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Request Number: FOI/15698

Category: Human Resources - Learning, Development and Training

Subject: Written Improvement Notices (WINs) 2022, 2024 and 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/for-organisations/foi/freedom-of-information-and-environmental-information-regulations/section-12-requests-where-the-cost-of-compliance-exceeds-the-appropriate-limit/  

Question 1
For the period 1 January 2022 – 31 December 2022:

The total number of Written Improvement Notices (WINs) issued that year and for what reason - Performance or Attendance.

Question 2
Of those issued, how many were overturned on appeal?

Question 3
If recorded, how many were issued to officers with a declared disability under DDA/Equality Act? (aggregate numbers only)

Question 4
A breakdown of WINs by department/role where they were issued (e.g., Dispatch, TRU, CID, Uniform patrol, RCU, Cyber, MIT, PSD, Neighbourhood)

Question 5
Of those who received WIN notices, were in IHR process or later retired under IHR.

Question 6
I would like to request the following information for the period 1 January 2024 – 31 December 2024:

The total number of Written Improvement Notices (WINs) issued that year and for what reason - Performance or Attendance.

Question 7
Of those issued, how many were overturned on appeal?

Question 8
If recorded, how many were issued to officers with a declared disability under DDA/Equality Act? (aggregate numbers only).

Question 9
A breakdown of WINs by department/role where they were issued (e.g., Dispatch, TRU, CID, Uniform patrol, RCU, Cyber, MIT, PSD, Neighbourhood).

Question 10
Of those who received WIN notices, were in IHR process or later retired under IHR.

Question 11
I would like to request the following information for the period 1 January 2025 to date of data production: The total number of Written Improvement Notices (WINs) issued that year and for what reason - Performance or Attendance.

Question 12
Of those issued, how many were overturned on appeal?

Question 13
If recorded, how many were issued to officers with a declared disability under DDA/Equality Act?

(Aggregate numbers only).

Question 14
A breakdown of WINs by department/role where they were issued (e.g., Dispatch, TRU, CID, Uniform patrol, RCU, Cyber, MIT, PSD, Neighbourhood).

Question 15
Of those who received WIN notices, were in IHR process or later retired under IHR.

Question 16
Under the Freedom of Information Act 2000, I would like to request the following information for the period 1 January 2024 – 31 December 2025; the total number of Written Improvement Notices (WINs) issued that year and for what reason - Performance or Attendance.

Question 17
Of those issued, how many were overturned on appeal?

Question 18
If recorded, how many were issued to officers with a declared disability under DDA/Equality Act? (aggregate numbers only).

Question 19
A breakdown of WINs by department/role where they were issued (e.g., Dispatch, TRU, CID, Uniform patrol, RCU, Cyber, MIT, PSD, Neighbourhood).

Question 20
Of those who received WIN notices, were in IHR process or later retired under IHR.

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.

The information you seek in your request is not held centrally or in a retrievable format on PSNI systems, to check each Written Improvement notice to determine the reason for it, if the officer has a declared disability under DDA/Equality Act and if they were in ill Health Retirement process or later retired would require a manual examination of each notice issued. In 2022 there were 232 Written Improvement Notices issued for attendance, this includes Police Officers, Police staff and leavers. To check each of these records to determine if they are relevant to your request would take approximately 5 minutes, this would take around 19 hours and this is just one part of your request in one year alone. Data for performance Written Improvement Notices would be held across the organisation and is not held centrally. Your request is grossly over the cost limits set out in FOIA. 

Questions 16-20 you have requested information up to December 2025, a Freedom of Information request is only valid for records that exist at the time of the request.

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 advise how many written improvement notices were issued for attendance, department breakdown and how many were overturned on appeal.

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.