October 22, 2025 | Human Resources , Officer and Staff: Recruitment and Promotion
Request Number: FOI/15573
Category: Human Resources – Officer and Staff: Recruitment Promotion
Subject: Promotion Process and Temporary Promotions
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:
Question 1
I would be grateful if you could provide current figures on temporary promotions and acting-up arrangements across the organisation. Specifically, I am seeking
a) The total number of police officers currently temporarily promoted or acting up
b) The total number of police staff currently temporarily promoted or acting up
c) Any breakdown available by department, grade, or duration of appointment
Question 2
Can you confirm how many staff or officers who were temporarily promoted subsequently secured the role on a substantive basis—without relinquishing the post during the transition? Over a period of 36 months will be sufficient.
Question 3
I am seeking the total number of police officers within the Police Service of Northern Ireland (PSNI) who were temporarily promoted between 8 August 2023 (the date of the PSNI data breach) and 8 August 2024 (its one-year anniversary).
Please provide a breakdown by rank if available, and indicate whether these figures include officers promoted to cover vacancies, operational needs linked to the data breach. If the data is not held in a consolidated format, I would appreciate any available internal reporting or summary figures that reflect temporary promotion activity during this period.
Question 4
I am seeking the number of staff members who, transitioned from a fixed-term contract to a permanent, full-time established role without being required to undergo a further competitive or formal selection process.
If available, please include
a) A breakdown by department or grade
b) Any applicable criteria or policy framework used to determine direct conversion
c) Whether these appointments were made under Regulation 8 of the Fixed-Term Employees (Prevention of Less Favourable Treatment) Regulations 2002 or similar internal provisions
Question 5
Please provide the following information regarding the use of derogations in promotion processes from 1 January 2022 to the present;
a) The number of times a derogation was applied
b) The grade or rank associated with each instance
c) The rationale or justification recorded for applying the derogation
d) Whether the derogation led to a direct appointment or bypassed standard competitive procedures
e) If available, please include any internal reports, summaries, or policy references that document or explain the use of derogations during this period.
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 in Questions 1-4 is held on PSNI database, it is not held centrally, one area alone advised that it would take approximately 20 hours to collect all the data requested and then create a response with their findings, and this is over the cost limits set out in FOIA. Q1 a & b would involve contacting all departments in the organisation to ask which of their personnel are ‘acting up’ Each department would then need to respond with their answer, To answer Question 2 alone would involve manual comparison/check SAP records, checking 80 records at approximately 6 minutes per record would be 8 hours, a further 1 hour to create the report with the findings.
For Question 3 - Our response would relate to the number of temporary promotions by reason, an individual Police Officer may have had multiple temporary promotions during this time period.
For Question 5 - Our systems do not record whether a promotion is as a result of a derogation request or not. It is therefore not possible to determine how many times a promotional derogation has been applied for and approved.
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 can provide a response for Question 2 if request is limited to the past 12 months
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.