FOI 85/25 Purchasing Information from Data Brokers
Enquiry Reference: 85 - 25
I write in connection with regards to your Freedom of Information request, firstly please accept my apology for the delay. Below is your request and our response.
Under The Freedom of Information Act 2000, could you please provide the following information:
In each of the last five calendar years (2019, 2020, 2021, 2022, 2023), how much did the force spend on purchasing information from data brokers such as Experian, Equifax, Acxiom and others?
Please provide a full breakdown of spend with each provider in each calendar year.- For what purposes does the force purchase information from data brokers?
|
Provider |
2019 |
2020 |
2021 |
2022 |
2023 |
Purpose |
|
Simunix |
£21,150 |
£28,200 |
£14,100 |
£14,100 |
£15,600 |
UK Phonebook |
|
NEC |
£15,707 |
£16,193. |
£16,696 |
£17,214 |
£17,214 |
Electoral Role |
|
GoePlace |
Centrally funded |
Address & Street data |
||||
|
Phoenix |
N/A |
N/A |
N/A |
N/A |
£17,417 |
Consumer Data |
Having made enquiries within the Force above is all the information we will disclose and anything else we would rely on the following:
Section 1 of the Freedom of Information Act 2000 places two duties on public authorities. Unless exemptions apply, the first duty at Section 1(1) (a) is to confirm or deny whether the information specified in a request is held. The second duty at Section 1(1) (b) is to disclose information that has been confirmed as being held. Where exemptions are relied upon, Section 17 of the Freedom of Information Act requires that I provide the applicant with a notice which: a) states that fact b) specifies the exemption(s) in question and c) state (if that would not otherwise be apparent) why the exemption applies.
The Cleveland Police Service can neither confirm nor deny that it holds any other information relevant to your request as the duty in s1(1)(a) of the Freedom of Information Act 2000 does not apply, by virtue of the following exemptions:
Section 30(3) Investigations and Proceedings Conducted by Public Authorities.
Section 31(3) Law Enforcement.
Section 30 is a qualified class-based exemption and there is a requirement to conduct a public interest test.
Section 31 is prejudice based qualified exemptions and there is a requirement to articulate the harm that would be caused in confirming or not that the information is held as well as carrying out a public interest test.
Public Interest Considerations
Section 30 - Factors Favouring Confirmation or Denial
By confirming or denying that any other information relevant to your question exists would satisfy the public that the police take their responsibility to investigate crime thoroughly and that public money is well spent in securing evidence in criminal activity.
Section 30 - Factors Against Confirmation or Denial
By confirming or denying that any other information relevant to this question exists would hinder the protection of any operations the force has under the guise of covert activity that the force would not want to be known by criminals. This information would be sensitive, and the Force would not want them to adapt their offending behaviour in order to avoid detection.
Section 31 - Factors Favouring Confirmation or Denial
Disclosure would provide transparency in how police investigate crime and provide reassurance that tactics are being utilised appropriately to prevent and detect criminal activity. It would also serve to demonstrate that the police are open and accountable.
Section 31 - Factors Against Confirmation or Denial
The police have a duty of care to the community at large. If an FOI disclosure revealed information to the world (by citing an exemption or stating no information held) that would undermine an investigation, this could be used to offenders' advantage and would compromise potential victims and the public generally. It may also encourage offenders to alter their behaviours resulting in further, undetected crime.
Balance Test
The factors above highlight the merits of confirming, or denying, whether any other information pertinent to this request exists. The Police Service is charged with enforcing the law, preventing and detecting crime and protecting the communities we serve. As part of that policing purpose, various types of investigations may or may not be ongoing. The Police Service will never divulge whether any other information pertinent to a request does or does not exist, if to do so would compromise an ongoing investigation, or undermine the policing purpose in the effective delivery of operational law enforcement. Whilst there is a public interest in the transparency of policing operations and investigations it will be overridden in exceptional circumstances. Therefore, at this moment in time the balance test for neither confirming nor denying that any other information is held is appropriate.
No inference can be taken from this refusal that further information does or does not exist.
The Cleveland Police response to your request is unique and it should be noted that Police Forces do not use generic systems or identical procedures to capture and record data therefore responses from Cleveland Police should not be used as a comparison with any other force response you receive.
If you are not satisfied with this response or any actions taken in dealing with your request, you have the right to request an independent internal review of your case under our review procedure. The Freedom of Information Code of Practice (see below link) states that a request for internal review should be made within 20 working days of the date on this response or 40 working days if extenuating circumstances to account for the delay can be evidenced. Public authorities are not obliged to accept internal reviews after this date.
https://www.gov.uk/government/publications/freedom-of-information-code-of-practice
Yours sincerely
Information Rights Decision Maker