased flexibly through the CCS framework and unit prices vary in response to market conditions.
Q2 - What Carbon reduction goals are in place within the organisation?
The Metropolitan Police Service is aligned with the UK government target to be zero carbon by 2050, however the organisation supports the Mayor of London’s ambition to accelerate this target for London to be Net Zero Carbon by 2030 and is working towards this goal within the constraints of available grant funds/budget and the need to manage disruption to operations.
Q3 - What is the contact email for the person who deals with sustainability and ESG matters within the organisation?
The Environment Team
Property Services
Email: [email protected]
Sidcup, Kent, DA15 7ES.
Q4 - Do you lease/rent or Purchase your MFD’s/Photocopiers?
Purchase
Q5 - Who is your current supplier?
CANON (VIA Capgemini)
Q6 - What is the current number of MFD’s/Photocopiers within the organisation
1400
Q7 - What make/model are the MFDs/Photocopiers
All canon and the following models (the MPS are in mid transformation so all the older models will be removed by end of the Financial Year)
Model
imagePRESS C165
IPF750
iR ADV DX C257i Desktop
iR ADV DX C5860i
iR3225
iR-ADV 6055
iR-ADV 6575
iR-ADV C5030i
iR-ADV C5051i
iR-ADV C5235i
iR-ADV C5240i
iR-ADV C5255i
IR-ADV DX 4735
iR-ADV DX 6780i
iR-ADV DX C257i
iR-ADV DX C257i Desktop
iR-ADV DX C257i Floor Standing
iR-ADV DX C3730
iR-ADV DX C3730i
iR-ADV DX C5750i
iR-ADV DX C5860i
LBP325x
LBP351x
LBP6750
LBP852Cx
TR150
TX4100
Q8 - What is the total mono print volume for the MFD’s/Photocopiers
26,236,397 copies
Q9 - What is the total colour print volume for the MFD’s/Photocopiers
13,469,948 copies
Q11 - When does the Rental and or service agreement end for the MFDs/photocopiers.
Feb 2028
Q12 - and what was the original contract term?
3 years +1 +1
Question Thirteen (13) to Twenty One (21)
Q13 - Do you lease/rent or Purchase your desktop printers?
Q14 - Who is the current supplier?
Q15- What is the current number of desktop printers within the organisation?
Q16 - What make/model are the desktop printers
Q17 - What is the total mono print volume for the desktop printers
Q18 - What is the total colour print volume for the desktop printers?
Q19 - What is the approximate spend on service over the last 12 months?
Q20 - When does the rental and or service agreement end for the desktop printers,
Q21 - and what was the original contract term?
All devices fall under the MFD category and are not split out separately. Information requested is therefore not applicable and not ‘recorded’ information.