Operation Kalmia - Recommendations against Chief Constable

Response to this request is long overdue. By law, under all circumstances, Northamptonshire Police and Crime Commissioner should have responded by now (details). You can complain by requesting an internal review.

Dear Northamptonshire Police and Crime Commissioner,

Operation Kalmia was a IPCC managed investigation into Staffordshire Police's investigation into the murder of Kevin Nunes. A number of very senior police officers were investigated as part of the operation including the now retired Chief Constable Adrian Lee.

Following the conclusion of the IPCC fInal report into Operation Kalmia recommended that a number of officers including Adrian Lee should face disciplinary proceedings and the recommendations were passed to the Police and Crime Commissioner (PCC) for Northamptonshire.

Around March 2015, The PCC publically announced that he had reviewed the recommendations contained in the IPCC report and decided that The Chief Constable should not face disciplinary charges. Subsequently the IPCC announced that they would not use their powers to order formal misconduct proceedings against the Chief Constable. As a result of the PCC's decision, the allegations of misconduct contained within the IPCC report were never tested before a properly convened disciplinary panel.

Follow the PCC's decision the Chief Constable isssued the following public statement:-

"Operation Kalmia - Statement from Chief Constable Adrian Lee
By now many of you will have heard the Police and Crime Commissioner’s formal announcement that there is no case to answer in relation to the allegations I faced under Operation Kalmia and the Police and Crime Commissioner as the appropriate Authority, having taken the best legal advice, has concluded that it is clear that there is no case to answer."

Operation Kalmia, attracted a huge amount of public interest following the decision of the appeal court to quash the convictions of five men previously convicted of the murder of Kevin Nunes. The case continues to attract a lot of public interest most recently following the decision by Staffordshire Police to settle a civil action brought by two of the men cleared of murder, paying out £200,000 in compensation.

The IPCC has indicated that the Operatin Kalmia final report is likely to be published later this months, which is likely to result in even more public interest in the case. The decision taken by several Police and Crime Commissioners not to implement the recommendations contained in the report, is of great interest to the general public.

I would like to request the following information:-

1. The names of any independent experts one at provided advice to the PCC regarding the recommended disciplinary action.

2. Copies of the written advice provided by the experts to the PCC.

3. Copies of the written instructions provided to any independent legal expert (QC) by or on behalf of the PCC.

4. The number and nature of disciplinary charges that the final report recommended that Adrian Lee should face.

5. Confirmation whether or not the PCC corresponded with other Police and Crime Commissioners that were required to consider the Operation Kalmia recommendations.

6. Copies of any correspondence (including records of telephone or personal meeting) sent or received between PCCs as at 5 above.

7. Copies of any correspondence between the PCC or his office and the IPCC over his decision not to implement the recommendation, including any correspondence designed to or likely to put pressure on the IPCC not to attempt to enforce the reports recommendations (I.e. Mention of possible legal action against the IPCC).

All of the information requested will be of interest to the public. Adrian Lee was a high profile public figure who made public announcements regarding Operation Kalmia. As a public facing official Adrian Lee cannot reasonably expect that his identity and part in this case should remain hidden, particularly when he airs her views on the case publically.

Independent experts providing advice to a public body, whose services are paid for from public funds must realise and accept that in doing so they expose themselves to being named publically. To maintain public trust a high degree of transparency is required particularly in cases such as this when the integrity or conduct of top police officers are under consideration.

Yours faithfully,

Mr L. Anderson

Commissioner, Northamptonshire Police and Crime Commissioner

Thank you very much for taking the time to contact me. Although I receive
a large number of emails and letters daily, I will endeavour to reply to
your message as soon as possible.

 

If you live in Northamptonshire then please make sure you have sent me
your full postal address including a postcode.

 

To learn more about what I have been up to, please visit
[1]www.northantspcc.org.uk.

 

Please note: protocol dictates that I can only assist constituents of
Northamptonshire with casework related enquiries. I will not sign
petitions, however I will directly raise your concerns with the relevant
authority where appropriate.

 

If you have sent me an invitation to an event, this will be sent to my PA
who will deal with this on my behalf.

