11. FoIA ‘Resources’ - Car Crime U.K.

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 refer to the precedent cited, specifically:

‘The burden must be proven to be grossly oppressive, and the test is whether a reasonable authority, with proper resources, should be expected to handle it.’.

I note the NPCC’s reliance on limited resources as a contributing factor in deeming my request(s) vexatious under Section 14(1) of the Freedom of Information Act 2000.

However, I refer to established ICO precedent which states:

“The burden must be proven to be grossly oppressive, and the test is whether a reasonable authority, with proper resources, should be expected to handle it.”
— ICO Guidance: Dealing with Vexatious Requests (source)

No indication was provided to me – either at the time of submission or cumulatively – that the NPCC was experiencing strain in processing my requests. I received no request to narrow, consolidate, or defer them. I would have welcomed the opportunity to cooperate and ease any perceived burden.

I primarily submit requests through the WhatDoTheyKnow platform to ensure transparency and avoid duplication by placing responses in the public domain for public reference. This reflects an intent to assist, not hinder, public bodies in managing demand.

It is also worth noting that responses I have received came from four different NPCC staff members, which suggested to me that a structured FOI team was in place, supported by operational capacity.

On NPCC Resources and Role

The NPCC represents at least 49 police forces across the UK (including England, Wales, Scotland, Northern Ireland, BTP, MDP, CNC, and Isle of Man). It also works collaboratively with:

The College of Policing,
The Home Office,
Other national and regional oversight bodies.

Given this significant national role, it is reasonable to expect that the NPCC would be appropriately resourced to manage its statutory obligations under FOIA.

I understand the NPCC has at least 4 employees associated with requests. This appears to be more than some constabularies. I am therefore surprised my approaches would be demanding upon the Authority.

Possibly the FoIA team are providing advice/guidance to the many constabularies they support causing a different, unusual burden?

Request Volume Context

While the NPCC publishes FOIA request information, national FOIA statistics from the Cabinet Office (April–June 2024) confirm that:

20,402 requests were received across monitored public bodies,
Representing a 31% increase compared to the same quarter in 2023.

If the NPCC’s request volume has similarly risen – and assuming it is consistent with national trends – the question arises: Has the NPCC scaled its FOI capacity accordingly?

Without transparency on the number of requests received or a record of correspondence requesting engagement or moderation, the claim that limited resources justify a Section 14 response appears premature and lacks necessary context.

Conclusion

Respectfully, I suggest that before invoking Section 14, authorities should:

Clearly communicate any concerns regarding resourcing or workload to the requester;
Offer an opportunity to modify or consolidate the request;
Provide meaningful context or comparative data when claiming excessive burden.

Absent those steps, the application of Section 14 appears disproportionate and procedurally unfair.

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The Request & Refusal:

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