4.6. NaVCIS Funding - 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.

Subject: Questions Regarding NaVCIS Operations, Funding, and Transparency of LoS Data

This submission seeks to reinforce the serious and legitimate purpose of my FOIA request relating to the activities of the National Vehicle Crime Intelligence Service (NaVCIS), with specific reference to:

The vehicles in respect of which NaVCIS has placed LoS (Lost or Stolen) markers on the Police National Computer (PNC);
The relationship between NaVCIS and the Finance and Leasing Association (FLA);
Concerns about the privately funded nature of a policing body and potential implications for public accountability.

It should also be noted that whilst this request is made of the NPCC, the information is likely to be held by the FLA – the FLA are not subject to the Freedom of Information Act – I am therefore forced to present to the NPCC

Funding Model of NaVCIS and Public Interest

Background: Private Funding and Operational Scope

Around 2010/2011, AVCIS was understood to be operating on central government funding. However, it was publicly confirmed in 2011 that government support would cease as part of budgetary cuts. As reported at the time:

“The British government will no longer provide the Association of Chief Police Officers Vehicle Crime Intelligence Service (AVCIS) with funding, effective April 2011.”
Source: FleetNews, 2011

This void was reportedly filled by private finance. Specifically, AVCIS was taken under the wing of the Finance and Leasing Association (FLA)—a trade body representing finance and leasing companies.

While this may have maintained the unit’s existence, it also raises legitimate concerns. The core issue is this:

Can a policing unit, funded by the finance industry, act without conflict when investigating crime that also serves the financial interests of its sponsors?

NaVCIS is a privately funded policing unit, supported by the Finance and Leasing Association (FLA) to recover finance vehicles alleged to be ‘stolen’ or misappropriated. According to public statements by NaVCIS and the FLA, this unit receives no direct government funding, and their operations are partly driven by commercial sponsorship from the finance industry. This raises significant public interest questions:

To what extent can a privately funded unit, acting under police powers, make impartial operational decisions?
Does NaVCIS prioritise investigations in accordance with its funding body’s interests over those of other stakeholders?
Is there a two-tiered policing model developing, whereby private sponsorship results in preferential access to public resources (e.g. the PNC, DVLA, constabulary enforcement)?

The House of Commons Home Affairs Committee has warned of the growing concern over policing partnerships with the private sector. Transparency is key to ensuring that public powers are not exercised to serve corporate objectives over public good.

Reference: House of Commons Home Affairs Committee, Policing for the Future (2018) – particularly paras. 150–162.

Recovery Revenue and Access-for-Fee Concerns

Some 10 years ago, insurers reported that AVCIS (now NaVCIS), having located non-financed stolen vehicles at UK ports, sought payment for their recovery. The rationale was that AVCIS was not funded to recover vehicles outside the FLA’s scope. Insurers were reportedly told that unless a “release fee” was paid, the vehicles could be exported – rendering recovery more costly or impossible.

AVCIS offered:

Recovery of a vehicle from port for a flat fee or 5% of its book value;
Access to ANPR (Automatic Number Plate Recognition) data within six months, as part of the package.

I was present at the meeting where the above was discussed.

This “pay-to-protect” model is possibly troubling when operated by an entity that appears to be exercising police powers under private influence.

My understanding is that NaVCIS funding was once tied to recoveries, with a possible commission-based model (19% of recovered vehicle value?).

Implications for Crime Data Integrity and Transparency

NaVCIS records vehicles as LoS on the Police National Computer, a process that can have criminal and civil implications for individuals found in possession of those vehicles. This directly affects public trust and could distort national crime figures:

Are these vehicles correctly recorded as stolen or are many cases civil disputes arising from fraudulent finance arrangements or defaults?
There is no such offence as “theft by fraud”. Mischaracterisation can lead to innocent third parties (e.g. buyers) being detained, searched, or accused based on ambiguous PNC flags.
These concerns are exacerbated by NaVCIS’s lack of transparency—it is not clear how many LoS records are placed each year, on whose authority, or how many result in criminal proceedings.

ICO Guidance on Section 14 FOIA is clear:

“A request which may be irritating or burdensome to deal with is not necessarily vexatious if it has a serious purpose and raises matters of public interest.”
(ICO, “Dealing with Vexatious Requests (Section 14(1))” Guidance)

My request does exactly that.

NaVCIS as a Public Body Exercising Public Powers

NaVCIS works in concert with police constabularies and has access to secure national law enforcement databases (e.g., PNC). It acts as a functional arm of UK policing, yet its funding, oversight, and priorities may not be subjected to the same levels of democratic scrutiny or public accountability.

My request seeks to:

Ensure public confidence in how LoS markers are being applied;
Understand the scope of NaVCIS’s activities and how many vehicles they are influencing the policing of;
Clarify whether NaVCIS vehicles are being correctly accounted for in national vehicle theft figures.

This is not speculative. These are fact-based, policy-relevant questions regarding public-police-private collaborations.

FOIA Must Enable, Not Inhibit, Transparency

Under Dransfield v Information Commissioner & Devon CC [2012] UKUT 440 (AAC) and Dransfield CA [2015] EWCA Civ 454, a request may only be refused under Section 14 if it is manifestly unreasonable, has no serious purpose, or lacks value.

In contrast, this request:

Relates to the public interest in policing transparency;
Seeks to understand the workings of a unit that impacts thousands of UK vehicle owners;
Asks questions that relate to national policy on policing and crime.

Such inquiries strike at the heart of FOIA’s purpose: to hold public authorities accountable, promote transparency, and encourage public understanding.

Optional Addendum: Recommended Reading

ICO Guidance on Section 14 FOIA (Vexatious Requests): Dealing with vexatious requests (section 14) | ICO
House of Commons Home Affairs Committee, Policing for the Future (2018): https://publications.parliament.uk/pa/cm201719/cmselect/cmhaff/515/515.pdf
The Transparency Project: Accountability in Public–Private Policing Partnerships (2020)
Policing Project unveils new transparency and accountability resources for police and communities — The Policing Project

NEXT PAGE – NaVCIS Costs & Recovery

The Request & Refusal:

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