13. FoIA ‘Prior FoIA Requests’

Following a request made of the NPCC, FOI Ref: 2233/2025, which was refused citing s.14 – vexatious, the below and associated links are submitted to support an Internal Review request.

I note the reference to my prior Freedom of Information requests as a basis for applying Section 14(1). However, I respectfully submit that this reasoning is neither proportionate nor consistent with ICO guidance or case law.

The ICO clearly states:

“Public authorities must not automatically refuse a request simply because the requester has made previous requests.”

The Upper Tribunal in Information Commissioner v Devon County Council & Dransfield [2012] UKUT 440 (AAC) similarly confirmed that the key test is proportionality, and that authorities must weigh both the burden and the value or purpose of a request in context.

There is no indication in the NPCC’s refusal that this balancing exercise has been undertaken.

Nature and Purpose of My Requests

Although I have submitted other requests to the NPCC, each has been made in good faith and addresses distinct, publicly relevant issues – particularly surrounding vehicle crime enforcement and national policing coordination. This request is materially distinct in both content and objective.

The NPCC operates as a centralised body with oversight or coordination roles across 49 police forces, including England, Wales, the Crown Dependencies, and specialist forces (e.g., BTP, MOD, CNC). It also leads on topics such as vehicle crime, through partnerships including the recently announced National Vehicle Crime Reduction Partnership (NVCRP).

As many constabularies no longer maintain dedicated vehicle crime units, the NPCC’s function as a national point of contact (and potential source of thematic data) makes it an appropriate and, arguably, essential route for such requests.

In 2022, when the NPCC could not assist directly, I was appropriately referred to individual constabularies. I acted accordingly. This demonstrates constructive engagement on both sides.

Previous Engagement and Cooperation

Where previous requests approached the Section 12 cost threshold, the NPCC engaged helpfully – offering guidance, clarifications, and proposed revisions. I responded positively to those suggestions.

I have not been advised previously that my behaviour was causing disruption. I have not received warnings or indications that my requests were becoming excessive. Such engagement – had it occurred – might have resolved concerns amicably and without recourse to Section 14.

Context: National Initiatives and Public Accountability

My efforts to trace the history and progress of national vehicle crime initiatives — including the 2019 Vehicle Crime Taskforce and the 2024 NVCRP — have met repeated informational barriers. FOIA requests have returned conflicting or empty results, with relevant authorities stating that meeting notes, records, or even awareness of certain initiatives are “not held.”

These gaps are themselves cause for concern and substantiate my request. They highlight the need for clarity, record-keeping, and transparency from national policing bodies on matters affecting public safety and resource allocation.

My 2019 submission to the Vehicle Crime Taskforce — a 19-page document raising detailed concerns — cannot now be located by any of the authorities to whom it was sent. I am now attempting to understand what (if anything) came of that initiative and what role the NPCC played in its development or subsequent strategies.

Conclusion: A Pattern of Constructive Conduct

I do not submit unfounded accusations. I am mindful of tone, lawfulness, and the need to avoid disruption. If my requests have occasionally required clarification, I have been responsive and willing to revise. In return, I have appreciated the assistance I previously received from the NPCC – which stands in contrast to the current refusal under Section 14.

This current request is proportionate, clearly stated, and grounded in a legitimate public interest. I believe it deserves consideration on its own merits and should not be dismissed based on prior, unrelated correspondence that was neither excessive nor vexatious.

NEXT PAGE – FoIA ‘Similar Requests’

The Request & Refusal:

The Internal Review (IR) submissions are provided on the associated pages: