09/08/2026 – Request for Internal Review of Section 14 Refusal
Dear NPCC,
Freedom of Information Act 2000 – Request for Internal Review
Reference: 3089/2025 [as stated in your letter dated 5 August 2026]
I request an Internal Review of the decision to refuse my request of 29 July 2026 under section 14(1) of the Freedom of Information Act 2000.
I have considered the refusal carefully. I recognise that section 14 exists to protect public authorities from disproportionate use of FOIA and that previous dealings with a requester may properly form part of that assessment. However, I do not consider that the reasoning given demonstrates that this request represents a disproportionate, manifestly unjustified, inappropriate or improper use of FOIA.
I ask that the reviewer considers the request afresh, in its present factual context and by reference to its actual scope, rather than treating the fact that I have previously sought information concerning vehicle crime as determinative.
The context in which this request was made
This Internal Review should be considered against an important and very recent factual background.
On 25 June 2026, the National Audit Office wrote under the heading “POTENTIAL SYSTEMATIC UNDER-RECORDING OF STOLEN VEHICLES” following consideration of the evidence I had supplied – see Appendix A.
The NAO records that its team met a Home Office official specifically to discuss PNC Lost/Stolen “weeding”. It records the Home Office as confirming that unconfirmed LoS records are removed from PNC after six weeks and that “it is this process which leads to the discrepancy between the police and DVLA databases.”
The NAO also records that it asked the Home Office what remedial action was proposed and was told that the Home Office is discussing with police forces whether the LoS confirmation step should be removed from LEDS. The NAO states that such a change would remove the data discrepancy caused by six-week weeding, although no timetable exists.
I subsequently sought the VE602/VE602J information from the Home Office – see Appendix B – in an attempt to quantify the problem. I clarified my request 06/07/2026 – see Appendix C
On 29 July 2026, the Home Office declined disclosure – see Appendix D – on the basis that it considers PNC vehicle information to be held on behalf of police forces and expressly stated:
“Given the subject matter of your request, the National Police Chiefs’ Council may be able to assist you.”
I approached the NPCC that same day, the subject request – see Appendix E.
Accordingly, the request now characterised as vexatious was not an unsolicited repetition of an old enquiry. It was the immediate and logical consequence of significant new evidence and of the Home Office expressly directing the enquiry to the NPCC.
The substantive concern
Still-outstanding stolen vehicles can cease to be recorded as stolen on PNC, and may never reach the DVLA as stolen, simply because the originating LoS report has not been administratively confirmed before automatic six-week weeding.
This is not hypothetical. Individual examples have been established; the NPCC itself warned Chief Constables about the resulting inaccurate vehicle status; the NAO has now recorded the Home Office’s confirmation that weeding contributes to the police/DVLA data difference. What remains unknown is the scale. That is precisely why I sought the VE602/VE602J information.
Introduction
The refusal states the current request is vexatious because of a history of “multiple similar requests”, burden, persistence and earlier ICO support.
But the current request is narrowly framed around VE602/VE602J governance and held information, expressly excludes personal/vehicle-level data, and arose because the Home Office itself directed me to the NPCC.
The continuity is brief, the subject matter concise:
• I received a letter from the NAO about ‘weeding’ – unconfirmed LoS reports on the PNC
• The NAO had spoken to the Home Office about the issue following receipt of my report/concerns
• I made a FoIA request of the Home Office
• The Home Office would not provide me with the information but directed me to the NPCC
• I made a request of the NPCC
• 5 working days later the NPCC cited the s14 exemption
The NPCC has nevertheless grouped together 16 references simply because they “have all been received in relation to stolen vehicles”.
ICO guidance expressly says that simply counting previous requests does not tell the full story, and an authority must consider how those requests were handled, including whether earlier responses were poor, absent, conflicting or created a need for clarification.
The present request is narrow, specific and materially different
My request arose directly from a current Home Office FOIA response.
The Home Office advised that it generates and issues VE602/VE602J vehicle weeding reports and, because it considers those reports to be held on behalf of police forces, specifically suggested that the NPCC may be able to assist.
I therefore asked the NPCC for recorded information about:
• whether it receives, accesses or retains VE602/VE602J reports;
• any aggregate, management or assurance information derived from them;
• recorded information concerning NPCC governance or oversight of the process;
• recorded information identifying the responsible national body if that role does not sit with the NPCC; and
• a recent VE602/VE602J report.
I expressly stated that the request was confined to governance, process and organisational responsibility and did not seek personal data or individual vehicle records.
This is therefore not a broad request for vehicle crime information. It is a focussed enquiry concerning a specific national PNC process and the location of responsibility for its governance and assurance.
The serious purpose has materially strengthened since the earlier requests relied upon
The refusal acknowledges that value or serious purpose is a central consideration under the Dransfield approach.
The current evidence demonstrates a substantial public-interest purpose.
• The NPCC itself issued a national circular to Chief Constables on 7 November 2024 concerning this very issue.
It described vehicles remaining “unconfirmed stolen” and consequently dropping off PNC after the weed period as causing “an inaccurate record of the vehicle status”, and asked forces to ensure stolen vehicle reports were confirmed within 24 hours so that PNC, third-party users and DVLA accurately reflected stolen status.
I do not suggest the NPCC has literally done nothing. Its 2024 national circular and the subsequent proposed reminder demonstrate some intervention. The more concerning point is that there is no evidence presently available to me that the effectiveness of those interventions was measured, that the volume of subsequent inappropriate weeding was audited, or that national assurance exists to demonstrate that the problem was resolved. The fact that further instances continue to arise suggests that reminders alone have not eliminated the risk.
