41 Homer Road
Monday 20 May 2019
Dear Ms Parsons, Re: Freedom of Information request – 52173
Thank you for your email of 31 January in which you ask about the storage of data relating
to information submitted by the public within Immigration Enforcement; your full request
can be found in Annex A.
Your query has been handled as a request under the Freedom of Information Act 2000.
Firstly, I would like to offer my apologies on behalf of the Department for the delay
responding to your request. We are now able to provide a partial response.
I can confirm that the database used is called the Intelligence Management System.
You also requested information regarding the storage of data. I can confirm the Home
Office holds this information. However, after careful consideration we have decided that
the information is exempt from disclosure under Section 38(1)(b) of the Freedom of
Information Act 2000, which relates to health and safety of individuals. Placing the location
of our data in the public domain could potentially risk the security of that data, including the
personal data of private individuals and could assist a cyber-attack. Taking into account all
of these considerations, it is my opinion that public interest clearly favours the non-
disclosure of information.
We also rely on section 31(1)(a) of the Freedom of Information Act 2000. Disclosing
information regarding the management, operation, location and maintenance of this
database would be likely to impact members of the public who submit information about
immigration offenders and consequently prejudice the prevention or detection of crime.
Our arguments for and against disclosure of this information can be found at Annex B.
If you are dissatisfied with this response you may request an independent internal review
of our handling of your request by submitting a complaint within two months to firstname.lastname@example.org,
quoting reference 52173.
If you ask for an internal
review, it would be helpful if you could say why you are dissatisfied with the response.
As part of any internal review the Department's handling of your information request would
be reassessed by staff who were not involved in providing you with this response. If you
were to remain dissatisfied after an internal review, you would have a right of complaint to
the Information Commissioner as established by section 50 of the FOIA.
Yours sincerely, Immigration Enforcement Secretariat
Annex A Re: Freedom of Information request - 52173
On 29th January you asked the following, which was logged as FOI 52152:
Please provide me with the most up-to-date contract for the orgsanisation(s) who
manage, operate and maintain the Information Management System database.
Alongside this, please can you provide me with the address of the data center(s)
where the database is stored. (for example, the Home Office Peel Centre Data
Centre in Hendon
On 31 January 2019 you provided the following clarification, which was logged as FOI
Firstly, apologies that my question was not clear.
I'm looking for information about the storage of data relating to Immigration
Enforcement. I believe there is a database called "Information Management
System": an intelligence database where "tip offs" of immigration offenders are
logged and analysed. And so, I'd like to request information regarding who
managed, operates and maintains this database or whatever this database is now
called (for example Sopra Steria or another company) and then where this
database is physically stored (which specific data centres are used for such).
Public interest test in relation to section:
31(1)(a) – Law enforcement; information disclosure would, or would be likely to
prejudice the prevention or detection of crime.
38(1)(b) – Health and safety; information disclosure would, or would likely endanger
the safety of any individual.
Some of the exemptions in the FOIA, referred to as ‘qualified’ exemptions, are subject to a public
interest test (PIT). This test is used to balance the public interest in disclosure against the public
interest in maintaining the exemption. We must carry out a PIT where we are considering using
any of the qualified exemptions in response to a request for information.
The ‘public interest’ is not necessarily the same as what interests the public. In carrying out a PIT
we consider the greater good or benefit to the community as a whole if the information is released
or not. Transparency and the ‘right to know’ must be balanced against the need to enable effective
government and to serve the best interests of the public.
The FOIA is ‘applicant blind’. This means that we cannot, and do not, ask about the motives of
anyone who asks for information. In providing a response to one person, we are expressing a
willingness to provide the same response to anyone. Considerations in favour of disclosing the information
There is a general public interest for the Government to be open and transparent, in order to
maintain public trust. This improves engagement with Government and allows for an informed
public debate. We take into account that the public interest could be served by disclosing the
information sought regarding collation of data on immigration offenders within the Home Office.
Transparency regarding Home Office collation and storage of data from the public would go some
way to meeting this interest and increase understanding.
Considerations in favour maintaining the exemption
If the department were to disclose the information requested, it could substantially prejudice our
ability to prevent and detect crime. Specifically, disclosing the location of the data storage could
lead to loss of public confidence in the Intelligence Management System, upon which the Home
Office is dependent on collating information on immigration offenders and offences. Disclosing
information on management, operation and maintenance
could increase the chance of cyber attack
on the database and loss of data that would impact on the health and wellbeing of individuals who
have provided information in confidence to the Home Office. Conclusion
We conclude that the balance of the public interest lies in maintaining the exemption and
withholding the information.