14. FoIA ‘Similar 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.

Response to NPCC’s Use of Undifferentiated FOIA Reference List

The NPCC has stated that the current request is “similar” to those previously received. However, no explanation or summary of those earlier requests is provided, only a list of FOIA reference numbers, without context or subject matter.

How similar to other requests?

This approach appears designed not to inform, but to overwhelm. A reader unfamiliar with the request history is left to manually search and review each entry without any guidance as to how or why they are deemed comparable. The Information Commissioner’s Office (ICO) has been clear in its guidance on Section 14 (vexatious requests) that public authorities should consider “context and history” and “explain their reasoning clearly” when making such determinations.

This failure to provide context or justification for the perceived similarity between requests could reasonably be interpreted as an attempt to imply impropriety by volume or pattern, without substantiating how these requests collectively meet the ‘vexatious’ threshold. This presentation is not only unhelpful; it risks prejudicing any subsequent internal review or independent assessment of the request’s legitimacy.

In Dransfield v Information Commissioner & Devon County Council [2012] UKUT 440 (AAC), the Upper Tribunal highlighted the importance of a holistic and evidence-based approach when evaluating whether a request is vexatious. A list of numbers alone, devoid of explanatory value, fails to meet this evidentiary standard.

Moreover, the act of requiring a requester to trawl through FOIA case numbers to decode the authority’s rationale is contrary to the spirit of transparency and accessibility embedded in the Freedom of Information Act 2000. The burden of justification lies with the public authority, not the requester.

I have sought assistance in this respect, but it has not been forthcoming.

Unless the NPCC can demonstrate how these prior requests are materially related in substance, scope, or behaviour, the implication that they form a pattern contributing to vexatiousness is both unfounded and potentially misleading.

The NPCC states:

Your request relates to similar requests previously received by you:

2202/2025 Initial Request
0093/2025 Initial Request
0044/2025 ICO Appeal of 426/2024 (subject to IR 450/2024)
0039/2025 Internal Review
0014/2025 Initial Request
0012/2025 Internal Review IR of 425/2024
0450/2024 Internal Review IR of 426/2024
0426/2024 Initial Request
0425/2024 Initial Request
0254/2024 Initial Request

Only 2202 bears any similarity – and this is tenous as the NPCC responded ‘no information held’, a stance I accepted immediately.

Only 3 requests arise in 2024 about which I comment here – NPCC 2024 disclosure log entries.

The list can be abbreviated to 6 requests (14 & 39 relating to the same request):

2202/2025 Initial Request
0093/2025 Initial Request
0044/2025 subject to IR 450/2024, ICO Appeal of 426/2024
0039/2025 Internal Review
0014/2025 Initial Request
0012/2025 Internal Review IR of 425/2024
0254/2024 Initial Request

None of the above are dated, and none are accompanied by any indication of the subject.

IR 39 was not accompanied by the original request reference. However, it is the IR associated with 0014. This is known to the NPCC as they had written 30/01/2025 acknowledging there was confusion – nothing worse i.e. vexatious – as follows

I have set out below all of your current Internal Reviews and those requests that are aggregated for cost purposes.

I think the confusion arises when using several email addresses and the WhatDoTheyKnow platform. In addition, when a response is sent, a query in turn may have different wording within the subject line causing further confusion.

In response to your email, I can confirm the following outstanding Internal Reviews:

Internal Review 450/2024 (IR of 426/2024) PNC Los Records Communication is in progress.
Internal Review 003/2025 (IR of 385/2024) NaVCIS & NVCRP is in progress
Internal Review 012/2025 (IR of 425/2024) PNC Los Records Communication is in progress.
Internal Review 039/2025 (IR of 014/2025) PNC Los Records Communication is in progress.

For complete transparency, presently, the following request references are aggregated for cost purposes (relating to PNC/LoS):

105/2024 UK’s Stolen Vehicle Data Sharing Agreement with other Countries – PNC LoS
176/2024 UK’s Stolen Vehicle Data Sharing Agreement with other Countries – PNC LoS
254/2024 PNC (VRM) LoS Weeding
425/2024 Weeding of PNC LoS Records Communication
426/2024 ACRP PNC LoS Notifications
014/2025 PNC LoS Records Communication

It is unclear whether the above are all aggregated, i.e. they effectively represent one request.

The subject request relates to the VRMs NaVCIS places to the PNC LoS register.

From the above and my first-hand knowledge of the requests, I can therefore elaborate:

2202/2025 Initial Request

This is related to the subject request in that it seeks VRM data submitted to the PNC LoS register. However, it seeks information for all constabularies. The NPCC stated they did not hodlt he information, explained why and I marked the request ‘not held’. I was directed to the Home Office, requested & received the information from them. The history can be read here which, in brief was:

PNC LoS records – similar to the subject
S12 engaged, assistance provided, Q5 withdrawn
Information ‘not held’
Accepted & closed
0093/2025 Initial Request

The NPCC could have expanded upon this considerably, at the time of citing vexatious in respect of the subject matter, adding that they had disclosed information. However, they failed to address the entire request. When I pointed this out they disclosed further information yet still not all that fell to the request – they allocated a new reference and cited … vexatious to withhold information they disclosed possessing, that I only knew of because they had identified it. Yet they kept it from me. The unnecessarily convoluted history can be read here.

