Dear Greater Manchester Police,

From analysis of materials released recently by the Metropolitan Police Service (MPS) it is clear that in 2015 and/or 2016, the force employed a consultant to facilitate a Transforming PSD project. His name is John Armstrong, a former Cheshire Constabulary superintendent.

Please disclose the following information:

1. The dates upon which the project commenced and concluded.

2. The total amount paid to Mr Armstrong (or his company) for this project.

3. The name of the former Price Waterhouse consultant who assisted Mr Armstrong and the amount paid to either him or his company.

4. The final Transforming PSD report, plus appendices. These should include the Terms of Reference. If they do not, then please disclose separately.

5. All email correspondence between any of DCC (later CC) Ian Hopkins, DCC Ian Pilling, ex-ACC Garry Shewan, ex-C/Supt David Hull, C/Supt Annette Anderson and Mr Armstrong during the period 1st January, 2015 and 31st December, 2016. Plus internal emails between the named GMP officers where either Transforming PSD and/or John Armstrong are searchable terms within those emails.

6. Details of any competitive tendering process engaged in by Mr Armstrong prior to taking up the consultancy.

7. Any data held by GMP that would assist the wider world in their understanding of a rationale that allowed ACC Shewan to appoint a friend, and former Cheshire Constabulary senior colleague, to such a key, and very high profile, project that screamed out for an independent mind.

Yours faithfully,

Neil Wilby
Investigative journalist

Twitter: @Neil_Wilby
Web: neilwilby.com

Greater Manchester Police

1 Attachment

Good afternoon Mr Wilby,

Please find attached FOI request extension letter.

Kind regards,

Samantha Markham
Information Compliance and Records Management Unit
Information Services Branch - Business Operations
Greater Manchester Police

show quoted sections

Dear Greater Manchester Police,

Please pass this on to the person who conducts Freedom of Information reviews.

1. On 15th January, 2015 I made two freedom of information requests that were broadly similar. They both concerned ‘Transforming PSD’ projects managed by the same provider, John Armstrong. One request was made to Greater Manchester Police (obviously) and the other to Cleveland Police (see below weblink).

https://www.whatdotheyknow.com/request/t...

2. One has been finalised correctly, courteously, helpfully. The other, it is respectfully submitted, and for all the reasons forensically set out below, is an embarrassing neglect of duty under the Act.

3. On the 19th working day, in the preceding post on this What Do They Know thread, GMP sought an extension of time in which to finalise an information request that was plainly expressed and sought disclosure of readily accessible materials in a matter of high public interest (in the legal sense rather than interesting to the public). Not least, because there is a strong suspicion that breaches of Standards of Professional Behaviour will be identified within the disclosures.

4. However, that response by GMP breached the Act, ICO Guidance and College of Police Authorised Professional Practice in the following ways:

a. GMP has provided no explanation as to why the response to the request did not comply with section 10 (1) of the Act. This requires a public authority to respond PROMPTLY. Asking for an extension on the 19th working plainly does not meet that test. See also para (l) below.

b. There is no evidence that stages 1 to 4 (Info gathering, NCND, Harm, Exemptions), as set out in APP, have been worked through, in dealing with the instant information request, to arrive at the point where a PIT can be considered. Indeed the paucity of the response, such as it is, forms strong evidence in support of the proposition that those 4 stages have been omitted and the PIT is, in fact, and in my respectful submission, a ruse to frustrate disclosure of materials requested.

c. Section 1(1)(a) of the Act requires a public authority to inform a requester whether it holds the information specified in the request. This is known as 'the duty to confirm or deny'. GMP has absented itself from that requirement.

d. GMP has not stated which exemption(s) it relies upon in order to consider a public interest test (PIT). For a PIT to be considered, the exemption must be qualified. By default, rather than formal expression, it is revealed that GMP do, in fact, hold at least some of the requested information.

e. GMP has not stated to which parts of the request it seeks to apply either an exemption or a PIT, or both. Relying on either the Act, Guidance, APP or common sense, there are parts of the request to which no exemptions could, conceivably, apply

f. GMP is required, therefore, to disclose without further delay such information that does not form part of the purported public interest test.

g. In accordance with APP, the identity of the requester should not be shared with information owners, or third party stakeholders, unless there is a policing purpose in doing so, for example intelligence gathering. It is respectfully submitted that this request has not been treated as ‘applicant blind’.

h. Instead, the standard adversarial approach is adopted against this particular requester, a journalist who has exposed wide-scale wrongdoing within Greater Manchester Police (and a handful of other police forces for that matter). Not least, its persistent and flagrant breach of the Act. ICO Guidance clearly states that the focus should be on whether the information is suitable for disclosure into the public domain, rather than the effects of providing the information to the individual requester.

j. Public confidence in the police is adversely, and seriously, affected if they routinely break the law themselves. Or, provide sub-optimal responses to requests that are visible to other users, and readers, of the What Do They Know website. Regrettably, this is very much the case with Greater Manchester Police.

k. The disclosure that falls out from this request, it is respectfully submitted, given other information that the requester already holds, is more likely than not to reveal other breaches of Standards by at least one senior officer.

l. In the latest edition of Blackstone’s Guide to the Freedom of Information Act 2000, it is argued that if a journalist is writing a story of pressing public importance, the public authority may be required to take account of the time sensitivity of the request in order to meet the ‘promptly’ test. That argument applies in this particular case. Four articles have already appeared on the subject matter related to this request. They have generated widespread comment and an article in The Times newspaper is expected to flow from them.

5. To assist the wider world in their understanding of the workings of GMP, in dealing with requests such as this one, please disclose all internal emails that directly relate to this request and fall in the narrow time window 15th January (the date the request was made) and 11th February, 2019. For convenience, these can be limited to: CC Hopkins, DCC Pilling, A/ACC Annette Anderson, any officer in the information management unit, any officer in the GMP press office, as sender or recipient. That may be done either as part of the resolution of this internal review request, or by way of a new request. Whichever is the most convenient to GMP.

