9. NPCC FoIA ‘191 emails’

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.

The NPCC states, concerning my 6 FoIA requests:

  • Of those requests, the emails generated in processing each of the above totals 191 which includes internal emails relating to the request in retrieval efforts and request for clarification with you.

I note the reference to six requests (plus reviews) said to have generated 191 internal emails. However, the basis for this figure and its relevance to a vexatiousness determination under Section 14(1) of the Freedom of Information Act 2000 (FOIA) remains unclear.

1. Lack of Detail Regarding Burden

It has not been explained how these emails were generated, what proportion resulted from routine internal administration, or whether they stemmed from multiple staff seeking clarification, misunderstanding, or duplicative internal routing.

Without visibility of the correspondence or a breakdown of its content, it is not possible to assess whether the burden cited is a product of the requests themselves or internal handling inefficiencies. I respectfully request greater transparency on this point to enable an informed response.

2. Disproportionate Figures

The assertion that 191 emails were generated from six requests (averaging over 30 emails per request) appears inconsistent with my own communications with the NPCC and the visible records published on WhatDoTheyKnow. There is no indication that I have engaged in repeated, voluminous correspondence, nor that I have harassed or overwhelmed the authority — the typical indicators of vexatiousness outlined by the Information Commissioner’s Office (ICO).

See ICO Guidance: Dealing with vexatious requests (s14) Specifically, Paragraph 21 states:

  • “A request is not vexatious simply because it causes annoyance or inconvenience.”

3. Nature of the NPCC’s Role

It is my understanding that the NPCC functions primarily as a hub for FOI requests — managing receipt, referral to the relevant lead force or national lead, monitoring, and response. If that is the case, then the burden may be dispersed across other authorities, rather than falling solely on NPCC personnel. If internal emails reflect referrals or communications with external contributors or leads, this should not be portrayed as disproportionate effort by the NPCC itself.

I also acknowledge – and appreciate – that the NPCC frequently provides assistance and helpful referral advice. That cooperative spirit is inconsistent with the suggestion that my requests are vexatious or burdensome.

4. Value vs. Burden

ICO guidance makes it clear that burden alone is not sufficient for Section 14 to apply. The purpose and value of the request must also be weighed. In this case, the public interest in police transparency and consistency across national policing roles lends weight to the importance of the information sought.

See Decision Notice FS50521612:

“The Commissioner is of the view that a balancing exercise should be conducted… A public authority cannot simply cite a high volume of correspondence and conclude vexatiousness.”

Conclusion

In summary, I would be grateful if the NPCC could clarify:

  • How the 191-email figure was calculated.
  • What proportion of those emails involve third-party liaison?
  • Whether any of the correspondence cited reflects avoidable internal repetition or escalation.
  • Why did no prior warning or early engagement occurred if a vexatious pattern was believed to be developing?

I ask to be provided the 191 email to enable an informed comment to be made.

I do not believe my conduct meets the high threshold required for a Section 14 refusal. My intention has always been to obtain meaningful, purposeful information in the public interest, as evidenced by previous communications/requests and the influence on policy I have had.

NEXT PAGE – FoIA ‘Senior Management Discussions’

The Request & Refusal:

  1. The Request
  2. Refusal

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

  1. The Internal Review Request
  2. FoIA & ‘Vexatious’
  3. FLA & the FoIA
  4. FoIA ‘Value & Serious Purpose:
    1. Lack of Action/Information about vehicle theft
    2. NaVCIS – theft or fraud?
    3. Policing-Plus
    4. Vehicle Rental Companies
    5. The PNC – a Blunt Tool?
    6. NaVCIS funding
    7. NaVCIS Costs & Recovery
    8. NaVCIS LoS Skewing the figures?
  5. FoIA & ‘Motive’
  6. FoIA & ‘Burden’
  7. FoIA & ‘Overwhelming’
  8. FoIA ‘Distress &/or Obstruction’
  9. FoIA ‘191 emails’
  10. FoIA ‘Senior Management Discussions’
  11. FoIA resources
  12. FoIA & ‘Response Timeliness’
  13. FoIA ‘Prior FoIA Requests’
  14. FoIA ‘Similar Requests’