KROLL & City London Police Relationship

Ian Puddick made this Freedom of Information request to City of London Police

The request was partially successful.

From: Ian Puddick

24 July 2011

Dear City of London Police,

1. Please could you provide the name of the officer that attended
the offices of KROLL in July 2009?
2.Please provide the name of the officer that interviewed Leena
Puddick at the office of KROLL (& Guy Carpenter Ltd) in 2009?
3.Please identify the rank of the officer that interviewed Leena
Puddick?
4. Please provide the email request for this meeting from KROLL to
City of London Police?
5.Please name the KROLL agent that requested this meeting ?
6.Please provide all records relating to this meeting ?
7.Was this interview carried out under caution and in accordance
with PACE ?

Yours faithfully,

Ian Puddick
www.policeexpenses.co.uk

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From: Knox Alexander
City of London Police

27 July 2011


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Acknowledgement

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From: Lockyear David
City of London Police

23 August 2011


Attachment Ian Puddick Reply.pdf
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Attachment Further Information Attachment.pdf
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Dear Mr Puddick

REQUEST FOR INFORMATION REF: COL/11/380, COL/11/381, COL/11/382,
COL/11/383, COL/11/384 AND COL/11/407

I write in connection with your request for information dated 24 July and
6 August 2011 in which you seek access to information relating to 48
questions contained in 6 separate emails, listed below.

Public Authorities are subject to two duties in respect of Section 1 of
the Freedom of Information Act. The first is to confirm whether or not
the requested information is held (subsection 1 (a)) and the second is to
disclose the information if it is (subsection 1(b)).

Both duties are subject to the exemption contained in Section 12(1) of the
Freedom of Information Act, where the cost of compliance exceeds the
appropriate limit.

In accordance with Section 5 of the Freedom of Information and Data
Protection (Appropriate Limit and Fees) Regulations 2004, your 6 requests
have been aggregated for the purpose of assessing the cost of complying
with Section 1 of the Freedom of Information Act.

In this case, the cost of complying with Subsection 1 (a) of Section 1
does not exceed the £450 limit prescribed by the Secretary of State in
accordance with powers contained in Section 12 of the Freedom of
Information Act. Unless another exemption applies, we have stated, below
each question, whether or not the information is held.

However, we estimate that the cost of complying with Subsection 1 (b) of
Section 1 would exceed the prescribed limit. For example, information
relating to question 17 of COL/11/380 is only contained in the individual
overtime claim form submitted by the officer working the overtime. In
order in retrieve the information, it would be necessary to examine each
record manually to determine if it relates to the criteria contained in
the question. We estimate that we would need to examine in excess of
2,000 overtime records and that it would take at least one minute to
examine each. The cost of completing this work would therefore exceed the
prescribed limit of £450.

The advice of the Information Commissioner's Office is that if one part of
a request exceeds the prescribed limit, then the entire request should be
regarded as over cost. The work has not therefore been done.

Duty to assist applicants

In accordance with Section 16 of the Freedom of Information Act, public
authorities have a duty to assist applicants where the cost of compliance
exceeds the prescribed limit.

We have included advice, where appropriate, below each question. In some
cases, we have also offered additional information where we believe that
it will be of assistance. Such information is offered outside the
provisions of the Freedom of Information Act.

COL/11/380

1. In July and August 2009 DC Colin Dawson went to KROLL offices and
had meetings with Managing Director Ben Hamilton and Aruna De Oliveria
Costa, how many meetings took place?

2. How many Police hours were spent at meetings?

Questions 1 and 2

By virtue of Section 40(5) of the Freedom of Information Act, the City of
London Police can neither confirm nor deny that information relating to
questions 1 and 2 is held.

The duty to confirm or deny does not arise by virtue of section 40(5)
where giving such confirmation or denial would disclose personal data of
which the applicant is not the data subject, in contravention of any of
the Data Protection Act Principles or Section 10 of the Data Protection
Act. Any disclosure made by virtue of the provisions of the Freedom of
Information Act is regarded as a public disclosure and not a disclosure to
an individual. In this case, confirmation or denial that the information
is held would publicly disclose whether or not a named individual was
involved in a criminal investigation. This is likely to be unfair and be
in contravention of the first Data Protection Act principle. This is a
class-based exemption and it is not necessary to demonstrate the potential
for harm to occur. In these circumstances, this is also an absolute
exemption which is not subject to an assessment of the public interest.

