7. FoIA & ‘Overwhelming’

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 am writing in response to your assertion that my FOIA request is potentially vexatious under Section 14(1), due to it being part of a series of requests allegedly submitted in quick succession, and which cumulatively amount to a “tipping point” of burden.

I respectfully contest this characterisation. While I acknowledge that I have made several requests (6 are cited in 2024 & 2025) to the NPCC, each has been distinct in scope, topic, and objective. I believe a closer examination of the context, substance, and chronology of my requests will demonstrate that the use of Section 14(1) in this instance is unjustified.

The number of requests cited about this matter, those considered by the NPCC to be ‘similar’, number 6; 3 in 2024 and 3 in 2025. I had not realised my approaches would be overwhelming and question such a response.

The NPCC is a hub for vehicle crime information, with NaVCIS falling under their remit, issuing guidance with their vehicle lead heading the latest vehicle crime task force. In 2023, the Home Office wrote:

‘The Government is committed to tackling vehicle crime and catalytic converter theft.

We are working closely with police and motor manufacturers through the National Vehicle Crime Working Group (NVCWG), chaired by ACC Jennifer Sims, the National Police Chiefs’ Council lead for vehicle crime, to take forward a programme of work to prevent and reduce theft of and from vehicles. This includes training police officers on methods used to steal vehicles, encouraging vehicle owners to secure their vehicles and working with industry to prevent theft. Through the NVWG a network of vehicle crime specialists has been established, involving every police force in England and Wales, to ensure better sharing of information and intelligence.’

UK Parliament written questions, statements & answers

More about the NVCWG can be read here – the response to an FoIA request of the NPCC. Seemingly, the NPCC do not keep minutes of their meetings.

In mid-2024, the National Vehicle Crime Reduction Partnership was announced. This also falls to the NPCC . It appears it has yet to meet yet is intended to address matters raised by the NVCWG … and the 2019 Vehicle Crimes Taskforce.

It is unsurprising the NPCC is the go-to organisation for vehicle theft-related information concerning prevention & detection of the crime and apprehension & prosecution of offenders

The NPCC has provided no dates associated with the requests being referred to; date of request, response and any resulting challenge/clarification.

If a request is submitted before a previous one has been addressed, this results from the two matters being unconnected. However, again, the NPCC does not cite examples from which to ascertain dates/subject matter and, in turn, make informed comments.

I do not ‘consistently submit requests within days of each other’; 6 requests are cited over many months. It is obvious these will, if clarification or review is sought, overlap.

Where a request is running and information is sought in relation to another matter, expecting a requestor to await the outcome of a previous, or any existing request, is unreasonable.

Certainly. Here is a carefully structured and legally grounded rebuttal to the NPCC’s statement that your request is vexatious due to being part of a pattern of frequent or successive requests. This response is written in a clear, firm, and professional tone consistent with your previous approach and reflects both relevant case law and ICO guidance:

Volume or Frequency Alone is Not Vexatious

The ICO’s guidance makes clear:

“You should not automatically refuse a request simply because the requester has made a series of requests in the past.”
— [ICO: Dealing with Vexatious Requests, Section 2.2]

The Upper Tribunal in Dransfield noted:

“A requester who consistently submits multiple FOIA requests or associated correspondence within days of each other… is more likely to be found to have made a vexatious request.”
— [Dransfield, [2012] UKUT 440 (AAC), para 32]

However, the Tribunal was clear that context, substance, and proportionality must be considered. The case does not stand for the proposition that all frequent or clustered requests are automatically vexatious. A request must be assessed on its own merits, taking into account intent, value, and burden.

Timing: Requests Submitted Responsibly

The submission of requests prior to receipt of full responses is not done recklessly or in bad faith. In many instances:

Responses are delayed, and where timelines are unclear, follow-up or new requests are appropriate;
Requests are thematically distinct but arise from a common line of inquiry (e.g. stolen vehicle processes, NaVCIS, PNC procedures), which naturally cluster;
The WDTK platform records request timings publicly and supports accountability.

Moreover, where clarification has been requested, I have made every effort to cooperate and limit scope where appropriate.

Pattern Does Not Equal Harassment

While the NPCC refers to a pattern of requests, no evidence has been provided that this has caused:

Harassment of staff;
Intemperate or offensive communication;
Malicious or improper use of FOIA.

Indeed, in all my correspondence, I have remained:

Cordial and focused on public interest issues;
Willing to refine or clarify queries;
Open to engagement with staff to limit burden and improve retrieval.

The ICO makes clear that Section 14(1) must only be used where there is a disproportionate impact, and not where a requester is simply persistent or thorough in matters of legitimate public concern.

The Purpose: Public Accountability

Each of my requests has had a serious purpose and reflects concern over matters such as:

Vehicle theft and fraud reporting;
NaVCIS’ relationship with public funding and industry;
Police use of DVLA and PNC systems;
Transparency in public-private policing initiatives.

These are clearly in the public interest and consistent with the rights of individuals to hold public authorities accountable.

Conclusion

While I acknowledge that several requests have been submitted over time, this alone does not justify refusal under Section 14(1). I respectfully request that:

My request be reviewed based on its individual merits;
The NPCC provide specific evidence of how the cumulative requests have crossed the threshold of “grossly oppressive” burden;
If clarification or narrowing would assist, I remain willing to discuss scope in good faith.

I again emphasise that I have not “bombarded” the NPCC, nor have I acted improperly. The right to submit FOIA requests must be jealously guarded, and any restriction on that right must meet the high legal threshold set by law and guidance.

I look forward to your reasoned reconsideration or escalation to internal review.

NEXT PAGE – FoIA ‘Distress &/or Obstruction’

The Request & Refusal:

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