21/05/2025
Dear City of London Police,
I am requesting the following information:
- how many complaints/notifications were made to ActionFraud for the years 2023 and 2024 i.e. 01/01/2023 to 31/12/2024:
a. by or on behalf of Finance & Leasing Association (FLA members)
b. by NaVCIS
- for the same period, those that relate to vehicles being obtained by fraud.
Please provide notification dates and outcomes for each complaint in a consolidated Excel spreadsheet i.e. a single row for each complaint conveying date to outcome.
- The number of referrals to NaVCIS i.e. the number of reports/complaints, directed to NaVCIS and date of referral
- Regarding to ‘1’ and ‘2’ above, any detail you are able to provide about the notifications i.e. information that is in a readily retrievable format and does not fall to personal information i.e. does not engage any exemption
21/05/2025 from CoLP:
REQUEST FOR INFORMATION REF: FOI2025/00815
Thank you for your Email of 21st May.
Your request will now be considered in accordance with the Freedom of Information Act 2000 (the Act).
Due to an increase in the volume of work received by the Information Access Team we regret to inform you that we have fallen behind in our processing and are experiencing delays. We can assure you we are working as fast as we can to process your request and we are looking into ways to increase our staffing to accommodate the increase of work received by City of London Police.
If you have any further enquiries concerning this matter, please contact us at [email address], quoting the reference number in the Subject line.
We will aim to send you a full response to your request for information under the Freedom of Information Act within twenty working days of our receiving your request, by 19th June 2025.
16/06/2025 CoLP response:
This request is being refused under Section 12(2) of the Freedom of Information Act 2000
(FOIA). Section 12 of the FOIA allows that public authorities do not have to comply with
section 1(1) of the Act, if the cost of complying would exceed the appropriate limit. In
accordance with the Freedom of Information Act, this letter represents a Refusal Notice for
this request.
Due to the complexity of this request, we would be unable to provide this information. Most
notably because this fraud typology appearing across many of the Home Office Crime Codes,
which would need for each crime reports to be reviewed individually; therefore, it would take
longer than the 18 hours to retrieve the information.
16/06/2025 to CoLP:
Dear City of London Police,
REQUEST FOR INFORMATION REF: FOI2025/00815
Please confirm whether you hold the information
I note that you did not include a calculation or explanation of the costs involved in providing the information. It would be useful if you could do so, to allow me to understand how best to reframe my request and not exceed the cost limit.
As I am sure you are aware, the FOI Act states that it is “the duty of a public authority to provide advice and assistance, so far as it would be reasonable to expect the authority to do so”, and the ICO consider it best practice to provide “arguments or evidence” when applying this exemption.
Your response indicated that providing the information I asked for in my original request would exceed the cost limit. I have reduced my request in scope, as follows:
- Regarding to ‘1’ and ‘2’ above, any detail you are able to provide about the
notifications i.e. information that is in a readily retrievable format and does not fall to
personal information i.e. does not engage any exemption
this appears to have been ignored.
Your response indicated that providing the information I asked for in my original request would exceed the cost limit. I believe that there may be a way to obtain this information at a lower cost, and I hope this is a helpful suggestion:
Provision of the fraud* typology codes potentially applicable.
The information that can be provided regarding each of the pertinent fraud* typologies
A time period reduction
*the request relates to ActionFRAUD i.e. this is a narrow area of crime (fraud) recorded and in turn for there to be limited codes related to vehicles – whether Home Office codes or your own
I am not assisted such that I can determine whether there may be a way to obtain this information at a lower cost
I would be grateful if you could offer me guidance into how I could best reframe the request in order to obtain as much of the information as possible, while bringing it below the cost limit.
As you may be aware, Section 16 of the FOI Code of Practice advises that bodies should ‘provide advice and assistance, so far as it would be reasonable to expect the authority to do so’ and ICO guidance (https://ico.org.uk/media/for-organisatio…) interprets this as a suggestion that the authority should provide suggestions of this nature.
It is disappointing and burdening not to be provided such assistance or calculation of the costs
As the basis of s12, the ‘complexity of this request’ is related to codes, there must surely be a means by which to provide pertinent code records and I would appreciate either this information or more explanation/guidance regarding the information held in a readily retrievable format.