It is evident constabularies have not complied with this directive. I understand that the NPCC re-issued guidance in 2025 and that the matter was raised with the NPVV by the NVCRP – National Vehicle Crime Reduction Partnership.
Yet, despite these activities, which I believe resulted from the concerns I raised, the issue remains, is current.
Furthermore, the issue has since developed considerably.
On 25 June 2026, the National Audit Office recorded that its team had met a Home Office official specifically to discuss PNC Lost/Stolen weeding.
This followed my submission of a 30+ page document, the result of months of work having uncovered what I suspected to be a serious failing of the PNC, the process of weeding.
The Home Office official confirmed the six-week mechanism and confirmed that it is this process, weeding, which leads to the difference between police and DVLA databases.
The NAO further recorded that the Home Office is discussing with police forces whether the Lost/Stolen confirmation step should be removed from the replacement LEDS functionality. The NAO noted that removal of the step would remove the data discrepancy caused by six-week weeding.
It is a known problem, as serious one:
• Weeding causes stolen vehicle NOT to be recorded as such after 6 weeks simply because constabulary staff fail to undertake an admin’ process; they do not CONFIRM a report.
I undertook analysis of 2025 data obtained from the DVLA and having made individual FoIA requests to 44 police constabularies. I monitored responses, tweaked the request, collated replies (received in multiple formats) and scrutinised the responses, comparing them with DVLA ‘stolen’ records. I applied a cautious approach to my subsequent statements.
Using the most conservative methodology, 107,734 police-recorded thefts against 87,452 DVLA LoS notifications: a difference of 20,282 records, or 18.83%.
An alternative methodology produces a 24.42% difference.
I do not suggest that every difference is attributable to weeding. There are legitimate reasons for divergence, including prompt recovery or cancellation.
The purpose of the present request is precisely to obtain the information needed to understand the scale and governance of the process rather than speculate about it.
The very information sought is capable of establishing the scale
That this is a problem is unquestionable; the NAO has confirmed, having consulted with the Home Office, the issue is real and causes stolen vehicle not to be recorded as such.
There is a further difficulty with relying upon section 14 on the basis that the subject lacks sufficient value.
The present request seeks information capable of answering an important question which presently cannot reliably be answered from published statistics:
• how many unconfirmed LoS reports actually progress through the VE602J process?
The significance of VE602J is now understood considerably better than when my earlier enquiries were made.
An unconfirmed Lost/Stolen report remaining unconfirmed at the relevant reminder point generates a VE602J notification. If it continues unconfirmed until six weeks after creation, the report is automatically weeded.
The VE602 information therefore provides a potentially direct means of measuring:
• how many LoS records remain unconfirmed long after initial creation; and
• how many ultimately reach automatic deletion.
That information is especially important because the presently available national datasets cannot reliably distinguish legitimate differences between police and DVLA records that have been deleted because an administrative confirmation step was not completed.
My analysis identifies a conservative difference of 20,282 records (18.83%) between 2025 police-recorded vehicle thefts and DVLA LoS notifications. I expressly do not suggest that those 20,282 records are all inappropriate weeding events.
Rather, that substantial unexplained difference makes measurement of VE602J outcomes more important.
The NPCC’s use of section 14 therefore produces a somewhat circular outcome:
• information is sought to establish the scale of a known problem, yet access is refused in part because the NPCC considers the subject insufficiently valuable to justify further enquiry.
The proper way to determine whether inappropriate weeding affects tens, hundreds or thousands of vehicles is not speculation. It is to examine the available records.
That is precisely what this request seeks to facilitate.
• What activity has the NPCC undertaken to address the issue since I first raised it with you in 2024?
• Why has this activity failed to address the issue?
The issue clearly has serious purpose. Disclosure may establish whether the NPCC’s previous interventions have been effective and whether any national assurance exists. At present, the evidence demonstrates that the issue was known, national reminders were issued, yet further suspected and confirmed instances have continued to arise
I find it difficult to reconcile the conclusion that the request lacks sufficient value with:
• the NPCC’s own national intervention;
• the NAO’s engagement;
• the Home Office’s engagement;
• the Home Office’s consideration of changing LEDS functionality; and
• the demonstrated scale of the police/DVLA data difference.
This is no longer an abstract or speculative concern.
The NPCC had itself previously been alerted to the issue
There is relevant history which the refusal does not appear to consider.
On 23 August 2024, the concern about weeding was raised directly with the then NPCC vehicle-crime lead, Jenny Sims. My records show no reply to that approach, although an NPCC national circular followed in November 2024.
In January 2026, a substantial evidence submission concerning the potential systematic under-recording of stolen vehicles was sent to several bodies – as mentioned previously; the 30+page report. The NPCC was expressly asked to confirm its position on weeding.
I have received no response to this
That history is relevant because continued requests for information do not arise in a vacuum. ICO guidance expressly states that when relying upon the number of previous requests, an authority must consider how it dealt with those requests.
Previous requests dealt with poorly, not answered, or answered inconsistently may mitigate against a later request being vexatious because they can themselves generate the need for clarification or further enquiries, see: ICO Link
The Internal Review should therefore consider whether some of the persistence now relied upon by the NPCC resulted from unresolved questions and NPCC failings, inattention and unprofessionalism, rather than an improper persistence with an already answered issue.
The NPCC had itself previously been alerted to the issue
The alleged persistence must be considered in the context of an unresolved problem
The refusal relies heavily upon the number of occasions on which I have previously raised matters relating to stolen vehicles and presents that history as evidence of unreasonable persistence.
