FOI 106/25
REQUEST
- In each of the last five calendar years (2019, 2020, 2021, 2022, 2023), how much did the force spend on purchasing information from data brokers such as Experian, Equifax, Acxiom and others?
Please provide a full breakdown of spend with each provider in each calendar year. For example, in the following format:
|
Provider |
2019 |
2020 |
2021 |
2022 |
2023 |
|
Experian |
|||||
|
Equifax |
|||||
|
Acxiom |
|||||
|
[insert others below] |
For what purposes does the force purchase information from data brokers?
RESPONSE
We consulted with our Finance department who have provided the following information regarding your request.
Question 1
|
Provider |
2019 |
2020 |
2021 |
2022 |
2023 |
|
Experian |
£89,300 |
£117,198 |
£148,983 |
£99,270 |
£91,111 |
|
Equifax |
£8,228 |
£11,827 |
£13,034 |
£12,069 |
£10,672 |
Please note there was no spend for the data broker Acxiom or any others.
Question 2
The costs provided includes licence fees as well as any additional charges billed monthly. South Wales Police utilises the Experian Mosaic product to better under its communities at a socio-demographic level.
South Wales Police neither confirms nor denies that it holds any other information relating to this request by virtue of the following exemptions:
Section 30(3) – Investigations and Proceedings Conducted by Public Authorities
Section 31(3) Law Enforcement
Section 30 (3) is a qualified class-based exemption and I am required to conduct a public interest test in neither confirming nor denying that information exists.
Section 31(3) is both prejudice based and qualified; the harm (prejudice) in confirming or denying should be evidenced, the public interest considered and both articulated to the applicant.
Evidence of Harm
A wide range of investigative methods are deployed by police in investigations and the gathering of evidence in order to bring the perpetrators of crime to justice, and where disclosure of information including, in some cases, confirming or denying information is held would risk prejudice to any such investigations it should not be given.
It must be considered that a disclosure under FOI is not a private transaction but rather a broadcast to the world. To confirm or deny that any other information is held in respect of ongoing covert investigations would risk revealing to criminals including organised criminal gangs, police intelligence and the focus of investigative activity particularly in financial and economic crime. Irrespective of whether any other information is or isn't held, ongoing covert investigations would be compromised if an offender were to be made aware of what may or may not be held about any specific lines of enquiry within covert investigations, namely the use of data brokers for intelligence gathering. To do so would enable them to take steps to alter their behaviour and/or destroy evidence, undermining the police’s key functions of detecting crime and apprehending offenders.
Additionally, in order to ensure the police, deliver effective law enforcement they liaise with various other law enforcement partners. By confirming or denying that any other information is held in respect of covert ongoing investigations, not only would operationally law enforcement and investigations be compromised as evidenced above, but any partnership working that may be in place would also be compromised.
Public Interest Considerations
Section 30 - Factors Favouring Confirmation or Denial
By confirming or denying that any other information relevant to your question exists would satisfy the public that the police take their responsibility to investigate crime thoroughly and that public money is well spent in securing evidence in criminal activity.
Section 30 - Factors Against Confirmation or Denial
By confirming or denying that any other information relevant to this question exists would hinder the protection of any operations the force has under the guise of covert activity that the force would not want to be known by criminals. This information would be sensitive, and the force would not want them to adapt their offending behaviour in order to avoid detection.
Section 31 - Factors Favouring Confirmation or Denial
Disclosure would provide transparency in how police investigate crime and provide reassurance that tactics are being utilised appropriately to prevent and detect criminal activity. It would also serve to demonstrate that the police are open and accountable.
Section 31 - Factors Against Confirmation or Denial
The police have a duty of care to the community at large. If an FOI disclosure revealed information to the world (by citing an exemption or stating no information held) that would undermine an investigation, this could be used to offenders' advantage and would compromise potential victims and the public generally. It may also encourage offenders to alter their behaviours resulting in further, undetected crime.
Balance Test
The factors above highlight the merits of confirming, or denying, whether any other information pertinent to this request exists. The Police Service is charged with enforcing the law, preventing and detecting crime and protecting the communities we serve. As part of that policing purpose, various types of investigations may or may not be ongoing. The Police Service will never divulge whether any other information pertinent to a request does or does not exist, if to do so would compromise an ongoing investigation, or undermine the policing purpose in the effective delivery of operational law enforcement. Whilst there is a public interest in the transparency of policing operations and investigations it will be overridden in exceptional circumstances. Therefore, at this moment in time the balance test for neither confirming nor denying that any other information is held is appropriate.