College of Policing, A Beacon of Transparency

Last Updated on March 2, 2019 by RetiredAndAngry

It may be a surprise to some of you but I am not a huge fan of the Direct Entry Scheme for Inspectors and Superintendents into the Police Service. Sorry to shock you, but it’s true. I am, however, curious about it.

We hear quite a lot about it but I was never really sure what sort of numbers we were talking about. So I set about finding out.

A couple of Freedom of Information requests to the College of Policing should sort that out.

1. Nationally, how many Direct Entry Inspectors have been recruited

Answer:- 54 (since the programme started in 2016)

2. How many of these have subsequently resigned or been dismissed?

Answer:- Information is held but is considered to be exempt from disclosure by virtue of the exemption provided under section 40(2) of the FoIA. The figures recorded are low and disclosure combined with information available in the public domain, creates a risk of an individual being identified. For further information about the College’s application of section 40(2) please refer to Appendix A.

3. Nationally, how many Direct Entry Superintendents have been recruited?

Answer:- 32 (since the programme started in 2014

4. How many of these have subsequently resigned or been dismissed?

Answer:- Information is held but is considered to be exempt from disclosure by virtue of the exemption provided under section 40(2) of the FoIA for the reasons given above. For further information about the College’s application of section 40(2), please refer to Appendix A.

It seems that they’re quite keen to let me know how many have been recruited, but not so keen to let me know how many have dropped out or been ‘let go’. I find that quite startling really because the very next paragraph is:-

The College is committed to openness and transparency. To assist you in your enquiries and in the spirit of the FoIA, it may be helpful for you to know that the number of Direct Entry inspectors who have resigned or been dismissed is 10 or less.

And

The College is committed to openness and transparency. To assist you in your enquiries and in the spirit of the FoIA, it may be helpful for you to know that the number of Direct Entry superintendents who have resigned or been dismissed is 10 or less.

Personally I don’t find that terribly helpful or transparent, because it doesn’t really tell me anything concrete that I can work with. However, it does tell me:-

A) Up to 18.5% of Direct Entry Inspectors have fallen by the wayside one way or another since 2016.

B) Up to 31% of Direct Entry Superintendents have quit or been let go since 2014.

Is this just simply a ‘Healthy Churn’? Maybe it’s the College making good on their promise to help officers to leave and become Policing Ambassadors in the big, wide world.

Or maybe the Direct Entry Scheme simply doesn’t work for a large percentage of the people in it.

Just a thought. Without the College being so helpfully transparent it would have been almost impossible to assess how successful the scheme has been. I’m sure that the majority of serving Sergeants and Chief Inspectors awaiting promotion are suitably reassured.

Oh, and by the way, for the benefit of any #FOIA Geeks who want to know what Appendix A says about the College’s Refusal to comprehensively answer questions 2 and 4, enjoy:-

Section 40(2) FoIA – Personal Information (applied to items 4 and 5 of your request)

40

(2) Any information to which a request for information relates is also exempt information if- (a) it constitutes personal data which do not fall within subsection (1), and
(b) either the first or the second condition below is satisfied.

Under section 40(2) FoIA (by virtue of section 40(3A)), personal data of a third party can be withheld if it would breach any of the data protection principles to disclose it. Personal data is defined in section 3(2) of the DPA 2018 as:

‘any information relating to an identified or identifiable living individual’

Section 3(3) defines an identifiable living individual as ‘a living individual who can be identified, directly or indirectly, in particular by reference to –
(a) an identifier such as a name, an identification number, location data or an online identified, or (b) one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the individual’

The two main elements of personal data are that the information must ‘relate’ to a living person and that the person must be identifiable. Information will relate to a person if it is about them, linked to them, has some biographical significance for them, is used to inform decisions affecting them, and has them as its main focus or impacts on them in any way.

A figure representing the number of individuals whom have resigned or have been dismissed from the Direct Entry programme may not in itself constitute as personal data. However, the low numbers identified as a result of the searches conducted, if combined with information in the public domain or otherwise, creates a substantial risk of an individual being identified. As such, it is our view that the information in question is categorised as personal data.

The data protection principles are given under Article 5 of the GDPR. Article 5(1)(a) states that personal data shall be ‘processed lawfully, fairly and in a transparent manner in relation to the data subject’. We consider that those attending the Direct Entry programme would have a reasonable expectation that certain information about them, held by the College, would not be disclosed further. The College has a duty of care towards those whose data we hold. It would not be fair and hence, a breach of Article 5, to put this information into the public domain without express consent having been given.

For your information, section 40(2) in these circumstances is an absolute exemption and there is no requirement for the public interest test to be considered.

Personally I can’t regard that as very ‘transparent’. I only know the identities of a handful of the recruits to this scheme, I’m certainly unaware of the identity of any who have dropped by the wayside. I only asked for a total number, how on earth I, or anyone else, could work out their identities from that is completely beyond me, but then I don’t have a degree, maybe that’s the reason.

2 comments on “College of Policing, A Beacon of Transparency

  1. Very interesting for all of the reasons you highlight. Having retired in the rank of Detective Chief Superintendent I can categorically say that I could not have performed at that level without having worked in each and every rank up to that one.

    In order to gain the necessary experience and operational credibility, any police officer needs to have worked in those ranks below the one in which he/she is currently holding. No doubt about that whatsoever!!

  2. The article also demonstrates with clarity that the direct entry scheme is simply NOT working!!! No surprise there then!

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