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Request Number: FOI/14575

Category: Incident and Crime Statistics - Sexual Offences

Subject: Sexual Offences

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 Details
I am writing to request the following information. Please can the information be broken down for each year between January 2020 - April 2025

Request 1 Details
How many cases have been recorded by your force between January 2020 and April 2025 for the following offences: 

Request 1A 
Disclosing, threatening to disclose, private sexual photographs and films with or without intent to cause distress

Request 1B
Sharing or threatening to share intimate photograph or film 

Request 1C
Voyeurism

Request 2
Can you provide any further information about these cases and include the outcome of each case in (1)?

Request 3
The number of cases involving threats to share intimate photographs or films in which alleged victims were unwilling or unable to contribute to police efforts to prosecute the alleged offender, between January 2020 and April 2025.

Request 4
Can you include the outcome and/or reason why the alleged victim did not continue with police efforts to prosecute the alleged offender?

Request 5 Details
The number of convictions and outcomes made each year between 2020 - 2025 for the following offences

Request 5A
Disclosing, threatening to disclose, private sexual photographs and films with or without intent to cause distress

Request 5B
Sharing or threatening to share intimate photograph or film

Request 5C
Voyeurism

Request 6
The number of convictions involving threats to share intimate photographs or films by repeat offenders.

Request 7
Can you include the outcome for each conviction?

Request 8
The number of reports of threats to share photographs or films which show, or appear to show, someone in an intimate state - This would be a breach of Section 188(4) of the Online Safety Act 2023.

Request 9
Can you include the outcome of each report?

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.

‘Sharing or threatening to share intimate photograph or film’ is covered under S188(4) of the Online Safety Act 2023, which only applies to England and Wales. For Requests 3 and 4, we have considered your request under the relevant offences within Northern Ireland – ‘Disclosing Private Sexual Photographs and Film with Intent to Cause Distress’ and ‘Threatening to Disclose Private Sexual Images’.

Whilst the information you seek is held electronically by the PSNI, some information 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 the data sought in 3 and 4 would require a manual trawl of all offence records, in regards to the offences listed, to understand if a victim statement is present and to ascertain if the victim has engaged throughout the investigation, or has subsequently disengaged at some point in the judicial process and the reasoning why the alleged victim did not continue with the process. Approximately 470 offences were recorded for ‘disclosing private sexual photographs and film with intent to cause distress/threatening to disclose private sexual images’ within the timeframe of this request. It has been estimated it would take anywhere between 10 and 30 minutes to review each case, and therefore, to retrieve the information sought in these parts of the request would exceed 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 can provide the following within the appropriate limit:

  • A response to Requests 1A and 1C.
  • The outcome of each case in Requests 1A and 1C.

To assist further with your request:
‘Sharing or threatening to share intimate photograph or film’ is covered under S188(4) of the Online Safety Act 2023, which only applies to England and Wales. Therefore, we would be unable to provide any data in regards to this type of offence (Requests 1B, 8 and 9).

  • Data regarding convictions is held by the Department of Justice NI and to get the most accurate information, we would advise Requests 5A, 5B, 5C, 6 and 7 are directed there.
  • Statistics relating to sharing intimate images and voyeurism for each financial year to 2024/25 were published on the PSNI website on 15th May (see link below). The number of crimes recorded can be found in Table 15 of the spreadsheet accompanying the police recorded crime monthly update to 31 March 2025, classified within ‘other sexual offences’, and the number of sanction outcomes/sanction outcome rates are available in Tables 16 & 16(rates).

https://www.psni.police.uk/about-us/our-publications-and-reports/official-statistics/police-recorded-crime-statistics

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.