6. As one might expect, this internal review request has been drafted with other consequential proceedings very much in mind. A full history of my FOI request and all correspondence is available on the What Do They Know website at this address: https://www.whatdotheyknow.com/request/t...

Yours faithfully,

Neil Wilby
Investigative journalist

Twitter: @Neil_Wilby
Web: neilwilby.com

Greater Manchester Police

Dear Neil Wilby,

Thank you for your email.

In light of your request for an internal review, I can advise that the extension letter to your FOI request should of confirmed the exemptions that GMP are considering as part of the Public Interest Test (PIT).

Please note that a revised extension letter will be sent to you today confirming the exemptions being considered.

Kind Regards

Caroline

Caroline Barker
Information Compliance Officer

Information Services Branch |Greater Manchester Police
Tel: 0161 856 2532 | Ext: 62532 | Postal address: c/o Openshaw Complex, Lawton Street, Openshaw, Manchester M11 2NS

show quoted sections

Greater Manchester Police

1 Attachment

Good afternoon Mr Wilby,

Please find attached an amended extension letter enclosing the exemptions GMP will be considering as part of your FOI request.

My apologies this was not communicated within the previous letter.

Kind regards,

Samantha Markham
Information Compliance and Records Management Unit
Information Services Branch - Business Operations
Greater Manchester Police

show quoted sections

Dear Greater Manchester Police (GMP),

I refer to the amended extension of time letter attached to your communication of even date.

If the officer dealing with this matter had read the internal review request it would have become immediately apparent what is required in order to satisfy the Act, APP and ICO Guidance.

Accordingly, I make a second internal review request which not only complains about breach of the Act, APP and ICO Guidance in terms identical to the first request (save for the reference to the omission of qualified exemptions), but the fact that this request is being dealt with by an officer who is plainly not conversant with the statutory or regulatory framework.

The consequence of this is the cost of my time, and wear and tear on my health.

GMP are, therefore, urged to have this matter dealt with at an appropriate level - preferably an experienced Information Rights lawyer - and issue a third letter that is fully compliant and deals, precisely, with the points set out in that first internal review request. It could not have been set out more plainly, or been more helpful.

Yours faithfully,

Neil Wilby
Investigative journalist

Twitter: @Neil_Wilby
Web: neilwilby.com

Edward Williams left an annotation ()

Please disclose the following information:

1. The dates upon which the project commenced and concluded.

How can sections 31 or 42 possibly be relevant?

Disgraceful response.

Neil Wilby left an annotation ()

GMP drinking in last chance saloon. Skirting dangerously close to Section 77 referral to Information Commissioner's Office.

Greater Manchester Police

Dear Neil Wilby,

Thank you for your email and your kind words.

Sorry to hear that you are dissatisfied with how GMP have handled your request including your internal request.

The below email will now be forwarded to the Unit's Manager attention for an appropriate internal review. As you seem very knowledgeable of the FOI legalisation you will be aware that there is no statutory time frame for carrying out internal reviews, but we will aim to provide you with a full response within 20 working days. However, please note that the unit is extremely busy at the moment and it may now be possible to provide you with a response within 20 working days.

Kind regards
Caroline

Caroline Barker
Information Compliance Officer

Information Services Branch |Greater Manchester Police
Tel: 0161 856 2532 | Ext: 62532 | Postal address: c/o Openshaw Complex, Lawton Street, Openshaw, Manchester M11 2NS

show quoted sections

Dear Greater Manchester Police,

Thank you for the prompt response to my communication of 13th instant. The tone and content of your observations are noted. It may be necessary to return to those at a later date.

As a journalist, a working knowledge of both freedom of information and data protection law is essential to the pursuit of that vocation.

As an investigative journalist, widely noted for enquiries into police misconduct, a working knowledge of the Police Act, 1996, is also essential. At Section 39A (see below) the College of Policing's Code of Ethics (the Code) is embodied within the Act.

https://www.legislation.gov.uk/ukpga/199...

The College of Police also issues Authorised Professional Practice (APP) to all police forces concerning the handling and finalisation of freedom of information requests.

The relationship between the Code and APP is that failure to follow the latter is a prima facie breach of the former. A serious matter on any independent view.

At section 2.7.1 of APP (see below weblink) there is explicit reference to the timescales to be applied to internal review requests. ".....a response MUST (emphasis added) be provided WITHIN (emphasis added) 20 working days.

https://www.app.college.police.uk/app-co...

It couldn't, in all truth, be set out more plainly. The rather blithe assertion, by GMP, in the communication of even date, that there is no fixed timescale (by reference to section 45 of the Act) is, accordingly, concerning. The Code of Practice embodied within that section recommends 20 working days as a limit, as does the Guidance issued by the Information Commissioner's Office. The latter (see below weblink) at para 84 also sets out the timescales for dealing with internal review requests. GMP has not pleaded 'exceptional circumstances' that might warrant a deviation from the prescribed 20 working day limit.

https://ico.org.uk/media/1624144/section...

At para 78, the Guidance makes reference to the requirement for public authorities (which includes police forces) to set out timescales for dealing with complaints as part of its publication scheme. Such information cannot be located, at the present time, on the GMP website.

An independent reviewer - and this request now appears to be almost certain to be escalated in one form or another - would be shocked to learn that the country's largest police force operates an information rights unit within which no-one is seized of a sufficiency of knowledge of either the Act, Code or APP (or all three). Or has a publication scheme that is apparently deficient in key areas.

