Staff in the Data Office and/or IRU with roles/ranks & responsibilities
Freedom of information request reference no: 01/FOI/24/035717, 01/FOI/24/035961, 01/FOI/24/035996, 01/FOI/24/036036, 01/FOI/24/036265
I note you seek access to the following information:
01/FOI/24/035717 -
Please provide the number of staff in the MPS data office and/or information rights unit, along with a broad level or detailed breakdown as may be practical/available of their roles/ranks and responsibilities.
01/FOI/24/035961 -
1) Please kindly provide any materials which address the change of email box from [email protected] to [email protected].
2) Please also kindly provide any materials which address the technical design (for example especially those which set out the necessity or rationale) which requires messages to be sent out from “DONOTREPLY” email addresses and replies to be cumbersomely manually readdressed to alternative addresses that can accept inbound mail.
01/FOI/24/035996 -
I understand that there has been a significant backlog in responding to ROA/SAR requests since there has been a great increase in the volume of such requests received particularly since the rise of the Gaza Israel conflict.
However, where such requests concern data implicating limited retention periods, such as body worn video footage, have there been any protocols developed to triage requests when they are received well within the relevant data retention periods so as to ensure that action is promptly taken to ensure that the relevant data is duly preserved until such time as the request can be substantively attended to?
If not, would you please consider implementing such a procedure in order to ensure that people’s data protection rights are maintained in light of and in spite of the backlog? Please, in this scenario, consider this paragraph as a complaint as to your manner of handling my and other members of the publics’ personal data, such as under the relevant provisions of the data protection act 2018.
01/FOI/24/036036 -
Please kindly provide for each of the past 8 years:
- the number of ROA requests received by MPS
- that of those fulfilled/completed
- if it would not exceed costs, the average amount of time from each of those’ s completion date since the date that they were originally received
- if it would not exceed costs, the longest time that a completed request had gone uncompleted after being received, and/or the shortest such period of time.
01/FOI/24/036265 -
Can you please provide the numbers of staff involved with the MPS Data Office and Information Rights Unit, as well as the organisational structure of these groups, as well as the breakdown of the staff by uniform/civilian status and rank?
Please note, the Information Rights Unit has recently changed names and is now called Data Rights. These requests are all considered to relate to that unit.
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) – A request for information must include the requester's real name.
Section 84 - “information” means information recorded in any form.
Section 21(1) - Information which is reasonably accessible by other means
Section 31(1)(a) – Law Enforcement
Section 40(2)(3A)(a) – Personal Information
Reason for decision
01/FOI/24/035717 -
This information is held by the MPS and has today been provided to you. Some of the information was already in the public domain and links have been provided.
Section 21(1) – Information accessible by other means - Some of the information requested has been identified as being accessible via other means 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.
01/FOI/24/035961 -
Some information has been located for part one of this request and has today been provided to you in a redacted format. This response therefore serves as a partial Refusal Notice under Section 17(1) of the Freedom of Information Act 2000 (the Act), in accordance with Section 40(2)(3A)(a) and Section 31(1)(a).
Section 31(1)(a) – Law Enforcement - The MPS utilises public facing mailboxes in order to control the flow of information into the Organisation in order to ensure it is handled efficiently and effectively. It ensures that those responsible for undertaking the relevant work are privy to the communications received and able to offer the best public service. It also enables them to ensure private mailboxes are clear of such correspondence, so they can undertake the work required of them. To release the personal contact details of staff (including their email addresses and phone numbers) would provide persons intent on disrupting the work of the MPS with information that would assist them to do so. In this regard, a person with this intent would be likely to use this information to make inappropriate contact with members of staff and/or send them vast amounts of unsolicited correspondence – thus ensuring they are unable to undertake the role required of them. This would disrupt the daily work of these members of staff and cause wider disruption to the work of the MPS, hindering their ability to both prevent and detect crime.
For the reasons outlined in the prejudice test, it cannot be considered in the public interest to provide information that could be used to disrupt the work of employees, so they are unable to undertake their roles and provide the public service required of them.
Furthermore, the release of the emails arguably satisfies the public interest as the body of the text addresses the point in question. The release of these email addresses and phone numbers would do little to add to the context of the information.
Having considered your request, I accept that there is a public interest in transparency when any request is made for police information. The public interest favouring release must however be balanced against any associated risk and/or prejudice that would be caused through disclosure.
Having carefully considered this, I have found that the public release and publication of the contact details of these members of MPS staff would be likely to provide persons intent on disrupting the work of the MPS with information that would assist them in this endeavour. Given this, and the fact that the removal of this information does not detract from the quality of the records disclosed, I have found that the release of this information is not in the public interest.
Section 40(2)(3A)(a) – Personal Information - Section 3 of the Data Protection Act 2018 confirms that information which relates to an identified or identifiable living individual is Personal Data.