It is concerning the codes are referred to as the ‘most’ pertinent exemption that gives rise to refusal. What other exemptions, if any are considered relevant and why have these not been proffered?
17/06/2025 from CoLP:
We will aim to send you a full response to your request for information under the Freedom of Information Act within twenty working days of our receiving your request, by 15th July 2025.
21/07/2025 to CoLP:
Dear City of London Police,
By when can I expect to receive the information? The 15th has passed
23/07/2025 from CoLP:
Our apologies for the delay. We are awaiting additional information from AF/NFIB and will provide a response as soon as we are updated.
21/08/2025 from CoLP:
Question 1 of your request was for information relating to complaints/notifications
made by or on behalf of the Finance & Leasing Association (FLA members) to Action
Fraud. In order to accurately identify those reports made by members of the FLA, it
would be necessary to manually review each one and we estimate that it would take
two minutes per report. The cost limit would therefore be reached after 540 reviews.
Action Fraud receives in excess of 500,000 reports per year and although we would
be able to filter some of the reports electronically, we would not be able to approach
the 540 case threshold. My apologies that this rationale was not articulated in the
original reply.
A search using the terms NaVCIS and National Vehicle Crime Intelligence Service
identified 280 matches for the 24 month period. Assuming a similar number of
matches were obtained for the same period using the terms Finance & Leasing
Association and FLA, the total number of reports would be within the cost threshold
for the manual review necessary to consider questions 2, 3 and 4 of your original
request. Please advise us if you wish to refine question 1 as described.
Where the cost of retrieval of the requested information exceeds the prescribed limit
there is no requirement to identify any other exemptions and in the absence of any
information to review, this is not likely to be possible. However, the Section 30
exemption, Investigations, is likely to be engaged in respect of any information held
by City of London Police for the purpose of investigations and proceedings.
If you have any concerns about the manner in which your request has been dealt
with, such concerns may be raised with the Information Commissioner via the
following link:
FOI and EIR complaints | ICO
Please contact us if we can be of further assistance
22/08/2025 to CoLP:
Please refine question 1 as described.
Any associated information about the date of allegation, value, complainant (commercial entity), outcome and date of conclusion would be appreciated.
Noting that there will be at least 280 records, if the data could be supplied in excel format, this would be helpful
It would assist me to review the request is [if] you could explain the process that is required to be adopted by the FLA/NaVCIS in relation to their vehicle loss investigations. I understand, with regard to insurers and IFED that in order to progress an allegation to IFED an insurer must first report the incident to ActionFraud (AF) who then direct the matter to IFED (or IFED are notified and liaise with AF).
- Does the same apply to the FLA/NaVCIS – should frauds first be reported to AF?
Your response
- ‘A search using the terms NaVCIS and National Vehicle Crime Intelligence Service identified 280 matches for the 24 month period. Assuming a similar number of matches were obtained for the same period using the terms Finance & Leasing Association and FLA, the total number of reports would be within the cost threshold for the manual review necessary to consider questions 2, 3 and 4 of your original request. Please advise us if you wish to refine question 1 as described.’
Suggests you believe both NaVCIS and the FLA would separately make notification but I suspect not. I would anticipate that the FLA, a body as opposed to a lender, would not identify as a victim. The victim would be the FLA member and given the number of these, a search would likely engage s12.
However, as NaVCIS only act for FLA members, it appears they are required to first notify AF of an allegation, that the FLA member is not – though whether the 280 matches for NaVCIS have been located as ‘complainant’ or party submission the report, as opposed to associated with an AF submission, is unknown.
- Does this appear correct? It is linked to ‘1’ above and any information about the procedure would be helpful
26/08/2024 from CoLP:
We will aim to send you a full response to your request for information under the Freedom of Information Act within twenty working days of our receiving your request, by 22nd September 2025.
22/09/2025 from CoLP:
The date that the response is due for your request, FOI2025/01336, has been changed to 6th October. This is because the Section 30 exemption is engaged – Investigations
23/09/2025 to CoLP
I am writing to acknowledge your citation of Section 30 of the Freedom of Information Act 2000 (FOIA) in relation to my request concerning fraud submissions involving vehicles.
PLease advise in what respect s30 applies to the CoLP.