The same independent reviewer may also be dismayed to learn that of the three previous information requests made to GMP by this applicant, none were compliant with the Act, at any stage of the process. The shortest period for the finalisation of the inevitable internal review requests that followed was 81 days. One made on 7th November, 2018 remains ignored up to the present day (see below weblink). That is one of a number of factors that are strongly indicative of a systemic, and adversarial, approach to information requests from this investigative journalist.

https://www.whatdotheyknow.com/request/a...

The above request spawned an article that has been very widely shared and the alleged irregularities set out out within it, have been the cause of very significant concerns to be aired publicly over the appointment of a very senior GMP officer. The disclosure that is still being withheld by GMP may well add to those concerns. There can be no other feasible explanation for a large, well-resourced police force, serving an important metropolitan region, flagrantly and deliberately breaching the Act, Guidance, APP and the Code to obstruct access to information that, in my respectful submission and on the facts of the case, properly falls for disclosure under the Act.

https://neilwilby.com/2018/11/17/when-th...

If this note appears long-winded, there are three principal purposes behind it:

Firstly, and most crucially, is the contemplation of a referral to the Information Commissioner's Office by way of Section 77 of the Act. Grounded in the premise that GMP are wilfully preventing disclosure, to delay the likely revelation of breaches of Standards of Professional Behaviour, Code of Ethics by senior GMP officers, using false premises to do so. One very clear indicator is GMP's otherwise inexplicable approach to question 1. Another is the approach to other requests made by this applicant. It is perfectly reasonable to assume that the instant request is headed the same way as those preceding it, and the motives of GMP are the same.

Secondly, this request (and those requests connected to it) is to be storified in a news article. It is, from a journalist's standpoint, a quite astonishing tale of alleged police incompetence, misdemeanour and a troubling, and almost complete, abdication of statutory responsibilities by a law enforcement agency. The article will, by extension, explore the adverse, and very serious, impact on public confidence in the wider police service.

Thirdly, it will inform and support the complaint made to the Information Commissioner over what I respectfully submit is a seriously sub-optimal finalisation of the information request and subsequent internal review request found at the below weblink:

https://www.whatdotheyknow.com/request/m...

GMP are, therefore and most respectfully, urged very strongly to address this request with the urgency it now plainly warrants. For emphasis, it is repeated that the request is plainly expressed, the subject materials readily retrievable, and there are, in my respectful submission and highly informed view, no exemptions that could be sensibly applied to prevent disclosure. That, most particularly, applies to question 1.

The suggestion, first made yesterday, that this matter is escalated to an information rights lawyer with a knowledge of the applicable statutory framework, is respectfully repeated here

Yours faithfully,

Neil Wilby
Investigative journalist

Twitter: @Neil_Wilby
Web: neilwilby.com

Greater Manchester Police

Good morning Mr Wilby,

To confirm in respect of your three points:

1) GSA 161/19 is still under consideration by the caseworker, so there isn’t at present a response for GMP to review. The caseworker issued to you a public interest test extension. After this period, if you require a review, the request will be considered.

2) GSA 2435/18 - https://www.whatdotheyknow.com/request/a... - I apologise in the delay in response to this request for review. I have asked that the caseworker Khalid Mahmood provide you with an update.

3) Thank you for notification that you have made a referral to the ICO. We will await further.

Ben Goddard
Acting Information Compliance and Records Management Unit Manager

Information Management | Information Services Branch | Greater Manchester Police
External: 0161 856 2529  | Direct: 0161 856 2512 | Openshaw Complex, Lawton Street, Openshaw, Manchester, M11 2NS

Not available on Wednesdays

Follow us on Twitter: @gmpolice

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The Data Protection Act 2018 is here. Personal Data Matters – Let’s get it right.
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show quoted sections

Dear Greater Manchester Police (GMP),

The plain fact is, on any independent view, that both of the extension notices you have provided within this What Do They Know thread are invalid. For the reasons I very carefully, and thoroughly, rehearsed in my communication to GMP yesterday (14th Feb).

If GMP's position is that they are not going to finalise the properly raised internal reviews, then I will exercise my right to refer the matter to the Informaion Commissioner without any further delay.

In the meantime I ask again - for the third time - that this request is referred to an experienced information rights lawyer who is prepared to carefully read what I have set out in the two internal review requests, understand both what is written and what is in issue, and then carefully provide an appropriate, lawful response.

Yours faithfully,

Neil Wilby
Investigative journalist

Twitter: @Neil_Wilby
Web: neilwilby.com

Greater Manchester Police

2 Attachments

Good afternoon Mr Wilby,

Please find attached GMP's response to your FOI request.

Please note - I need to send the documents you have requested in separate emails due to their size and my inbox capacity.

Kind regards,

Samantha Markham
Information Compliance and Records Management Unit
Information Services Branch - Business Operations
Greater Manchester Police

show quoted sections

Greater Manchester Police

1 Attachment

Please find attached documents.

Kind regards,

Samantha Markham
Information Compliance and Records Management Unit
Information Services Branch - Business Operations
Greater Manchester Police

show quoted sections

Greater Manchester Police

2 Attachments

Please find attached documents.

Kind regards,

Samantha Markham
Information Compliance and Records Management Unit
Information Services Branch - Business Operations
Greater Manchester Police

show quoted sections

Greater Manchester Police

1 Attachment

Please find attached final document.

Kind regards,

Samantha Markham
Information Compliance and Records Management Unit
Information Services Branch - Business Operations
Greater Manchester Police

show quoted sections

Greater Manchester Police

Dear My Wilby,

Your request for review of the handling of your request for information
pertaining to the appointment of ACC Mabs received by GMP on 9th September
2018 has been brought to my attention.

This email serves to inform of an ongoing review of the handling of your
request for information under the Freedom of information Act 2000.

