Freedom of Information, Information Compliance Unit, Kent Police Headquarters, Sutton Road,
Maidstone, Kent ME15 9BZ Phone: 01622 654413
Fax: 01622 654437 - e-mail: xxxxxxxxxxxxxxxxxxxx@xxxx.xxx.xxxxxx.xx
Mr C Nolan
Date:
4th September 2009
xxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxxxxx.xxx
Tel No. (DDI)
01622 664429
FOI Ref.
6094/2009
Dear Mr Nolan,
FREEDOM OF INFORMATION REQUEST 6094/2009
I write in connection with your request for information received by Kent Police on the 11th
August 2009.
I note that you seek access to information relating to Automatic Number Plate Recognition
(ANPR).
Following receipt of your request searches were conducted within Kent Police and I can now
respond as follows.
The use of Automatic Number Plate Recognition (ANPR) technology can help to detect, deter,
and disrupt criminality, including terrorism, and is a tactical option providing new lines of
enquiry and evidence in the investigation of crime. ANPR is a technology that automatically
reads vehicle registration marks (VRM’s) allowing these details to be compared against
database records.
ANPR data comprises ‘read’ and ‘hit’ data. A read is the capture of the VRM and image of the
vehicle as it passes through the camera: read data is the term used to describe all the data
collected as vehicles pass through the ANPR reader. A hit is a match to a VRM held within the
database being searched.
The strategic intent of the ANPR strategy for the Police Service is to target criminals through
their use of the road. In fulfilling this intention, the ANPR strategy will help meet the primary
Police Service aims to:
Reduce crime and terrorism
Increase the number of offences brought to justice, including serious major crime
Reduce road traffic casualties
Increase public perceptions
Make more efficient use of police resources
The ANPR strategy aims to meet these police service targets using ANPR to complete the
following actions:
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Deter criminals and terrorists through an increased likelihood of detection
Disrupt criminal activities and networks by intelligence led interventions
Remove prolific and serious offenders from the streets
Increase arrests
Increase sanctioned detections
Improve compliance with road traffic laws
Increase visible policing
An ANPR database is a list of vehicles of interest to a particular force or specialist area against
which ANPR read data is checked. There are a number of databases loaded onto the ANPR
system. These databases include for example PNC files, local force databases, foreign force
databases, and MIDAS (motor insurance) database. The read data from ANPR cameras is
checked against these databases in order to identify vehicles of interest.
The above information has been provided from the document entitled ‘Practice Advice on The
Management and Use of Automatic Number Plate Recognition’ which can be located on the
Association of Chief Police Officers (ACPO) website which can be located using the following link
http://www.acpo.police.uk/
This document includes for example a full list of all databases included on the ANPR database,
details of further actions that ANPR cameras can be used in relation to, and information
regarding how ANPR cameras operate. This document explains how the images are stored and
how ANPR can be used in operational policing.
1. The total number of images recorded/processed by the ANPR system in the Kent region in
2008.
Answer: In 2008 there were 227,170,606 reads recorded by the Automatic Number Plate
Recognition (ANPR) system.
2. The total number of these images that were flagged as "vehicles of interest" in 2008.
Answer: In 2008 there were Kent Police recorded 561,449 vehicles as ‘vehicles of interest’.
3. The total number of arrests made due to an ANPR lead being followed (i.e. pulling over of a
vehicle) in 2008.
Answer: It would be theoretically possible for us to extract this data from our systems.
However, this would require the manual examination of a 227,170,606 records, which would
involve an expenditure of resources that would far exceed the amount that a public authority is
required to invest in responding to a request, i.e. the cost of locating and retrieving the
information exceeds the “appropriate level” (currently eighteen hours) as stated in the Freedom
of Information (Fees and Appropriate Limit) Regulations 2004. The information is therefore
exempt under Section 12(1) of the Freedom of Information Act and in accordance with section
17(1) of the Act this letter must act as a Refusal Notice for this part of your request.
(1) Section 1(1) does not oblige a public authority to comply with a request for information if
the authority estimates that the cost of complying with the request would exceed the
appropriate limit.
FOIA, Section 12 - Exemption where cost of compliance exceeds appropriate limit
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4. The location of all ANPR sites currently in use by Kent Police.
Answer: This information is exempt from disclosure under the exemptions at Section 24(1) -
National Security, and Section 31 (1)(a)(b) and (c) - Law Enforcement, of the Freedom of
Information Act 2000. This letter must therefore act as a refusal notice for this part of your
request.
Section 24 of the Freedom of Information Act (2000) creates an exemption from disclosing
information where the exemption is required “for the purpose of safeguarding national
security”. Section 31 of the Act creates an exemption from the right to know if releasing the
information would or would be likely to prejudice a range of law enforcement functions and
activities, including the prevention and detection of crime. In this case, to release the
information would have a detrimental impact on the prevention and detection of crime, and
therefore the information is exempt from being released. Sections 24 and 31 are prejudice-
based, qualified exemptions, which require that I consider the public interest, and provide
evidence of harm that may be caused by disclosure. I am including the relevant subsections of
the exemptions, the public interest test and the evidence of harm below.
Section 24 (1) National Security
(1) Information which does not fall within section 23(1) is exempt information if exemption
from section 1(1)(b) is required for the purpose of safeguarding national security.
