Dear Gloucestershire Constabulary,

I am writing under the Freedom of Information Act 2000, to make a request for information relating to your organisation’s development and/or use of digital decision tools for policing and law enforcement.

By digital decision tools, I mean any technology that uses software algorithms to process digital data and generate outputs either to (a) *support* policing decisions, by providing information or recommendations to a human police officer, who retains discretion in making the final decision; or (b) *automatically* trigger a policing or law enforcement decision based on the generated output(s).

By ‘policing and law enforcement decisions’, I mean any decisions taken by police officers in carrying out their duties to detect and prevent crime, to protect the public and reduce harm, to maintain public order, to enforce the law, and to bring offenders to justice. This may include (but is not limited to) decisions concerning the imposition of enforcement notices (e.g., speeding fines), case/complaints-handling, resource allocation, criminal investigations (particularly those concerning whether to pursue inquiries in relation to specific persons, and what action(s) to take, such as arrest or questioning, stop and search etc.), and decisions made at the pre-trial stage about individuals, including detention and charging decisions.

EXAMPLE TOOLS OF INTEREST

To help with my inquiry, examples of the kinds of tools I am requesting information on include:

1. *Digital dashboards*: any tool which processes and organises data sets to generate data visualisations to assist policing work. For example, they might provide information about ongoing and/or recently reported incidents, the analysis of crime patterns, workload and resource allocation, and data shared with public agencies such as the emergency services. These dashboards might, for instance, be used to improve emergency response times, assist officer decision-making, resource management, and so on. For example, Qliksense.

2. *Individual risk assessment tools*: any tool which processes data to generate predictions about the ‘risk’ posed by an individual relating to an undesirable outcome, such as their risk of committing a serious violent crime in the future, risk of general recidivism, risk of self-harm, or risk of becoming a victim of harm. For example, the London Gangs Matrix or the Harm Assessment Risk Tool (‘HART’) that has previously been used by Durham Constabulary.

3. *Geospatial crime ‘hotspot’ mapping tools*: any tool which processes historical crime data to identify patterns indicating potential crime ‘hotspot’ areas (i.e., geographical locations where crime is predicted to be most likely to occur within a given time period). For example, PredPol.

4. *Automated biometric analysis tools* (including live facial recognition systems): any tool which processes biometric data for the purposes of identifying individuals ‘of interest’ (i.e., according to s.205 of the Data Protection Act 2018: biometric data is data relating to the physical, physiological, or behavioural characteristics of a person, such as facial images, fingerprints, or retina scanning). For example, NeoFace Watch.

5. *Any other tool to assist policing and law enforcement work*: any other tool that uses software algorithms to generate outputs to help inform policing decisions made by your organisation, or to automatically trigger decisions based on those outputs (e.g., Automated Number Plate Recognition (ANPR) systems, social network analysis, case ‘solvability’ analysis, and so on).

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SPECIFIC INFORMATION REQUESTED

My specific information requests are listed and numbered below.

To help reduce the resources needed to respond to my numbered requests, you may limit your detailed responses to *ten* tools, and then simply list the name(s) and policy purpose(s) of any other tools.

If your organisation has deployed and/or developed *ten or fewer* tools in total (including those currently deployed, in development, being piloted or formerly developed or piloted but never deployed), please skip straight to the numbered requests below.

If your organisation has deployed and/or is developing (or has developed) *more* than ten tools in total, please follow the guidance below to identify which ten tools to provide information about, in response to the numbered requests:

● If *more* than ten tools have been deployed for *operational* use by your organisation, please respond to the numbered requests for the ten *most recently* deployed (including those no longer in use) and merely list the name(s) and policy purpose(s) for any other tools that have been deployed or developed (including ones currently in development);

● If your organisation has deployed *fewer* than ten tools for operational use (or none at all), please respond to the numbered requests in relation to any other tools that your organisation is (or was formerly) *developing or piloting,* until you have reached a total of ten tools. Again, please respond for those tools *most recently* put into development or piloted until you reach the limit of ten tools in total, and then simply list the name(s) and policy purpose(s) for any remaining tools.

FOR EACH RELEVANT TOOL (UP TO TEN IN TOTAL), CAN YOU PLEASE:

1. Supply the *name(s)* of each tool, including any tool(s) which are no longer used (or were developed and/or piloted but never deployed).

2. Please specify the stage of maturity of each tool in terms of the following three possibilities (i) currently in operational use or formerly deployed for operational use (ii) currently under development or was developed in the past but never deployed (iii) currently being piloted or was piloted in the past, but never deployed.

3. Explain the *reason(s)* why your organisation decided to develop and/or deploy each tool, including the intended *policy purpose(s)* of the tool (e.g., to reduce criminal offending by aiming to improve the identification of potential victims of a criminal offence or to identify individuals ‘of interest’ to police, using the automated analysis of digital data).

