FOI 332/26
Request
Under the Freedom of Information Act 2000, I would be grateful if you could provide the following information.
- A list of any artificial intelligence, machine learning, or algorithmic decision-making systems currently used by the force. If possible, please include the name of the system, its purpose, and when it was first introduced.
- A list of any AI or algorithmic systems that were previously used by the force but are no longer in use.
- Copies of any policies, guidance, or internal documents relating to the use of AI or automated decision-making tools within the force.
- Copies of any impact assessments relating to these systems.
- Any reports, evaluations, or testing that have been carried out to assess the accuracy, reliability, or potential bias of these systems.
- Details of any partnerships with external organisations (for example technology companies, universities, or other agencies) relating to the development or use of AI systems.
- Copies of any strategies, roadmaps, or plans relating to future adoption of AI technologies within the force.
If it helps with the request, I am primarily interested in information held between January 2020 and the present.
Response
We have consulted with our Digital, Data and Technology department who have provided the following information in relation to your request.
Question 1
South Wales Police (SWP) use a limited number of digital systems that incorporate automation, analytics, or algorithmic techniques to support policing and corporate functions. These technologies are used to assist human users and do not make fully automated operational or law enforcement decisions about individuals without human oversight.
Question 2
SWP does not maintain a centrally held historical register categorised specifically as “AI” or “algorithmic” systems. Any systems decommissioned since January 2020 were retired through standard ICT, governance, and procurement processes. To identify and categorise historic systems would require the creation of new information, which is not required under FOIA. Accordingly, this information is not held in recorded form for the purposes of the Act.
Question 3
SWP holds a formal policy governing the acceptable and ethical use of artificial intelligence technologies. Please see attached document ‘Artificial Intelligence-Acceptable Use Policy v1 Redacted-2-PDF.pdf’.
This policy sets out governance arrangements, ethical principles, acceptable and prohibited use, approval processes, and oversight mechanisms for the use of AI within the force.
In relation to the redacted information, the following exemptions apply:
Section 31(1)(a)(b) – Law Enforcement
Section 40(2) – Personal Information
Section 31(1)(a)(b) is a qualified, prejudice-based exemption and the legislators accept that there may be harm if released. The authority is therefore required to articulate the harm that may be caused and consider the public interest arguments for and against the disclosure of the information.
Section 40(2) is an absolute, class-based exemption and therefore the authority is not required to consider the public interest in disclosure.
Section 31(1)(a)(b) Law Enforcement
Overall Harm
A disclosure in response to a Freedom of Information request is not a disclosure to the individual applicant but a release into the public domain. It is important that a Police Force safeguards its effective and efficient service and does not disclose information that could undermine that.
Disclosure of the requested information would reveal our tactical capabilities and compromise the prevention or detection of crime and the apprehension or prosecution of offenders. This would hinder future investigations by assisting those who are intent on undertaking criminal activity.
Public Interest Test
Factors favouring disclosure - By disclosing the requested information, this would provide openness and transparency and better awareness to the public.
Factors against disclosure - The security of the public is of paramount importance and the Police Service will not divulge information if to do so could compromise law enforcement.
Balance Test
Whilst there is public interest in police transparency, there is stronger public interest in safeguarding information which could assist those who wish to disrupt the police service.
Therefore, it is our opinion that for these issues the balance test lies in favour of withholding the information.
In accordance with the Act, this letter acts as a refusal notice for this part of your request.
Section 40(2) Personal Information
The Data Protection Act covers processing of personal data about a living individual. Personal data means data which relate to a living individual who can be identified-
- from those data, or
- from those data and other information which is in the possession of,or is likely to come into the possession of, the data controller or any other person in respect of the individual.
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, has them as its main focus or impacts on them in any way.
If we disclosed these details, this would provide significant detail which could identify an individual and would breach the first principle of the Data Protection Act 2018.
In accordance with the Act, this letter represents a refusal notice for your request.
Question 4
Where required, impact assessments (for example Data Protection Impact Assessments or Equality Impact Assessments) are conducted at a system or use‑case level in line with legal and governance requirements.