Unfortunately owed to a number of factors the review has not concluded,
significant work has been undertaken however your concerns have not been
addressed in their entirety. I am currently assessing information
retrieved and endeavour to provide a response on Monday 1^st March. 

Apologies for any inconvenience this may cause or has caused over the
lapse in time, I can assure you that the Compliance function in
collaboration with departmental and/or operational Officer support process
over 4000 requests annually, and such lapses are a rarity.

I’d like to also take this opportunity to thank you for your patience thus
far.

Best wishes, Khalid

 

Yours sincerely

Khalid Mahmood
Information Compliance & Records Management Officer
Information Services Branch - Information Management
Greater Manchester Police

 

Postal Address: c/o Openshaw Complex, Lawton Street, Openshaw, Manchester,
M11 2NS

 

Tel: 0161 856 9924 

Ext: 69924 

[mobile number]        

Follow us on Twitter: @gmpolice

--------------------------------------------------------

The contents of this e-mail should be treated as OFFICIAL unless otherwise
indicated.

--------------------------------------------------------

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Manchester Police for a less urgent matter call 101.
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Greater Manchester Police

Dear Mr Wilby,

Further to my email of Fri 29^th March, initially I would like to take
this opportunity to apologise for the delayed responses that have resulted
in you raising grievances and for the failure of the initial response
dated 6^th November 2018 to satisfy your requirements. A review of a
request for information involves tracing steps taken in the processing of
a request and the application of any exemptions to ensure a fair balance
between the public interest for transparency without prejudice to law
enforcement.

Request for reviews of the handling of requests exercising rights granted
under part 1 of the Freedom of Information Act 2000(FOIA), are viewed as
an opportunity to ameliorate discrepancies and any related dissatisfaction
and I hope this email will address some of your points. Your request for
review presents the following numbered 1 to 6 with 1 and 2 stroked through
for receiving prior resolution;

1. An explanation is still required for the breaches of sections 10 and 17
of the Act. That should include disclosure of any lessons learned data
accruing from the instant request.

2. No response has been provided to Question 8 in the information request
and no disclosure made. Please remedy this defect as a matter of urgency.
It appears that the disclosure officer has confused the answer to Question
8 with Question 7(b).

3. It would be readily apparent to any independent reviewer that not all
disclosure of the emails has been made. There are glaring deficiencies.
Some by plain, and obvious, inference. Others within my certain knowledge.
That may be down to oversight, but that would be a generous
characterisation given the already vexed history of ACC Hussain's
appointment, just over one month ago.

4. The officer carrying out the review is, accordingly, invited to concern
themselves, particularly, with the type of searches that were made, and by
whom. That same officer should be independent of the influence of those
very senior officers whose emails form part of the instant  information
request , particularly DCC Pilling.

5. To assist with the first principles of the Act, and the chief
constable's very public and repeated commitments to transparency, the
internal reviewer is invited to disclose all internal GMP correspondence,
notebook, or day book (paper or electronic) entries of those officers
concerned with the finalisation of this request and those who were subject
of it. From the date the request was made (9th September, 2018) until the
date it was finalised (6th November, 2018). If this matter progresses from
the complaint already lodged with the Information Commissioner, such
disclosure would, doubtless, assist her investigation.

6. Notwithstanding the issues raised in the preceding paragraphs, please
note my appreciation and thanks for the disclosure made, so far. This
assistance, when police resources are particularly precious, gives visible
support to the vocation of journalist and "social watchdog" - and helps
maintain public confidence in the police service.

7. a request for information made on 29^th August 2018 has been ignored
completely.

You request for this review be undertaken by an Officer “independent of
the influence of those very senior officers whose emails form part of the
instant information request, particularly DCC Pilling”. Relative to your
aforementioned request, and akin to most organisations, GMP is a
structured entity with the responsibilities of the Chief Constable
delegated to staff and officers throughout the organisational hierarchy,
therefore your request 4 for independence of the internal structure would
only be possible by use of an external organisation, unfortunately this
option is not available to and I believe is not a mandatory requirement
nor a Right under the legislation in question to which your request
pertains. Having said that, a review is being undertaken independently of
the original case worker without interference from senior leadership.

On receipt of your request citing the FOIA, processing undertaken prior to
a response to you followed a structured process involving the collation of
information requested by a central point in the compliance function via
delegates of the GMP senior leadership team which was initially partly
provided within the statutory period for response with additional
information provided at a later date following clarification, followed by
its assessment and disclosure to you. Granted this process encountered an
extended period of processing for which I believe an apology has been
provided in writing to you on 7^th November 2018 with an explanation
concerning part of the extended period in question.

In 3 above, you speculate that not all information has been disclosed to
you in particular making reference to emails in relation to which you
claim either by inferring or from acquaintance with information pertaining
to deficiencies in the information disclosed therein or I assume in the
number of emails disclosed to you about the appointment in question. For
clarity and in setting expectations, currently it is not GMP policy for
retention of all correspondences, therefore it is entirely possible that
not all correspondences were deemed necessary for retention and may
therefore have been disposed of. On 06 November 2018 emails held by GMP in
relation to your request were disclosed to you, on review of the material
disclosed I have assessed the use of exemptions from Section 31 and 40 of
the FOIA and owed to careful redactions, it is evident that obvious
personal data that identifies a third party has been withheld from
disclosure demonstrating that exemptions have been utilised appropriately.
As part of this review. some exceptions in the applications have been
noted and subsequently overridden, the information identified as not being
exempt from duties under Section 1b of the FOIA relates to guidance for
vetting levels should this be of interest to you, please inform me in
response to this email and arrangements will be made for its disclosure to
you. I would be much obliged if you would assist by affording the review
process with indications of such claimed informed deficiencies in 3 above.
Should the claimed deficiencies refer to information withheld owed to
mitigation by means of exemptions I believe adequate clarity of such has
been provided to you in compliance with Section 2 of the FOIA. As an
extension to this review I have requested further/repeat searches to
ensure your request has been sufficiently honoured, however should you
have insight that may assist with searches, please do not hesitate to
inform searches as you deem appropriate. 

