c/o PO BOX 481
Tel: 02380 478922
Email: [National Police Chiefs Council request email]
Dear Mr Perrin FREEDOM OF INFORMATION REQUEST REFERENCE NUMBER: 000164/15
Thank you for your request for information regarding ANPR and the ICO which has now been
considered. Applicant Initial Question 02/09/2015:
ANPR is a powerful crime fighting tool. The system gathers very large amounts of data daily about
people's movements and stores it for a number of years. In the five year strategy, "Policing the
Roads in Partnership 2015 – 2020" National Lead for Policing the Roads
Chief Constable Suzette Davenport set out some basic principles, one of which was :
'Accountability – we are answerable for our decisions, actions and omissions'.
Issues arising from a system on the scale of ANPR such as privacy can be mitigated by good system
design and effective governance. I should be grateful for information you hold in your records
about the governance of the ANPR system, particularly at a national level such as (but not
Structure of governance ‐ committees, their membership papers and minutes produced or
consumed by or within the governance structure ‐ such as board papers, minutes of meetings,
records of decisions taken correspondence with the Information Commissioner's office about the
I am interested in the period 2013‐2015 but would welcome relevant information you may hold
prior to that time.
ANPR is almost unique globally in its scale and, as it holds billions of records of people's
movements there is a very strong public interest in publishing the information I request.
I would invite you also to add such information to your publication scheme on an ongoing basis. If
you do publish this already then please point me to it ‐ I can't find a reserve of documents about
ANPRs operation and governance on your websites.
1st Floor, 10 Victoria Street, London SW1H 0NN T 020 7084 8950 F 020 7084 8951
I prefer to receive information electronically through this service. If you can answer only part of
this request then please do so rather than rejecting the whole thing. Should you require any
clarification in order to answer this request then please contact me through this service. Applicant Refined Question after clarification sought 16/09/2015:
1. For the financial years 2013 – 2015 please provide any record which details the structure
and governance of the ANPR system.
2. For the financial years 2013 – 2015 please provide any minutes of the ANPR working group.
3. For the financial years 2013 – 2015 please provide all recorded communication with the
Information Commissioner’s Office (ICO) in respect of ANPR.
The NPCC does not hold information captured by part one of your request and draft documents
attached to information in part three of your request. This is because there is no record which
details the structure and governance of the ANPR system. In addition, the attachments at 11 and
12 below are not held for the purposes of FOI as the information is still in draft form. The
information is yet to be ratified. I have consulted with the ANPR Portfolio and the Home Office
who advise me that it is intended for final versions of the information to be ratified no later than
Please be advised that should you submit a further request for the final versions of these
documents, they may be subject to a number of exemptions.
Section 17 of the Freedom of Information Act 2000 requires the NPCC< when refusing to provide
information by way of exemption, to provide you with a notice which: (a) states that fact, (b)
specifies the exemption in question and (c) states why the exemption applies. In accordance with
the Freedom of Information Act 2000 this letter acts as a refusal notice to those aspects of your
The NPCC does hold information captured by parts two and three of your request and I have
pleasure in detailing below the information held and attached to this letter: Part two
1. Minutes of ANPR National User Group Meeting 20/01/2015 released in full
2. Minutes of ANPR National User Group Meeting 18/03/2015 released in full
3. Minutes of ANPR National User Group Meeting 03/06/2015 released in full
4. Email ANPR Portfolio to ICO 26/11/2014 13:21 S31 redaction
5. Email ICO to ANPR Portfolio 26/11/2014 13:18 released in full
6. Email ANPR Portfolio to ICO 24/11/2014 08:51 S31 redaction
7. Email ICO to ANPR Portfolio 21/11/2014 13:18 released in full
8. Email ICO to ANPR Portfolio 16/12/2014 13:50 S31 redaction
9. Email ICO to ANPR Portfolio 30/06/2015 16:06 S31 redaction
10. Letter ICO to ANPR Portfolio 30/06/2015 Proposal to extend the national ANPR retention
period released in full
11. Email ANPR Portfolio to ANPR Portfolio including ICO 19/09/2015 10:00 S31 redactions
12. Email ANPR Portfolio to ANPR Portfolio including ICO 05/05/2015 15:04 S31 redactions
13. Email ICO to ANPR Portfolio 29/01/2015 10:56 S31 redaction
14. Email ANPR Portfolio to ANPR Portfolio 22/01/2015 17:23 S31 redaction
15. Email ANPR Portfolio to ICO 02/12/2014 14:25 S31 redaction
16. Email ICO to ANPR Portfolio 01/12/2014 15:27 S31 redaction
17. Email ANPR Portfolio to ICO 21/10/2014 12:07 S31 redaction
18. Email ICO to ANPR Portfolio 23/04/2015 17:14 S31 redaction
19. Email ANPR Portfolio to ICO 23/04/2015 01:10 released in full
20. Email ANPR Portfolio to ANPR Portfolio including ICO 17/10/2014 11:55 S31 redaction
21. Attachment to Email above ANPR Data Request Form released in full
Some of the information held and relayed to you has minor redactions by virtue of S31 Law
Enforcement and S23 Information Supplied by, or Concerning, Certain Security Bodies. S31 Law Enforcement – the legislation:
(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
I have engaged exemption 31(a)(b) Law Enforcement for the redaction of some of the telephone
numbers within the correspondence. Section 31 is a qualified and prejudice‐based exemption.