These documents contain sensitive operational and personal data and are therefore exempt from disclosure.
Question 5
Assurance, testing, and evaluation activities are undertaken where appropriate as part of supplier assurance, governance oversight, and alignment with national policing standards.
Specific reports and testing outputs are exempt from disclosure.
Question 6
South Wales Police work with external suppliers, academic institutions, and national policing bodies in accordance with procurement, governance, and legal requirements.
Details of specific partnerships, contractual arrangements, or development activities are exempt from disclosure.
Questions 4, 5 and 6
Your request for information has now been considered, and I am not obliged to supply the information you have requested. In relation to questions 4, 5 and 6 the following exemptions apply:
Section 31(1)(a)(b) – Law Enforcement (Questions 4, 5 & 6)
Section 40(2) Personal Information (Question 4 only)
Section 43(2) – Commercial Interests (Question 6 only)
Section 31(1)(a)(b) is a qualified, prejudice-based exemption and the legislators accept that there may be harm if released. The authority is therefore required to articulate the harm that may be caused and consider the public interest arguments for and against the disclosure of the information.
Section 40(2) is an absolute, class-based exemption and therefore the authority is not required to consider the public interest in disclosure.
Section 43(2) is a qualified, class-based exemption which requires the authority to consider the public interest in disclosure.
Section 40(2) Personal Information
The Data Protection Act covers processing of personal data about a living individual. Personal data means data which relate to a living individual who can be identified-
- from those data, or
- from those data and other information, which is in the possession of,or is likely to come into the possession of, the data controller or any other person in respect of the individual.
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, has them as its main focus or impacts on them in any way.
If we disclosed these details, this would provide significant detail which could identify an individual and would breach the first principle of the Data Protection Act 2018.
Section 31(1)(a)(b) Law Enforcement
Overall Harm
A disclosure in response to a Freedom of Information request is not a disclosure to the individual applicant but a release into the public domain. It is important that a Police Force safeguards its effective and efficient service and does not disclose information that could undermine that.
Disclosure of the requested information would reveal sensitive operational information, which would compromise the effectiveness, integrity or security of policing capabilities. This would compromise the prevention or detection of crime and the apprehension or prosecution of offenders. Furthermore, it would hinder future investigations by assisting those who are intent on undertaking criminal activity.
Public Interest Test
Factors favouring disclosure - There is a general public interest in understanding how AI is used to support policing functions, including the efficiency and effectiveness of core processes, and in ensuring that novel technologies are used lawfully and proportionately. Disclosure could support external scrutiny and promote confidence in policing practice.
Factors against disclosure - Disclosure of the request information would be likely to prejudice the prevention and detection of crime, the apprehension or prosecution of offenders, and the operation of law enforcement tactics and methodologies. The security of the public is of paramount importance, and the Police Service will not divulge information if to do so could compromise law enforcement.
Section 43(2) Commercial Interests
Public Interest Test
Factors favouring disclosure - Disclosing the requested information would promote openness and transparency in relation to commercial duties and may contribute to public debate.
Factors against disclosure - The police service has a moral duty to protect the sensitive commercial information it holds about any private company it has dealings with. Disclosure would be likely to prejudice the commercial interest of the company involved and affect future procurement for the Force as the information has been provided to us in confidence and is of a commercially sensitive nature. Disclosure is also likely to damage the relationship between South Wales Police and the supplier involved. This may in the future reduce the number of companies tendering therefore reducing the opportunities for South Wales Police to secure the best value.
Balance Test
Whilst there is public interest in police transparency, there is stronger public interest in safeguarding information which could assist those who wish to disrupt the police service.
While is it accepted that accountability and demonstrating transparency in the use of public funds is a strong factor favouring disclosure, in this case the requested information concerns the potential disclosure of information which would be detrimental to a supplier’s ability to compete fairly when bidding for future tender opportunities.
Therefore, it is our opinion that for these issues the balance test lies in favour of withholding the information.