Section 30(1)(a) can only be claimed by a public authority that has a duty to investigate offences. As discussed above, a duty imposes an obligation to carry out the investigations as opposed to a discretionary power to do so.
Whilst I understand the CoLP constitutes a law enforcement orgnaistaion with a duty to investigate:
a. Action Fraud (AF) is a data repository, a database of fraud allegations encompassing all manner of offences
b. AF collates data submitted to constabularies beyond CoLP
C. AF disseminates cases (not necessarily all) to others to investigate.
My request is specific and seeks complaints/notifications were made to ActionFraud for the years 2023 and 2024 i.e. 01/01/2023 to 31/12/2024:
a. by or on behalf of Finance & Leasing Association (FLA members)
b. by NaVCIS
These matters will neither be investigated by AF nor by CoLP. NaVCIS, funded by the FLA, is engaged to investigate allegations made by FLA members.
It therefore does not appear CoLP can claim ‘section 30’ in the circumstances. Please confirm this is your understanding or explain where I have misunderstood.
I draw a parallel to insurance fraud; an insurer, having identified suspected fraud, cannot simply convey this allegation to IFED (a CoLP department) – unlike NaVCIS). The insurer is required to submit a notification to AF, who refer the matter to IFED. I have assumed the process to be engaged by the FLA is similar to that of an insurer – the first stop is AF – that you hold information suggests this is the case. Please correct or clarify my understanding if necessary. s.11 https://ico.org.uk/media2/raajgqfq/inves…
Should you still consider Section 30 to be engaged, I refer you to the following:
While I recognise that Section 30 — “Investigations and proceedings conducted by public authorities” — is a qualified exemption, I must stress that it does not grant an automatic right to withhold information. It is subject to a Public Interest Test (PIT), and you are therefore obligated to justify non-disclosure based on a careful and specific assessment. I note this is being undertaken; however, I also understand you should identify to which parts of my request the PIT is being applied.
When citing section 30(1)(a) you need to explain not only how the duty to investigate arises but also which offence or offences, usually defined in common law or statute, are relevant in the particular circumstances. s.12 – https://ico.org.uk/media2/raajgqfq/inves…
Section 30(1)(a)(i)-(ii) and 30(1)(b) may apply where information has at any time been held for the purposes of a criminal investigation or potential criminal proceedings. However, I beleive this exemption must be applied narrowly and in a targeted manner, only where disclosure would prejudice ongoing or potential proceedings or undermine law enforcement effectiveness.
I have specifically requested 2023 and 2024 so as not to prejudice any ongoing investigations i.e. not sought 2025. However, I do not beleive the data i have requested could fall to section 30, given the relatively non-specific, statistical nature of the request
In the context of fraud relating to vehicles — a matter of wide public concern, consumer protection, and public funds — there is a strong public interest in transparency regarding:
- The scale and frequency of such fraud submissions;
- How public resources are allocated in response;
- Any systemic risks or patterns the public should be aware of.
Information relating to the effectiveness of a police investigation should not be withheld under Section 30 where there is minimal risk of prejudice and clear public benefit in disclosure.
To assist with assessing the legitimacy of your exemption, please provide:
- A breakdown of which parts of my request you believe Section 30 applies to;
- Details of any consultations, exchanges or internal discussions regarding this request;
- A summary of the factors being weighed in the Public Interest Test;
24/09/2025 from CoLP
Action Fraud (AF) and the National Fraud Intelligence Bureau (NFIB), both part of the City of London Police, work closely together to receive and analyse fraud and cybercrime reports. All such reports are held for the purpose of investigation and we therefore consider that Section 30 (1) (a) applies to all such reports.
Consideration of the Public Interest in disclosure has not yet been concluded and we are unable to
comment further at this time but your comments are noted and will be given consideration.
Please contact us if you have any further questions.
24/09/2025 to CoLP
Thank you for your response. If you would also bring the following to the attention of the party considering this matter:
My understanding is that Action Fraud (AF), administered by the City of London Police, is the national reporting centre for fraud and cybercrime. Its role appears often misunderstood – and in this instance as my request relates to FLA notifications directed to NaVCIS, AF has the briefest of ‘touches’ on a submission, undertaking no investigation – does not duplicate the role of NaVCIS. Were it to do so, AF would be committing time & resources to FLA crimes. NaVCIS has bene clear – they cost the taxpayer nothing.