 

Stephen Mold

Police and Crime Commissioner

 

 (   Telephone 101 or 03000 111 222 (if out of  county) 

+   Address West Wing, FHQ, Wootton Hall, Northampton, NN4 0JQ

: E-mail [2][email address]

+ Web [3]www.northantspcc.org.uk

 Twitter @northantsopcc 

References

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1. file:///tmp/www.northantspcc.org.uk
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3. http://www.northantspcc.org.uk/

Commissioner, Northamptonshire Police and Crime Commissioner

1 Attachment

Ref No: 04092017-1

 

Dear Mr Anderson

 

Thank you for your email of 04 August 2017 requesting information about
Operation Kalmia.

 

Your request is being dealt with under the terms of the Freedom of
Information Act 2000 and will be answered within twenty working days. 

 

If you have any queries about this request do not hesitate to contact me.
Please remember to quote the reference number above in any future
communications.

 

 

Yours sincerely,

 

Emily Evans

Governance Assistant

 

( Telephone 101 or 03000 111 222 (if out of county) 

+ Address West Wing, Police HQ, Wootton Hall, Northampton, NN4 0JQ

:   Email [1][email address]

+ Web [2]www.northantspcc.org.uk

+ Twitter @northantsopcc 

 

 

[3]cid:image001.jpg@01D21F1C.0663E100

 

 

Evans Emily, Northamptonshire Police and Crime Commissioner

1 Attachment

Ref No: 04092017-1

 

Dear Mr Anderson

 

 

1. The names of any independent experts one at provided advice to the PCC
regarding the recommended disciplinary action.

 

We are not obliged under section 22 of the FOIA to provide information
that is intended for future publication. In line with the terms of this
exemption, we have considered whether it would be in the public interest
for us to provide you with the information ahead of publication, despite
the exemption being applicable. In this case, I have concluded that the
public interest favours withholding the information.

When assessing whether or not it was in the public interest to disclose
the information to you, we took into account the following factors:

Public interest considerations favouring disclosure

· Disclosure would improve transparency in the operations of the OPCC.

· Disclosure of the information under FOIA would be consistent with the
OPCC’s commitment to proactively publish data on matters of a wider public
interest.

Public interest considerations favouring withholding the information

· As the information is of interest to the wider public it is important it
can be accessed simultaneously by the general public rather than piecemeal
by disclosure to a small number of individuals under the FOIA. In addition
this, the OPCC publishes all FOI responses on its website, which would
make the information available to anyone with access to the internet.
Therefore it is in the wider interest that information is accessible to
the wider public by adhering to the publication schedule.

· The information relates to a number of other police forces and the IPCC,
therefore the early release of information could be prejudicial to a
number of third parties outside of Northamptonshire.

We reached the view that, on balance, the public interest is better served
by withholding this information under section 22 of the FOIA at this time.

You may be interested to know that this information is due to be published
by the IPCC “as soon as possible” and should be available at the following
web address:

[1]https://www.ipcc.gov.uk

 

2. Copies of the written advice provided by the experts to the PCC.

This information we hold relating to your request is exempt as it
constitutes legal advice. We are not obliged to provide information
subject to legal professional privilege (section 42(1) of the Act). 

 

The information has been communicated between lawyers and clients. This
information cannot be disclosed because the confidential relationship
between lawyer and client is protected. This information is therefore
exempt under Section 42 (Legal Professional Privilege).

 

When assessing whether or not it was in the public interest to disclose
the information to you, despite the exemption being applicable, we took
into account the following factors:

 

Public interest considerations favouring disclosure:

There is a general public interest in authorities being accountable for
the quality of their decision-making and ensuring that decisions have been
made on the basis of good quality legal advice is part of that
accountability. Transparency in the decision-making process and access to
the information upon which decisions have been made can enhance this
accountability. It could also be seen that there is a public interest in
some cases in knowing whether or not legal advice has been followed.

 

Public interest considerations favouring withholding the information

 

Section 42 reflects a strong public interest in the Office of the
Northamptonshire Police and Crime Commissioner (OPCC) being able to
communicate freely with its legal advisers to provide and receive advice
in confidence. At various times, the OPCC requires high quality and
comprehensive legal advice for the effective conduct of their business.
That advice needs to be given in context and with a full appreciation of
the facts, which is necessary to be sought and given in a timely fashion
to ensure policy develops in a fully informed way. The legal adviser needs
to be able to present the full picture to the OPCC which not only includes
arguments in support of their final conclusions, but also the arguments
that may be made against them. It is in the nature of legal advice that
often sets out the possible “for and against” arguments a particular view
of weighing up their relative merits. Without such comprehensive advice
the quality of the OPCC’s policy and decision-making would be much reduced
for the following reasons: 

 

• It would not be fully informed and this would be contrary to the public
interest; 

 

• There is a risk that should legal advice (provided internally) be
disclosed, it could mean lawyers and OPCC staff may avoid making a
permanent record of the advice given and/or only make a partial record of
the advice provided in future policy/decision-making processes.

