11/06/2026 to the ICO:
I wish to complain about Essex Police’s refusal of FOI 23526 and the subsequent internal review outcome dated 10 June 2026.
In my submission, the refusal under sections 14(1) and 14(2) FOIA is inadequately reasoned and unsupported by evidence.
Section 14(2)
Essex Police have never identified:
• the previous request said to be identical or substantially similar;
• which elements of my request overlap with previous requests;
• whether any such request was complied with; or
• why a reasonable interval has not elapsed.
Instead, the force merely states that “elements” of the request overlap with earlier requests.
The request sought recorded information created, amended, circulated or relied upon between January 2023 and May 2026 concerning third-party SARs, section 53 DPA 2018, section 184 DPA 2018, the September 2023 meeting referred to by Essex Police, and creation of the A98b process.
Essex Police have not demonstrated that these specific records were previously requested or disclosed.
Section 14(1)
The force argues that compliance would require searches across multiple departments and systems and extensive retrieval, collation, review and redaction.
However:
• no estimate of burden has been provided;
• no estimate of staff time has been provided;
• no estimate of cost has been provided;
• no systems have been identified; and
• no departments have been identified.
The reasoning resembles a section 12 costs refusal rather than a properly evidenced section 14 refusal.
Section 16
The force failed entirely to engage with its duty to provide advice and assistance.
My internal review specifically suggested narrowing the request to:
• current templates only;
• September 2023 meeting records only;
• section 184 guidance only; or
• A98b process material only.
The review contains no explanation of whether these alternatives were considered and no explanation why assistance was not offered.
Failure to address central issue
The request concerns an important and specific matter: Essex Police’s reliance on section 184 DPA 2018 when discouraging use of third-party subject access requests.
Essex Police previously relied upon section 184 in correspondence and subsequently confirmed that managers met with the insurance team to review templates and processes.
The request seeks the recorded information underpinning those statements.
Rather than addressing that issue, Essex Police characterise the request as a broad request for numerous categories of material.
Conclusion
I respectfully submit that Essex Police have not demonstrated that section 14(2) applies, have not adequately justified section 14(1), and have failed to provide advice and assistance under section 16.
I therefore ask the Commissioner to investigate and determine whether Essex Police has complied with its obligations under the Freedom of Information Act 2000.