3. How much overtime was claimed by DC Colin Dawson throughout
Operation BOHAN?

I confirm that this information is held by the City of London Police.

Additional information

This information is personal data relating to a third party and we believe
that the exemption contained in section 40 of the Freedom of Information
Act - Personal Information, would be engaged, should the question remain
in a refined request.

4. Please provide details of the monitoring and auditing of claims made
for all overtime throughout the duration of Operation BOHAN?

This information is not held by the City of London Police.

Additional information

No special measures relate to the management of overtime in respect of
Operation Bohan.

5. Please provide details of criteria laid down in for claims relating
to overtime together with any guidelines received from the Home Office

I confirm that this information is held by the City of London Police.

Additional information

This information is contained in Police Regulations, and may be viewed via
the following link:

[1]http://www.legislation.gov.uk/uksi/2003/...

6. Please confirm how many meetings took place between Detective Chief
Inspector Chandler, Detective Superintendent Davies and KROLL MD, Ben
Hamilton?

7. Please confirm how many meetings took place between Detective Chief
Inspector Chandler, Detective Superintendent Davies and KROLL Head of
Security, Dan Mead?

Questions 6 and 7

By virtue of Section 40(5) of the Freedom of Information Act, the City of
London Police can neither confirm nor deny that information relating to
questions 6 and 7 is held.

The duty to confirm or deny does not arise by virtue of section 40(5)
where giving such confirmation or denial would disclose personal data of
which the applicant is not the data subject, in contravention any of the
Data Protection Act Principles or Section 10 of the Data Protection Act.
Any disclosure made by virtue of the provisions of the Freedom of
Information Act is regarded as a public disclosure and not a disclosure to
an individual. In this case, confirmation or denial that the information
is held would publicly disclose whether or not a named individual was
involved in a criminal investigation. This is likely to be unfair and be
in contravention of the first Data Protection Act principle. This is a
class-based exemption and it is not necessary to demonstrate the potential
for harm to occur. In these circumstances, this is also an absolute
exemption which is not subject to an assessment of the public interest.

8. How many ex City of London Police Officers now work at KROLL?

This information is not held by City of London Police.

9. Was Dan Mead formally employed by City of London Police, in any
capacity?

I confirm that this information is held by the City of London Police.

Additional information

This information is personal data relating to a third party and we believe
that the exemption contained in section 40 of the Freedom of Information
Act - Personal Information, would be engaged, should the question remain
in a refined request.

10. Please provide a list of all officers employed by City of London
Police who are members of the following organisation - Freemason. If
names cannot be provided, please provide figures of the known number of
Police Officers who are Freemasons.

I confirm that this information is held by the City of London Police.

Additional information

There is no requirement for an officer to disclose this information, but
if he or she does, the information is manually recorded in the officer's
personnel file. Retrieval of the data would require a manual search of
every personnel record and is likely to be over cost should this question
remain in a refined request.

11. How much overtime in total was claimed by officers in 2009?

12. How much overtime in total was claimed by officers in 2010?

13. How much overtime was claimed by officers in the Counter Terrorism
and Major Crimes Directorate in 2009?

14. How much overtime was claimed by officers in the Counter Terrorism
and Major Crimes Directorate in 2010?

15. How many Terrorist investigations were carried out in the period 2009
- 2010?

16. How many NON-Terrorist investigations were carried out in the period
2009 - 2010?

17. How much overtime was claimed by officers from the Counter Terrorism
and Major Crimes Directorate on NON-Terrorist investigations?

Questions 11 to 17

I confirm that this information is held by the City of London Police.

COL/11/381

1. Please list meetings with News International?

2. Please list meetings with KROLL?

3. How many meeting did Commissioner Adrian Leppard have with News
International and KROLL?

Questions 1, 2 and 3

We would need to seek clarification from you in respect of the time scale
and names or groups of individuals to whom you are referring.

4. How many social functions has the Commissioner attended at the
invitation of News International and KROLL?

I confirm that this information is held by the City of London Police.

Additional information

Hospitality received by officers of ACPO rank is recorded in the City of
London Police publication scheme and may be viewed via the following link:

[2]http://www.cityoflondon.police.uk/NR/rdo...

We have no record of the Commissioner having received any hospitality from
News International or Kroll.

5. How much money did City of London Police pay KROLL for the
investigation services?

We would need to seek clarification from you in respect of which
investigation services you are referring to.

6. How much is the City of London Police entertainment budget?

I confirm that this information is held by the City of London Police.

