27/08/2026 to Chief Constable Stephens – head of the National Police Chief’s Council
Sent: 27 August 2026 18:32
To: Gavin.Stephens@npcc.police.uk
Cc: info@npcc.police.uk; jon.vale@npcc.police.uk
Subject: requester-specific national circular issued by NPFDU on 25 June 2024
Dear Chief Constable Stephens,
I write again concerning CRU 603/24, the national communication dated 25 June 2024 which identified me and included the statement:
“I suspect that [SUBJECT] is keeping requests private on that site…”
I copy Chief Inspector Jon Vale because he responded to my original approach to your office.
On 8 May 2026, Chief Inspector Vale told me, on behalf of the NPCC, that he had reviewed my concerns and was satisfied that the CRU response was “entirely appropriate under the circumstances and in line with the established functions of the CRU.”
I challenged that conclusion and identified a series of important factual and governance questions which his response had not answered.
On 11 May, Chief Inspector Vale replied:
“I am not in a position to expand on my previous response…”
and:
“To be clear, I will not be engaging further on this matter.”
The position has since changed materially.
MPS complaint outcome PC/5233/26
Following Chief Inspector Vale’s direction that I take the matter to the Metropolitan Police Service complaints process, I did precisely that. I attach the resulting MPS complaint determination, their ‘outcome report’.
The MPS expressly considered the CRU communication, correspondence between myself and NPCC personnel including Chief Inspector Vale, explanations provided by NPCC personnel, and the available material concerning governance and subsequent handling.
Its conclusions included:
- Identification/content – service not acceptable.
- Only limited information was identified demonstrating an evidential basis for the statement that I was suspected of “keeping requests private”.
- Commentary concerning identifiable individuals should be evidence-based, necessary and proportionate.
- The absence of retained recipient information, distribution lists or associated metadata was identified as a shortcoming in record-keeping and auditability.
- Governance and decision-making – service not acceptable.
- Only limited documentary material was identified demonstrating governance considerations, dissemination oversight, proportionality assessment or formal audit arrangements.
- Handling of my concerns by NPCC personnel – service not acceptable.
- Chief Inspector Vale was specifically identified under that complaint head.
- The MPS expressly recorded that the correspondence stating that further engagement would not take place contributed to the substantive concerns remaining unresolved.
The MPS therefore reached materially different conclusions from Chief Inspector Vale’s assurance to me on 8 May that what had occurred was “entirely appropriate”.
The SAR disclosure itself
There is a further point which I believe now requires consideration. The offending communication was uncovered by the NPCC itself in response to my Subject Access Request NPCC SAR 1383. Yet, although that disclosure revealed that the CRU had circulated the statement that it “suspect[ed]” I was keeping requests private, the SAR material disclosed to me did not identify any underlying evidence, enquiry, factual material or reasoning supporting that requester-specific assertion.
That is significant. The NPCC disclosed the adverse commentary about me, but apparently no corresponding material demonstrating why it had been made.
Standing alone, I appreciate that the contents of a Subject Access Response cannot necessarily establish that no other information ever existed. However, the position can no longer be considered in isolation.
The sequence is now:
- my SAR disclosed the assertion but no apparent evidential foundation for it;
- the MPS complaint consideration subsequently identified only limited information demonstrating an evidential basis for the commentary; and
- when I later expressly requested recorded information, guidance, enquiries, briefings or other material held and relied upon in support of that statement, the NPCC responded “No information held”, a position subsequently maintained on internal review.
I therefore ask a very simple question:
- what was the evidential basis upon which an adverse, requester-specific suspicion concerning me was considered sufficiently sound to be circulated nationally?
The evidential basis has also subsequently been tested
There is now a further material development.
Through FOI 2962/2026 I specifically sought:
“Recorded information, guidance, policy, enquiries, briefings or other material held and relied upon in support of”
the statement that I was suspected of keeping requests private.
The NPCC answered “No information held” in relation to that part of the request.
That position was subsequently considered at Internal Review 3064/2026 and maintained.
I appreciate the important distinction between the absence of recorded information and proof that no individual could ever have held some unrecorded thought or belief. However, this now leaves a remarkably unsatisfactory position.
- The NPCC nationally circulated a speculative statement concerning an identifiable individual;
- I challenged its factual basis;
- Chief Inspector Vale initially defended the handling as entirely appropriate
- Chief Inspector Vale then declined to answer further questions;
- the MPS subsequently found the service unacceptable in three material respects; and
- the NPCC has since confirmed that it holds no recorded material of the kind specifically sought in support of the statement.
There is also a contradiction with Mr Vale’s 8 May answer. He wrote that the advice was based “solely on the application of FOIA legislation” and would have been issued in the same terms irrespective of identity. But the phrase “I suspect that Mr Swift is keeping requests private” plainly isn’t an explanation of FOIA legislation: it is a factual/speculative observation about me. My 11 May response already identified precisely that problem.
I do not consider that the unanswered questions can reasonably remain unanswered.
I therefore ask the NPCC Chair’s Office to answer the following
- Does the NPCC continue to stand by Chief Inspector Vale’s conclusion of 8 May 2026 that the handling of CRU 603/24 was “entirely appropriate”?
If so, please explain how that position is reconciled with the subsequent MPS findings.
- Does Chief Inspector Vale himself continue to stand by that conclusion?
I ask this specifically because it was his substantive assessment communicated to me before he declined further engagement.
- What was the factual basis for the statement that I was suspected of “keeping requests private”?
In answering, please take account of the fact that:
- NPCC SAR1383 disclosed the statement but did not disclose to me any apparent evidential foundation for it;
- the MPS subsequently identified only limited information demonstrating an evidential basis for the commentary; and
- FOI 2962/2026 and IR 3064/2026 subsequently confirmed that the NPCC does not hold the recorded information specifically sought in support of that statement.
If the NPCC cannot now identify the evidence upon which this nationally circulated statement was based, please say so plainly.
- Who received CRU 603/24?
If the complete recipient footprint cannot now be established, please confirm:
- what searches have been undertaken;
- what recipient/distribution information remains available;
- what is irretrievably unavailable; and
- why a nationally disseminated, requester-specific communication cannot now be fully audited.
- What was encompassed by the reference to the “Police network” and “other agencies”?
This question was expressly put to the NPCC in May and remains unanswered.
- What corrective action has now been taken regarding the requester-specific statement?
In particular:
- has CRU 603/24 been corrected, withdrawn or annotated;
- have systems holding it been amended or annotated;
- have recipients been advised that the evidential basis for the “keeping requests private” commentary has not been established;
- and, if none of those things has occurred, why not?
- What action has actually resulted from the organisational learning identified by the MPS?
I am not asking merely whether the finding was “brought to the attention” of personnel. I am asking what, if anything, changed as a result.
- Were the records identified in my preservation request of 25 May 2026 preserved?
That request expressly included drafts, internal discussions, approval/dissemination records, recipient information, records concerning the “keeping requests private” assertion, and records concerning both Chief Inspector Vale’s 8 May response and the subsequent decision not to engage further.
A response is now required
I am conscious that Chief Inspector Vale previously stated that he would not engage further. I am not seeking to reopen repetitive correspondence simply because I disagreed with an answer.
The difficulty is quite different.
The questions were not answered; the person who defended the conduct then declined further engagement; and subsequent independent complaint findings and NPCC disclosures have materially undermined important aspects of the position upon which that closure was based.
It would therefore be difficult to understand the NPCC continuing to rely upon the May 2026 decision not to engage as a reason for avoiding these questions now.
I am seeking a substantive response by reference to and addressing each numbered point.
If Chief Inspector Vale maintains that he will not respond, I ask that the Chair’s Office itself provides the answers or identifies the senior NPCC officer who will do so.
I would be grateful for a response within seven days.
Attachments: