Modern Slavery incidents

Waiting for an internal review by Lancashire Constabulary of their handling of this request.

Dear Lancashire Constabulary,

As part of ongoing data sharing protocols, incidents stored either on a log or the Force Crime System (FCS) relating to slavery and human trafficking are shared with the Home Office for reporting purposes.

Please provide the number of incident reports logged by your constabulary under the following opening codes between the periods of 1 June 2019 and September 31 2019.

N200/01 - NRM referral pending reasonable grounds decision
N200/02 – NRM referral negative reasonable grounds decision
N200/03 – NRM referral - Duty to notify only
N200/04 – NRM referral – Positive reasonable Grounds/Police Referral – Outside England and Wales
N200/05 – NRM referral – Negative reasonable Grounds – Outside England/Wales
N200/06 –NRM referral – transferred to another force in England and Wales

Please note that logged incidents should not be omitted on the basis of their eventual recording status. This request is for incident reports that fit the above criteria, which may or may not eventually be recorded.

Kind regards,
M Esslemont

FOI, Lancashire Constabulary

If you are emailing a valid Freedom of Information request please treat
this as a formal acknowledgement.

 

Your request will now be considered in accordance with the Freedom of
Information Act 2000, known hereafter as ‘the Act’. You should receive a
response within the statutory timescale of 20 working days as defined in
the Act (from when Lancashire Constabulary receive a valid request).

 

Please note that disclosure is subject to the information not being exempt
or containing a reference to a third party.

 

Some requests may also require either full or partial transference to
another public authority in order to answer your query in the fullest
possible way. Again, you will be informed if this is the case.

 

Lancashire Constabulary is committed to ensuring that all services it
provides are accessible to everyone, including those with disabilities. If
you find the web-site or a document difficult to access please notify us
so that we can assist.

I would like to take this opportunity to thank you for your interest in
Lancashire Constabulary.

 

Regards,

 

Compliance Team

Professional Standards Department

Information Compliance and Disclosure Section

Lancashire Constabulary Headquarters

 

Tel: 01772 413203

Email: [1][email address]

 

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References

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FOI, Lancashire Constabulary

3 Attachments

FREEDOM OF INFORMATION REQUEST REFERENCE NO: 3844/19

Please find attached Lancashire Constabulary’s response to your recent
request for information made under the Freedom of Information Act 2000.

I would like to take this opportunity to thank you for your interest in
Lancashire Constabulary.

Data Protection Office

Lancashire Constabulary Headquarters

Tel: 01772 413203

Email: [1][email address]

 

 

 

Personal Data Matters – Let’s Get it Right!

 

 

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References

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Dear Lancashire Constabulary,

Please pass this on to the team member responsible for conducting Freedom of Information reviews.

I am writing in regards to a recent Freedom of Information request (DPO/FOI/003844/19) that was submitted on 15th October 2019. I requested information under six different opening codes, and you replied that my request had been considered and I could find the information in the "response given" which was the following:
"There have been 12 National Referral Mechanism reports between 1st June 2019 and 30th September 2019."
This is minimal in the extreme and does not satisfy the criteria of a response to the question posed, which stipulated that a figure for all six opening codes should be provided. Please can I have the information for the six opening codes as originally requested?

Thank you in advance for your assistance, which I am sure that you will provide.

A full history of my FOI request and all correspondence is available on the Internet at this address: https://www.whatdotheyknow.com/request/m...

Yours faithfully,
M Esslemont

FOI, Lancashire Constabulary

If you are emailing a valid Freedom of Information request please treat
this as a formal acknowledgement.

 

Your request will now be considered in accordance with the Freedom of
Information Act 2000, known hereafter as ‘the Act’. You should receive a
response within the statutory timescale of 20 working days as defined in
the Act (from when Lancashire Constabulary receive a valid request).

 

Please note that disclosure is subject to the information not being exempt
or containing a reference to a third party.

 

Some requests may also require either full or partial transference to
another public authority in order to answer your query in the fullest
possible way. Again, you will be informed if this is the case.

 

Lancashire Constabulary is committed to ensuring that all services it
provides are accessible to everyone, including those with disabilities. If
you find the web-site or a document difficult to access please notify us
so that we can assist.

I would like to take this opportunity to thank you for your interest in
Lancashire Constabulary.

 

Regards,

 

Compliance Team

Professional Standards Department

Information Compliance and Disclosure Section

Lancashire Constabulary Headquarters

 

Tel: 01772 413203

Email: [1][email address]

 

show quoted sections

 

References

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1. mailto:[email address]

FOI, Lancashire Constabulary

1 Attachment

Dear M Esslemont,

 

Your request for an Internal Review has been booked on under the reference
number 4241/19. You should receive a response from us in due course.

 

Kind Regards,

 

 

Data Protection Office

Lancashire Constabulary Headquarters

Tel: 01772 413329

Email: [1][email address]

 

[2]Description: Description: Description:
cid:image001.jpg@01D4BEC3.E9F38DA0 

 

Personal Data Matters – Let’s Get it Right!

 

 

 

 

show quoted sections

Dear Lancashire Constabulary,

By way of clarification regarding FOI 3844/19, I'd like to also make it clear that this request asks for disagreggated data according to each opening code, rather than a blanket figure.

If you need any further clarification ahead of your internal review decision, please do get in touch.

A full history of my FOI request and all correspondence is available on the Internet at this address: https://www.whatdotheyknow.com/request/m...

