June 17, 2025 | Incident and Crime Statistics , Human Trafficking and Modern Slavery
Request Number: FOI/14464
Category: Crime/Incident Statistics – Serious and Organised Crime
Subject: Human trafficking
Request and Answer:
Your request for information below has now been considered. In respect of Section 1(1)(a) of the Freedom of Information Act 2000 (FOIA) We can confirm that the Police Service of Northern Ireland (PSNI) does hold the information you have requested however it is estimated that the cost of complying with your request for information would exceed the “appropriate costs limit” under Section 12(2) of the Freedom of Information Act 2000. We have explained to you below that when PSNI estimates whether the appropriate limit is likely to be exceeded, it can include the costs of complying with two or more requests if certain conditions are met. In this case those conditions are met and complying with all of your requests would in our estimation exceed that appropriate limit set out in Regulation. We have explained this further below but also we followed the Information Commissioner’s Office guidance ‘Requests where the cost of compliance exceeds the appropriate limit’ in relation to this request, which also provides further detail on the application of Section 12 (2) of the FOIA. This guidance is available on the ICO website at the following link:
Request
I am writing to request the following under FOI:
Request 1
The number of arrests made for offences related to human trafficking (specifically for sexual exploitation and labour exploitation) in each of the last 10 years (June 2015 - present)?
Request 2
Please provide a breakdown by type of exploitation?
Request 3
The number of investigations launched into suspected human trafficking offences in each of the last 10 years?
Request 4
Please provide a breakdown by type of exploitation?
Request 5
The number of victims of human trafficking identified by the PSNI in each of the last 10 years. Please provide a breakdown by
a) gender,
b) age, and
c) nationality (if available)
Request 6
The number of referrals made by the PSNI to support services for victims of human trafficking in each of the last 10 years?
Request 7
Details of any specific operations or initiatives undertaken by the PSNI in the last 10 years to target human trafficking, including the number of arrests and victims identified through these operations?
Request 8
The number of convictions secured for human trafficking offences (specifically for sexual exploitation and labour exploitation) in each of the last 10 years?
Request 9
Information on the training provided to PSNI officers on identifying and responding to human trafficking?
Request 10
The number of reports received by the PSNI alleging the purchase of sex since June 1st, 2015?
Request 11
The number of arrests and prosecutions related to the purchase of sex since June 1st, 2015?
Request 12
Any internal assessments or reports conducted by the PSNI on the impact of the law criminalising the purchase of sex on human trafficking and prostitution in Northern Ireland.
Answer
Section 17(5) of the Freedom of Information Act 2000 requires the Police Service of Northern Ireland, when refusing to provide such information (because the cost of compliance exceeds the appropriate limit) to provide you the applicant with a notice which states that fact.
It is estimated that the cost of complying with your request for information would exceed the “appropriate costs limit” under Section 12(2) of the Freedom of Information Act 2000. Section 12 of FOIA allows a public authority to refuse to deal with a request where it estimates that it would exceed the appropriate limit to either comply with the request in its entirety or confirm or deny whether the requested information is held. The estimate must be reasonable in the circumstances of the case. The ‘appropriate limit’ is currently £600 for central government and £450 for all other public authorities including PSNI. The relevant Regulations which define the appropriate limit for section 12 purposes are The Freedom of Information and Data Protection (Appropriate Limit and Fees) Regulation 2004 SI 2004 No 3244. These are known as the ‘Fees Regulations’ for brevity.
Regulation 4(3) of the Fees Regulations states that a public authority can take into account the costs it reasonably expects to incur in carrying out the following permitted activities in complying with the request:
(i) determining whether the information is held;
(ii) locating the information, or a document containing it;
(iii) retrieving the information, or a document containing it; and
(iv) extracting the information from a document containing it.
Under those regulations PSNI can calculate the time spent on each of these permitted activities at £25 per hour (thus if the activity(s) takes more than 18 hours PSNI will be in excess of the ‘appropriate limit’).