There is an obvious difficulty with that reasoning in the particular circumstances of this request.
The subject has been raised repeatedly because the underlying problem has not been resolved.
The NPCC was alerted directly to the weeding issue in August 2024. No response was received. Thereafter, in November 2024, the NPCC itself considered the matter sufficiently serious for its Vehicle Crime Lead to circulate all Chief Constables, expressly identifying that unconfirmed stolen vehicle reports could drop off PNC and cause an inaccurate record of vehicle status.
The issue nevertheless continued.
Further national engagement during 2025 resulted in another proposed communication to forces. I was informed that forces were to be reminded to confirm LoS reports promptly and that the NPCC Operational Vehicle Crime Lead would arrange a further communication through ChiefsNet.
The issue nevertheless continued.
In January 2026, I supplied substantial research specifically seeking the NPCC’s position concerning the potential systemic under-recording of stolen vehicles. My records do not identify a substantive response from the NPCC to that submission.
Since then, the National Audit Office has independently engaged with the Home Office. The NAO records the Home Office as confirming both the six-week weeding mechanism and that this process contributes to the difference between police and DVLA stolen-vehicle data. The Home Office has also told the NAO that it is discussing whether the confirmation requirement should be removed from LEDS.
The chronology therefore raises a question which is highly relevant to the section 14 assessment:
If the NPCC considers that I have raised this matter too many times, what effective action or assurance has occurred in response to those earlier approaches such that further enquiry has become unreasonable?
Persistence with an answered and resolved matter may be unreasonable. Persistence because an identified national data-quality problem remains unresolved, while new evidence continues to emerge, is materially different.
Indeed, the history relied upon by the NPCC arguably supports rather than undermines the serious purpose of the present request. It demonstrates that the concern has existed for some time; that the NPCC has itself recognised it; that national reminders have been issued; and that there nevertheless remains no identified national measure of the scale of inappropriate weeding or assurance that the reminder process has solved it.
That is why VE602/VE602J has now become important.
The request does not revisit the question “does weeding exist?”. That is established.
It seeks to move the enquiry forward and establish:
the scale at which unconfirmed LoS reports reach the VE602J two-week reminder stage;
the number which remain unconfirmed and are subsequently weeded at six weeks;
whether those outcomes are monitored or analysed nationally; and
who provides assurance that genuinely outstanding stolen vehicles are not being lost from the system through administrative non-confirmation.
Those questions have not previously been answered.
The list of 16 references materially overstates the number of independent requests
The refusal lists 16 references and describes them as “multiple similar requests” which “have all been received in relation to stolen vehicles”.
That presentation requires closer analysis. The list of 16 items expressly includes, the following 7:
i. 450/2024 – IR of 426/2024
ii. 012/2025 – IR of 425/2024
iii. 039/2025 – IR of 014/2025
iv. 044/2025 – ICO Appeal
v. 2266/2025 – arising from the NaVCIS request
vi. 2298/2025 – ICO Appeal
vii. 2859/2026 – IR of 2838/2026
and possibly other references which are procedural continuations or closely related follow-ups rather than independent originating requests.
Internal Reviews and ICO appeals should not simply be counted as though each represents another unsolicited substantive FOIA request.
Indeed, the ICO has previously addressed precisely this type of problem in another case concerning my requests. In decision IC-355444-P4T3, the Commissioner was not persuaded by an authority’s reliance upon an inflated number of overlapping requests and noted that the actual number of distinct FOI requests was significantly smaller. Coincidentally, the police constabulary concerned also did little more than provide a list of references without request dates or a brief explanation of the request and similarity:
https://carcrime.uk/250829-ico-gwent-police/. The misrepresentation is currently subject of a police investigation.
The Commissioner also recognised that requesting an Internal Review was reasonable where the original response had not fully dealt with the scope of the request.
I therefore ask the reviewer to distinguish between:
- originating information requests;
- Internal Reviews;
- ICO appeals;
- correspondence arising from an authority’s response; and
- genuinely separate subject matters advising:
a) date of the request
b) the similarity claims (other than ‘Vehicle related’)
A raw total of reference numbers does not demonstrate a disproportionate burden.
The refusal demonstrates that the NPCC is able readily to identify and aggregate historic correspondence attributed to me. That makes the absence of dates, subject-matter analysis and differentiation between originating requests, Internal Reviews and appeals particularly difficult to understand.
“All concerning stolen vehicles” is too broad a basis for aggregation
The refusal says the listed matters “have all been received in relation to stolen vehicles”.
That is an extremely broad subject classification.
Previous matters have included, amongst other things:
• ACRO attribution of LoS records – ‘ACRO’ being associated with PNC on/off records
• communications/dissemination of guidance;
• disclosure of vehicle makes and models – the NPCC’s determination as the basis to withhold information, on which they quickly u-turned.
• national theft data;
• vehicle-theft investigations;
• differing operational issues concerning PNC records.
The fact that these matters ultimately concern vehicles or stolen vehicles does not make them all repetitions of the present request. Indeed, none are; the current request clearly follows a distinct path:
• Years of enquiries & consideration
• Approaches to various parties to highlight the issue
• An understanding of the VE602 process
• A request of the Home Office for VE602 data – only to be informed this authority considers themselves to be a ‘processor’ for the purposes of the information and referred me to the NPCC
• My request of the NPCC
The present request concerns one specific technical and governance mechanism: VE602/VE602J, its outputs and the national assurance arrangements surrounding six-week weeding.
ICO guidance recognises that previous requests may form part of a section 14 assessment, but it does not suggest that an authority can aggregate every request falling within a very broad subject category without considering the degree of actual overlap. Simply counting requests “will not reveal the full story” – ICO link above – ‘How do we consider burden, motive and harassment?’
The temporal argument is weak
The refusal states that requests have been numerous and made in quick succession, including before the NPCC had an opportunity to respond to earlier requests.
Yet the schedule relied upon is predominantly historical.
The current request was made on 29 July 2026. The list cited against me contains references dating principally from 2024 and 2025. Only one distinct originating request in the list is identified as a 2026 request, namely 2838/2026, with 2859/2026 being its Internal Review.
Two requests in 6 months are considered ‘quick succession’?
That is materially different from a pattern in which numerous overlapping requests are presently being submitted within days of one another.
Moreover, the current request arose only because new information had emerged in July 2026 concerning VE602J and because the Home Office directed me to the NPCC. It could not sensibly have been made in this form in 2024 or 2025.
There has been a substantial change in the evidential position
The Home Office has now confirmed that:
• Lost/Stolen reports are created unconfirmed;
• VE602J issues reminder notifications;
• records still unconfirmed at six weeks are weeded; and
• VE602J report notifications are archived, with the last four runs stored.
The Home Office expressly corrected its previous statement that report notifications were not stored writing
29/07/2026, the Home Office wrote::
‘There was some misunderstanding here regarding the storage question, and so it was not
correct for us to say that the report notifications are not stored. The report notifications
created by VE602J each week and sent to forces are archived, and so the last four runs
are stored.’
This is new information.
The Home Office added:
‘the Home Office acts as a processor in relation to vehicle data on the PNC. Any information we hold is held on behalf of the police forces that use the system and therefore does not fall within
the scope of the FOI Act.
Given the subject matter of your request, the National Police Chiefs’ Council may be able
to assist you. Contact details can be found on the NPCC website at
https://www.npcc.police.uk.’
It directly prompted the current enquiry about whether the NPCC receives or accesses those reports and who provides national assurance.
29/07/2026 is the date of the subject request to the NPCC – https://www.whatdotheyknow.com/request/national_governance_and_assuranc
A request prompted by newly disclosed information cannot fairly be characterised simply as unreasonable repetition of historic enquiries.
- Burden has not been demonstrated in relation to this request
The NPCC states that there are only two FOI decision-makers and that its threshold for grossly oppressive burden is therefore lower than that of a larger authority.
I do not dismiss the resource constraints of the FOI team.
However, the refusal provides no estimate of the work required to answer the present request.
There is no indication of:
• how many repositories would need to be searched;
• how many staff would need to be consulted;
• whether the VE602 reports are held;
• whether governance documents are held;
• how long the searches would take;
• how much information would need to be reviewed;
• or why the current request itself is particularly burdensome.
The request is focussed.
If the NPCC holds no VE602 reports and no governance information, the substantive response may be very short, ideally advising who does hold the information, to whom the Home Office should have referred us.
If it does hold such material, the request asks for identifiable categories of existing information.
The ICO’s guidance states that where burden is the primary concern, authorities should consider whether section 12 is applicable and, particularly where a request is otherwise reasonable, should consider assisting the requester to narrow it before relying upon section 14.
No such attempt was made here.
I expressly sought to minimise burden
My request was deliberately constructed to avoid unnecessary searches.
I did not seek:
• individual VRMs;
• personal data;
• victim information;
• operational case files;
• all historic VE602 reports;
• or a national reconstruction of every weeded vehicle.
I asked primarily whether recorded information existed concerning receipt, analysis and governance and, if a report was held, for the most recent example.
This was intended to establish who owns or assures the process, not to impose a large data-extraction exercise.
If any part of the request were considered disproportionately burdensome, I would have been willing to narrow it further.
Motive
The refusal recites “motive” as one of the broad Dransfield themes but identifies no improper motive in this request.
• What does the NPCC believe my motive is, given the concerns I have presented to them about this issue which they appear powerless to address?
The motive is straightforward and has remained consistent:
• to understand the weeding process
• to determine whether valid Lost/Stolen vehicle records are being removed from national systems because the confirmation process has not been completed,
• how often that occurs i.e. the extent of the problem
• what national assurance exists to prevent or identify it.
I believe, I have a good grasp of the weeding process.
I have established that inappropriate weeding occurs; the NAO has independently confirmed that the weeding process contributes to the police/DVLA data difference. What remains unknown—and what the VE602 information may help establish – is the scale
I am not claiming to know the answer; you are using FOIA to try to find it. I cannot filter out those VRMs that are removed from the PNC LoS register for reasonable grounds and those which have been weeded. I do not believe any constabulary or authority could extract such ‘reasonable grounds’ from their recovery statistics – constabulary records are generally poorly kept, reliant on manual, not compulsory update sin many respects.
However, I have determined that weeding records are the subject of a simple process, contained within a single form, a VE602. Additionally, that these alerts are held by the Home Office, a data ‘processor’ and therefore not disclosing the data, on behalf of the NPCC.
The Home Office says it holds PNC information on behalf of police forces and says the NPCC “may be able to assist”. Obviously. My next port of call was the NPCC
The questions that now seem pertinent are
• Why, despite the NPCC’s previous interventions, does the issue appear to persist, and what assurance exists that those interventions have been effective?
• Why is weeding still occurring?
A simple question, given the time I have applied to this and that I have alerted the NPCC to the issue on several occasions is:
• Why should I even have to make such a request; why does the problem persist?
That concern is supported by actual examples of vehicles being weeded while still outstanding. In one Surrey case, the force explained that the DAF safety-net report had not been addressed because of a backlog, the record weeded, and it was re-entered five days later.
Gwent police manually override weeding; in late 2024 (following concerns I raised) they instructed staff to confirm LoS reports when they are made. Clearly, the process is unnecessary. However, as evidenced by subsequent events, this directive was overlooked as more inappropriately weeded cases were identified. More troubling, Gwent did not have the resources to monitor the two and six weeks alerts.
An ongoing matter, which appears to be the result of weeding, saw a VRM removed from the LoS register 01/06/2026 and not returned for 2 months.
An investigation into Gwent police weeding matters is ongoing but my recent analysis places them in the top 5 of constabularies with the largest difference in LoS matters reported to them and those received by the DVLA; a discrepancy of over 60%
This is therefore an evidence-led enquiry into the integrity of national policing data, not a personal dispute with the NPCC or its staff.
A further Gwent Example
A current Gwent Police matter illustrates why the question remains live. A Lost/Stolen marker relating to a vehicle which remained outstanding was removed from PNC on 1 June 2026 and remained absent for approximately two months. The precise mechanism responsible is presently under enquiry; the timing and circumstances are consistent with six-week weeding, but I do not rely upon that conclusion until the force has established the facts.
What is beyond dispute is that a vehicle reported stolen and apparently still outstanding ceased for a substantial period to display the LoS marker upon which policing, DVLA notification and third-party provenance systems depend.
That is exactly the type of occurrence which national assurance ought to be capable of identifying and explaining.
Harassment or distress has not been evidenced in relation to this request
The refusal relies upon general statements concerning harassment and refers to Rod Cooke v IC, a case involving years of correspondence directed at a small parish council operated by volunteers and a part-time clerk.
That factual context is materially different.
The NPCC is the national coordinating body for policing. The request concerns an issue on which the NPCC itself has previously taken national action by circulating Chief Constables.
Nothing in the request is offensive, accusatory, threatening or personally directed at staff.
The refusal does not identify any wording or feature of this particular request capable of causing harassment or distress.
I appreciate that volume of correspondence can itself contribute to burden. But there is no ‘volume’. Furthermore, that is not the same as establishing that a narrowly worded public-interest request concerning an unresolved national governance question is manifestly unjustified.
The reliance upon IC-387981-N0T4 requires considerable caution
The refusal says that decision notice IC-387981-N0T4 involved “almost identical circumstances”.
I respectfully disagree.
That decision concerned a request dated 4 April 2025 seeking extensive vehicle-level information concerning NPCC/NaVCIS PNC submissions over two calendar years, including make, model, recovery information, vehicle age, value, offence classifications, policies, seizure criteria and numbers of complaints. The request sought financial information about a police/private partnership that sees those with access to police information effectivley repossessing vehicles and are incentivised to do so.
The current request is materially different.
It seeks a very limited body of recorded information concerning:
• whether the NPCC receives VE602J reports;
• whether it holds aggregate or assurance information;
• its governance role; and
• the responsible authority if that role sits elsewhere.
The earlier ICO decision itself accepted that vehicle crime is a serious issue and acknowledged relevance to policing and insurance. Its conclusion turned substantially upon the specific volume and overlap of correspondence then occurring and the anticipated further engagement generated by that request.
Furthermore, that decision is presently under appeal to the First-tier Tribunal under reference FT/EA/2025/0440. The ICO’s own public record expressly records that status – ICO link
It is therefore wrong to treat that decision as conclusively determining the status of materially different future requests, and particularly one arising from significant new evidence obtained after the ICO considered the earlier matter.
The earlier ICO decision itself said persistence alone was insufficient
There is an especially important passage in IC-387981-N0T4.
The Commissioner observed that the previous requests ‘could be’ regarded as tending towards unreasonable persistence on a ‘particular topic’, but expressly stated that this would not, in itself, be sufficient to render the request vexatious.
That principle is directly relevant here. The current refusal appears to move very quickly from:
• previous requests concern stolen vehicles
to:
• therefore the latest request represents unreasonable persistence and section 14 applies.
The reviewer should instead undertake the holistic balancing exercise required by Dransfield, with particular weight given to the substantially increased serious purpose and the limited burden of the present request.
- The NPCC’s own conduct demonstrates that the issue has serious purpose
The NPCC cannot readily characterise the subject as lacking sufficient value while overlooking its own earlier intervention.
Its November 2024 circular expressly:
• sought the assistance of Chief Constables;
• referred to the “accuracy and completeness” of PNC stolen-vehicle records;
• identified unconfirmed vehicles dropping off PNC as causing inaccurate vehicle status; and
• asked forces to address the issue.
That is powerful evidence that the matter was considered significant enough to justify national intervention.
The current question is what happened thereafter and what assurance exists that the process is working.
That it is understood the guidance was reissued and the matter was again referred to the NPCC by the NVCRP does not simply convey the seriousness of the issue but also that the NPCC’s actions have been ineffectual, require return consideration.
National governance remains unresolved
The emerging evidence is concerning not because it proves that every weeded record is erroneous, but because responsibility is unclear.
The Home Office describes itself as processor, although it generates VE602J reminders and retains the last four runs. It has directed enquiries to the NPCC.
Whilst the Home Office has thereby avoided my questions about the extent fo the problem, it has engaged in an exchange with the National Audit Office with whom I (not the Home Office or the NPCC) raised concerns.
The Home Office has confirmed weeding is giving rise to the discrepancy in the number of vehicle recorded stolen at the DVLA and by the police. The police, the Home Office and NPCC are aware:
STILL-OUTSTANDING STOLEN VEHICLES CAN CEASE TO BE RECORDED AS STOLEN ON THE PNC — AND NEVER REACH THE DVLA — WHEN THEIR LoS REPORTS ARE NOT CONFIRMED BEFORE AUTOMATIC WEEDING.
This reinforces why VE602 matters: I am asking for precisely the information that may allow the scale to be measured.
Regarding stolen vehicles, how much more serious can the issue be; the current system is capable of benefiting those in possession of stolen vehicles by removing an important policing marker, while prejudicing recovery opportunities, victims, insurers, provenance providers and potentially innocent purchasers.
The current request therefore asks a very simple governance question:
• Who, at national level, receives, reviews or assures the operation of the VE602J weeding mechanism?
If the NPCC has no such role, that in itself is useful information and may be answered succinctly.
If it does have such a role, there is a strong public interest in understanding it and addressing the issue.
The NAO has understandably stated that it does not presently intend to conduct further work on the matter. It is an audit institution, not the body responsible for day-to-day policing data governance.
The question therefore returns to the bodies responsible for PNC/LEDS and national policing governance.
• The Home Office has directed me to the NPCC
• The NPCC has responded by refusing even to establish what information it holds.
This illustrates rather than resolves the central problem:
• who is taking responsibility for assuring that genuine outstanding stolen-vehicle records are not being lost through administrative non-confirmation?
The practical importance of identifying weeded records
The issue is not confined to statistical accuracy.
Where a genuinely outstanding stolen vehicle has been weeded because its LoS report remained administratively unconfirmed, there are potentially identifiable consequences.
An audit capable of identifying such records could establish whether, during the period in which the vehicle ceased to show as stolen:
the DVLA record was subject to keeper or other relevant activity;
the vehicle or registration was queried on PNC;
vehicle provenance enquiries were undertaken;
ownership or keeper details subsequently changed; or
investigative or recovery opportunities may consequently have been missed.
There is also an obvious potential impact upon an innocent purchaser who acquires a vehicle during a period in which authoritative systems fail to disclose its true stolen status.
These are precisely the reasons why establishing the volume of inappropriate weeding is important. The enquiry is not statistical curiosity. It concerns recovery of stolen property, policing opportunities, victims, insurers, data users and potentially innocent purchasers.
The request has generated external public and institutional interest
This research is no longer confined to private correspondence.
The NAO considered the matter sufficiently significant to approach the Home Office and specifically ask what remedial action was intended.
The issue has also now attracted wider industry and media attention, based upon my large national comparison of police and DVLA data. The conservative analysis identifies a 20,282-record difference for 2025.
I mention this not to suggest that media interest determines FOIA rights, but because it materially demonstrates objective public interest and serious purpose, which the NPCC’s balancing exercise is required to consider.
Section 16 and less restrictive alternatives
The refusal includes section 16 in its annex but does not identify any meaningful advice or assistance offered before section 14 was applied.
ICO guidance recommends that authorities considering section 14 should consider viable alternatives and, particularly where burden is the concern, explore whether a requester is willing to refine the request. ICO link.
The ICO also advises authorities contemplating section 14 to review the position carefully, consult the appropriate decision-makers and recognise the importance of the Internal Review as an opportunity genuinely to reconsider the decision. ICO link.
Which ‘decision makers’ were consulted?
I therefore expressly confirm that if some element of the present request imposes a difficulty, I remain willing to consider sensible narrowing rather than requiring the NPCC to undertake disproportionate work.
That willingness should not be interpreted as altering the original request for Internal Review purposes; it is simply an invitation to resolve the matter constructively.
A difficult irony in the section 14 decision
There is an uncomfortable irony in the basis of the refusal.
The NPCC relies upon the number of occasions on which I have raised vehicle-weeding and related matters as evidence supporting section 14.
Yet that history also demonstrates that the NPCC has been on notice of the concern for a considerable period.
Its own national communications demonstrate that it recognised the risk. Subsequent reminders demonstrate that the first intervention did not finally resolve it. The more recent NAO/Home Office evidence now demonstrates that weeding contributes to the national police/DVLA data difference.
Against that background, the fact that I have continued asking what is happening is not readily separated from the fact that the underlying question remains unanswered.
• If the concern has been raised too often, the obvious counter-question is: what has been done to establish that the problem has actually been resolved?
I am not asking the Internal Reviewer to adjudicate upon the merits of abolishing weeding. I am asking that the reviewer recognise the substantial and evolving public-interest purpose behind seeking information capable of establishing its scale and governance.
What I ask the Internal Reviewer to determine
I respectfully ask the reviewer to reconsider section 14(1) and specifically address:
a) The actual burden of this request, rather than relying primarily upon historic workload.
b) The distinction between substantive requests, Internal Reviews and ICO appeals in the list of 16 references.
c) The actual degree of overlap between the previous matters and the VE602J governance request.
d) The age and frequency of the previous requests, particularly the fact that most references relied upon originate in 2024 or 2025.
e) The changed factual circumstances, including the Home Office’s recent confirmation concerning VE602J and archived reports.
f) The NPCC’s own November 2024 national circular, demonstrating that the subject had sufficient significance to warrant intervention.
g) The objective serious purpose now evidenced by the national police/DVLA data comparison and NAO/Home Office engagement.
h) Whether any improper motive exists; none is identified in the refusal.
i) What harassment or distress is caused by this particular request, as opposed to general reliance upon historic correspondence.
j) Why IC-387981-N0T4 is said to involve “almost identical circumstances” when its underlying information request was materially broader and concerned different information, and when that decision is itself presently under appeal.
k) Whether assistance or narrowing could reasonably have avoided reliance upon section 14.
The speed and apparent basis of the section 14 assessment
I also invite the reviewer to consider the speed with which section 14 was applied.
My request was submitted on 29 July 2026. The section 14 refusal is dated 5 August 2026.
I welcome prompt FOIA decision-making and do not criticise the NPCC merely for responding quickly. However, the speed of the refusal is difficult to reconcile with an important part of the reasoning relied upon to justify it.
The NPCC describes a significantly resource-constrained FOIA function, comprising only two decision-makers, and says my correspondence has created disproportionate demands extending beyond that team into other business areas and requiring discussion with Senior Management.
Yet within approximately five working days of this request, the NPCC was apparently able to identify and consider a substantial history extending back to 2024, encompassing numerous request references, Internal Reviews and ICO proceedings; consider the cumulative effect of that history; assess burden upon other NPCC business areas; take account of Senior Management discussions; consider previous ICO decisions; and undertake the holistic balancing exercise required by section 14.
That raises a legitimate question as to the nature of the assessment actually undertaken.
If the historic correspondence is as extensive and burdensome as the refusal suggests, how was that substantial retrospective exercise completed so readily, while apparently no attempt was made to establish whether the narrowly defined VE602/VE602J information requested was held and could simply be disclosed?
This is particularly relevant because the request was deliberately limited. In essence, I sought to establish whether the NPCC receives or retains VE602J reports, whether it holds aggregate or assurance information derived from them, and what recorded information identifies responsibility for national governance of the process.
I therefore ask the reviewer to be satisfied that the decision of 5 August resulted from a genuine individual assessment of this particular request and its circumstances, rather than the application of a pre-existing position concerning my previous use of FOIA.
That distinction is important. The existence of previous requests may properly form part of a section 14 assessment, but it cannot remove the requirement to consider the value, purpose, burden and circumstances of the request actually before the authority.
Given the limited questions asked, it is not apparent from the refusal that establishing whether the NPCC holds the specified VE602/VE602J material would necessarily have required more work than the historical analysis undertaken to support the section 14 refusal.
Conclusion
I recognise the NPCC’s entitlement to protect finite resources from genuinely disproportionate FOIA use. Equally, section 14 is a significant restriction upon the statutory right of access and the ICO describes the threshold as a high one.
The request of 29 July 2026 is concise, specific and prompted directly by new information provided by the Home Office. It seeks to establish responsibility and assurance for a national PNC process which:
• the NPCC itself has previously identified as capable of producing inaccurate stolen-vehicle records;
• the NAO has now raised with the Home Office;
• the Home Office has confirmed contributes to the difference between police and DVLA data;
• is under consideration in relation to the design of LEDS; and
• is associated with a substantial, independently assembled national data gap.
Against that background, I do not consider it reasonable to characterise this request as a manifestly unjustified, inappropriate or improper use of FOIA merely because I have previously investigated vehicle crime matters.
I therefore ask that section 14(1) be withdrawn and that the request be processed in the ordinary way.
If the reviewer nevertheless maintains section 14(1), I would ask that the review provides a sufficiently specific explanation addressing the issues above so that the factual and legal basis of the decision can be properly understood and, if necessary, considered by the Information Commissioner.
Yours faithfully,
Appendix A. 25/06/2026 NAO letter POTENTIAL SYSTEMATIC UNDER-RECORDING OF STOLEN VEHICLES
Reference GF 3845-26
POTENTIAL SYSTEMATIC UNDER-RECORDING OF STOLEN VEHICLES
Thank you for contacting the National Audit Office (NAO) setting out your concerns about the reporting of stolen vehicles. You raised concerns around the practice of “weeding”, whereby lost or stolen (LoS) markers are removed from vehicles when a report is not confirmed within six weeks.
Your correspondence has been passed to me as the NAO Director responsible for the Home Office.
The NAO and the Comptroller & Auditor General (C&AG), who is head of the NAO, are both independent of government. Our functions are to audit and express an opinion on the accounts of government departments and other central government bodies, and to carry out examinations into the economy, efficiency and effectiveness with which government departments and other public sector bodies have used their resources.
I read with interest the information you provided and my team has met with an official at the Home Office to discuss the matter. As you set out, when a vehicle is reported as stolen to a local police force, an LoS marker is registered on the Police National Computer.
The LoS marker is initially labelled as unconfirmed, enabling police officers to conduct due diligence before confirming that a theft has occurred. At that point the status is changed to confirmed. Only once an LoS marker is labelled as confirmed is it included in the report available to the DVLA. If the report remains unconfirmed after 6 weeks, it is removed from the PNC – the process known as “weeding”.
The official my team spoke with confirmed that it is this process which leads to the discrepancy between the police and DVLA databases, with the police database including both unconfirmed and confirmed vehicle thefts and the DVLA database holding only the latter.
We asked the Home Office what remedial action it planned to take to address the data gap. You may be aware of the National Law Enforcement Data Service (LEDS), which we previously examined in our 2021 report, The National Law Enforcement Data Programme. This is a national policing system designed to replace the functionality provided by the Police National Computer.
The Home Office told my team that it is in discussions with police forces to understand whether it is appropriate to remove the LoS confirmation step from the new functionality being created through LEDS. Should this step be taken, it would remove the data discrepancy caused by “weeding” at the six-week mark. The official confirmed that there was no timetable for making this change.
