Business interests

Dear Sir or Ms,

On 12 February you submitted the following request:

Dear West Yorkshire Police,

Please provide details of any registered business interests or
secondary employment for:

a) Police Officers

b) Police Staff

Yours faithfully,

Independent Police Support Group

Unfortunately we have just realised that our system did not log this request and so nothing has
yet been done in response.

We apologise for this oversight. We will treat this request with urgency and respond as quickly as
possible.

Yours sincerely,

John Coop
FOI Team

_________________________________________________

LOCAL POLICE UPDATES: Use your postcode to read local news from your
Neighbourhood Policing Team, and sign up for free email updates,
on http://www.westyorkshire.police.uk/npt

This email carries a disclaimer, a copy of which may be read at
http://www.westyorkshire.police.uk/email...

Dear Independent Police Support Group,

You may remember that you submitted a request regarding the business
interests and secondary employment of police officers and police support
staff employed by West Yorkshire Police on 2 June 2010. We provided you
with a response at the time and it seemed that was sufficient for your
requirements. However, we did notice at a later date that the spreadsheet
we'd provided had within it information that should not have been
released. We contacted the WhatDoThey Know website to ask if this
spreadsheet could be removed, and whilst they did this, they did feel that
more information should have been provided than we initially gave. After
consulting with the Information Commissioner's Office on this matter and
taking advice from them, we are now happy to provide a more extensive
release of information than we initially gave to you at the time. (See
attached)

There are still areas of information that we cannot provide, however we
have been advised by the ICO about what information should be disclosed.
Our advice from the ICO was that the following information should NOT be
provided:

* Employee names;
* Business / Secondary employment addresses;
* Employee ID Numbers;
* Specific Business names;
* Detailed Division / Department information - specifically for
employees in high risk or specialist roles
* Specific Property Addresses; and
* Comments where the information could identify individuals

However, the ICO felt that the following information SHOULD be provided:

* Details of the type of business interest / secondary employment (with
the proviso that in some cases it may be necessary to withhold some
details that may identify employees)
* Rank / Grade (Unless this would identify individuals)
* Basic Division details

With regard to the information redacted from the spreadsheet, for ease of
understanding I've colour coded them, with Blue indicating the use of the
Section 40(2) exemption (Personal information) and Yellow indicating the
use of the Sections 40 (2) and Section 38 (Health & Safety) exemptions. In
terms of the Public Interest (PIT) and Harm tests we present the following
rationale:

S40(2) – Personal Information

To disclose personal information relating to officers and staff which
would lead to their identification, such as name, employee number and role
title, would breach principle 1 (fairly and lawfully processed), principle
2 (processed for limited purposes) and principle 6 (processed in line with
the rights of the data subject) of the Data Protection Act (1998).

Section 40(2) is an absolute and class-based exemption and so requires no
harm or public interest test to be undertaken.

S38 (1)(a)(b) – Health & Safety

Harm

To disclose information relating to the business type, business categories
and also the departments of the individuals who have secondary business
interests could cause significant risk and harm to those individuals due
to the nature of the work carried out both in the Force and the secondary
business interest.

In addition, if the individual’s business became associated with West
Yorkshire Police it could cause damage as the business may be deliberately
targeted. This would compromise the health and safety of not only the
individual, but also any family members who are involved in the business
or those who reside in the home address if the business is conducted from
home. Further to this, some individuals choose to keep their employment
with West Yorkshire Police as a private matter and separate from any
secondary business they may have, therefore to disclose information which
would compromise this may cause harm if the business becomes associated
with the Police or if the individual is identified as working for the
Police as a result.

PIT

Factors favouring disclosure are that it would provide a full
representation of the information requested for research purposes.

Factors favouring non-disclosure are that it may compromise the health and
safety of the individuals concerned or any friends or family who are
business associates. If through the disclosure of information it becomes
known that the individual works for the Police, this may cause harm or
even hinder any future commercial interests. Furthermore, due to the
nature of some roles within the Force it is necessary to ensure
information of a sensitive nature is not disclosed which could compromise
the safety of staff and officers at work and in their home lives.

Please accept our apologies for any inconvenience this may have caused you
and I trust that this new disclosure will be of more value.

Steve Harding
Head of Information Management
Corporate Support Department

Tel: 01924 292486 or 22486 (Internal)
Fax: 01924 292726 or 22726 (Internal)

e-mail: [email address]

_________________________________________________

REPORT MINOR CRIME ONLINE: Report a West Yorkshire crime online, request a
callback or report lost property, all via our website
http://www.westyorkshire.police.uk/

This email carries a disclaimer, a copy of which may be read at
http://www.westyorkshire.police.uk/email...