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 Personal Data:
• Names of individual members of staff within the MPS
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 set out in the 2018 Act and these can be found at section 34.
In this instance I have decided that the disclosure of the Personal Data would be incompatible with the first Data Protection principle which states that the processing (in this case the disclosure) of the data must be both lawful and fair.
In relation to part two, no information has been located and therefore this information is not held by the MPS.
01/FOI/24/035996 -
Some of the information requested here is held and has today been provided to you in full. However, in relation to the second part of your request, this is not valid in accordance with Section 8(1) of the Act.
Section 8(1) – A request for information must include the requester's real name.
In this Act, unless the context otherwise requires—
“information” means information recorded in any form.
01/FOI/24/036036 -
The final two questions within this request would engage Section 12(1) and so they have been removed upon your request. However, the rest of this request is held and is provided below.
01/FOI/24/036265 -
This request is partially exempt in accordance with Section 14(2) – Repeated, as it asks for the same information requested under reference 01/FOI/24/035717 – the number of, and ranks of, the staff within the Data Office and Data Rights (formally Information Rights Unit). This information has been provided below.
Section 14(2) - identical, or substantially similar to a previous request submitted by the same individual - Where a public authority has previously complied with a request for information which was made by any person, it is not obliged to comply with a subsequent identical or substantially similar request from that person unless a reasonable interval has elapsed between compliance with the previous request and the making of the current request.
The other information requested within this request is held by the MPS and can today be provided to you.
Disclosure
01/FOI/24/035717 -
Please provide the number of staff in the MPS data office and/or information rights unit, along with a broad level or detailed breakdown as may be practical/available of their roles/ranks and responsibilities.
The MPS holds this information and can today provide the following response to you.
Please note, you have mentioned both the Data Office and Information Rights Unit in this response. As already explained, the Information Rights Unit is now known as Data Rights, which forms one part of the wider Data Office. The information provided here relates to both but has been provided separately.
The total number of MPS Data Office staff is 264, and the following breakdown of Banding applies -
| BB2 | 1 |
| BB3 | 2 |
| Band S | 4 |
| Band B | 11 |
| Band U | 1 |
| Band L | 2 |
| Band C | 38 |
| Band M | 18 |
| Band D | 105 |
| Band N | 22 |
| Band E | 56 |
| Band F | 3 |
| Band G | 1 |
The total number of Data Rights staff is 79, and the following breakdown of Banding applies -
| Band B | 2 |
| Band C | 7 |
| Band D | 35 |
| Band E | 35 |
| TOTAL | 79 |
The work undertaken by the staff within Data Rights covers the MPS handling of all aspects of Information Rights requests, details of which can be found here:
What is the Data Protection Act?
When can the police disclose information about me?
What is the Freedom of Information Act?
The Publication Scheme
Your information rights
01/FOI/24/035961 -
1) Please kindly provide any materials which address the change of email box from [email protected] to [email protected].
2) Please also kindly provide any materials which address the technical design (for example especially those which set out the necessity or rationale) which requires messages to be sent out from “DONOTREPLY” email addresses and replies to be cumbersomely manually readdressed to alternative addresses that can accept inbound mail.
In relation to this request, some emails have been located in relation to part one. These have today been provided in a redacted format – with the names and email addresses redacted in accordance with Section 40(2)(3A)(a) and Section 31(1)(a). Please find these attached. No other recorded information has been located.
In relation to part two of this specific request, our searches failed to locate any recorded information relevant to your request, and therefore the information you have requested is not held by the MPS.
01/FOI/24/035996 -
I understand that there has been a significant backlog in responding to ROA/SAR requests since there has been a great increase in the volume of such requests received particularly since the rise of the Gaza Israel conflict.
However, where such requests concern data implicating limited retention periods, such as body worn video footage, have there been any protocols developed to triage requests when they are received well within the relevant data retention periods so as to ensure that action is promptly taken to ensure that the relevant data is duly preserved until such time as the request can be substantively attended to?
If not, would you please consider implementing such a procedure in order to ensure that people’s data protection rights are maintained in light of and in spite of the backlog? Please, in this scenario, consider this paragraph as a complaint as to your manner of handling my and other members of the publics’ personal data, such as under the relevant provisions of the data protection act 2018.
In relation to the first part of this request, the MPS can confirm that we do hold recorded information.
Data Rights already have a process in place for securing body worn video (BWV) footage. The below is an extract taken from our in house all information guidance, in respect of searching for and securing BWV.
