5th December 2019
Internal Review reference 003917/19
I write in connection with your request for an internal review of our response to FOI 003222/19.
I am writing to request an internal review of Norfolk Constabulary's handling of my FOI
request 'Coordinate Location Systems for Emergency Call Centre Use' (003222/19). A full
history of my FOI request and all correspondence is available on the Internet at this
would like to complain about two aspects of your responses to my request.
First, in its initial response of 3rd October, the Constabulary claimed that the Section 31
exemption was engaged and that more time was needed to conduct a public interest test.
No explanation for the engagement of the Section 31 exemption was provided at the time,
and there is no mention of the exemption or the public interest test in the final response.
There was also no confirmation of what information was held in the response of 3rd
Please provide an explanation of what has happened here, including the Constabulary's
documented reasons for (initially) believing that Section 31 exemption was engaged, and
the outcome of the public interest test that was presumably conducted.
Does the Constabulary accept that it failed to comply with FOIA s1(1)(a) in its response of
3rd October by not stating what information was held? Does the Constabulary now accept
that Section 31 does not apply to any of the requested information, and thus it breached
FOIA s1(1)(b) in failing to communicate the information within 20 working days?
Secondly, regarding the information supplied in the Constabulary's response of 17th
* My item 4 was not answered. If no such evaluation was undertaken, please confirm that
this is the case. If it was, then please provide details. (If no evaluation was undertaken, this
raises worrying questions about how the decision to promote What3Words came to be
made. I'll make a separate FOI request about this if necessary.)
* In relation to item 5, can you confirm whether the "Enhanced Information Service for
Emergency Calls" information you get includes AML/ELS GPS location data, rather than
just relying on cell town triangulation? I note that the report at https://eena.org/wp-
content/uploads/2019/07/2019_07_17_AML_Report_Card_Update.pdf from July 2019
states on 30% of police forces use AML data from stage 1 PSAP. Please confirm whether
or not Norfolk one of those to be using it.
* For item 6, you have not provided any SOP/Guidelines for call-handlers needing to
determine a caller's location (I was not referring specifically to using What3Words here, but
on any methods staff are encouraged/trained to used when talking to a caller who can't
identify their location). I'm sure you must have some guidelines or training materials to
advise/train staff how to do this. Please confirm that such documents either do not exist, or
provide the relevant guidelines / training documents if they do.
* In your response to item 7, you stated that the tweet was only liked by a force account.
This is incorrect: the tweet was re-tweeted by the official Norwich Police account
@NorwichPoliceUK . Please confirm that you accept this. Regarding identifying the
incident, I think you should be able to deduce which incident was being referred to from the
information in the tweet. In particular, the date (25th August) and the fact that the Air
Ambulance was called (evident from the first reply to the tweet) should narrow things down
considerably. The following newspaper articles may also help you further:
9080858/ . I assume the recordings of the calls you receive are kept, so you should be able
to review these for any difficulty in determining a location and any mention of What3Words.
However, I guess it is possible that the tweeter is mistaken and it was an ambulance
control centre operator rather than a police one who was unable to determine the location.
Please let me know, if, having identified the incident, you believe this may be the case.
In conducting this Internal Review I have read through all of the information including the initial FOI
request, the FOI responses and the argument for the Internal Review. I also met with the Chief
Inspector from the Control room to discuss what information is held. When comparing the
information requested and the information provided I agree with the points raised by the applicant
and a revised response has to be issued. However, the scope of the Internal Review is restricted
to the points raised on the individual questions by the applicant.
The following information is to be provided in a revised response whilst the information provided in
the original response to the questions not listed below, remain unchanged:
Q4/ Prior to deciding to use and promote What3Words for emergency use, what evaluation of
other systems (e.g. lan/lon, OS Grid references, Mapcodes, Open Location Codes, or AML/ELS)
was carried out or reviewed? In particular, was any analysis done as to the effectiveness of
conveying a What3Words location versus an OS grid reference over a poor phone line, and how
one or other parties being non-native English speakers might affect things?
A4. No evaluation or analysis of other systems was conducted, therefore no information is held.
from smartphones, and how is this
information available to them? Is this available from all 999, 911 and 112 calls made from
compatible smartphones? If not, why not?
A5. Smartphone technology is not available to Control Room Operators. No information is held in
relation to the reasons for this.
6/ Please provide a copy of any Guidelines or Standard Operating Procedures for control room
staff who need to find the location of a caller on a mobile phone. Are staff able to interpret OS Grid
references and/or Open Location Codes if the caller provides these?
A6. There are many reasons why a Control Room Operator may need to find the location of a
caller on a mobile phone. For example, a missing person or an abandoned call. The original
response included a Standard Operating Procedure (SOP) on ‘999 & Other Calls – Abandoned,
Accidental, Nuisance & Silent’. The SOP provided included a narrative box that stated ‘Consider
Immediate subscriber check through CCR Supervisor & ‘Golden Hour’ checks’. The training
provided to Control Room Operators is, in these circumstances, to contact the Duty Control Room
In relation to the second part of the question. The response is Yes, staff are able to interpret OS
Grid references and/or Open Location Codes if the caller provides these.
7/ In the case described at https://twitter.com/skipptg/status/1165928846702579712
, which was
recently retweeted by the Norwich Police twitter account, can you confirm that the incident
happened as described, and explain why an AML/ELS location was not available from the original
Q7. This was retweeted by the Norwich Police twitter account.
I have undertaken searches to locate the incident. It cannot be guaranteed but a CAD was located
which best fits the description i.e. a motorcycling road traffic collision in a rural location using
what3words to identify the location. The incident identified happened as described in the tweet.
No information is held. The Control Room received a call from the Ambulance Service and not the
If you are not satisfied with this response, please refer to our review procedure (copy enclosed) for
further information on what to do next.
Information Compliance Manager
Norfolk & Suffolk Constabularies
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