In accordance with the Act, this letter acts as a refusal notice for this part of your request.
Question 7
South Wales Police does not hold a standalone AI strategy or roadmap document. Consideration of future adoption of AI technologies is addressed within broader digital, data, and ICT strategies, aligned to national policing guidance and ethical standards.
In addition, South Wales Police will neither confirm nor deny any further information is held under the following exemptions:
Section 24(2) (National Security)
Section 31(3) (Law Enforcement)
Section 24 Section and 31 are qualified, prejudice-based exemptions and the legislators accept that there may be harm if released. The authority is therefore required to articulate the harm that may be caused and consider the public interest arguments for and against the disclosure of information.
Overall Harm
Having disclosed high‑level information about routine, non‑sensitive uses of Artificial Intelligence (AI), South Wales Police will neither confirm nor deny whether it holds any further information that would indicate whether AI is, or is not, used in connection with counter‑terrorism, serious and organised crime, covert intelligence activity, or specialist digital forensics supporting those functions. The duty to confirm or deny is disapplied by virtue of sections 24(2) (National Security) and 31(3) (Law Enforcement) of the Freedom of Information Act 2000. This response should not be taken as an indication of whether any additional information is held.
Confirming or denying whether AI is used by South Wales Police in counter‑terrorism, serious and organised crime, covert intelligence or specialist digital forensics would enable hostile actors to infer the presence, absence or maturity of particular policing capabilities. This type of capability insight is of practical value to adversaries who routinely adapt their behaviour to exploit perceived weaknesses, overwhelm less technologically equipped forces, or adjust methods to avoid detection. Even a single confirmation or denial could be combined with publicly available information from other forces to build a detailed national picture of capability. This mosaic effect represents a realistic and actionable risk, providing information that could materially undermine national security and the effectiveness of law‑enforcement operations.
Public Interest Test – Section 24(2) National Security
Factors in favour of confirming or denying - There is a strong public interest in openness and transparency about the use of AI in policing. Confirming or denying the existence of information could contribute to informed public debate about how emerging technologies are deployed, the safeguards in place, and whether they align with legal and ethical standards. Disclosure can enhance accountability, promote trust, and reassure the public that AI use is subject to appropriate oversight.
Factors against confirming or denying - There is an overriding public interest in protecting national security. Confirming or denying the existence of information about AI deployment in CT, SoC, covert intelligence, or linked specialist forensics would provide adversaries with useful insights into operational capabilities and priorities. Even a simple confirmation or denial could enable hostile actors to adjust methods, exploit potential gaps, or test thresholds. The resulting risk to national security would be real and more than trivial, and is not mitigated by partial or local confirmations, because the cumulative mosaic effect across multiple forces would still disclose sensitive capability at a national level.
Public Interest Test – Section 31(3) Law Enforcement
Factors in favour of confirming or denying - There is a general public interest in understanding how AI is used to support policing functions, including the efficiency and effectiveness of core processes, and in ensuring that novel technologies are used lawfully and proportionately.
Confirmation or denial could support external scrutiny and promote confidence in policing practice.
Factors against confirming or denying - Confirming or denying the existence of information relating to AI use in CT, SoC, covert intelligence, or specialist digital forensics would be likely to prejudice the prevention and detection of crime, the apprehension or prosecution of offenders, and the operation of law enforcement tactics and methodologies. Knowledge of whether specific capabilities exist, or do not exist, enables offenders to adapt behaviour, exploit capability gaps, frustrate investigations, and increase the cost and complexity of counter‑measures. The public interest strongly favours maintaining an NCND to preserve the effectiveness of law enforcement and the safety of the public.
Balance Test
For the reasons set out above, South Wales Police will neither confirm nor deny whether it holds information indicating AI is used in CT, SoC, covert intelligence activity, or specialist digital forensics supporting those functions.
The public interest in maintaining the NCND position under sections 24(2) and 31(3) outweighs the public interest in confirmation or denial.
This response should not be taken as an indication of whether or not any further relevant information is held.