When a public authority is estimating whether the appropriate limit is likely to be exceeded, it can include the costs of complying with two or more requests if the conditions laid out in Regulation 5 of the Fees Regulations can be satisfied. Those conditions require the requests to be:
- made by one person, or by different persons who appear to the public authority to be acting in concert or in pursuance of a campaign;
- made for the same or similar information; and
- received by the public authority within any period of 60 consecutive working days.
Regulation 5(2) of the Fees Regulations requires that the requests which are to be aggregated relate “to any extent” to the same or similar information. This is quite a wide test but public authorities should still ensure that the requests meet this requirement.
PSNI can advise that in order to provide:
- The number of investigations launched into suspected human trafficking offences in each of the last 10 years? (Request 3)
- breakdown by type of exploitation (Request 4)
- The number of referrals made by the PSNI to support services for victims of human trafficking in each of the last 10 years (Request 6)
- Details of any specific operations or initiatives undertaken by the PSNI in the last 10 years to target human trafficking (Request 7)
Will require a manual trawl of PSNI systems (NRM Database and NICHE) as you seek 10 years of data. It will take PSNI over 18 hours to determine what information we hold relevant to Requests 3, 4, 6 and 7 for the 10 year time period you seek, consequently putting this request over cost.
In accordance with the Freedom of Information Act 2000, this letter should be considered as a Refusal Notice, and the request has therefore been closed.
Advice and Assistance
You may wish to submit a refined request in order that the cost of complying with your request may be facilitated within the ‘appropriate limit’. In compliance with Section 16 of the Act, we have considered how your request may be refined to bring it under the appropriate limit.
Subject to a new request PSNI can:
- Provide a response to Request 1.
- For Request 5 the number of police recorded crime offences of Modern Slavery can be provided, an offence of Modern slavery is recorded for each victim of Modern Slavery. Definition of Modern Slavery from the Home Office counting rules: Modern Slavery is defined as the exploitation of an individual by others for personal or commercial gain. Whether tricked, coerced or forced; they lose their freedom. This includes but is not limited to slavery and servitude, forced and compulsory labour, human trafficking, including criminal and sexual exploitation, and debt bondage. Age, gender and nationality can be provided.
- Provide a response to Request 9.
- Provide a response to Request 10. In addition we can provide the number of police recorded crime offences of Paying for sexual services of a person offences under Article 64A (a) of The Sexual Offences (Northern Ireland) Order 2008.
- In relation to Request 11 we can provide the number of arrests for Paying for sexual services of a person offences under Article 64A (a) of The Sexual Offences (Northern Ireland) Order 2008.
Submission of a refined request would be treated as a new request, and considered in accordance with the Freedom of Information Act 2000, including consideration of relevant Part II exemptions.
If you have any queries regarding your request or this decision please do not hesitate to contact me on [email protected] When contacting the Corporate Information Branch, please quote the reference number listed at the beginning of this letter.
If you are dissatisfied in any way with the handling of your request, you have the right to request a review. You should do this as soon as possible or in any case within two months of the date of issue of this letter. In the event that you require a review to be undertaken, you can do so by writing to the Corporate Information Manager, Corporate Information Branch, PSNI Headquarters, 65 Knock Road, Belfast, BT5 6LE or by emailing [email protected]
If, following an Internal Review carried out by an independent decision maker, you remain unhappy about how your request has been handled you have the right to apply in writing to the Information Commissioner, under Section 50 of the Freedom of Information Act, at ‘Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. There are a number of other platforms you can use to contact the ICO and these can be found on the ICO’s website at the following link: Make a complaint | ICO (https://ico.org.uk/make-a-complaint/).
In most circumstances, the Information Commissioner will not investigate a complaint unless an internal review procedure has been carried out however, the Commissioner has the option to investigate the matter at their discretion.
Please be advised that PSNI replies under Freedom of Information may be released into the public domain via our website @ www.psni.police.uk
Personal details in respect of your request have, where applicable, been removed to protect confidentiality.