4. Identify the data sources used as ‘inputs’ to the tool and indicate whether this data has been collected from internal police data sources (e.g., crime data), external public-sector data sources (e.g., data held by local authorities), or external data sources made available by private-sector organisations (e.g., mobile communications data). Please further indicate whether the tool is updated with new data on a manual basis, by a human user responsible for inputting data (including how frequently this usually occurs), or if it is updated on a real-time basis using an automated live data feed.

5. Identify the *output(s)* that each tool produces/produced in order to serve its intended policy purpose, and what these outputs are taken to *indicate or signify.* For example: an individual risk assessment tool may produce a ‘risk classification’ for each assessed person (e.g., ‘high’, ‘medium’ or ‘low risk’). What is it, specifically, that each person is at ‘high risk’ or ‘low risk’ of, in this scenario (e.g., being arrested under suspicion of having committed a serious offence within the next two years)?

6. Indicate the kind(s) of *decision(s)* each tool supports/supported or triggers/triggered and about *whom or what*? For example: who to stop and search? Where to send police patrols? Should an arrested person be retained in police custody?

7. Identify the *intended user(s)* of each tool. For example: does/did the tool provide information to a front-line officer on patrol, a duty officer in a custody suite, both, or someone else?

8. *List* and provide electronic copies of any *additional documents* or information relating to each tool, including:
● Any training manuals or materials for staff, promotional materials, briefing papers, reports, or records of performance evaluations and other technical documents that provide overviews or summary information about each tool.
● Any impact assessments (e.g., data protection or human rights impact assessments), or risk assessments, that have been undertaken in relation to the tool or tools indicated.
● Any legal documents relating to the assessment or statement of the legal authorisation/legal basis for using each tool.

FOR TOOLS *CURRENTLY* OR *FORMERLY* IN OPERATIONAL USE ONLY, CAN YOU PLEASE:

9. Please indicate whether in relation to each tool, users receive any *training* about tool-use, indicating what that training consists (or consisted) of, who provides this training (including whether this is in-house or external), and who receives training.

10. Indicate the *time-period* during which each tool was, or had been, in operational use, identifying the *date(s)* when each tool was first deployed (and when its use was ended, if applicable).

11. If your organisation later decided to *stop* the tool’s operational use, can you please further explain your reason(s) for doing so, and indicate when that decision was made?

FOR TOOLS CURRENTLY UNDER DEVELOPMENT OR PILOTING (OR FORMERLY UNDER DEVELOPMENT OR PILOTED, BUT NEVER DEPLOYED) ONLY, CAN YOU PLEASE:

12. Indicate the *time period* during which development or piloting for each tool took place/has been taking place, including when development or the pilot began, the *expected/planned launch date* for tools still under development, and whether the launch will be on a pilot basis or for operational use.

13. If your organisation later decided to *abandon the development* of a tool or decided *not to deploy* that tool for operational use following a pilot period, can you please further explain your reason(s) for doing so, and indicate when that decision was made.

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If my request is too wide or unclear, I would be grateful for your advice and assistance, under s.16 of the FOIA 2000, explaining why so that I can refine and clarify my request. If any of the information is already in the public domain, please can you direct me to it, using URLs and page references if necessary.

If the release of any of the information requested is legally prohibited on the grounds of breach of confidence, I ask that you supply me with copies of the confidentiality agreement.
I understand that you are required to respond to my request within the 20 working days after you receive this letter. I would be grateful if you could confirm in writing that you have received this request.

Yours faithfully and with thanks,

Dr. Adam Harkens

Dear G Macpherson,

Many thanks for your response and for taking the time to consider my freedom of information request. I am writing with suggested refinements to my initial request, and to ask that you re-consider it in light of these suggestions.

If there are other ways that I can refine my request so that the scope remains within the appropriate limit under the FOIA2000, I would greatly appreciate your advice.

Before setting out my suggested refinements, I would first like to highlight that my request was carefully designed to ensure the time required to respond to it was kept to a minimum. For example, as set out in my initial request, I have advised that information is only being requested for up to ten relevant tools (chosen on the basis of being most recently deployed for operational use, most recently piloted, or most recently developed). This has been achievable by other forces, who organised their responses using a simple table. Such a table sets out shortened forms of my requests in rows, with their direct responses on a tool-by-tool basis in the columns. Using a table like this, or a similar format, may help to reduce the time needed to extract and present any relevant information that I have requested. There should be no need to redact any information using this format, and the responses can be quite short.

Here is a response with an example table:
https://www.whatdotheyknow.com/request/d...

A direct link to the document is available here:
https://www.whatdotheyknow.com/request/8...

Considering the above, if you believe that further refinements are still required, I suggest that the scope of my request can be reduced in at least three ways.

Firstly, I can remove my request for “electronic copies of any *additional documents* or information relating to each tool” (number 7). This request may be a significant contributor to the cost of identifying, locating, retrieving, and extracting the relevant information. I would therefore be happy to remove this request if it is too onerous.