AF receives reports from the public via its online portal or call centre. These reports are processed and passed to the National Fraud Intelligence Bureau (NFIB) for assessment and intelligence purposes.
NFIB may disseminate intelligence packages to local police forces, regulators, or other agencies – in this case, promptly directing the matter to NaVCIS.
Furthermore, AF does not conduct investigations into individual cases. AF is not a body with operational responsibility for arrests, interviews, or prosecutions. Investigations remain the responsibility of local police forces or other competent agencies to which cases are referred – NaVCIS and NaVCIS only in the context of my request.
Section 30(1)(a) of the FOIA allows public authorities to withhold information if it relates to “any investigation which the public authority has a duty to conduct with a view to it being ascertained … whether a person should be charged with an offence.”
This exemption presupposes that:
- The authority itself is carrying out (or has carried out) an investigation; and
- The information is held for the purposes of that investigation.
In the case of Action Fraud:
Reports are not “investigations”; they are allegations or intelligence inputs.
AF has no statutory duty to investigate or determine charges.
The holding of information by AF is for collation and dissemination, not for direct investigative purposes.
The Information Commissioner has previously clarified that Section 30 cannot be applied in a blanket manner to information simply because it is crime-related. For Section 30(1)(a) to bite, there must be a clear investigative context where the authority itself is responsible for investigating and potentially bringing charges.
To suggest that Action Fraud may withhold all reports under Section 30(1)(a) is to stretch the exemption beyond its statutory intention. AF’s primary function is administrative and intelligence-led – not investigative. Reports are only intelligence for those who do have investigative responsibility. Therefore, reliance on Section 30(1)(a) by AF appears misplaced.
Action Fraud is the national reporting/recording centre for fraud, not an investigative body. The ICO’s guidance limits FOIA s30(1)(a) to authorities with a statutory duty or specific power to investigate. Unless Action Fraud can identify the legal duty under which it is itself investigating and tie the information to that investigation’s purpose, s30(1)(a) is misapplied
- Please identify the specific investigation AF (not another force) has a duty to conduct, cite the statutory duty relied upon, and link the withheld information to that investigation’s purposes. Absent that, s30(1)(a) is misapplied
Research:
The ICO’s own guidance is explicit: s30(1)(a) can only be used by authorities that have a duty or specific powers to conduct criminal investigations and the authority must explain how that duty arises (usually by statute) and which offence(s) are in view. Simply handling crime-related information is not enough (Investigations & Proceedings s.30)
City of London Police’s written evidence to Parliament describes Action Fraud/NFIB as the national reporting and recording centre for fraud and financially-motivated cybercrime; dissemination and intelligence assessment happen via NFIB. This supports the position that AF receives and routes allegations; it does not itself investigate (written evidence submitted by the City of London Police)
The ICO draws a bright line between a duty to investigate (qualifies for s30) and a mere discretionary power or general function (does not). Authorities must show the statutory source of that duty when invoking s30(1)(a). AF’s reporting/triage function doesn’t meet that test (Investigations & Proceedings s.30)
The fact that information concerns crime doesn’t automatically make it s30 information. The purpose for which AF holds it matters. AF holds reports to record, assess and disseminate—not to conduct arrests/interviews or decide on charges
17/12/2025 to CoLP:
Please identify the specific investigation AF (not another force) has a duty to conduct, cite the statutory duty relied upon, and link the withheld information to that investigation’s purposes. Absent that, s30(1)(a) is misapplied
08/01/2025 to CoLP:
24/09/2025 you wrote:
‘Action Fraud (AF) and the National Fraud Intelligence Bureau (NFIB), both part of the
City of London Police, work closely together to receive and analyse fraud and
cybercrime reports. All such reports are held for the purpose of investigation and we
therefore consider that Section 30 (1) (a) applies to all such reports. Consideration of
the Public Interest in disclosure has not yet been concluded and we are unable to
comment further at this time but your comments are noted and will be given
consideration.’
Please note my subsequent response in this thread.
Please advise by when i can expect a response, the information requested.
08/10/2025 complaint submitted to the ICO