This request the production of evidence of what prejudice may be caused and consideration as to
the public interest in disclosure.
Disclosure of the information would disrupt established lines of communication which ensure the
effective and efficient use of staff and resources. There is a danger that the disclosure of direct dial
telephone numbers, mobile phone numbers or direct email addresses would enable an individual
to disrupt communications to a department or individual by making multiple or incessant calls /
Disclosure of the information may result in the normal priorities and workflow of the department
being disrupted if members of the public become aware of an individual’s contact details and used
them rather than going through normal policing channels. This could become a significant issue if
malicious intent or deliberate obstruction was the intent of the caller, as it would lead to the law
enforcement function of the force or unit being compromised. The non‐disclosure of office
telephone numbers was upheld in the Scottish Decision notice (see link below): http://www.itspublicknowledge.info/ApplicationsandDecisions/Decisions/2007/200600550.aspx
Disclosure of the information could also enable an individual, intent on committing an offence to
make contact with the department or individual, pose as a police officer and try to glean
information which would assist in their offending behaviour.
The public interest in disclosure of the information would improve contact with members of staff
that work for the NPCC or the police. This would ensure that the public have direct contact with
relevant services, and this may have the effect of improving public confidence in force
If the NPCC or the force has made efforts to improve contact for the public by setting up service
centres and publicising centralised numbers then the disclosure of direct dial numbers or mobile
phone numbers or email addresses would negate those efforts and lead to a less effective system.
If members of the public were able to contact individuals directly they might cause harassment or
disrupt that persons core responsibilities by blocking the line of communication. Disclosure of the
information does not enhance the correspondence that you have already been given.
The NPCC will not disclose information which may place police staff or officers at risk, or prejudice
the effective management of law enforcement. The lack of the enhancement to the public debate
that the reacted points produce, coupled with the risks leave me in no doubt that the balance, at
this time lies in non disclosure. S23 Information Supplied by, or Concerning, Certain Security Bodies – the legislation
(1) Information held by a pubic authority is exempt information if it was directly or indirectly
supplied to the public authority by, or relates to, any of the bodies specified in subsection (3). This
is an absolute exemption and there is no requirement for me to conduct a public interest test.
Freedom of Information Officer & Decision Maker www.npcc.police.uk
If you are dissatisfied with the response you have been provided with, in compliance with the
Freedom of Information legislation, you can lodge a complaint with NPCC to have the decision
reviewed within 20 working days of the date of this response. The handling of your request will be
looked at by someone independent of the original decision, and a fresh response provided.
It would be helpful, if requesting a review, for you to articulate in detail the reasons you are not
satisfied with this reply.
If you would like to request a review, please write or send an email to NPCC Freedom of
Information, c/o PO Box 481, Fareham, Hampshire, PO14 9FS.
If, after lodging a complaint with NPCC, you are still unhappy with the outcome, you may make an
application to the Information Commissioner at the Information Commissioner’s Office, Wycliffe
House, Water Lane, Wilmslow, Cheshire, SK9 5AF.