Corporate Information Branch Action Plan

This Plan sets out the mitigating actions and key milestones for the Police Service of Northern Ireland (PSNI) 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 document, ‘backlog’ refers to requests which have not been allocated for processing. It is also important to recognise that this Plan has been developed in the context of a financial crisis for the PSNI, with significant challenges around organisational funding and resourcing.

There is currently a Departmental Risk with regard to information request handling backlogs and non-compliance. Request handling updates are provided to PSNI strategic oversight boards, and monthly performance statistics are submitted to stakeholders including PSNI’s Senior Information Risk Owner (SIRO), and the Information Commissioners Office (ICO).  

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%. In May 2024, PSNI proactively implemented an Action Plan to improve compliance and reduce the number of unallocated requests. This Plan, alongside monthly performance outcomes, was published on PSNI’s external website. Compliance peaked in November 2024 at 96% and 89% for FOI and SAR, respectively. Following the implementation of a new case management system in December 2024, request handling compliance once again reduced and the number of unallocated requests increased (see Section 3.1 and 3.2). As the number of requests not being responded to within legislative timeframes increases, the number of complaints and requests for update also increase. These further reduce PSNI’s request handling capacity as work to investigate queries and provide updates diverts resources from core request handling processes. 

As of 6 May 2025, a total of 406 requests (each containing multiple questions/parts) received by Corporate Information Branch had not been allocated to an EO2 Decision Maker.

PSNI successfully sustained legislative compliance with regard to statutory obligations and ICO targets 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%. Following the proactive development and implementation of an Action Plan in May 2024, compliance peaked in November 2024 at 96% and 89% for FOI and SAR, respectively. Unfortunately, the implementation of a new case management system in December 2024, sustained resourcing challenges, and increasing request numbers have all contributed to recent reductions in compliance during the first quarter of 2025. 

PSNI’s Corporate Information Branch has a substantive establishment of 29.6 posts. As of 06 May 2025, this Branch had 21.6 police staff members. Work is ongoing to secure additional 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).

A number of measures were implemented by PSNI, and documented in the May 2024 Action Plan, to monitor and improve request handling timeliness. While these measures delivered positive outcomes and allowed PSNI to increase compliance throughout the delivery of the 2024 Action Plan, recent reductions in compliance have resulted in the requirement to further streamline request handling processes. Some of these steps include:

• Implementation of request handling ‘Support Clinics’
• Review of request handling quality assurance processes
• Triage function extended to subject access requests
• Streamlining of internal reporting processes   
• Continuing to implement system functionality to reduce administrative burdens 
   

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.

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 March 2026.  

The outcomes which will evidence the successful delivery of this objective are:

1. By the end of March 2026, PSNI will close 90% of Data Protection and Freedom of Information requests within legislative timeframes.
2. By the end of March 2026, 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.  
   
    

The identified outcomes aim to achieve both the eradication of backlogs of unallocated requests, and to deliver 90% compliance by the end of March 2026. As FOI compliance is approximately 57%, this will require a 3-4% improvement (on the original figure) each month, from the beginning of June 2025, until the target is achieved at the end of March 2026.  As DPA compliance is approximately 73%, this will require a 1-2% improvement (on the original figure) each month, from the beginning of June 2025, until the target is achieved at the end of March 2026 (see Section 4.6 for full monthly breakdown).  

As of 6 May 2025, PSNI had 132 FOI requests which had not been allocated to an EO2 Decision Maker. By ensuring that 14 of these requests are allocated each month, from June 2025, the target can be achieved by the end of March 2026. As of the 6th May 2025, PSNI had 274 DPA requests which had not been allocated to an EO2 Decision Maker. By ensuring that 28 of these requests are allocated each month, from June 2025, the target can be achieved by the end of March 2026 (see Section 4.6 for full monthly breakdown).     

 

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.

To ensure appropriate oversight and transparency, monthly performance updates against the milestones detailed in Section 4.7 will be published to PSNI’s external website and provided to the Information Commissioners Office.

*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