June 24, 2025 | Incident and Crime Statistics , Sexual Offences
Request Number: FOI/14904
Category: Incident and Crime Statistics - Sexual Offences
Subject: Offences by Minors Involving Deepfake Content (2024–2025)
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 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(1) of the Freedom of Information Act 2000 and this will be further explained below. PSNI have 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 (1) of the FOIA. This guidance is available on the ICO website at the following link:
https://ico.org.uk/media/for-organisations/documents/1199/costs_of_compliance_exceeds_appropriate_limit.pdf
Request 1
Under the Freedom of Information Act, I am requesting the number of recorded crimes or incidents from 1 January 2024 to the present in which the following keywords appear in incident summaries, crime reports, or investigation notes:
"deepfake” OR "AI-generated” OR "synthetic media” OR "fake nude” OR "fake video”
Please provide:
The number of such incidents, broken down by month, where the suspect or perpetrator was under 18 at the time of the offence.
Request 2
Where available, the associated offence type or classification, e.g. harassment, sexual offence, malicious communications, etc.
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(1) 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.
Enquiries made in relation to your request has identified that retrieval of information to respond to your request would exceed the FOI legislative cost of 18 hours as set by the Secretary of State.
PSNI can confirm that while we hold the information requested, it is not available in a retrievable format. As there are no specific offences codes for the circumstances requested, PSNI cannot identify relevant records through the specific offence committed. ‘False/deep fake’ videos/images may sit within a range of classifications making it difficult to narrow down the scope of any search without it being a keyword search.
It should be noted, that ‘keyword search’ is considered by the PSNI to be extremely unreliable, due to the need for search through unstructured data. For unstructured data fields we also cannot rely on the data having been entered in such a way as to identify those records that are relevant. This means that PSNI cannot automatically determine the context of the term found in the search result and a manual review is almost always be required to decide if the result meets the criteria of the FOI request.
Spelling mistakes, abbreviations and aliases can all affect the reliability of a keyword search. In addition, we do not have the ability to search for keywords within external documents stored in our database, so the scope with which we can do a keyword search is limited.
To identify offences which have involved the use of ‘deepfake’/AI-generated images and videos would require manual examination of each crime record. For the period January 2024 – April 2025 there were around 12,800 recorded offences under the stalking and harassment classification (which includes harassment and malicious communications). To manually examine this many records would take around 1,600 hours, vastly exceeding the legislative timeframe of 18 hours. Adding in additional offence classifications e.g. Obscene Publications, sharing intimate images (revenge porn), blackmail etc would further extend the time required.
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.
Unfortunately, due to system limitations and the reasoning provided above we are unable to offer any further refinement for this request.