In 5 noted above, you make an additional request for ‘all internal GMP
correspondence, notebook, or day book (paper or electronic) entries of
those officers concerned with the finalisation of this request and those
who were subject of it. From the date the request was made (9th September,
2018) until the date it was finalised (6th November, 2018)’, which I
assume relates to the staff involved in the processing of your request for
information from the Information compliance function in GMP?, upon
clarification, I will ensure that appropriate searches are undertaken to
acquire the necessary information for disclosure, however owed to its
administrative burden I would welcome your reasoning for this additional
request.

Thank you for your acknowledgment of the strains on Police resources,
unfortunately the compliance function has faced significant constraints,
and owed to the nature of the work predominantly governed by statute, its
prioritisation is risk based; consequently cases presenting monetary or
judicial implications or high risk to GMP information Assets are afforded
the utmost priority.  Additional to the aforementioned, of late I have had
a number of unforeseen days away from the office appended by further
planned time away from the office resulting in a single working day per
week during March.

I will be requesting information pertaining to your request on 29^th
August to be forwarded to me for inclusion. I acknowledge that this email
may not be to your entire satisfaction, however I hope the above affords
some assurance that work is underway in ensuring a fair and balanced
outcome to your request for review and that you will accept apologies
offered for any inconvenience delays may cause or have caused over the
lapse in time since your request and progress thus far.

I’d like to also take this opportunity to thank you for your patience thus
far, I endeavour to append to the above in due course. Should you have
interim enquiries, please do not hesitate to contact me via the details
below.

Best wishes, Khalid

 

 

From: Khalid Mahmood
Sent: 29 March 2019 21:30
To: 'Neil Wilby ([FOI #545264 email])'
Subject: Internal review of Freedom of Information request - Transforming
PSD project - GSA 0161/19

 

Dear My Wilby,

Your request for review of the handling of your request for information
pertaining to the appointment of ACC Mabs received by GMP on 9th September
2018 has been brought to my attention.

This email serves to inform of an ongoing review of the handling of your
request for information under the Freedom of information Act 2000.

Unfortunately owed to a number of factors the review has not concluded,
significant work has been undertaken however your concerns have not been
addressed in their entirety. I am currently assessing information
retrieved and endeavour to provide a response on Monday 1^st March. 

Apologies for any inconvenience this may cause or has caused over the
lapse in time, I can assure you that the Compliance function in
collaboration with departmental and/or operational Officer support process
over 4000 requests annually, and such lapses are a rarity.

I’d like to also take this opportunity to thank you for your patience thus
far.

Best wishes, Khalid

 

Yours sincerely

Khalid Mahmood
Information Compliance & Records Management Officer
Information Services Branch - Information Management
Greater Manchester Police

 

Postal Address: c/o Openshaw Complex, Lawton Street, Openshaw, Manchester,
M11 2NS

 

Tel: 0161 856 9924 

Ext: 69924 

[mobile number]        

Follow us on Twitter: @gmpolice

--------------------------------------------------------

The contents of this e-mail should be treated as OFFICIAL unless otherwise
indicated.

--------------------------------------------------------

-I am not in the office on Thursdays and Fridays-

 

 

To contact the police in an emergency call 999 or to contact Greater
Manchester Police for a less urgent matter call 101.
For the latest news and information about your Neighbourhood Policing Team
visit www.gmp.police.uk. You can also follow us on Twitter:
www.twitter.com/gmpolice or find us on Facebook:
www.facebook.com/GtrManchesterPolice , Flickr: www.flickr.com/gmpolice1 or
YouTube: www.youtube.com/gmpolice

You can find your local policing team on social media at
www.gmp.police.uk/socialmedia.
Download our smartphone app from the App Store or Google Play
www.gmp.police.uk/apps

This e mail carries a disclaimer, a copy of which may be read at:
   
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Greater Manchester Police

Dear Mr Wilby,

In response to your presumption of omissions from emails disclosed to you
further searches were conducted to determine any omitted emails. I have
been informed that all emails concerning the appointment were disclosed to
you, I appreciate that this may not be to your satisfaction, however
maintain that should you present additional information to support your
request, accounting for such information further searches can be
performed.

I take this opportunity to thank you for your patience in anticipation of
a response to your request dated 29^th August.

Regards, Khalid

 

 

 

From: Khalid Mahmood
Sent: 02 April 2019 19:28
To: 'Neil Wilby ([FOI #545264 email])'
Subject: RE: Internal review of Freedom of Information request -
Transforming PSD project - GSA 0161/19

 

Dear Mr Wilby,

Further to my email of Fri 29^th March, initially I would like to take
this opportunity to apologise for the delayed responses that have resulted
in you raising grievances and for the failure of the initial response
dated 6^th November 2018 to satisfy your requirements. A review of a
request for information involves tracing steps taken in the processing of
a request and the application of any exemptions to ensure a fair balance
between the public interest for transparency without prejudice to law
enforcement.

Request for reviews of the handling of requests exercising rights granted
under part 1 of the Freedom of Information Act 2000(FOIA), are viewed as
an opportunity to ameliorate discrepancies and any related dissatisfaction
and I hope this email will address some of your points. Your request for
review presents the following numbered 1 to 6 with 1 and 2 stroked through
for receiving prior resolution;

1. An explanation is still required for the breaches of sections 10 and 17
of the Act. That should include disclosure of any lessons learned data
accruing from the instant request.

2. No response has been provided to Question 8 in the information request
and no disclosure made. Please remedy this defect as a matter of urgency.
It appears that the disclosure officer has confused the answer to Question
8 with Question 7(b).