You may be interested to consider a further source of data on vehicle theft: the Crime Survey for England and Wales. The relevant data for the most recent and other years are here: Nature of crime: vehicle-related theft – Office for National Statistics.
These include data on the proportion of vehicles that, once stolen, are returned to their owners. The Office for National Statistics uses the Crime Survey to estimate the changing incidence of certain crimes over time. The data for vehicle theft, since 1981, are available in tables A1a and A1b here: Crime in England and Wales: Appendix tables – Office for National Statistics.
I do not intend to conduct further work on this matter at this time. However, given the importance of LEDS, it is possible we will consider the programme again in future.
Thank you again for bringing your interesting and informative research to our attention.
Yours sincerely,
Dr Tim Phillips,
Director, Home Affairs
Appendix B. 30/06/2026 – Home Office FoIA Request – DAF VE602
DAF VE602 PNC LoS Weeding Reports to Constabularies
To the Home Office
I am advised:
‘Home Office PNC Services generate and issue a weekly weeding/reminder report (DAF VE602 or similar) to police forces; and that this report includes statistical outputs relating to the number of vehicle records weeded, including distinctions between confirmed and unconfirmed reports’*
please provide the last report (referred to above) or if not retained, please explain why not and provide the next available report with the date this was issues.
I anticipate this report will:
- not provide VRMs
- provide:
a. the date of theft report for each entry
b. separate 2 week & 6 week notifications
c. identify the constabularies concerned
d. be supplied in spreadsheet format – csv would be acceptable
I am seeking to ascertain the number of VRMs notified to constabularies as being potentially subject to weeding due to NOT being ‘confirmed’ at 2 and at 6 weeks.
I wish to be provided the information per constabulary.
if a separate report conveys the number of weeded matters , this would be appreciated.
Additionally, if there has been any recent consideration of weeding i.e. since 01/01/2026, this too would be appreciated. I do not need a copy of the PNC users manual – , section 9 deals with the matter
Appendix C. 06/07/2026 – clarification to the Home Office re FoIA 9165
Further to my request, I understand:
- the National Audit Office has raised the issue with the Home Office
- The Home Office is discussing with police forces whether the Lost/Stolen confirmation step should be removed from LEDS, the replacement system for PNC.
The Home Office has indicated that operational matters concerning PNC Lost/Stolen markers, weeding, completeness of police-held stolen vehicle data and associated assurance activity sit with the NPCC. I understand that day-to-day operational use of PNC may sit with police forces and/or NPCC structures. However, it is difficult to reconcile a simple “NPCC matter” position with the NAO’s account that a Home Office official was able to confirm the mechanism, confirm the cause of the discrepancy, and explain that the Home Office is discussing with police forces whether the Lost/Stolen confirmation step should be removed from LEDS.
The Home Office does send a weekly report to forces. That appears to engage more than local operational policing. It concerns national system design, PNC / LEDS functionality, DVLA-facing data flows, data integrity, crime statistics and public protection.
It also appears relevant that the Home Office issues or maintains PNC user material – for example, the PNC User Manual. If the Home Office has a role in the manual, the system, LEDS replacement functionality, or the national technology framework within which this process operates, then it appears there is a substantial interest in 6-week weeding and its consequences
Appendix D. 29/07/2026 – The Home Office Response – referral to the NPCC
FoIA 9165 – VE602
Freedom of Information Act 2000 Request (Our Reference: FOI2026/09165)
Thank you for your email of 03 July 2026 in which you ask for a copy of the latest weekly weeding report that is issued to police forces. A full copy of your request can be found in Annex A. Your request has been handled as a request for information under the Freedom of Information Act 2000.
As stated in our response to FOI2023/04138 of 31 October 2023, the Home Office acts as a processor in relation to vehicle data on the PNC. Any information we hold is held on behalf of the police forces that use the system and therefore does not fall within the scope of the FOI Act.
Given the subject matter of your request, the National Police Chiefs’ Council may be able to assist you. Contact details can be found on the NPCC website at https://www.npcc.police.uk
Appendix E. 29/07/2026 FoIA to the NPCC – VE602
https://www.whatdotheyknow.com/request/national_governance_and_assuranc
Dear National Police Chiefs’ Council,
The Home Office has advised, in response to FOI2026/09165, that it generates and issues VE602 (VE602J) vehicle weeding reports but considers those reports to be held on behalf of police forces.
https://www.whatdotheyknow.com/request/daf_ve602_pnc_los_weeding_report
The Home Office has suggested that the NPCC may be able to assist in relation to these reports.
I therefore seek the following recorded information held by the NPCC.
- Please provide any information which records, describes or explains whether the NPCC receives, accesses or retains VE602 / VE602J reports generated by the Police National Computer.
- Please provide any recorded information held by the NPCC derived from, summarising, analysing or otherwise referring to VE602 / VE602J reports, including any statistical, management or assurance information.
- Please provide any policy, guidance, governance documentation, terms of reference, meeting minutes, memoranda, reports or other recorded information describing the NPCC’s role (if any) in the governance, assurance or oversight of the VE602 / VE602J process or the associated vehicle weeding process.
- If the NPCC does not undertake such governance or oversight, please provide any recorded information identifying the organisation or authority responsible for national governance or assurance of the VE602 / VE602J process.
If the NPCC holds VE602 / VE602J reports, - please provide the most recent report, suitably redacted if necessary. If the report is withheld, please identify the exemption(s) relied upon and explain why they apply.
For clarity, this request is confined to governance, process and organisational responsibility. It does not seek personal data or individual vehicle records.
Yours faithfully