January 09, 2026 | Organisational Information and Performance , Service Instructions
Request Number: FOI/15602
Category: Organisational Information & Performance - Service Instructions
Subject: PSNI Guidance on Interacting with Insurers
Request and Answer:
Your request for information has now been considered. In respect of Section 1(1)(a) of the Act we can confirm that the Police Service of Northern Ireland does hold information to which your request relates and this is being provided to you.
However, we consider some of the information you seek in this request exempt by virtue of Section 31 of FOIA and have detailed our rationale as to why these exemptions apply. We have also provided you with links to guidance issued by the Information Commissioner’s Office which we have followed in responding to your request.
Request Details
Authority/communications re insurance
Any PSNI policies/guidance on officer interactions with insurers.
Clarification Sought
Could you confirm if your request is referring to vehicle insurers?
Clarification Received
Yes, my request refers to vehicle (motor) insurers. To assist you, I’m narrowing and itemising
the scope as follows (electronic copies preferred):
Timeframe: 1 January 2023 to present.
Request 1
Policies/Procedures/Guidance
Current PSNI policies, SOPs, or internal guidance for liaison with motor insurers and their agents (including loss adjusters, panel solicitors, the Motor Insurers" Bureau (MIB) and Insurance Fraud Bureau (IFB))—covering collision reports, suspected insurance offences, and insurer requests for disclosure.
Answer 1
MIB have an agreement with police that MIB can receive a Traffic Collison Report (or equivalent report in the absence of a TCR) free of charge, however other material will be charged. This agreement also applies to those companies representing MIB.
The MIB ‘Untraced Drivers Agreement’ can be viewed in through the following link:
https://www.mib.org.uk/media/166901/2004-northern-ireland-untraced-drivers-agreement.pdf
Additionally, a third party information request by agencies can only be processed if it is made with express consent from the person to whom the information refers. Such requests must also be accompanied by a ‘lawful’ purpose. The PSNI require a request for third party information in writing alongside a completed OCMT 5 (RTC) form alongside any fees that may be applicable. Forms are available for viewing from the PSNI Website:
https://www.psni.police.uk/request/third-party-information-request/guidance-third-party-sharing-information
Material or information is only released upon completion of all PSNI Investigations and any criminal proceedings have concluded.
Furthermore, during the Student Officer Development Programme, the only information provided about liaison with MIB is in relation to the Police officer helpline, where officers can check status of a vehicle via the MIB at the roadside. This is covered in the “Production of Documents Lesson”. During this lesson we state that this is the preferred method to obtain live time insurance information rather than phoning insurance companies directly, as MIB will give a call reference number. There is no further formal input in the Student Officer Development Programme in relation to civil requests and civil cases following road traffic collisions.
The PSNI has records of internal guidance to ensure that requests for data are processed correctly. However, as these materials reveal policing methodology we have chosen to withhold these records.
Section 17(1) of the Freedom of Information Act 2000 requires the Police Service of Northern Ireland, when refusing to provide such information (because the information is exempt) to provide you the applicant with a notice which:
- states that fact,
- specifies the exemption in question and
- states (if not otherwise apparent) why the exemption applies.
The exemption, as well as the factors the Department considered when deciding where the public interest lies, is listed below:
Section 31(1) (a) (b) - Law Enforcement – Information would be likely to prejudice (a) the prevention or detection of crime (b) the apprehension or prosecution of offenders.
The full text of exemptions can be found at www.legislation.gov.uk and further guidance on how they operate can be located on the Information Commissioners Office website www.ico.org.uk.
Section 31 is a prejudice based qualified exemption which means there is a requirement to evidence the prejudice (harm) in disclosure and consider the public interest.
Exemptions Explained
Section 31 Harm
Release of the internal guidance relevant to this request, could assist those intent on criminality against PSNI in disrupting the functions of the organisation. Consequently, this could place additional burden on police resources which may lead to the endangering of the health and safety of members of the public.
Section 31 Public Interest Test
Section 31 - Factors Favouring Disclosure
Disclosure of the requested information could provide transparency and demonstrate openness.
Section 31 - Factors Favouring Non-Disclosure
Release of internal guidance into the public domain could assist those intent on criminality against PSNI, by providing information that could assist them in disrupting the functions of the organisation. This would place an additional burden on police resources and potentially lead to vulnerabilities which could result in more criminal activity, placing the public in harm’s way. Any information which could be of assistance to those with criminal intent, strongly prejudices the PSNI’s law enforcement functions if released.
Section 31 Balancing Test
A disclosure of information under Freedom of Information is a release to the world in general and not just to the individual requesting the information. Once information is disclosed by FOI there is no control or limits as to who or how the information is shared with other individuals, therefore a release under FOI is considered a disclosure to the world in general.
Information should not be released, if it is likely to negatively impact the PSNI’s law enforcement functions. This information may be used by criminals in combination with other information they have gathered to try and prejudice law enforcement. PSNI is aware of the mosaic and precedent effects of releasing information which may be of use to criminals. A clear link exists between knowledge available to criminals and the way they operate, with the resultant impact on PSNI potentially giving a tactical advantage to criminals.
It is for these reasons that the public interest must be against release of the internal PSNI guidance subject to this request.
Request 2
Data-sharing instruments
Any Memoranda of Understanding / data-sharing agreements / protocols with MIB, IFB, DVLA, and the Motor Insurers’ Database (MID) that govern sharing of collision or driver/vehicle data for civil or fraud-related purposes.
Answer 2
Your request for information has now been considered. In respect of Section 1(1)(a) of the Act we can confirm that the Police Service of Northern Ireland (PSNI) does not hold information in relation to your requests. Enquiries made in relation to your request failed to locate any records or documents relevant to your request based on the information you have provided.
The Data-Sharing Agreements that govern the PSNI sharing with the stated organisations are held by the NPCC. PSNI do not hold these agreements therefore this request should be issued to the NPCC as they are the data controller of these agreements.
Accordingly, we have determined that the Police Service of Northern Ireland does not hold the information to which you seek access.
Request 3
Disclosure process & legal basis
Guidance for handling insurer requests (e.g., forms or portal processes used, criteria applied, decision-making steps) and the legal basis relied upon for disclosure to insurers (for example, references to DPA 2018 / UK GDPR provisions).
Answer 3
The PSNI will only supply material that is relevant to the requestor and only upon completion of all investigations and / or criminal proceedings as per General Data Protection Regulation.
The caveat below is placed on the bottom of all our correspondence to ensure that the Data Protection Act is not breached by the requestor:
‘In order to ensure that we continue to meet our obligations under the Data Protection Act, we will only process requests for third party information if they are submitted and fully completed on an OCMT 5, a copy of which is available for download on the PSNI website:
https://www.psni.police.uk/request/third-party-information-request
Some material can only be released on the provision of a court order and upon receipt, the normal administration process applies – we use wording below to show that fees are still applicable:
‘We have been advised by our Legal Services Branch that although the court has directed that the documents requested be released, the normal procedure for these requests applies and the relevant fees should be paid.’
Request 4
Templates & charging
Templates used to provide information to insurers (e.g., collision report request forms) and the current fees/charging schedule for such disclosures.
Answer 4
For the current fees/charging schedule in addition to more information regarding such disclosures, please follow the links below:
https://www.psni.police.uk/request/third-party-information-request
https://www.psni.police.uk/request/third-party-information-request/fees
As this information will be released into the public domain, we have made the decision to withhold PSNI templates as these could be used for fraudulent purposes. The exemption we have applied to the templates, as well as the factors the Department considered when deciding where the public interest lies, is listed below:
Section 31(1) (a) (b) - Law Enforcement – Information would be likely to prejudice (a) the prevention or detection of crime (b) the apprehension or prosecution of offenders.
The full text of exemptions can be found at www.legislation.gov.uk and further guidance on how they operate can be located on the Information Commissioners Office website www.ico.org.uk.
Section 31 is a prejudice based qualified exemption which means there is a requirement to evidence the prejudice (harm) in disclosure and consider the public interest.
Exemptions Explained
Section 31 Harm
Release of templates used by the PSNI to provide information to insurers, could assist those attempting to commit fraudulent crimes regarding insurance claims. Consequently, this could place additional burden on police resources which may lead to the endangering of the health and safety of members of the public.
Section 31 Public Interest Test
Section 31 - Factors Favouring Disclosure
Disclosure of the requested information could provide transparency and demonstrate openness.
Section 31 - Factors Favouring Non-Disclosure
Release of PSNI templates into the public domain could assist those intent on criminality, by providing information that could assist them. This would place an additional burden on police resources and potentially lead to vulnerabilities which could result in more criminal activity, placing the public in harm’s way. Any information which could be of assistance to those with criminal intent, strongly prejudices the PSNI’s law enforcement functions if released.
Section 31 Balancing Test
A disclosure of information under Freedom of Information is a release to the world in general and not just to the individual requesting the information. Once information is disclosed by FOI there is no control or limits as to who or how the information is shared with other individuals, therefore a release under FOI is considered a disclosure to the world in general.
If released into the public domain, this information has the potential to be used by individuals to commit crime. A clear link exists between knowledge available to criminals and the way they operate, with the resultant impact on PSNI potentially providing information that could be used to assist with criminal activities. An increase in crime has a direct impact on PSNI resources and, in turn, puts the public at risk.
We have therefore decided that the public interest must be against release of the templates sought in relation to this request.
Request 5
Officer statements/civil proceedings
Any guidance concerning PSNI officers providing statements or attending civil proceedings at the request of insurers.
Answer
Your request for information has now been considered. In respect of Section 1(1)(a) of the Act we can confirm that the Police Service of Northern Ireland (PSNI) does not hold information in relation to your requests. Enquiries made in relation to your request failed to locate any records or documents relevant to your request based on the information you have provided.
The PSNI have found no guidance on providing statements for the purpose of civil proceedings.
Accordingly, we have determined that the Police Service of Northern Ireland does not hold the information to which you seek access.