“In respect of DOTT securing BWV footage there are four points to consider:
| 1 | Applicant explicitly states they want BWV in relation to an incident they describe (i.e., give dates for or other identifiable information | DOTT must review the crime report to look for BWV links and officer’s names/numbers to search evidence.com on. DOTT must secure any footage they find and put the link(s) in the event log and markers on the case. If it’s no longer held/can’t be found DOTT need to clearly state that in the event log. |
| 2 | Applicant doesn’t give details and instead asks for “everything you hold on me” but makes no reference to BWV or footage. | We ask the applicant to specify what they want but in this case they have not. We should not assume that the applicant wants footage included in their request. Including footage significantly increases the cost to the public purse so is only to be included if actually asked for. DOTT should not search for any footage. |
| 3 |
Applicant doesn’t give details and instead asks for “everything you hold on me including BWV/footage”. IIP searches are required either on the dates specified or (if no dates given) on the last 7 years. Results show only a few* hits. |
As per row 1, DOTT must secure any footage we will hold but as we don’t have specific details to search on the guidance for a “reasonable” search needs to kick in. Here there were not many hits, so DOTT need to review ALL the located reports to look for BWV links and officer’s names/numbers to search evidence.com on. DOTT must secure any footage they find and put the link(s) in the event log and markers on the case. |
| 4 |
Applicant doesn’t give details and instead asks for “everything you hold on me including BWV/footage”. IIP searches are required either on the dates specified or (if no dates given) on the last 7 years. Results show many** hits |
Here there are too many hits for us to consider – it is not in the public interest to invest limitless money/resources from the public purse. DOTT can’t look at ALL the located reports that would be excessive. The important thing is that DOTT secure the most “at risk” footage. So, DOTT need to carry out thorough checks on footage from the last 32 days. In addition, DOTT should look for footage for a further 20 minutes to look for BWV links and officers names/numbers to search evidence.com on Start from the most recent reports and work backwards chronologically. DOTT must secure any footage they find and put the link(s) in the event log and markers on the case. |
*Few hits would be 5 of less separate incidents
**Many hits would be 6 or more separate incidents
Important Note For Caseworkers about BWV Retention Markers:
After footage has been secured by DOTT and the request is allocated to a caseworker, the caseworker will determine what footage is needed for the request. If the footage that DOTT secured is not needed or relevant – the retention marker on the footage must be removed by the caseworker. This is because we will not have a lawful purpose for retaining the footage and no business purpose.”
In relation to the second part of your request, this is not valid in accordance with Section 8(1) and Section 84 of the Act, as you are not requesting recorded information. Instead, you are requesting that the MPS consider implementing a policy and asking us to record a complaint on behalf of yourself and others if a policy is not already in place.
The Freedom of Information Act is not the appropriate route to make suggestions or raise complaints and / or concerns. This can be done via other avenues, and the link containing details of how to do so can be found below:
01/FOI/24/036036 -
Please kindly provide for each of the past 8 years:
- the number of ROA requests received by MPS
- that of those fulfilled/completed
- if it would not exceed costs, the average amount of time from each of those completion date since the date that they were originally received
- if it would not exceed costs, the longest time that a completed request had gone uncompleted after being received, and/or the shortest such period of time.
We are pleased to confirm that the information requested in the first two parts of this request is held and already available in the public domain. It can be found here:
Right of access performance dashboard | Metropolitan Police
Although we note that average response times are provided on the 'despatch' tab at this link, we have become aware of a system issue which means that the data is better than the averages shown. We are working on fixing that issue, however in the meantime, answering your specific questions would only be possible with a manual review of all the cases. Therefore, in order to locate, retrieve and extract the average and longest / shortest amount of time taken to process a completed ROA request, it would involve an individual manually reviewing each individual case and assessing the date it was received and when it was closed and then calculating the average / working out which cases took the most and least time. Even at only one minute per case, 2022’s requests would take in excess of 220 hours to review and therefore these questions would far exceed the appropriate limit set out in the Fees Regulations. These questions would therefore engage Section 12(1) – which means they, and the rest of the requests, would be exempt under our rights to aggregation. As you have stated ‘if it would not exceed costs’, these have been considered withdrawn and not considered further.
01/FOI/24/036265 -
Can you please provide the numbers of staff involved with the MPS Data Office and Information Rights Unit, as well as the organisational structure of these groups, as well as the breakdown of the staff by uniform/civilian status and rank?
The number of staff within the Data Office and Data Rights has been provided above in response to 01/FOI/24/03717, as has a breakdown according to ‘rank’. Please note, all staff in the Data Office are civilian staff and therefore we do not have ‘ranks’ but instead are categorised by ‘bands.
The organisational structure of the Data Office is as below -
The organisational structure of Data Rights has been attached.
I hope this information is of use to you.
The MPS notes that you have a significant number of open FOI requests. Please be mindful that as an organisation we have finite resources to deal with FOI requests and we are currently seeing an unprecedented demand within this area. We respectfully ask that you consider this when submitting future requests.