• To disclose information provided in a legal capacity to a third party
could breach the confidentiality status of privileged communications. The
OPCC regards the notion of legal privilege as absolute and this greatly
outweighs the argument for releasing such information.

 

We have reached the view that, on balance, the public interest is better
served by withholding this information under Section 42 of the Act at this
time.

 

3. Copies of the written instructions provided to any independent legal
expert (QC) by or on behalf of the PCC.

 

Please refer to the answer to question number 2

 

 

4. The number and nature of disciplinary charges that the final report
recommended that Adrian Lee should face.

 

Please refer to the answer to question number 2

 

5. Confirmation whether or not the PCC corresponded with other Police and
Crime Commissioners that were required to consider the Operation Kalmia
recommendations.

 

The Office of the Northamptonshire Police and Crime Commissioner may hold
the information on the subject you have requested. However, I have to
advise you that we will not be able to answer your request without
exceeding the appropriate limit. This is because both the former Police
and Crime Commissioner and the OPCC Chief Executive are no longer in post
and all materials relating to Operation Kalmia were heavily restricted.

Section 12 of the Freedom of Information Act 2000 allows a public
authority to refuse a request if the cost of providing the information to
the applicant would exceed the ‘appropriate limit’ as defined by the
Freedom of Information and Data Protection (Appropriate Limit and Fees)
Regulations 2004:

“12 Exemption where cost of compliance exceeds appropriate limit

(1) Section 1(1) does not oblige a public authority to comply with a
request for information if the authority estimates that the cost of
complying with the request would exceed the appropriate limit”.

The regulations provide that the appropriate limit to be applied to
requests received by local authorities is £450 (equivalent to 2.5 days of
work).  In estimating the cost of complying with a request for
information, an authority can only take into account any reasonable costs
incurred in:

(a)    determining whether it holds the information,

(b)    locating the information, or a document which may contain the
information,

(c)     retrieving the information, or a document which may contain the
information, and

(d)    extracting the information from a document containing it”.

For the purposes of the estimate the costs of performing these activities
should be estimated at a rate of £25 per hour.

The information that you have requested is not held in an easily
accessible format by the OPCC.  We believe that it would take a
considerable amount of time to extract and collate the information
requested.  We would need to examine email archives, search through a
large paper archive and ask a senior members of staff to check their
records to determine whether they may hold any information falling within
the scope of your request.

I have estimated that it would take around 28 hours to complete a search
of the OPCC’s archive as we currently have six large four draw filing
cabinet containing around 24 box files and nearly 40 archive boxes of
correspondence. Given the OPCC has recently moved offices, the archive is
currently being reorganised which further complicates any search.

Taking into account the likely costs of searching the records, we believe
that the cost of complying with your request would far exceed the
appropriate limit as set out by the Freedom of Information Act.

As a result, we are refusing your request under section 12 of the Freedom
of Information Act 2000. 

If you would like to discuss ways of narrowing your request to bring it
within the cost threshold, please don’t hesitate to contact me.

You have the right to request an internal review of our decision to apply
this exemption; details of how to do this are provided in the letter that
accompanies this refusal notice.

 

6. Copies of any correspondence (including records of telephone or
personal meeting) sent or received between PCCs as at 5 above.

Please refer to the answer to question number 5

 

7. Copies of any correspondence between the PCC or his office and the IPCC
over his decision not to implement the recommendation, including any
correspondence designed to or likely to put pressure on the IPCC not to
attempt to enforce the reports recommendations (I.e. Mention of possible
legal action against the IPCC).

Please refer to the answer to question number 5

 

If you are dissatisfied with the handling of your request, you have the
right to ask for an internal review. Internal review requests should be
submitted within two months of the date of receipt of the response to your
original letter and should be addressed to: Martin Scoble, Chief
Executive, Office of the Northamptonshire Police and Crime Commissioner,
West Wing, Force Headquarters, Wootton Hall, Northampton, NN4 0JQ

Please remember to quote the reference number above in any future
communications.

If you are not content with the outcome of the internal review, you have
the right to apply directly to the Information Commissioner for a
decision. The Information Commissioner can be contacted at: Information
Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9
5AF.