3. It would be readily apparent to any independent reviewer that not all
disclosure of the emails has been made. There are glaring deficiencies.
Some by plain, and obvious, inference. Others within my certain knowledge.
That may be down to oversight, but that would be a generous
characterisation given the already vexed history of ACC Hussain's
appointment, just over one month ago.

4. The officer carrying out the review is, accordingly, invited to concern
themselves, particularly, with the type of searches that were made, and by
whom. That same officer should be independent of the influence of those
very senior officers whose emails form part of the instant  information
request , particularly DCC Pilling.

5. To assist with the first principles of the Act, and the chief
constable's very public and repeated commitments to transparency, the
internal reviewer is invited to disclose all internal GMP correspondence,
notebook, or day book (paper or electronic) entries of those officers
concerned with the finalisation of this request and those who were subject
of it. From the date the request was made (9th September, 2018) until the
date it was finalised (6th November, 2018). If this matter progresses from
the complaint already lodged with the Information Commissioner, such
disclosure would, doubtless, assist her investigation.

6. Notwithstanding the issues raised in the preceding paragraphs, please
note my appreciation and thanks for the disclosure made, so far. This
assistance, when police resources are particularly precious, gives visible
support to the vocation of journalist and "social watchdog" - and helps
maintain public confidence in the police service.

7. a request for information made on 29^th August 2018 has been ignored
completely.

You request for this review be undertaken by an Officer “independent of
the influence of those very senior officers whose emails form part of the
instant information request, particularly DCC Pilling”. Relative to your
aforementioned request, and akin to most organisations, GMP is a
structured entity with the responsibilities of the Chief Constable
delegated to staff and officers throughout the organisational hierarchy,
therefore your request 4 for independence of the internal structure would
only be possible by use of an external organisation, unfortunately this
option is not available to and I believe is not a mandatory requirement
nor a Right under the legislation in question to which your request
pertains. Having said that, a review is being undertaken independently of
the original case worker without interference from senior leadership.

On receipt of your request citing the FOIA, processing undertaken prior to
a response to you followed a structured process involving the collation of
information requested by a central point in the compliance function via
delegates of the GMP senior leadership team which was initially partly
provided within the statutory period for response with additional
information provided at a later date following clarification, followed by
its assessment and disclosure to you. Granted this process encountered an
extended period of processing for which I believe an apology has been
provided in writing to you on 7^th November 2018 with an explanation
concerning part of the extended period in question.

In 3 above, you speculate that not all information has been disclosed to
you in particular making reference to emails in relation to which you
claim either by inferring or from acquaintance with information pertaining
to deficiencies in the information disclosed therein or I assume in the
number of emails disclosed to you about the appointment in question. For
clarity and in setting expectations, currently it is not GMP policy for
retention of all correspondences, therefore it is entirely possible that
not all correspondences were deemed necessary for retention and may
therefore have been disposed of. On 06 November 2018 emails held by GMP in
relation to your request were disclosed to you, on review of the material
disclosed I have assessed the use of exemptions from Section 31 and 40 of
the FOIA and owed to careful redactions, it is evident that obvious
personal data that identifies a third party has been withheld from
disclosure demonstrating that exemptions have been utilised appropriately.
As part of this review. some exceptions in the applications have been
noted and subsequently overridden, the information identified as not being
exempt from duties under Section 1b of the FOIA relates to guidance for
vetting levels should this be of interest to you, please inform me in
response to this email and arrangements will be made for its disclosure to
you. I would be much obliged if you would assist by affording the review
process with indications of such claimed informed deficiencies in 3 above.
Should the claimed deficiencies refer to information withheld owed to
mitigation by means of exemptions I believe adequate clarity of such has
been provided to you in compliance with Section 2 of the FOIA. As an
extension to this review I have requested further/repeat searches to
ensure your request has been sufficiently honoured, however should you
have insight that may assist with searches, please do not hesitate to
inform searches as you deem appropriate. 

In 5 noted above, you make an additional request for ‘all internal GMP
correspondence, notebook, or day book (paper or electronic) entries of
those officers concerned with the finalisation of this request and those
who were subject of it. From the date the request was made (9th September,
2018) until the date it was finalised (6th November, 2018)’, which I
assume relates to the staff involved in the processing of your request for
information from the Information compliance function in GMP?, upon
clarification, I will ensure that appropriate searches are undertaken to
acquire the necessary information for disclosure, however owed to its
administrative burden I would welcome your reasoning for this additional
request.

Thank you for your acknowledgment of the strains on Police resources,
unfortunately the compliance function has faced significant constraints,
and owed to the nature of the work predominantly governed by statute, its
prioritisation is risk based; consequently cases presenting monetary or
judicial implications or high risk to GMP information Assets are afforded
the utmost priority.  Additional to the aforementioned, of late I have had
a number of unforeseen days away from the office appended by further
planned time away from the office resulting in a single working day per
week during March.

I will be requesting information pertaining to your request on 29^th
August to be forwarded to me for inclusion. I acknowledge that this email
may not be to your entire satisfaction, however I hope the above affords
some assurance that work is underway in ensuring a fair and balanced
outcome to your request for review and that you will accept apologies
offered for any inconvenience delays may cause or have caused over the
lapse in time since your request and progress thus far.

I’d like to also take this opportunity to thank you for your patience thus
far, I endeavour to append to the above in due course. Should you have
interim enquiries, please do not hesitate to contact me via the details
below.

Best wishes, Khalid

 

 

From: Khalid Mahmood
Sent: 29 March 2019 21:30
To: 'Neil Wilby ([FOI #545264 email])'
Subject: Internal review of Freedom of Information request - Transforming
PSD project - GSA 0161/19

 

Dear My Wilby,

Your request for review of the handling of your request for information
pertaining to the appointment of ACC Mabs received by GMP on 9th September
2018 has been brought to my attention.

