The full chronology can be found at the post ‘A problem acknowledged — but how big is it?’
c/o PO BOX 481
Fareham
Hampshire
PO14 9FS
Tel: 02380 478922
Email: npcc.foi.request@npfdu.police.uk
02/09/2026
Internal Review Reference Number: 3103/2026
Freedom of Information request reference number: 3089/2026
Thank you for your correspondence dated 09 August 2026 requesting an internal review of the NPCC response issued on 05 August 2026 in relation to Freedom of Information request 3089/2026 (See Annex A).
Initial Response
The NPCC refused the request S17 Freedom of information Act (FOIA) citing exemption S14(1) Vexatious
Review Decision
I have conducted a review of the handling of your request and have considered:
- your original request;
- the refusal notice issued under section 14(1) of the Freedom of Information Act 2000 (“FOIA”);
the extensive representations submitted in support of your Internal Review;
- the history and context of previous correspondence between yourself and the NPCC concerning stolen vehicle recording, Lost/Stolen (LoS) processes and associated governance issues; and
- relevant ICO guidance and case law, including Dransfield v Information Commissioner & Devon County Council and ICO Decision Notice IC-387981-N0T4.
Having completed the review, I uphold the original decision to refuse the request under section 14(1) FOIA on the basis that it is vexatious.
This review has considered the request afresh and has taken account of the additional arguments and evidence presented. However, those submissions do not alter my conclusion that, when assessed in the full context of your correspondence with the NPCC, the request represents a disproportionate use of FOIA resources and that the cumulative burden imposed on the NPCC outweighs the value likely to be obtained from further engagement on this subject.
Consideration of the Request in its Present Context
I acknowledge your argument that the request followed receipt of a Home Office FOIA response and that you were directed towards the NPCC as a possible source of assistance.
I also acknowledge your contention that the request concerns VE602/VE602J processes rather than vehicle crime generally.
However, section 14 requires a public authority to consider requests in context. The ICO’s guidance and the Upper Tribunal in Dransfield make clear that a request which may appear reasonable when viewed in isolation can nevertheless be vexatious when viewed against the background of previous requests and correspondence.
The Internal Review has therefore considered both the content of the request and the wider pattern of engagement.
While the particular wording of this request differs from earlier requests, it remains closely connected to the same longstanding subject matter, namely:
- PNC Lost/Stolen recording processes;
- vehicle weeding procedures;
- national governance of those processes;
- vehicle crime recording and reporting; and
- alleged inaccuracies arising from Lost/Stolen recording mechanisms.
The request therefore cannot reasonably be assessed in isolation from the wider course of correspondence.
Serious Purpose and Public Interest Value
I accept that your request was made in pursuit of an issue which you genuinely consider to be important. I further acknowledge:
- your analysis of police and DVLA datasets;
- your correspondence with other public bodies;
- your engagement with the National Audit Office;
- your references to Home Office discussions regarding LEDS functionality; and
- the NPCC’s previous communications to policing partners regarding Lost/Stolen record confirmation.
Nothing in this review concludes that your concerns are frivolous or that they lack any public interest element.
However, under section 14 the existence of a public interest purpose is not determinative.
As explained by the Upper Tribunal in Dransfield, even where a request pursues matters of accountability or transparency, a public authority is entitled to consider whether the cumulative impact of persistent requests has become disproportionate.
The issue for this review is therefore not whether vehicle theft recording is important. It plainly is. The issue is whether the continued use of FOIA directed at the NPCC on substantially interconnected aspects of the same subject remains proportionate when balanced against the burden created.
Having considered the matter afresh, I conclude that it does not.
Burden and the Cumulative Effect of Previous Requests
A substantial proportion of your Internal Review submission is directed towards distinguishing this request from previous matters.
I accept that not every reference cited in the refusal notice represents a wholly separate originating FOIA request. Some relate to Internal Reviews, ICO complaints or subsequent correspondence. However, that fact does not materially alter the assessment.
Section 14 is concerned with the burden imposed upon the authority rather than simply the number of originating requests. Internal Reviews, complaint handling, ICO investigations, consultations with subject matter experts, engagement with senior management, and subsequent correspondence all consume organisational resources.
The cumulative impact on the NPCC arises from the entirety of that engagement rather than solely from the initial requests themselves.