 

Kind Regards,

 

 

 

Emily Evans

Governance Assistant

 

( Telephone 101 or 03000 111 222 (if out of county) 

+ Address East House, Police HQ, Wootton Hall, Northampton, NN4 0JQ

:   Email [2][email address]

+ Web [3]www.northantspcc.org.uk

+ Twitter @northantsopcc 

 

 

[4]cid:image001.jpg@01D21F1C.0663E100

 

 

 

 

 

From: Evans Emily On Behalf Of Commissioner
Sent: 05 September 2017 10:19
To: 'Mr L. Anderson' <[FOI #429081 email]>
Subject: RE: Freedom of Information request - Operation Kalmia -
Recommendations against Chief Constable - FOI 04092017-1

 

Ref No: 04092017-1

 

Dear Mr Anderson

 

Thank you for your email of 04 August 2017 requesting information about
Operation Kalmia.

 

Your request is being dealt with under the terms of the Freedom of
Information Act 2000 and will be answered within twenty working days. 

 

If you have any queries about this request do not hesitate to contact me.
Please remember to quote the reference number above in any future
communications.

 

 

Yours sincerely,

 

Emily Evans

Governance Assistant

 

( Telephone 101 or 03000 111 222 (if out of county) 

+ Address West Wing, Police HQ, Wootton Hall, Northampton, NN4 0JQ

:   Email [5][email address]

+ Web [6]www.northantspcc.org.uk

+ Twitter @northantsopcc 

 

 

[7]cid:image001.jpg@01D21F1C.0663E100

 

 

Dear Evans Emily,

Thank you for your recent correspondence concerning my FIO request. Whilst I disagree with the application of certain exemptions under the Act, I will delay a request for a formal internal review until after I have read the long awaited IPCC final report which I understand should be released on Wednesday 4th October 2017.

I note your view that my request for information will exceed the cost limit set under the FIO Act, and your offer to consider how to bring it under the cost limit. I would be grateful for any suggestions you can make to streamline the request to reduce the work required and bring it under the cost limit.

I believe that emails can usually be electronically searched therefore minimising the time required, and similarly in large organisations letters are used stored electronically with an indexing system to allow correspondence to be found quickly, I'm sure that a professional organisation such as your would have such a system. If it assists I would be prepared to amend my request to emails and letters between The PCC and IPCC in relation to the Operation Kalmia report and recommendations for misconduct against retired Chief Constable Adrian Lee.

Yours sincerely,

Mr L. Anderson

Commissioner, Northamptonshire Police and Crime Commissioner

1 Attachment

Ref: 02102017-1

 

Dear Mr Anderson

 

Further to your email dated 2^nd October 2017 relating to your amended
request for emails and letters between The PCC  and IPCC in relation to
the Operation Kalmia report and recommendations for misconduct against
retired Chief Constable Adrian Lee is being dealt with under the terms of
the Freedom of  Information Act 2000 and will be answered within twenty
working days (30^th October 2017).

 

Please remember to quote the reference number above in any future 
communications.

 

 

Yours sincerely,

 

Emily Evans

 

 

 

Emily Evans

Governance Assistant

 

( Telephone 101 or 03000 111 222 (if out of county) 

+ Address East House, Police HQ, Wootton Hall, Northampton, NN4 0JQ

:   Email [1][email address]

+ Web [2]www.northantspcc.org.uk

+ Twitter @northantsopcc 

 

 

[3]cid:image001.jpg@01D21F1C.0663E100

 

 

 

 

 

Dear Commissioner,

Thank you for your correspondence dated 2nd October 2017. I delayed my response to allow me to read the long awaited Operation Kalmia IPCC Final Report which was finally released albeit in a heavily redacted form on the 4th October 2017. (https://www.ipcc.gov.uk/cy/node/23041). I note that the release by the IPCC does not include any of the information that I requested under the provisions of the FIO Act from the PCC for Northamptonshire.

In response to the position taken by the PCC in respect of the various request I made, I have outlined my views and objections below.

1. The names of any independent experts one at provided advice to the PCC
regarding the recommended disciplinary action.

The PCC has refused this information under Section 22 of the Act - Future Publication.

The ICO state in the guideance :-

" Future publication
5. For the exemption in section 22 to apply, the public authority must, at the time of the request, hold the information and intend that it or ‘any other person’ will publish it in future. This means that it must have a settled expectation that the information will be published at some future date."

Could the PCC please state when and by whom this information will be published.

2. Copies of the written advice provided by the experts to the PCC.
3. Copies of the written instructions provided to any independent legal
expert (QC) by or on behalf of the PCC.
4. The number and nature of disciplinary charges that the final report
recommended that Adrian Lee should face.

The PCC has refused this information under section 42(1) of the Act - Legal Professional Privilege.

For this exemption to relied upon the ICO guidance states:

"In the Bellamy decision, the Tribunal acknowledged that there are two types of privilege within the concept of LPP:
 litigation privilege; and, 
advice privilege "

In this case the PCC was seeking advice regarding his/her duties as an Appropriate Officer in respect of the recommendations of the IPCC in respect of the Adrian Lee the Chief Constable at the time. Such advice was not in respect of litigation against the PCC and therefore the first strand does not apply. In respect of the second strand, the PCC was not taking advice in anticipation of any action against him/her or the office of the PCC, the ICO guidelines go on to state:

"Advice from a lawyer about financial matters or on an operational or strategic issue is unlikely to be privileged, unless it also covers legal concerns, such as advice on legal remedies to a problem."

In my opinion this advice related to the operational or strategic issue of whether to discipline the Chief Constable and the impact that would have on the reputation and management of Northamptonshire Police. The issue of legal advice obtained by Mr Lee would of course be legal privilege material.

In considering the public interest issue when contemplating using the exemption of legal privilege, the PCC states

" There is a risk that should legal advice (provided internally) be
disclosed, it could mean lawyers and OPCC staff may avoid making a
permanent record of the advice given and/or only make a partial record of
the advice provided in future policy/decision-making processes.

• To disclose information provided in a legal capacity to a third party
could breach the confidentiality status of privileged communications. The
OPCC regards the notion of legal privilege as absolute and this greatly
outweighs the argument for releasing such information.

These two paragraphs are very concerning for these reasons:-

The first statement suggests that disclosure of advice could result in staff deliberately not recording advice to prevent its future disclosure. Withholding material to avoid staff having to break the rules on what they subsequently record cannot be considered ethical or professional, if the PCC feel this is a possibility he/she should ensure staff are properly trained and effectively monitored so that advice is appropriately recorded.

The second statement states that the OPCC regards the notion of legal privilege as absolute. This is a bold statement but fails to take into account that OPCC is not responsible for deciding the whether legal privilege is absolute, this is the responsibility of the lawmakers and the courts.

The public have the right to know whether public officials such as the PCC are properly carrying out the duties of the Public Office they hold. Mr Simmonds the PCC responsible for taking the decision in respect of the IPCC recommendations made a number of public comments on the matter indicating he had based his decision on legal advice, therefore the public have a right to see the advice provided, particularly if it did not entirely support the decision he then took. (see https://www.northantspcc.org.uk/press-re...)

In respect of request number 4 (The number and nature of disciplinary charges that the final report
recommended that Adrian Lee should face), I fail to see how this information can be considered to be legal privilege, as it relates to recommendations from a statutory body with a duty investigate allegations of police misconduct and to make recommendations.

I strongly feel that the application of Section 42(1) in this case is unjustified and does not support the openness and transparency that the OPCC should deliver. Recent and past media cover show that this matter is of great public interest across the United Kingdom.

5. Confirmation whether or not the PCC corresponded with other Police and
Crime Commissioners that were required to consider the Operation Kalmia
recommendations.
6. Copies of any correspondence (including records of telephone or
personal meeting) sent or received between PCCs as at 5 above.
7. Copies of any correspondence between the PCC or his office and the IPCC
over his decision not to implement the recommendation, including any
correspondence designed to or likely to put pressure on the IPCC not to
attempt to enforce the reports recommendations (I.e. Mention of possible
legal action against the IPCC).

The OPCC has responded to this three points by suggesting that the work required would exceed the cost threshold of £450:-

"I have estimated that it would take around 28 hours to complete a search
of the OPCC’s archive as we currently have six large four draw filing
cabinet containing around 24 box files and nearly 40 archive boxes of
correspondence. Given the OPCC has recently moved offices, the archive is
currently being reorganised which further complicates any search."

I note the OPCC has indicated a willingness to consider a narrowed request to bring the cost down to within limit and I did write on the 4th October 2017 in this regard. Whilst I await a reply to my correspondence I still find it difficult to believe that in a professionally run office such as the OPCC the filing and index system is not such that all the documentation cannot be found without manually going through each and every archive box and filling cabinet.

