Mr. P. Gadd
Direct Line: 01622 652610
Date: 20 January 2020
FOI Ref: 19/11/1609 & 19/11/1675
Dear Mr. Gadd,
Freedom of Information Request 19/11/1609 & 19/11/1675
I write in response to your two requests for information under the Freedom of Information Act
2000 (FOIA) received on 4 November and 19 November 2019. Since both requests relate to the
same subject matter, they will both be responded to in this letter.
1/Could you please provide any correspondence ,documents, emails or any methods of communication you
have between Kent Police and Kent County Council regarding use of the Town & Police Act 1847, Section 21,
Road Closure. For the Period 1st Jan 2018 to 4Nov 2019
2/Could you please provide any correspondence ,documents, emails or any methods of communication you
have between Kent Police and Ashford Borough Council regarding use of the Town & Police Act 1847,
Section 21, Road Closure. For the Period 1st Jan 2018 to 4Nov 2019
3/ Could you please provide any correspondence ,documents, emails or any methods of communication you
have between Kent Police and Kent County Council regarding the Boxing Day Meeting in Tenterden for the
period 1st Jan 2018 to 4Nov 2019
4/ Could you please provide any correspondence ,documents, emails or any methods of communication you
have between Kent Police and Ashford Borough Council regarding the Boxing Day Meeting in Tenterden for
the period 1st Jan 2018 to 4Nov 2019
Could you please provide any emails, documents or correspondence between Kent Police and Ashford
Borough Council regarding the meeting on Boxing Day Meeting of the Ashford Valley Hunt Ltd @ High St,
Tenterden in 2018.
Also, any information to include for the 2019 Boxing Day meeting.
Could you provide anything you have for the Period 1st October 2018 to 19 Nov 2019.
The attached appendix provides copies of correspondence between Kent Police, Ashford Borough
Council, and Kent County Council, with regard to road closures and Boxing Day meetings in
Some information is exempt from disclosure by virtue of the following exemptions:
Section 31(1)(a)(b) Law enforcement
Section 40(2) in conjunction with Section 40(3A)(a) Personal information
Section 43(2) Commercial interests
Freedom of Information, Coldharbour, London Road, Aylesford, Kent, ME20 7SL
This is available in
large print on request
Information exempted at Section 31(1)(a)(b) contains:
Traffic Management Plans
Event Management Plans
Event Notification Form
Operationally sensitive material
Information exempted at Section 40(2) in conjunction with Section 40(3A)(a) contains personal
information, in this case the names of individuals.
Information exempted at Section 43(2) relates to insurance liability documents.
Evidence of harm
Management plans, risk assessments and information containing operationally sensitive material, if
disclosed into the public domain, would be of great use to any person or persons wishing to
disrupt an event, or engage in actions involving or resulting in criminal acts.
Factors in favour of disclosure at Section 31
Disclosure of this information would contribute to openness and transparency, and provide insight
into how individual events are planned and organised.
Factors in favour of non-disclosure at Section 31
The information compiled in these documents has been provided to Kent Police for the purposes of
ensuring public safety, and in confidence by the event organisers. The disclosure of event planning
information, particularly for events which may occur more than once, would highlight sensitive
planning details which if known publicly could highlight any perceived security vulnerabilities which
could be exploited by those wishing to frustrate, disrupt or cancel an event at the planning stage
or as it takes place. Any disclosure which would risk harm to those involved in an event or to the
general public, and requiring the diversion of police resources is not considered to be in the public
Personal information is information that relates to a living individual who can be identified from
that information alone or from that information together with other information in the possession
of, or likely to come into the possession of, the Chief Constable. The information requested
includes the names of individuals, the disclosure of which under FOIA would constitute the
processing of personal information contrary to the Data Protection Act 2018.
Factors in favour of disclosure at Section 43
Disclosure of insurance liability documents would contribute to openness and transparency, and
provide insight into how individual events are planned and organised.
Factors in favour of non-disclosure at Section 43
The financial information contained within these documents belongs to the event organisers, the
public disclosure of which would be prejudicial to event organisers as it would highlight for what
and for how much they are paying for insurance, undermining their ability to receive insurance in
the future at fair market rates.
Having reviewed the arguments above, whilst it can be considered to be in the public interest to
provide correspondence between Kent Police, Ashford Borough Council and Kent County Council
concerning road closures and the Boxing Day meetings in Tenterden, provision of the precise
Kent Police : PSD FOI
Form 3540b rev Jan 2011 [erev 2/11] v1
planning details would undermine the joint approach to event management, putting events at risk
of disruption and requiring the diversion of police resources to contend with any unrest or criminal
activity, and cannot be considered to be in the public interest.
I apologise that this reaches you outside of the twenty working day limit, but thank you for your
interest in Kent Police. If you have any queries about your request or the application of the
Freedom of Information Act generally, please contact this office quoting the reference number
Public Disclosure Officer
Your right to appeal
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 40 working days from the date the response is issued to request that Kent
Police carry out an internal review.
If your request for a review concerns the decision to apply an exemption, it would assist if you
would outline why you believe the exemption does not apply.
Kent Police will acknowledge receipt of any request for a review and aim to respond as soon as
practicable, in most cases within 20 working days of receipt. If the review will not be completed in
this timescale, you will be informed.
You may lodge your request for a review in writing:
Our email address is: email@example.com
Our postal address is:
Freedom of Information
If you are still dissatisfied following our internal review, you have the right under section 50 of the
Act to appeal directly to the Information Commissioner who would normally expect you to have
exhausted the internal review procedure provided by Kent Police.
For information on how to appeal to the Information Commissioner please visit the website at
www.ico.org.uk. Alternatively, phone or write to:
Information Commissioner's Office
0303 123 1113
Kent Police : PSD FOI
Form 3540b rev Jan 2011 [erev 2/11] v1