Additional information

The City of London Police does not hold an entertainment budget, but does
hold a hospitality budget, for items such as tea and coffee for visitors.

7. Please provide details of absenteeism from duty from serving Police
officers due to illness, injury at work?

I confirm that this information is held by the City of London Police.

COL/11/382

1. Please could you provide the number of times in 2010 officers from
the Counter Terrorism and Major Crimes Directorate went undercover and
attended Speakers Corner, Hyde Park London and listened to Ian Puddick
speak in public?

2. Please name the officer in charge that authorised DC Julian Bell to
attend Speakers Corner on a Sunday in the capacity of working undercover
to listen to Ian Puddick?

3. How many did DC Julian Bell attend Speakers Corner to listen to Ian
Puddick?

4. Please confirm DC Julian Bell works for City of London Counter
Terrorism and Major Crimes Directorate?

5. On what grounds was such surveillance justified?

Questions 1, 2, 3 and 5

This information is not held by City of London Police.

Additional information

No officer has attended Speaker's Corner `undercover' to listen to Ian
Puddick. The officer to whom you refer was not on duty and did not visit
Speaker's Corner to listen Ian Puddick speak.

Question 4

I confirm that this information is held by the City of London Police.

Additional information

I confirm that Dc Julian Bell works within the City of London Counter
Terrorism and Major Crimes Directorate.

COL/11/383

1. Please could you provide the name of the officer that attended the
offices of KROLL in July 2009?

2. Please provide the name of the officer that interviewed Leena
Puddick at the office of KROLL (& Guy Carpenter Ltd) in 2009?

3. Please identify the rank of the officer that interviewed Leena
Puddick?

4. Please provide the email request for this meeting from KROLL to City
of London Police?

5. Please name the KROLL agent that requested this meeting?

6. Please provide all records relating to this meeting?

7. Was this interview carried out under caution and in accordance with
PACE?

Questions 1 to 7

By virtue of Section 30(3) (questions 1 to 7) and Section 40(5) (questions
2 to 7) of the Freedom of Information Act, the City of London Police can
neither confirm nor deny that this information is held.

Information is exempt by virtue of section 30(1) where it has, at any
time, been held for the purpose of an investigation. The duty to confirm
or deny does not arise in relation to information which is exempt by
virtue of this section. In this case, the information, if held, would
have been obtained for the purpose of a criminal investigation. This is a
class-based exemption and it is not necessary to demonstrate the potential
for harm to occur. It is however a qualified exemption subject to an
assessment of the public interest and the factors favouring confirmation
and non-confirmation that the information is held or not held are listed
below.

Assessment of the public interest

Factors favouring confirmation or denial

The case has attracted some media interest and confirmation or denial
would disclose whether or not the named individual and organisations were
involved in the investigation.

Factors not favouring confirmation or denial

Investigations often require a partnership approach together with the
cooperation and contribution of members of the public and other
organisations. There is an expectation that the detail such
investigations will remain confidential and confirmation or denial that
the information is held would disclose whether or not the named individual
and organisations were involved in the investigation. This would
undermine the partnership approach and confidence in the police service,
compromising the likelihood of cooperation in the future.

Balancing the public interest

We believe that the benefit to the public is limited, when compared to the
potential harm to future investigations and therefore conclude that the
public interest does not favour confirmation or denial in this case.

The duty to confirm or deny does not arise by virtue of section 40(5)
where giving such confirmation or denial would disclose personal data of
which the applicant is not the data subject, in contravention any of the
Data Protection Act Principles or Section 10 of the Data Protection Act.
Any disclosure made by virtue of the provisions of the Freedom of
Information Act is regarded as a public disclosure and not a disclosure to
an individual. In this case, confirmation or denial that the information
is held would publicly disclose whether or not a named individual was
involved in a criminal investigation. This is likely to be unfair and be
in contravention of the first Data Protection Act principle. This is a
class-based exemption and it is not necessary to demonstrate the potential
for harm to occur. In these circumstances, this is also an absolute
exemption which is not subject to an assessment of the public interest.

COL/11/384

1. Please could you provide me with the time that I signed my charge
sheet at Wood Street Police Station Sept 2009?

I confirm that this information is held by the City of London Police.

Additional Information

This information is the personal data of the applicant and we believe that
the exemption contained in section 40 of the Freedom of Information Act -
Personal Information, would be engaged, should the question remain in a
refined request.

However, it is available free of charge as part of the custody record,
outside the provisions of the Freedom of Information Act, subject to the
data subject providing proof of identity and a private address for
correspondence.

