Employers with roles which focus on promoting equality, diversity and inclusion

 

I note you seek access to the following information:

 

1. I am writing to request the number of employees employed by your force on 1 January 2023 whose roles were specifically focused on promoting equality, diversity and inclusion.

 

2. Please also specify the job title and annual salary of each of these individuals.

 

Finally, please provide the same information for 1 January 2019, 1 January 2020, 1 January 2021 and 1 January 2022.

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 21 – Information reasonably accessible via other means

Section 40(2)&(3) - Personal Information

 

 

Section 21 – Information reasonably accessible via other means

 

 

I am pleased to inform you that information relating to the pay banding and details of the pay associated with each band requested is held by the MPS and is already in the public domain.  Some of the information can be accessed via the following the MPS Publication Scheme.

 

• Salary information can be found via the following links:

 

 

• Salary details for the broad bands:

August 2022 information is available via the link below:

 

 

The information requested has been identified as being as it is already published.  Where information is already in the public domain we are not required to re-publish the data; instead public authorities are required to direct you to the information, which we have done in this instance.  This action is in accordance with Section 21 of the Freedom of Information Act.

 

Some of the requested information (salary information) contains personal information which is exempt from disclosre.  

 

The release of the exact salary would breach UK GDPR principle (a) (lawfulness, fairness and transparency).

 

Please see a link to the ICO guidance linked below, which provides more detail on page 16 under the ‘Salaries and bonuses’ heading.

 

 

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.

 

Having considered your request, I have found that some of the information requested contain personal data, namely the ‘annual salary of each of these individuals’. Having given regard to the legitimate interest in respect of each person’s personal data, I have found that:

 

Personal data relating to Officers/Staff - 

a. There is a general public interest in setting out how public servants conduct their business. There is accordingly a legitimate interest in disclosing the names of the police officers/staff members involved in this investigation.

 

b. The disclosure of this information is necessary to meet the legitimate interest identified at point a above.

 

c. In this case, the release of the salaries would be unexpected, unfair and distressing to them, on the basis that they would not reasonably expect their salaries to be published in response to a Freedom of Information Act request. In this regard, the disclosure of this personal data would constitute a disproportionate interference with the right to privacy of the data subject(s) and be likely to cause unwarranted harm to them.

 

The provision to refuse access to information under Section 40(2)(a)(b) and (3A)(a) of the Act is both absolute and class based. When this exemption is claimed, it is accepted that harm would result from disclosure. There is accordingly no requirement to demonstrate what that harm may be in refusing access to information. 

 

 

 

Information in response to question 1 can be found within the attached spreadsheet.

January 2019
Team	Rank/Band	Number of roles
Community Engagement & Inclusion	Detective Chief Inspector	2
Community Engagement & Inclusion	Detective Sergeant	2
Community Engagement & Inclusion	Chief Superintendent	1
Community Engagement & Inclusion	Police Sergeant	2
Community Engagement & Inclusion	Superintendent	2
Community Engagement & Inclusion	Band E	2
Community Engagement & Inclusion	Band D	2
		13

January 2020
Level 6 Organisation	Rank/Band	Number of roles
Recruitment & Diversity	Police Constable	2
Recruitment & Diversity	Police Sergeant	1
Resourcing Tal&Inclu	Inspector	2
Community Engagement & Inclusion	Police Sergeant	2
Community Engagement & Inclusion	Detective Sergeant	2
Community Engagement & Inclusion	Police Constable	1
Community Engagement & Inclusion	Chief Superintendent	1
Community Engagement & Inclusion	Band B	1
Community Engagement & Inclusion	Band D	3
Community Engagement & Inclusion	Band E	1
Resourcing Tal&Inclu	Chief Superintendent	1
Resourcing Tal&Inclu	Police Sergeant	1
Resourcing Tal&Inclu	Broadband 3	1
Resourcing Tal&Inclu	Unbanded	1
Resourcing Tal&Inclu	Band A	2
Resourcing Tal&Inclu	Band C	6
Resourcing Tal&Inclu	Band B	7
Resourcing Tal&Inclu	Band D	5
Resourcing Tal&Inclu	Band E	3
		43

 

 

January 2021
Team	Rank/Band	Number of roles
CoP Diversity & Inclusion Advisor	Band C	2
Recruitment & Diversity	Police Sergeant	1
Resourcing Tal&Inclus	Chief Inspector	1
Resourcing Tal&Inclus	Detective Chief Superintendent	1
Resourcing Tal&Inclus	Inspector	4
Resourcing Tal&Inclus	Police Constable	3
Resourcing Tal&Inclus	Detective Inspector	1
Resourcing Tal&Inclus	Unbanded	1
TLI Inclusion	Band B	2
Resourcing Tal&Inclus	Band B	1
Resourcing Tal&Inclus	Band D	1
Resourcing Tal&Inclus	Band E	1
TLI Inclusion	Band A	1
Talent Leadership & Inclusion	Broadbands	1
Community Engagement & Inclusion	Band E	1
		22

 

 

January 2022
Team Name	Rank/Band	Number of roles
Vetting Equality Team Uplift	Band E	3
Vetting Equality Team Uplift	Band D	1
TLI Inclusion	Band C	2
TLI Inclusion	Band A	1
Talent Leadership & Inclusion	Broadbands	1
TLI Inclusion	Band B	1
Community Engagement & Inclusion	Police Constable	2
Community Engagement & Inclusion	Band E	1
		12

 

January 2023
Team Name	Rank/Band	Number of roles
Recruitment & Diversity	Police Constable	2
Vetting Equality Team	Band D	4
Culture and Inclusion	Band C	3
Culture and Inclusion	Band B	2
Inclusion	Inspector	1
Inclusion	Detective Sergeant	1
Inclusion	Chief Inspector	1
Inclusion	Police Constable	4
Inclusion	Detective Constable	1
Inclusion	Police Sergeant	1
Inclusion	Band D	3
Talent Leadership & Inclusion	Band D	1
Community Engagement & Inclusion	Police Constable	1
		25

 

 

• Current salary details for the broad bands: