Purchasing information from data brokers

Freedom of information request reference no: 01.FOI.23.032792

I note you seek access to the following information:

1. How much does the force spend on purchasing information from data brokers such as Experian, Equifax, Acxiom and others?
2. Please could you provide a full list of data brokers from which the force has purchased information?
3. For what purposes does the force purchase information from data brokers?
4. Please could you identify the force’s legal basis for purchasing information from data brokers?
5. Please could you provide a breakdown of how much the force has spent with each data broker it has purchased information from?
6. If information is purchased from data brokers, is it then provided (when relevant/appropriate) in response to subject access requests?

Please could you provide the information from 1 January 2021 up until the present day?

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 8(1) – valid requests must be made in writing
Section 31(1)(a)&(b) - Law Enforcement

Reason for Decision

Section 31(1)(a)&(b) - Law Enforcement - Law enforcement measures and resources are put in place to protect the community that we serve.

Other than the information already disclosed for Question Three (3) today, any further disclosure is exempt to protect police methodology and policing tactics to enable the prevention and detection of crime.

Disclosure would undermine MPS intelligence capabilities and possible current law enforcement policing tactics, including in respect of how it conducts investigations and security checks.

Disclosure is likely to therefore compromise public trust in our handling of sensitive resources which in turn would compromise any ongoing or future operations to protect public safety and law enforcement within the UK. This would increase the risk of harm to the public in possible future scenarios and occasions.

Disclosure regarding individual purchasing would also inform the public what information the MPS does not do – which again would provide valuable intelligence to criminals or those wishing to subvert law enforcement and exploit any gaps in the MPS’s intelligence picture or operational tactics.
Full disclosure would involve be releasing sensitive operational detail. This would enable those with the time, capacity and inclination to try and map intelligence, strategies and tactics used by the MPS and other police services across the country.

In this case, disclosure may enable individuals, perpetrators of violent or other serious crime and terrorist organisations to identify expert our tools, intelligence and methods used or not used by the MPS as part of an operation at a given location and time. The effectiveness of current and future strategies to combat criminal activity may be compromised and so would inhibit the ability to prevent crime.

The disclosure of any further information that may be held would not be of benefit to the community as a whole, as relevant substantial information is already in the public realm. The additional information would not, in the view of the MPS, greatly further the public’s understanding and instead could only be used to hinder law enforcement and crime prevention.

The strongest reason favouring non-disclosure is ensuring public safety is not compromised by disclosing policing methodology, tactics and intelligence that will enable individuals to evade detection and law enforcement or be used to damage public confidence in police handling of sensitive personal data.

The MPS will not willingly disclose information which will place our resilience and the public at risk by undermining law enforcement capabilities, tactics and methodology.

Therefore the MPS has determined that the public interest favours the application of this exemption for Question Three (3).

This decision is reached on the understanding that the public interest is not what interests the public, but is what would be of greater good to the public if disclosed to the public as a whole. As advised, the Public Interest has been met to a large extent by the information already disclosed into the public domain that already one has access to.

Disclosure

The MPS is able to today disclose the information for Question One (1), Two (2), Three (3), Five (5).

In respect of Question Three (3), any further details held are exempt by virtue of the following exemption;

• Section 31(1)(a)&(b) Law Enforcement

In respect of Question Four (4), no recorded information is held.

Question Six (6) has been classed as invalid under the remit of FOI with assistance provided.

Q1 - How much does the force spend on purchasing information from data brokers such as Experian, Equifax, Acxiom and others?

January 2021 – present as below:
• Experian - £1,558,584.24
• Equifax - £1,219,606.35
• D&B (annually) £29,561.00
• WorldCC (annually) £5400.00

Q2 - Please could you provide a full list of data brokers from which the force has purchased information?

• Experian
• Equifax
• Transunion (previously CallCredit)
• Dunn & Bradstreet
• WorldCC

Q3 - For what purposes does the force purchase information from data brokers?

Police Investigations, security checks and vetting.

Dunn & Bradstreet and WorldCC are used for commercial due diligence.

Q4 - Please could you identify the force’s legal basis for purchasing information from data brokers?

Recorded information is not held to answer this question. There is no legal gateway recorded to purchase information.

Q5 - Please could you provide a breakdown of how much the force has spent with each data broker it has purchased information from?

Please find the information disclosed above for Question One (1), which captures the same answer to this request.

Q6 - If information is purchased from data brokers, is it then provided (when relevant/ appropriate) in response to subject access requests?

Your request is for opinion and context and the information you have requested is not held. This is a request for hypothetical context or opinion based on any number of scenarios regarding individuals.

Responses to Subject Access Requests handled on a case by case basis and are subject to law enforcement exemptions just as the Freedom of Information Act is.

For example, if credit data is held as part of an investigation or for evidential purposes