2. Please could you provide me with the time that DS John Ellis and DC
Colin Dawson accessed the electronic door entry system to the custody area
and the interview room (DS Craig Mullish has this information)?

We would need to seek clarification from you in respect of the day and
approximate time of the occurrence to which you refer.

3. Please details the criteria of City of London Police concerning
interviewing people WITHOUT caution in relation intelligence gathering
interviews, under what basis have these been approved and provide details
confirming the legality of such interviews.

I confirm that this information is held by the City of London Police.

COL/11/407

1. Please confirm how much money Kroll invoiced City of London Police
for this joint operation [Operations Bohan and Marten]?

2. Please could you provide the name and rank of the officer that
provided Kroll or anyone other private company with my phone location,
also known as 'pinging'?

Questions 1 and 2

This information is not held by the City of London Police.

Additional information

No information or funds have been passed to Kroll in relation to the above
named operations.

3. Please provide details of any and all hospitality offered by Kroll
to any City of London Police?

4. Please provide name and rank of any City of London Police officer
that has accepted hospitality from Kroll?

This information is not held by City of London Police.

Additional information

There is no record of any hospitality having been offered to any City of
London staff member by any Kroll employee.

5. Please provide the number of times DC Colin Dawson met with Kroll
operatives at Kroll London Office?

6. Please provide the number of times DS John Ellis met with Kroll
operatives at Kroll London Office?

7. Please provide the number of times Detective Chief Inspector
Chandler met with Kroll MD Mr Benedict Hamilton at City of London Police
offices between 1 June - 30 August 2009

8. Please provide the number of times Detective Superintendent Davies
met with Kroll MD Mr Benedict Hamilton at City of London Police offices
between 1 June - 30 August 2009

Questions 5 to 8

By virtue of Section 30(3) (questions 5 to 8) and Section 40(5) (questions
7 and 8) of the Freedom of Information Act, the City of London Police can
neither confirm nor deny that this information is held.

Information is exempt by virtue of section 30(1) where it has, at any
time, been held for the purpose of an investigation. The duty to confirm
or deny does not arise in relation to information which is exempt by
virtue of this section. In this case, the information, if held, would
have been obtained for the purpose of a criminal investigation. This is a
class-based exemption and it is not necessary to demonstrate the potential
for harm to occur. It is however a qualified exemption subject to an
assessment of the public interest and the factors favouring confirmation
and non-confirmation that the information is held or not held are listed
below.

Assessment of the public interest

Factors favouring confirmation or denial

The case has attracted some media interest and confirmation or denial
would disclose whether or not the named individual and organisations were
involved in the investigation.

Factors not favouring confirmation or denial

Investigations often require a partnership approach together with the
cooperation and contribution of members of the public and other
organisations. There is an expectation that the detail such
investigations will remain confidential and confirmation or denial that
the information is held would disclose whether or not the named individual
and organisations were involved in the investigation. This would
undermine the partnership approach and confidence in the police service,
compromising the likelihood of cooperation in the future.

Balancing the public interest

We believe that the benefit to the public is limited, when compared to the
potential harm to future investigations and therefore conclude that the
public interest does not favour confirmation or denial in this case.

The duty to confirm or deny does not arise by virtue of section 40(5)
where giving such confirmation or denial would disclose personal data of
which the applicant is not the data subject, in contravention any of the
Data Protection Act Principles or Section 10 of the Data Protection Act.
Any disclosure made by virtue of the provisions of the Freedom of
Information Act is regarded as a public disclosure and not a disclosure to
an individual. In this case, confirmation or denial that the information
is held would publicly disclose whether or not a named individual was
involved in a criminal investigation. This is likely to be unfair and be
in contravention of the first Data Protection Act principle. This is a
class-based exemption and it is not necessary to demonstrate the potential
for harm to occur. In these circumstances, this is also an absolute
exemption which is not subject to an assessment of the public interest.

9. How many officers from city of London Counter Terrorism & Major
Crimes Directorate have left the service for employment at KROLL?

This information is not held by City of London Police.

Please accept my apologies for the delay in replying to your request.
Should you have any further questions, please contact me, quoting one of
the reference numbers above.

Yours sincerely

Inspector Dave Lockyear

Information Access Manager

P Please consider the environment before printing my email

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References

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1. http://www.legislation.gov.uk/uksi/2003/...
2. http://www.cityoflondon.police.uk/NR/rdo...
3. http://www.cityoflondon.police.uk/

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