This Action Plan outlines how the Police Service of Northern Ireland's Corporate Information Branch will achieve Information Request Compliance and Backlog Reduction.
Corporate Information Branch Action Plan
1.0 Purpose
This Plan sets out the mitigating actions and key milestones for Police Service of Northern Ireland to improve compliance and eradicate Freedom of Information Act (FOI) and Data Protection Act (DPA) request handling backlogs. It should be noted that, in the context of this paper, ‘backlog’ refers to requests which have not yet been allocated for processing.
2.0 Governance
There is currently a Departmental Risk with regard to information request handling backlogs and non-compliance. A Strategic ‘Gold’ Group is in place to oversee actions and performance with regard to request handling and updates are provided to Police Service of Northern Ireland strategic oversight boards. Monthly performance statistics are also submitted to stakeholders including PSNI’s Senior Information Risk Owner (SIRO), and the Information Commissioners Office (ICO).
3.0 Context
In 2022 PSNI successfully delivered a previous ICO Action Plan to improve compliance and reduce long-standing request handling backlogs. PSNI subsequently successfully sustained legislative compliance with regard to statutory obligations and ICO targets for a period of 12 months, until the organisation experienced a significant data leak following the release of a routine FOI request. In September 2023, request handling compliance dropped below the ICO target of 90%. Ongoing internal monitoring of compliance figures evidenced a lack of improvement in performance and highlighted the development of request handling backlogs (see Section 3.1 below). As the number of requests not being responded to within legislative timeframes grew, the number of complaints and requests for update also increased. These further reduce Branch capacity as work to investigate queries and provide updates diverts resource from core request handling processes. It should be noted that, when compared with the same period last year (Jan-Aug 2023 vs Jan-Aug 2024), PSNI has experienced an increase in the number of requests and questions received by 18.4% and 34.38%, respectively.
3.1 Unallocated Requests
As of 1 August 2024, a total of 129 requests (each containing multiple questions/parts) received by PSNI had not been allocated for processing.
Unallocated Requests | Mar | Apr | May | Jun | Jul | Aug | Sept |
---|---|---|---|---|---|---|---|
Freedom of Information | 163 | 136 | 55 | 17 | 6 | 0 | 0 |
Data Protection | 225 | 189 | 140 | 127 | 119 | 129 | 113 |
Total Unallocated | 388 | 325 | 195 | 144 | 125 | 129 | 113 |
3.2 Compliance
PSNI successfully sustained legislative compliance with regard to statutory obligations and ICO targets for a period of 12 months until August 2023, when the release of a routine FOI request resulted in a significant data leak. By September 2023, request handling compliance dropped below the ICO target of 90%. It is considered that a reduction in request processing capacity as a result of the requirement to divert resources to support investigations, including those conducted by the ICO and Independent Review Team, in addition to undertaking priority work to review previously published FOI responses, initiated the development of a request handling backlog. This is likely to have been exacerbated by significant gaps in the PSNI’s organisational budget, a reduction in available resources within CIB, an increased number of DPA requests, an uplift in the number of questions received in FOI and DPA requests, and anecdotal evidence indicating a reduction in risk appetite/confidence with regard to the release of information.
3.3 Resourcing
Corporate Information Branch has a substantive establishment of 21 posts. As of 01 July 2024, CIB had 11.6 substantive police staff members in post, supported by 12 temporary personnel. Work is ongoing to secure substantive personnel to fill established posts however, this must be considered in the context of the severe financial and resourcing challenges faced, and publicly acknowledged, by the PSNI (and wider public service); align with the recommendations of the Reviews/Investigations both before, and after the 2023 Data Leak; and represent a sustainable solution for request handling.
3.4 Actions to Date
Some of the steps taken by the PSNI to monitor and improve request handling timeliness include:
- Implementation of a strategic ‘Gold’ Group to oversee actions and request handling performance
- Updated reports to improve understanding of performance and communication of barriers
- Personnel dedicated to either ‘Backlog Reduction’, or ‘Compliance’
- Triage/support functions identified and implemented to streamline request handling
- Temporary personnel secured to increase request handling capacity while permanent resourcing solution is considered
- FOI Service Instruction updated and ongoing work to re-establish organisational confidence
- Collaborative working with other business areas to:
- Reduce administrative burdens associated with request handling
- Increase awareness of how officers/staff can access their own personal information
- Increase internal awareness of request handling processes and legislative obligations
- Streamline internal request handling processes with record owners
- Work initiated to identify common themes/categories of information sought to support proactive publication
4.0 Action Plan
The ICO has set a target for all organisations to close a minimum of 90% of all of requests received, within statutory timescales. This requirement was re-affirmed in the ‘Timeliness of responses to information access requests by police forces in England, Wales and Northern Ireland’ report.
4.1 Objective
As a result of the ongoing work and implementation of actions identified in Section 3.4 of this report, PSNI’s key objective under this Action Plan is to achieve legislative compliance with regard to request handling by the end of November 2024.
4.2 Outcomes
The outcomes which will evidence the successful delivery of this objective are:
- By the end of November 2024, PSNI will close 90% of Data Protection and Freedom of Information requests within legislative timeframes.
- By the end of November 2024, PSNI will allocate Data Protection and Freedom of Information requests by the end of the first working day after the request is received and confirmed to be valid.
4.3 Measures
The identified outcomes aim to achieve both the eradication of backlogs of unallocated requests, and to deliver 90% compliance by November 2024. As FOI compliance was approximately 47% at the commencement of this Plan, a 6% improvement (on the original figure) will be required each month, from the beginning of May 2024, until the target is achieved at the end of November 2024. As DPA compliance was approximately 72% at the commencement of this Plan, a 2-3% improvement (on the original figure) will be required each month, from the beginning of May 2024, until the target is achieved at the end of November 2024 (see Section 4.5 for full monthly breakdown).
At the end of April 2024, PSNI had 136 FOI requests which had not been allocated for processing. By ensuring that 20 of these requests are closed each month, from the beginning of May 2024, the target can be achieved by the end of November 2024. At the end of April 2024, PSNI had 189 DPA requests which had not been allocated for processing. By ensuring that 27 of these requests are closed each month, from the beginning of May 2024, the target can be achieved by the end of November 2024 (see Section 4.5 for full monthly breakdown).
4.4 Indicators
A number of indicators have been identified to understand and support staff performance with regard to request handling as work to achieve the overarching objective continues.
Action Plan Progress
Month | FOI Request Targets | DPA Request Targets | FOI Outcomes | DPA Outcomes | ||||
Unallocated | Compliance | Unallocated | Compliance | Unallocated | Compliance | Unallocated | Compliance | |
March | Pre-Action Plan | 163 | 58% | 225 | 73% | |||
April | 136 | 47% | 189 | 72% | ||||
May | 115 | 55% | 160 | 75% | 55 | 55% | 140 | 74% |
June | 95 | 61% | 133 | 78% | 17 | 77% | 127 | 79% |
July | 75 | 67% | 106 | 80% | 6 | 91% | 119 | 79% |
August | 55 | 73% | 79 | 82% | 0 | 91% | 129 | 73% |
September | 35 | 79% | 52 | 85% | 0 | 95% | 113 | 73% |
October | 15 | 85% | 25 | 88% | ||||
November | 0 | 91% | 0 | 90% |
*Outcome of resourcing considerations (Section 3.3) may negatively impact the delivery of this Plan
** PSNI/Public Sector financial and resourcing challenges may negatively impact the delivery of this Plan