Yours faithfully,
M Esslemont

FOI, Lancashire Constabulary

If you are emailing a valid Freedom of Information request please treat
this as a formal acknowledgement.

 

Your request will now be considered in accordance with the Freedom of
Information Act 2000, known hereafter as ‘the Act’. You should receive a
response within the statutory timescale of 20 working days as defined in
the Act (from when Lancashire Constabulary receive a valid request).

 

Please note that disclosure is subject to the information not being exempt
or containing a reference to a third party.

 

Some requests may also require either full or partial transference to
another public authority in order to answer your query in the fullest
possible way. Again, you will be informed if this is the case.

 

Lancashire Constabulary is committed to ensuring that all services it
provides are accessible to everyone, including those with disabilities. If
you find the web-site or a document difficult to access please notify us
so that we can assist.

I would like to take this opportunity to thank you for your interest in
Lancashire Constabulary.

 

Regards,

 

Compliance Team

Professional Standards Department

Information Compliance and Disclosure Section

Lancashire Constabulary Headquarters

 

Tel: 01772 413203

Email: [1][email address]

 

show quoted sections

 

References

Visible links
1. mailto:[email address]

FOI, Lancashire Constabulary

3 Attachments

FREEDOM OF INFORMATION REQUEST REFERENCE NO: 3844/19

Please find attached Lancashire Constabulary’s response to your recent
request for information made under the Freedom of Information Act 2000.

I would like to take this opportunity to thank you for your interest in
Lancashire Constabulary.

Data Protection Office

Lancashire Constabulary Headquarters

Tel: 01772 413203

Email: [1][email address]

 

 

 

Personal Data Matters – Let’s Get it Right!

 

 

show quoted sections

 

References

Visible links
1. mailto:[email address]

Dear FOI,

I wish to request an internal review of case ref 3844/19, in which I ask for the opening codes as they relate to modern slavery referrals for support.

My request for internal review is being made on the basis that a section 40(2) exemption has been incorrectly applied. As the latest correspondence is a response to an internal review, I am also initiating a complaint with the Information Commissioner's Office which I will be happy to rescind upon the provision of the correct information.

You have provided an incomplete response, on the basis that section 40(2) of the FOI Act 2000 asks that personal data should be "processed fairly, lawfully and in a transparent manner", and/ or Section 35(1) of the Data Protection Act 2018; "that processing for any of the law enforcement purposes must be lawful and fair."

You have claimed that due the low figures returned, in relation to these opening codes, anonymity cannot be maintained for individuals referenced. I contest this for the following reasons.

- PRECEDENT -
Opening codes are maintained by forces in order to report into the Home Office as a wider body capable of collating incident reports. Both Q1 statistics on the National Referral Mechanism (NRM) published by the National Crime Agency (NCA) in April this year, and Q2 NRM statistics published by the Home Office as the new Single Competent Authority (SCA) in November this year, outline via datasets the exact number of individuals for whom the following opening codes relate:

N200/01 - NRM referral pending reasonable grounds decision
N200/02 – NRM referral negative reasonable grounds decision
N200/04 – NRM referral – Positive reasonable Grounds/Police Referral – Outside England and Wales
N200/05 – NRM referral – Negative reasonable Grounds – Outside England/Wales
N200/06 –NRM referral – transferred to another force in England and Wales

These reports reference individual referrals between forces as they relate to much smaller sample sizes, and also refer to highly detailed 'sensitive' and 'personal' information such as gender, age, and nationality - all of which I have not requested. For this reason, the threshold of 'identifiable' information requested by myself falls far below that shared with partnership bodies for the purposes of publication.

- ANONYMITY -
Section 40(2) of the FOIR Act 2000 pertains to information which has not been anonymised at the point of collation. The expressed nature of the Modern Slavery 1 (MS1) form, as represented in the remaining opening code (N200/03 – NRM referral - Duty to notify only), is of anonymity at the point of data extraction. For this reason, the one remaining opening code, not already in the public domain in some capacity regardless of sample sizes, is exempt from your exemption due to the nature of data collection at the point of reporting. If Lancashire Constabulary cannot guarantee the anonymity of individuals engaging with the MS1 form, it is in contravention of the stated safeguarding purpose of this mechanism.

I trust that reconsideration of this outcome will yield positive results, at which point all ICO action will be rescinded.

Yours sincerely,
M Esslemont

FOI, Lancashire Constabulary

If you are emailing a valid Freedom of Information request please treat
this as a formal acknowledgement.

 

Your request will now be considered in accordance with the Freedom of
Information Act 2000, known hereafter as ‘the Act’. You should receive a
response within the statutory timescale of 20 working days as defined in
the Act (from when Lancashire Constabulary receive a valid request).

 

Please note that disclosure is subject to the information not being exempt
or containing a reference to a third party.

 

Some requests may also require either full or partial transference to
another public authority in order to answer your query in the fullest
possible way. Again, you will be informed if this is the case.

 

Lancashire Constabulary is committed to ensuring that all services it
provides are accessible to everyone, including those with disabilities. If
you find the web-site or a document difficult to access please notify us
so that we can assist.

I would like to take this opportunity to thank you for your interest in
Lancashire Constabulary.

 

Regards,

 

Compliance Team

Professional Standards Department

Information Compliance and Disclosure Section

Lancashire Constabulary Headquarters

 

Tel: 01772 413203

Email: [1][email address]

 

show quoted sections

 

References

Visible links
1. mailto:[email address]