Section 31 (1) (a) (b) (c) Law Enforcement
1) Information which is not exempt information by virtue of section 30 is exempt information if
its disclosure under this Act would, or would be likely to, prejudice—
(a) the prevention or detection of crime,
(b) the apprehension or prosecution of offenders,
(c) the administration of justice,
Public Interest Test Kent Police should be accountable for any decision that they make in relation to ANPR cameras,
including decisions surrounding where these cameras should be located, and the disclosure of
the location and purpose of each ANPR camera would ensure that Kent Police remain
accountable.
Concerns have been voiced in the public arena concerning the number of cameras used for
surveillance and disclosure of this information could also serve to ensure that public debates on
the subject of ANPR cameras are correctly informed and accurate by assisting the public in
gaining a clear understanding of how and why locations for permanent cameras are selected.
However, public safety is of paramount importance to the policing purpose and the disclosure of
this information could have a detrimental impact on public safety. The aim of the force is to
protect and serve the people of Kent by preventing crime, protecting property and saving and
preserving life, and the release of this information could compromise this aim. The release of
this information would lead to less crimes being prevented, and less lives being preserved as
information from these cameras is used to improve road safety and detect serious offences.
ANPR cameras are used to detect a multitude of traffic offences, including for example
detecting cars that have no tax or insurance, and for detecting stolen vehicles. Revealing the
location and purpose of each camera would be providing the criminal fraternity with information
that could be used to avoid arrest and detection.
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Further to this it is occasionally necessary to use ANPR cameras in covert surveillance
operations, and to reveal the location and the purpose of these cameras would detrimentally
impact upon these investigations, having a negative impact on law enforcement, which would
also affect the safety of members of the public.
Evidence of Harm
The harm here is twofold. The most important argument is that to provide the locations of all
ANPR cameras would assist those committing offences, including criminals and terrorists
planning to commit serious offences, and help them evade detection. The ANPR network is an
important tool in the fight against serious and organised crime and terrorism and anything that
could lessen the effectiveness of that tool would be harmful to our national security, law
enforcement and public safety. Although it is not possible to provide concrete evidence that
such harm may occur, the police service considers the risk to be likely and the harm self-
evident.
The second harm that may occur relates to the cameras themselves becoming the targets of
criminal activities. In a similar example, the location of speed cameras was previously provided
in response to a Freedom of Information request and this led to a number of camera sites being
vandalised. Whilst the original request was for information relating to speed camera sites, it is
felt that the same harm could occur if the sites of permanent ANPR cameras were disclosed.
On the 6 September 2007 a response was sent to Matthew Davis of John Connor Press
Associates in relation to a Freedom of Information Act request for information connected with
ten cameras in Wiltshire that detected the most speeding offences.
The response given listed the ten cameras and the response stressed that they were listed in no
particular order. The camera locations were also given (as requested) using Ordnance Survey
map references. The information was published in a National Newspaper.
On the following night - the 1st October 2007 - one of the cameras – situated at Devils Batch on
the A303 was attacked and set on fire. The camera housing, pole and camera, were all
destroyed in the fire and replacements cost £42060. Although this camera had been damaged
before, it is the police service’s considered opinion that the adverse media coverage directly
contributed to the attack in October 2007.
Although this case does not relate to an ANPR camera the disclosure of this information could
result in ANPR cameras being targeted in a similar way. Speed Cameras are overt devices and
are often subject to such attacks. Indeed, there are websites devoted to celebrating these acts
of criminal destruction.
When one considers that there are clearly persons in the community who are prepared to
commit acts of serious criminal damage on cameras that are used for speed enforcement, it is
likely that persons who are engaged in more serious criminal activities would have a vested
interest in the destruction of cameras that can be used to detect more serious offences.
Balancing Test
In this case, whilst awareness of the location of ANPR cameras would ensure that Kent Police
remains accountable, and would provide the community with detailed information making them
aware that forces are tackling the issue of crime and road safety, these arguments are
outweighed by the reasons against disclosing this information. Much of the purpose of
accountability, in terms of informing public debate, is already served by the information that is
available and which has been referred to earlier in this response.
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Public safety is of the highest importance and as releasing this information would compromise
effective law enforcement and by extension, public safety, I believe that the harm
considerations and the importance of the factors favouring non-disclosure outweigh those in
favour of disclosure. I have therefore determined that the disclosure of the above information
would not be in the public interest.
Thank you for your interest in Kent Police and I hope that the information we have been able to
provide is of use to you. A sheet, which summarised your rights, was enclosed with the
acknowledgement sent to you and as suggested therein, should you have any further questions
concerning your request, please contact me quoting the reference number shown above.
Yours sincerely,
Laura Birchley
Freedom of Information Administrator
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Your right to complain
We take our responsibilities under the Freedom of Information Act seriously but, if you feel your
request has not been properly handled or you are otherwise dissatisfied with the outcome of
your request, you have the right to complain. We will conduct an internal review to investigate
the matter and endeavor to reply within 20 working days.
You may lodge your complaint by writing to:
Supt. Paul Gladstone
Head of the Information Compliance Unit
Professional Standards Department
Kent Police Headquarters
Sutton Road,
Maidstone Kent
ME15 9BZ
Or by e-mailing
xxxxxxxxxxxxxxxxxxxx@xxxx.xxx.xxxxxx.xx
If you are still dissatisfied following our internal review, you have the right under section 50 of
the Act to complain directly to the Information Commissioner. Before considering your
complaint, the Information Commissioner would normally expect you to have exhausted the
complaints procedures provided by Kent Police.
The Information Commissioner can be contacted at:
FOI Compliance Team (complaints)
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
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