This email serves to inform of an ongoing review of the handling of your
request for information under the Freedom of information Act 2000.

Unfortunately owed to a number of factors the review has not concluded,
significant work has been undertaken however your concerns have not been
addressed in their entirety. I am currently assessing information
retrieved and endeavour to provide a response on Monday 1^st March. 

Apologies for any inconvenience this may cause or has caused over the
lapse in time, I can assure you that the Compliance function in
collaboration with departmental and/or operational Officer support process
over 4000 requests annually, and such lapses are a rarity.

I’d like to also take this opportunity to thank you for your patience thus
far.

Best wishes, Khalid

 

Yours sincerely

Khalid Mahmood
Information Compliance & Records Management Officer
Information Services Branch - Information Management
Greater Manchester Police

 

Postal Address: c/o Openshaw Complex, Lawton Street, Openshaw, Manchester,
M11 2NS

 

Tel: 0161 856 9924 

Ext: 69924 

[mobile number]        

Follow us on Twitter: @gmpolice

--------------------------------------------------------

The contents of this e-mail should be treated as OFFICIAL unless otherwise
indicated.

--------------------------------------------------------

-I am not in the office on Thursdays and Fridays-

 

 

To contact the police in an emergency call 999 or to contact Greater
Manchester Police for a less urgent matter call 101.
For the latest news and information about your Neighbourhood Policing Team
visit www.gmp.police.uk. You can also follow us on Twitter:
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This e mail carries a disclaimer, a copy of which may be read at:
   
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Greater Manchester Police

2 Attachments

Dear Mr Wilby,

The ICO recently concluded your complaint with a decision notice ordering
GMP to make provision of information previously not made available to you
as part of the initial response to your request for information in
accordance with the Freedom of Information Act 2000.

In response to the request and Order from the ICO, GMP have decided to
honour the decision notice and to that effect attached is a copy of
vetting guidelines and managers guide previously not disclosed to you.

Yours sincerely

Khalid Mahmood
Information Compliance & Records Management Officer
Information Services Branch - Information Management
Greater Manchester Police

 

Postal Address: c/o Openshaw Complex, Lawton Street, Openshaw, Manchester,
M11 2NS

 

Tel: 0161 856 9924 

Ext: 69924 

[mobile number]        

Follow us on Twitter: @gmpolice

--------------------------------------------------------

The contents of this e-mail should be treated as OFFICIAL unless otherwise
indicated.

--------------------------------------------------------

-I am not in the office on Thursdays and Fridays-

 

 

 

 

 

From: Khalid Mahmood
Sent: 16 April 2019 10:46
To: 'Neil Wilby ([FOI #545264 email])'
Subject: RE: Internal review of Freedom of Information request -
Transforming PSD project - GSA 0161/19

 

Dear Mr Wilby,

In response to your presumption of omissions from emails disclosed to you
further searches were conducted to determine any omitted emails. I have
been informed that all emails concerning the appointment were disclosed to
you, I appreciate that this may not be to your satisfaction, however
maintain that should you present additional information to support your
request, accounting for such information further searches can be
performed.

I take this opportunity to thank you for your patience in anticipation of
a response to your request dated 29^th August.

Regards, Khalid

 

 

 

From: Khalid Mahmood
Sent: 02 April 2019 19:28
To: 'Neil Wilby ([FOI #545264 email])'
Subject: RE: Internal review of Freedom of Information request -
Transforming PSD project - GSA 0161/19

 

Dear Mr Wilby,

Further to my email of Fri 29^th March, initially I would like to take
this opportunity to apologise for the delayed responses that have resulted
in you raising grievances and for the failure of the initial response
dated 6^th November 2018 to satisfy your requirements. A review of a
request for information involves tracing steps taken in the processing of
a request and the application of any exemptions to ensure a fair balance
between the public interest for transparency without prejudice to law
enforcement.

Request for reviews of the handling of requests exercising rights granted
under part 1 of the Freedom of Information Act 2000(FOIA), are viewed as
an opportunity to ameliorate discrepancies and any related dissatisfaction
and I hope this email will address some of your points. Your request for
review presents the following numbered 1 to 6 with 1 and 2 stroked through
for receiving prior resolution;

1. An explanation is still required for the breaches of sections 10 and 17
of the Act. That should include disclosure of any lessons learned data
accruing from the instant request.

2. No response has been provided to Question 8 in the information request
and no disclosure made. Please remedy this defect as a matter of urgency.
It appears that the disclosure officer has confused the answer to Question
8 with Question 7(b).

3. It would be readily apparent to any independent reviewer that not all
disclosure of the emails has been made. There are glaring deficiencies.
Some by plain, and obvious, inference. Others within my certain knowledge.
That may be down to oversight, but that would be a generous
characterisation given the already vexed history of ACC Hussain's
appointment, just over one month ago.

4. The officer carrying out the review is, accordingly, invited to concern
themselves, particularly, with the type of searches that were made, and by
whom. That same officer should be independent of the influence of those
very senior officers whose emails form part of the instant  information
request , particularly DCC Pilling.

5. To assist with the first principles of the Act, and the chief
constable's very public and repeated commitments to transparency, the
internal reviewer is invited to disclose all internal GMP correspondence,
notebook, or day book (paper or electronic) entries of those officers
concerned with the finalisation of this request and those who were subject
of it. From the date the request was made (9th September, 2018) until the
date it was finalised (6th November, 2018). If this matter progresses from
the complaint already lodged with the Information Commissioner, such
disclosure would, doubtless, assist her investigation.

6. Notwithstanding the issues raised in the preceding paragraphs, please
note my appreciation and thanks for the disclosure made, so far. This
assistance, when police resources are particularly precious, gives visible
support to the vocation of journalist and "social watchdog" - and helps
maintain public confidence in the police service.