Vexatious was also cited 11/04/2025 – the same date vexatious was cited regarding the subject request.

The request was for an NPCC circular about the disclosure of vehicle makes & models. It is unrelated, not similar to the subject request.
0044/2025 subject to IR 450/2024, ICO Appeal of 426/2024

One of those requests that never felt as if it should have been treated as such. Indeed, I did ask if it could be dealt with other than by FoIA.

The request is NOT similar to the subject request.

I noted, when reviewing a batch of vehicle registration marks (VRMs) placed to the PNC LoS register, that the inputting organisation ‘ACRO’, as opposed to a specific constabulary. I asked to whom I should direct enquiries about such ‘ACRO’ records – who was submitting the entries. The request was generic, not about a specific VRM; however, I provided a specific VRM to assist the NPCC/ACRO in understanding what I was referring to, to locate such an entry, to assist.

There followed a concern by the NPCC that I was seeking personal information; I clarified this was not the case.

Ultimately, ‘no information‘ was held. I am no further forward. This appeared odd – clearly ACPO is associated with PNC LoS entries yet the NPCC could identify no relevant information, despite:

‘Requests to ACRO Criminal Records Office can also be made to the National Police Chiefs’ Council’ (source – WDTK)

A response from Ashleigh Beney, Head of National Police Freedom of Information and Data Protection Unit indicates ‘426’ was the initial response, ‘450’ was the IR.

The request does not feature in the NPCC’s 2024 Freedom of Information (FOI) Disclosure Logs.
0014/2025 Initial Request 0039/2025 Internal Review

The request is NOT similar to the subject request.

The request relates to the NPCC’s ‘all chief constables’ circular process/facility. It was linked to the WEEDING of PNC LoS records disclosure – see 0012 below. But, specifically, I was trying to ascertain who at the MPS ‘all chief constable’ circulars were received by.

I approached the MPS (by use of FoIA) – they could not tell me; they could not locate the circulars/recipients!

The MPS, struggling, referred me to the NPCC.

This was the request to the NPCC. All I wished to ascertain is where the circulars were going – I was concerned the WEEDING matter had not been acted upon and this sparked my interest in the recipients.

I had anticipated the NPCC returning promptly with a list of names or a generic email address. Instead, while they helpfully clarified the system was not email-based, it seemed to be some form of intranet; they could not identify the recipients.

I am no further forward:

*The NPCC does not know to whom at the MPS their ‘all Chief Constables’ guidance/advice/messages are sent
*The NPCC does not know if said messages to the MPS are read or acted upon
*The MPS does not know who receives the messages

The situation appears to require review. Whilst I am incredulous of the NPCC response, for example, surely someone at the MPS had replied or queried a circular, such that a point of contact could be discerned, it appeared I was being stonewalled. Possibly my writing has encouraged a review of the system.

21/02/2025, I wrote about the odd situation here: A System Built on Blind Faith? The Flaws in Police Information Dissemination – Car Crime U.K.

This was aggregated with 0012 (below) i.e. arguably should be considered a single request.
0012/2025 Internal Review IR of 425/2024

This relates to the WEEDING of PNC LoS records. It is unconnected to the subject request, not similar. It was an issue that took me a considerable time to have addressed and resulted in the NPCC circulating ‘all chief constables’, alerting them to my concerns.

425 – sought the WEEDING circular the NPCC issued, and which I was provided – 241107 All Chief Constables Circular re ‘Weeding’ – Car Crime U.K.

0014 (‘4’ above) – sought to understand who at the MPS received the WEEDING circular (disclosed – 425)

The disclosure (425) was unnecessarily repeated here.

The NPCC’s 2024 Freedom of Information (FOI) Disclosure Logs’ provides two entries for the request; the response letter and disclosure. Both entries confirm the issue relates to ‘weeding’ – it is unrelated to the number of PNC LoS records NaVCIS has submitted. The disclosed information can be viewed here:

425 2024 NPCC Attachment Weeding of PNC LoS Records Communication
425 2024 NPCC Response Letter – Weeding of PNC LoS Records Communication
0254/2024 Initial Request

This request is not similar to the subject request.

As per the 30/01/2025 email from the NPCC (above), the request relates to: 254/2024 PNC (VRM) LoS WEEDING

29/07/2024 I asked the NPCC for information about ‘WEEDING’ – the automated removal of Vehicle Registration Marks (VRM) from the Police National Computer’s (PNC) Lost or Stolen (LoS) register after 6 weeks if not ‘confirmed’ i.e. if an officer had not updated the PNC that the LoS record was confirmed. The process was troubling me.

I specialise in vehicle-related insurance claims. These include claims following the alleged theft of a vehicle. I was encountering many situations where a vehicle, reported stolen, was ‘falling off PNC LoS’ after about 6 weeks, giving the impression the vehicle had been found. The issues:

• Has the vehicle been found or has an oversight occurred
• The police are reluctant to speak with anyone other than a victim of crime (vehicle theft)
• The police tend not to speak with insurers or their representatives
• If I approach the police, they tend to cite an MoU and request £150+ to tell me about the vehicle’s status – I am slowly making inroads here
• I am forced to contact the victim and ask them to approach the police
• The victim has generally not been told the vehicle was recovered, because it has not been!
• The victim is, on occasions, reluctant to accept my update/concern – they tend to believe the police would have told them that I am mistaken … or worse.
• I am required to explain – such was the problem, I referred to our process as a police safety net and provided an online explanation rather than explain individually – https://cmaclaims.co.uk/vehicle-recovery/
• Claims were being delayed – on occasions, police staff were contradicting my stance, could not be troubled top check PNC (Possibly just looked at the crime report) but ultimately conceded an error had occurred and amended the record

I can provide evidence raising concerns about the issue in 2023 – https://www.whatdotheyknow.com/request/01022023_circular_re_stolen_vehi?

My writing on the subject has been extensive:

https://cmaclaims.co.uk/vehicles-reported-not-recorded-stolen/
https://cmaclaims.co.uk/stolen-vehicle-removed-from-pnc-error/
https://cmaclaims.co.uk/vrm-not-on-pnc-los/
https://cmaclaims.co.uk/vehicle-recorded-stolen-check-again/
https://carcrime.uk/pnc-los-report-weeding/

07/11/2024, the NPCC circulated all Chief Constables (as referred to above):

An issue has been brought to my attention regarding vehicles that are remaining recorded as “unconfirmed stolen” effectively dropping off the PNC after the specified weed period causing an inaccurate record of the vehicle status. Could I ask that you check within your force whether all stolen vehicle reports are recorded as “confirmed” as stolen within 24hrs*** and seek to address should this not be the case. This will ensure the PNC, third party data users and other agencies, such as DVLA, databases accurately reflect a vehicle’s stolen status.

https://carcrime.uk/241107-all-chief-constables-circular-re-weeding/

Addressing ‘weeding’ results in no benefit for me. The issue (and many others) is something I identified, realised was causing problems and sought to address. The procedure only benefited vehicle thieves – searches of VRMs would return no stolen marker by the police or DVLA, the car was less likely to be found (at a cost to insurers) and recovery statistics were being skewed.

Similarities

The NPCC does not explain how these are considered similar. They are not, except in respect of 2202/2025 to which your response is assigned ref. 2202/2024 and states ‘not held’, see: https://www.whatdotheyknow.com/request/pnc_los_vrm_information.

As above, I have annotated the request on WDTK as ‘not held’ and have taken no further action i.e. I noted your response and accepted this.

Of the 6 requests, 3 fall to 2024 and, as conveyed above, are dissimilar. Two are recorded within the NPCC’s 2024 Freedom of Information (FOI) Disclosure Logs’. They are recorded under the NPCC’s

A further 3 arose in 2025:

0014/2025 Initial Request

0093/2025 Initial Request – a Google search of this reference + NPCC reveals the link to the WDTK request clearly headed ‘PNC Inaccuray & Disclosure of Vehicle Makes & Models‘ – a request for the NPCC’s guidance to ‘all chief constables’ not to disclose vehicle makes & models – unconnected with the subject request for NaVCIS PNC LoS submissions.

2202/2025 Initial Request – located on WhatDoTheyKnow, the request asked for ‘PNC LoS (VRM) Information’, the LoS submissions by all constabularies to the PNC. The NPCC responded ‘not held’.

Arguably, I could have referred them to the data they hold for NaVCIS – that NaVCIS makes submissions to the PNC LoS register and this data would be held. However, I sought the information from the Home Office and the subject request addresses the information the NPCC hold (could have supplied in response to 2202)

None of the above appear within the NPCC’s 2025 FoI Disclosure Log under ‘Digital, Data and Technology’ (where 254/2024 & 425/2024 are displayed). This also indicates that they are not considered to be connected, similar. As of 22/04/2025, there are no records held under ‘Digital, Data and Technology’.

In conclusion, I respectfully ask that the ‘vexatious’ exemption is withdrawn and the information is disclosed as soon as possible.

Thank you

Reference, Research & Resources:

What does vexatious mean? ICO online
Dealing with vexatious requests – ICO Guidance
When can a request be considered vexatious or repeated? ICO guidance
Vexatious – Annex of example tribunal decisions
Dransfield v Information Commissioner (Section 50: Jurisdiction): [2020] UKUT 346 (AAC) – Appeal
Dransfield – Upper Tribunal Appeal No. GIA/399/2020
Defining Vexatious Requests under the Freedom of Information Act: Insights from IC v. Dransfield ([2012] UKUT 440 (AAC))
Vexatious or manifestly unreasonable information requests – the Court of Appeal’s view
Vexatious and manifestly unreasonable requests: definitive guidance from the Upper Tribunal – see also panopticonblog.com – section 14

The Request & Refusal:

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