Professionalising Investigation Programme

Request: FOI/00013423

Category: Human Resources - Learning, Development and Training

Subject: Professionalising Investigation Programme

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
Please provide numbers and age profile of PSNI officers who held PIP2 accreditation in April 2017. (Please define age profile in groups between 20-29, 30-39, 40-49, 50+)
The numbers and age profile of PSNI officers who held PIP2 ACTIVE in August 2017.
The numbers and age profile of PSNI officers who held PIP2 INACTIVE in August 2017.
The numbers and age profile of PSNI officers who held PIP2 INTERIM in August 2017.
The numbers and age profile of PSNI officers who held PIP2 UNREGISTERED in August 2017.
The numbers and age profile of PSNI officers who held PIP2 ARCHIVED in August 2017.
 
Request 2
The numbers and age profile of PSNI officers who requested “PIP2 Grandfather Rights” in 2017 (please define age profile in groups between 20-29, 30-39, 40-49, 50+).

Request 3
The numbers and age profile of PSNI officers who were granted “PIP2 Grandfather Rights” in 2017 (please define age profile in groups between 20-29, 30-39, 40-49, 50+).

Request 4
Please provide numbers of serving PSNI officers who held PIP2 accreditation in August 2018 (please define age profile in groups between 20-29, 30-39, 40-49, 50+)
The numbers and age profile of PSNI officers who held PIP2 ACTIVE in August 2018.
The numbers and age profile of PSNI officers who held PIP2 INACTIVE in August 2018.
The numbers and age profile of PSNI officers who held PIP2 INTERIM in August 2018.
The numbers and age profile of PSNI officers who held PIP2 UNREGISTERED in August 2018.
The numbers and age profile of PSNI officers who held PIP2 ARCHIVED in August 2018.

Request 5
Please provide the numbers and age profile of PSNI officers who obtained PIP2 accreditation through the National Investigators Exam (NIE) per year since 2017 (please define age profile in groups between 20-29, 30-39, 40-49, 50+).

Request 6
Please provide numbers of PSNI officers who held PIP2 accreditation in August 2024 (please define age profile in groups between 20-29, 30-39, 40-49, 50+)
The numbers and age profile of PSNI officers who held PIP2 ACTIVE in August 2024.
The numbers and age profile of PSNI officers who held PIP2 INACTIVE in August 2024.
The numbers and age profile of PSNI officers who held PIP2 INTERIM in August 2024.
The numbers and age profile of PSNI officers who held PIP2 UNREGISTERED in August 2024.
The numbers and age profile of PSNI officers who held PIP2 ARCHIVED in August 2024.

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.

Whilst the information you seek is held electronically by the PSNI, it is not held in a format that would allow its retrieval without manual intervention. PSNI is not saying it does not hold the data that you request, however to extract the data you have sought in your request would require a manual trawl of PSNI’s records – hence putting the request grossly over the 18 hour cost limit set out under the FOIA.

To retrieve all the information you have requested would require a manual review of all relevant records. Age breakdowns and some status histories cannot be retrieved without manual intervention. Additionally, the College of Policing (Est. 2012) run the current NIE & PIP programme which has been in place since 2015, so all accreditations since then will have been via the current NIE qualification and subsequent skills development and portfolio pathway. There are no records which show a clear breakdown of when officers sat the NIE, passed it, then completed the requisite skills course and portfolio within specific timeframes and what their age profile was. Accurate figures would involve a manual trawl of all those who have been PIP 2 accredited since 2017 (excluding those granted Grandparent’s Rights). An excess of 500 records would require a manual review, and at a conservative 10 minutes per review, it would take more than 80 hours to retrieve the data you are seeking. Therefore, your request exceeds the 18 hour cost limit.

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. 

We may be able to provide the following under the appropriate limit:
 

• Total number of current serving officers who have PIP2 on their record from the start of time to 30/04/2017.
• The number of PSNI officers who requested “PIP2 Grandfather Rights” in 2017.
• The numbers and age profile of PSNI officers who were granted “PIP2 Grandfather Rights” in 2017.
• Total number of current serving officers who have PIP2 on their record from the start of time to 31/08/2018.
• Total number of current serving officers who have PIP2 on their record from the start of time to 31/08/2024.

Please be advised that Active/Inactive/Interim/Unregistered/Archived status cannot be accurately provided at this time, so figures would only reflect all those who have any PIP 2 status at the relevant time. Work is ongoing between departments to provide a process to allow for officers’ PIP status to be accurately reflected on the system. 

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.