Secondly, I can limit the scope of my request to those tools that are *currently in operation only*, again with a view to reducing the time required to identify, locate, and extract the relevant information. You can limit the number of tools to ten, chosen on the basis of those that have *most recently been deployed.* This will reduce the number of tools within scope, and remove the need for you to respond to requests 11 and 12.

Thirdly, I can limit the time-frame of the request to the *last five years*.

Unfortunately, I am unable to focus on one or two specific tools, per your suggestion, as I do not have the requisite information about your organisation's use of such tools to make the necessary decision in this regard.

I hope that my suggestions can help us to find a productive compromise, and I appreciate the time you have taken to consider and respond to my request. Please can you let me know if you find these suggestions to be suitable, and provide me with an update on the status of my request as a result? I look forward to hearing from you.

Yours sincerely,

Adam

Dear Gloucestershire Police,

Many thanks for your response. I would like to keep this request open.

I am writing with some suggested refinements to my initial request, in an effort to make the request easier to respond to - these are set out below, underneath this email. Can you please let me know whether these refinements will suffice for the request to remain under the cost threshold? I am happy for this to be logged as a new request if necessary, given that you have intimated that the case will be closed.

To summarise, my refinements include:

1. Changing the scope of the request, so that information only on tools *currently in operational use* is being requested.

2. Reducing the scope of the example tools included in the request, so that *5. Any other tool...* has been removed. This should significantly reduce the number of documents required to be reviewed.

3. Reducing the number of total questions. I am now only asking for information on (a) the name of the tool; and (b) its policy purpose.

To further help with ease of reporting, it may help to have a look at other responses that I have received, where the information was set out in a simple table.

Here is a response with an example table:
https://www.whatdotheyknow.com/request/d...

A direct link to the document is available here:
https://www.whatdotheyknow.com/request/8...

Many thanks,

Dr. Adam Harkens

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I am now writing to limit my request to the following:

Digital decision tools *currently in operational use* by your force (up to a total of ten - chosen on the basis of *most recent deployment*, where more than ten are in use).

By digital decision tools, I mean any technology that uses software algorithms to process digital data and generate outputs either to (a) *support* policing decisions, by providing information or recommendations to a human police officer, who retains discretion in making the final decision; or (b) *automatically* trigger a policing or law enforcement decision based on the generated output(s).

By ‘policing and law enforcement decisions’, I mean any decisions taken by police officers in carrying out their duties to detect and prevent crime, to protect the public and reduce harm, to maintain public order, to enforce the law, and to bring offenders to justice. This may include (but is not limited to) decisions concerning the imposition of enforcement notices (e.g., speeding fines), case/complaints-handling, resource allocation, criminal investigations (particularly those concerning whether to pursue inquiries in relation to specific persons, and what action(s) to take, such as arrest or questioning, stop and search etc.), and decisions made at the pre-trial stage about individuals, including detention and charging decisions.

EXAMPLE TOOLS OF INTEREST

To help with my inquiry, examples of the kinds of tools I am requesting information on tools including:

1. *Digital dashboards*: any tool which processes and organises data sets to generate data visualisations to assist policing work. For example, they might provide information about ongoing and/or recently reported incidents, the analysis of crime patterns, workload and resource allocation, and data shared with public agencies such as the emergency services. These dashboards might, for instance, be used to improve emergency response times, assist officer decision-making, resource management, and so on. For example, Qliksense.

2. *Individual risk assessment tools*: any tool which processes data to generate predictions about the ‘risk’ posed by an individual relating to an undesirable outcome, such as their risk of committing a serious violent crime in the future, risk of general recidivism, risk of self-harm, or risk of becoming a victim of harm. For example, the London Gangs Matrix or the Harm Assessment Risk Tool (‘HART’) that has previously been used by Durham Constabulary.

3. *Geospatial crime ‘hotspot’ mapping tools*: any tool which processes historical crime data to identify patterns indicating potential crime ‘hotspot’ areas (i.e., geographical locations where crime is predicted to be most likely to occur within a given time period). For example, PredPol.

4. *Automated biometric analysis tools* (including live facial recognition systems): any tool which processes biometric data for the purposes of identifying individuals ‘of interest’ (i.e., according to s.205 of the Data Protection Act 2018: biometric data is data relating to the physical, physiological, or behavioural characteristics of a person, such as facial images, fingerprints, or retina scanning). For example, NeoFace Watch.

SPECIFIC INFORMATION REQUESTED - FOR EACH RELEVANT TOOL, CAN YOU PLEASE:

1. Supply the *name(s)* of each tool.

2. Explain the *reason(s)* why your organisation decided to develop and/or deploy each tool, including the intended *policy purpose(s)* of the tool (e.g., to reduce criminal offending by aiming to improve the identification of potential victims of a criminal offence or to identify individuals ‘of interest’ to police, using the automated analysis of digital data).