COMPARATIVE EVIDENCE NOTE
25/04/2026
Emerging Pattern in Police Section 14 FOIA Responses – NPCC / Gwent / Staffordshire.
This note records a recurring structural feature observed in recent police Freedom of Information Act section 14(1) (“vexatious”) responses, namely the presentation of request history in a manner that appears to inflate volume while withholding the particulars necessary for independent assessment.
The concern is not presently framed as an allegation of coordinated misconduct. Rather, it is that multiple authorities are exhibiting a materially similar methodology when advancing section 14 arguments.
Numerical Inflation by Counting Internal Reviews as FOI Requests
NPCC – Tribunal matter
Tribunal Matter – quantity without chronology
The issue first arose sharply in the Appellant’s present Tribunal proceedings against the NPCC.
The NPCC has relied heavily on the suggestion that a series of related requests were made concerning the NVCRP, NaVCIS, vehicle theft statistics and associated funding matters, said to be sufficient to justify section 14(1).
Yet despite repeated reliance on this history:
- no dates have been supplied,
- no subject-by-subject schedule has been produced,
- no intervals between requests have been identified,
- and no clear distinction has been drawn between substantive FoIA requests, internal reviews and ordinary follow-up correspondence.
In practical terms, the Tribunal is being asked to accept that there were ‘many similar requests‘ without being shown a transparent chronology capable of independent assessment.
That matters because
- numbers, without context, create their own impression.
- a bare recital of references can suggest relentless bombardment.
- a dated chronology may reveal a far smaller number of discrete requests spread over months.
The NPCC’s presentation supplies the former impression while withholding the latter detail.
Gwent Police – the Commissioner was not persuaded
This concern is not speculative. In Decision Notice IC-355444-P4T3, the Information Commissioner considered Gwent Police’s reliance on overlapping and repeated requests to support section 14.
The Commissioner rejected the portrayal.
Importantly, she recorded that:
- “the actual numbers of FOI requests are minimal relating to three separate requests over the seven month period.”
She further noted that Gwent Police had failed to provide supporting information relevant to its assertions – even when asked to do so.
In other words, the authority’s depiction of repeated burden was broader than the evidence justified.
This is a significant marker – the Commissioner has already found one police authority wanting where the request volume was overstated.
Staffordshire Police – not really 7 requests
A more recent (17/04/2026) Staffordshire Police Internal Review provides perhaps the clearest public illustration. In refusing a request under section 14, Staffordshire state:
- “Since 10th May 2025, 7 FOI request have been submitted…”
That sounds, on first reading, like a substantial and repetitive campaign. But the references listed by Staffordshire are:
21907
21971
21986 IR of 21907
22046 IR of 21971
22736
22742
22760 IR of 22742
Three of the seven cited “FOI requests” are not fresh requests at all. They are Internal Reviews.
The practical picture therefore becomes:
- 4 substantive FOI requests – in almost a year.
- 3 Internal Reviews
- presented collectively as “7 FOI requests”
That may sound like a technical drafting point, but the optics are materially altered.
- “7 requests” suggests persistence and pressure.
- “4 requests over approximately 11 months, with statutory internal reviews” suggests something rather different.
Yet no explanation is offered for the conflation.
More than FOI – blending everything into “bombardment”
Staffordshire goes further. Having listed the seven references, the response then adds:
- four Right of Access requests, and
- Professional Standards complaint activity,
before concluding that there has been:
- “constant bombardment of requests and complaints…”
This is revealing.
A Freedom of Information request, an Internal Review, a Subject Access or Right of Access request, and a complaint are not interchangeable administrative nuisances. They are separate statutory or procedural routes serving different legal purposes.
Yet once blended together, they create one enlarged numerical story:
- the troublesome applicant who is everywhere.
Whether each route was lawfully used becomes secondary to the cumulative impression.
Staffs online response can be read here.
The missing information in all three examples
Across the NPCC, Gwent and Staffordshire examples, the same omissions repeatedly appear:
- no clear dates,
- no subject descriptions,
- no explanation of overlap,
- no breakdown of what is a fresh request and what is review-stage correspondence,
- little or no concrete evidence of actual retrieval burden.
Instead, the decision-maker often presents:
a list of references + a broad statement of similarity = a section 14 burden narrative.
This makes independent testing difficult.
The requester is left challenging an impression, rather than a chronology.
A pattern, not yet a proven policy
At this stage it would be wrong to leap to accusations of central coordination. There is, as yet, no proof that these responses stem from a single author, a common template, or direct National Police Chiefs’ Council instruction. But the structural resemblance is becoming difficult to ignore.
Across separate authorities, one sees:
- quantity asserted
- details withheld
- administrative remedies blended together
- the requester presented as inherently burdensome
Whether this reflects:
- shared training,
- template language,
- informal advice,
- or simply the spread of a convenient handling style,
is not yet known. What can be said safely is this:
- section 14 is increasingly being supported by arithmetic and optics in circumstances where the chronology itself remains opaque.
Why this matters
Section 14 exists to protect public authorities from abuse. It does not exist to allow broad-brush numerical narratives to replace transparent evidential schedules.
If Internal Reviews are being counted as FOI requests, if complaints and access requests are being folded into one “bombardment” story, and if dates and subject matter are omitted, then a requester – and indeed the Commissioner or Tribunal – may be judging burden by impression rather than fact.
That should concern anyone interested in transparency. Because once “many requests” becomes an elastic phrase, section 14 becomes far easier to invoke and far harder to challenge.
Have you encountered this conduct?
This article records three examples presently identified. It may be a coincidence, an emerging convention.
Either way, the issue warrants wider scrutiny.
Have you have encountered:
- police FOIA refusals listing reference numbers without dates,
- Internal Reviews counted as FOI request volume,
- Subject Access requests or complaints blended into section 14 burden,
- or broad assertions of “many similar requests” unsupported by particulars,
Examples welcomed: If you have encountered similar police Freedom of Information responses, particularly where Internal Reviews or other statutory requests have been counted toward section 14 burden, please get in touch.