Some observers may be concerned as am I that the reliance on Section 12(1) FIO Act - Cost limit, may on occasions be used by public bodies wishing to conceal information that they would otherwise be required to publish, this would of course be in a breach under the Act.

I note that PCC Matthew Ellis who represents Staffordshire OPCC, has in the interests of transparency published his correspondence with the IPCC over the recommendations made in the Operation Kalmia final report. ( https://www.staffordshire-pcc.gov.uk/201... ). The public are entitled to expect a similar level of transparency from the OPCC for Northamptonshire.

I would ask that you now conduct an internal review into the decisions outlined above.

Yours sincerely,

Mr L. Anderson

Commissioner, Northamptonshire Police and Crime Commissioner

2 Attachments

FOI 04092017-1

 

Dear Mr Anderson,

 

Please find attached response to your FOI appeal.

 

Kind Regards

 

 

 

Emily Evans

Governance Assistant

 

( Telephone 101 or 03000 111 222 (if out of county) 

+ Address East House, Police HQ, Wootton Hall, Northampton, NN4 0JQ

:   Email [1][email address]

+ Web [2]www.northantspcc.org.uk

+ Twitter @northantsopcc 

 

 

[3]cid:image001.jpg@01D21F1C.0663E100

 

 

 

 

Commissioner, Northamptonshire Police and Crime Commissioner

3 Attachments

FOI 30102017-1

 

Dear Mr Anderson

 

Please find attached response to your FOI request.

 

Kind regards

 

 

Emily Evans

Governance Assistant

 

( Telephone 101 or 03000 111 222 (if out of county) 

+ Address East House, Police HQ, Wootton Hall, Northampton, NN4 0JQ

:   Email [1][email address]

+ Web [2]www.northantspcc.org.uk

+ Twitter @northantsopcc 

 

 

[3]cid:image001.jpg@01D21F1C.0663E100

 

 

 

 

Dear Commissioner,

Thank you for your correspondence dated 26th October 2017, which included some letters sent between your office and the IPCC. I note that within those documents is a letter jointly signed by Mr Simmonds (PCC Northamptonshire) and Mr Ellis (PCC Staffordshire).

What is unclear from the documents or text of the accompanying letter is just how the two Police Commissioners came to be writing a joint letter. It is clear that some form of dialogue took place between the two commissioners, either in person or by correspondence. Given that obvious fact it would seem that some material has been omitted from the documentation released so far. I request copies of any letters, emails, notes or minutes of meeting between the two commissioners prior to and following the date of the joint letter to the IPCC.

I note the PCC's view regarding request 2 being exempt by virtue of Section 42, however I disagree and will consider an appeal to the ICO on this point in due course. In the interim time however I would like to ask for the name of the QC that provide the advice to the PCC, this information is not subject to legal privilege.

In respect of request no 4, {The number and nature of disciplinary charges that the final report recommended that Adrian Lee should face} this information was not given in the IPCC Final Report therefore I would be grateful if you would deal with this request again.

In respect of request no 5. {Confirmation whether or not the PCC corresponded with other Police and
Crime Commissioners that were required to consider the Operation Kalmia recommendations. }. The information provided to date indicates that there was correspondence between Northamptonshire and Staffordshire, however there is no mention one way or the other in respect of Gloucestershire of West Midlands. Please answer that part of Request no 5.

I note that in the original response there was a suggestion that dealing with some of my requests would exceed the threshold set by the FIO ACT, I would respectfully ask that further consideration be given to that assessment before any appeal is made to the ICO, as an observer it is difficult for me to envisage that the relevant material would not be stored separately to the letters already supplied and therefore the estimate made appears grossly too high. It will of course be a matter for the ICO to investigate and made a determination on should an appeal be necessary.

Yours sincerely,

Mr L. Anderson

Evans Emily, Northamptonshire Police and Crime Commissioner

2 Attachments

Dear Mr Anderson,

 

Please find attached letter in response to your email below.

 

Kind regards,

 

 

 

Emily Evans

Governance Assistant

 

( Telephone 101 or 03000 111 222 (if out of county) 

+ Address East House, Police HQ, Wootton Hall, Northampton, NN4 0JQ

:   Email [1][email address]

+ Web [2]www.northantspcc.org.uk

+ Twitter @northantsopcc 

 

 

[3]cid:image001.jpg@01D21F1C.0663E100

 

 

 

 

 

 

 

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