Accordingly, although I acknowledge that the number of originating requests is lower than the total number of references listed, this does not materially reduce the overall burden assessment.
Nor does it alter the fact that a significant volume of NPCC resource has repeatedly been directed towards closely related issues concerning vehicle crime recording and Lost/Stolen data processes over an extended period.
New Evidence and Changed Circumstances
You submit that significant new circumstances now exist, including:
- correspondence from the National Audit Office;
- Home Office explanations regarding six-week weeding; • information regarding archived VE602J reports; and
- discussion surrounding LEDS development.
I acknowledge that some of this information post-dates earlier requests. However, the existence of additional information does not require a public authority to disregard the history of previous engagement concerning the same underlying issue.
Although the factual background may have evolved, the central concern remains substantially the same as that which has formed the subject of prolonged correspondence with the NPCC since 2024.
Accordingly, I do not agree that these developments are sufficient to displace the section 14 considerations identified in the original refusal.
Motive
You state that the refusal identifies no improper motive. I agree.
The NPCC does not conclude that your motive is malicious, abusive or intended to harass staff personally. However, section 14 does not require evidence of bad faith.
The ICO and Tribunal authorities make clear that a request may be vexatious because of its disproportionate impact, cumulative burden or unreasonable persistence, even where the requester sincerely believes the issue is important.
The decision to apply section 14 is therefore not dependent upon establishing an improper motive.
Harassment and Distress
You argue that this request is professionally worded and cannot reasonably be characterised as harassing.
I accept that the request itself is courteous and contains no offensive language.
The original refusal did not suggest otherwise.
The relevance of harassment in section 14 cases is often found not in the wording of an individual request but in the cumulative effect of sustained correspondence on staff and organisational resources.
The Internal Review accepts that the concerns identified in the refusal arise primarily from cumulative burden and persistent engagement rather than from the wording of this particular request.
ICO Decision Notice IC-387981-N0T4
You argue that the circumstances are not identical and that the decision is currently the subject of Tribunal proceedings.
I accept that the request considered within IC-387981-N0T4 was not identical in wording or scope to the present request.
The original refusal perhaps overstated the degree of similarity.
However, the relevance of that decision lies not in its precise factual match but in its consideration of a prolonged pattern of correspondence by the same requester regarding related subject matter.
The Commissioner accepted that the NPCC was entitled to take that wider pattern into account when applying section 14.
While each request must be considered on its own merits, I remain satisfied that the principles applied by the Commissioner remain relevant to the current request.
Section 16 Advice and Assistance
You argue that the NPCC should have explored refinement before relying on section 14. I have considered that point carefully.
In some cases, narrowing or clarification may assist in reducing burden. However, the burden identified in this case does not arise principally from the wording or breadth of the present request. Rather, it arises from the cumulative impact of the wider pattern of correspondence and engagement relating to the same overarching subject matter.
Consequently, I am not persuaded that narrowing the wording of the request would have materially addressed the basis upon which section 14 was applied.
Speed of the Original Decision
You suggest that the speed with which the refusal was issued may indicate that insufficient consideration was given to the request. I do not accept that conclusion.
The ability to reach a decision promptly was assisted, in part, by the extensive organisational knowledge already held regarding the history of previous correspondence and the subject matter involved.
A decision reached within a short timeframe does not of itself indicate that appropriate consideration was not undertaken.
I am satisfied that the request was considered before the refusal was issued.
Conclusion
Having reviewed the request and your representations in full, I conclude that:
- the request concerns a matter which has been the subject of extensive and prolonged engagement with the NPCC;
- there is a clear continuation of a longstanding line of enquiry;
- the cumulative burden arising from that engagement remains significant;
- the existence of public interest value does not outweigh that burden in the circumstances of this case; and
- the threshold for section 14(1) is met when the request is viewed in its full historical context.
Accordingly, the original decision is upheld and the NPCC continues to rely upon section 14(1) FOIA.
If you remain dissatisfied with this outcome, you may complain to the Information Commissioner’s Office.
Ashleigh Beney
Head of NPFDU
Right of Appeal
If you remain unhappy about how your request has been handled you have the right to apply directly to the information Commissioner. For information on how to make an application to the Information Commissioner please visit their website at www.ico.org.uk alternatively, write to or phone:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
Phone: 0303 123 1113
My response to the IR can be read here, as cab the NPCC’s refusal to engage further.