7. a request for information made on 29^th August 2018 has been ignored
completely.

You request for this review be undertaken by an Officer “independent of
the influence of those very senior officers whose emails form part of the
instant information request, particularly DCC Pilling”. Relative to your
aforementioned request, and akin to most organisations, GMP is a
structured entity with the responsibilities of the Chief Constable
delegated to staff and officers throughout the organisational hierarchy,
therefore your request 4 for independence of the internal structure would
only be possible by use of an external organisation, unfortunately this
option is not available to and I believe is not a mandatory requirement
nor a Right under the legislation in question to which your request
pertains. Having said that, a review is being undertaken independently of
the original case worker without interference from senior leadership.

On receipt of your request citing the FOIA, processing undertaken prior to
a response to you followed a structured process involving the collation of
information requested by a central point in the compliance function via
delegates of the GMP senior leadership team which was initially partly
provided within the statutory period for response with additional
information provided at a later date following clarification, followed by
its assessment and disclosure to you. Granted this process encountered an
extended period of processing for which I believe an apology has been
provided in writing to you on 7^th November 2018 with an explanation
concerning part of the extended period in question.

In 3 above, you speculate that not all information has been disclosed to
you in particular making reference to emails in relation to which you
claim either by inferring or from acquaintance with information pertaining
to deficiencies in the information disclosed therein or I assume in the
number of emails disclosed to you about the appointment in question. For
clarity and in setting expectations, currently it is not GMP policy for
retention of all correspondences, therefore it is entirely possible that
not all correspondences were deemed necessary for retention and may
therefore have been disposed of. On 06 November 2018 emails held by GMP in
relation to your request were disclosed to you, on review of the material
disclosed I have assessed the use of exemptions from Section 31 and 40 of
the FOIA and owed to careful redactions, it is evident that obvious
personal data that identifies a third party has been withheld from
disclosure demonstrating that exemptions have been utilised appropriately.
As part of this review. some exceptions in the applications have been
noted and subsequently overridden, the information identified as not being
exempt from duties under Section 1b of the FOIA relates to guidance for
vetting levels should this be of interest to you, please inform me in
response to this email and arrangements will be made for its disclosure to
you. I would be much obliged if you would assist by affording the review
process with indications of such claimed informed deficiencies in 3 above.
Should the claimed deficiencies refer to information withheld owed to
mitigation by means of exemptions I believe adequate clarity of such has
been provided to you in compliance with Section 2 of the FOIA. As an
extension to this review I have requested further/repeat searches to
ensure your request has been sufficiently honoured, however should you
have insight that may assist with searches, please do not hesitate to
inform searches as you deem appropriate. 

In 5 noted above, you make an additional request for ‘all internal GMP
correspondence, notebook, or day book (paper or electronic) entries of
those officers concerned with the finalisation of this request and those
who were subject of it. From the date the request was made (9th September,
2018) until the date it was finalised (6th November, 2018)’, which I
assume relates to the staff involved in the processing of your request for
information from the Information compliance function in GMP?, upon
clarification, I will ensure that appropriate searches are undertaken to
acquire the necessary information for disclosure, however owed to its
administrative burden I would welcome your reasoning for this additional
request.

Thank you for your acknowledgment of the strains on Police resources,
unfortunately the compliance function has faced significant constraints,
and owed to the nature of the work predominantly governed by statute, its
prioritisation is risk based; consequently cases presenting monetary or
judicial implications or high risk to GMP information Assets are afforded
the utmost priority.  Additional to the aforementioned, of late I have had
a number of unforeseen days away from the office appended by further
planned time away from the office resulting in a single working day per
week during March.

I will be requesting information pertaining to your request on 29^th
August to be forwarded to me for inclusion. I acknowledge that this email
may not be to your entire satisfaction, however I hope the above affords
some assurance that work is underway in ensuring a fair and balanced
outcome to your request for review and that you will accept apologies
offered for any inconvenience delays may cause or have caused over the
lapse in time since your request and progress thus far.

I’d like to also take this opportunity to thank you for your patience thus
far, I endeavour to append to the above in due course. Should you have
interim enquiries, please do not hesitate to contact me via the details
below.

Best wishes, Khalid

 

 

From: Khalid Mahmood
Sent: 29 March 2019 21:30
To: 'Neil Wilby ([FOI #545264 email])'
Subject: Internal review of Freedom of Information request - Transforming
PSD project - GSA 0161/19

 

Dear My Wilby,

Your request for review of the handling of your request for information
pertaining to the appointment of ACC Mabs received by GMP on 9th September
2018 has been brought to my attention.

This email serves to inform of an ongoing review of the handling of your
request for information under the Freedom of information Act 2000.

Unfortunately owed to a number of factors the review has not concluded,
significant work has been undertaken however your concerns have not been
addressed in their entirety. I am currently assessing information
retrieved and endeavour to provide a response on Monday 1^st March. 

Apologies for any inconvenience this may cause or has caused over the
lapse in time, I can assure you that the Compliance function in
collaboration with departmental and/or operational Officer support process
over 4000 requests annually, and such lapses are a rarity.

I’d like to also take this opportunity to thank you for your patience thus
far.

Best wishes, Khalid

 

Yours sincerely

Khalid Mahmood
Information Compliance & Records Management Officer
Information Services Branch - Information Management
Greater Manchester Police

 

Postal Address: c/o Openshaw Complex, Lawton Street, Openshaw, Manchester,
M11 2NS

 

Tel: 0161 856 9924 

Ext: 69924 

[mobile number]        

Follow us on Twitter: @gmpolice

--------------------------------------------------------

The contents of this e-mail should be treated as OFFICIAL unless otherwise
indicated.

show quoted sections