NPCC internal reviews 3157/2026 and 3176/2026

correspondence did not constitute a valid request for recorded information under the Freedom of 
Information Act 2000 (FOIA). 
 
Having carefully reviewed the original email, I find that the decision should be upheld. 
 
While FOIA requests do not need to refer expressly to the Act or follow a prescribed format, a 
public authority must be able to identify, from the correspondence received, the recorded 
information being sought. Your original correspondence consisted predominantly of commentary, 
personal observations, allegations, opinions, and requests for action by public authorities. The 
email concluded with requests for authorities to "come clean" and for instructions to be given to 

 
 
 
various bodies, rather than requests framed as seeking recorded information held by a public 
authority. 
 
Although your original correspondence referred to a range of historical events and organisations, 
it did not clearly specify any recorded information sought from the NPCC, NaCTSO or any other 
body. In those circumstances, it was reasonable for the original decision maker to conclude that 
no identifiable request for recorded information had been made and that the correspondence 
could not be processed under FOIA. 
 
Subsequent Correspondence 
 
Your internal review request contains a substantially revised and detailed set of questions seeking 
specific categories of recorded information relating to: 
 
1. the 1988 operation at Great House Farm; 
2. BP Properties Ltd v Buckler [1987] EWCA Civ 2; 
3. police and security involvement; 
4. predecessor and successor records; 
5. record searches and retention arrangements; and related matters. 
These requests were not articulated in the original correspondence to the degree necessary for 
the NPCC to identify them as requests for recorded information. Rather than clarifying an existing 
FOIA request, your later email introduces a number of new and significantly more specific 
requests for information. This was acknowledged on 7 September reference 3156/2026 and a 
response issued 17 September. 
 
An internal review considers the appropriateness of the original decision based on the 
correspondence available to the decision maker at the time. On that basis, I am satisfied that the 
original conclusion was reasonable and in accordance with FOIA. Therefore, the internal review 
upholds the original decision. 
 
Internal Review 3176/2026 of Freedom of Information Request 3156/2026   
 
I have also considered your request for an internal review of the response issued on 16 September 
2026 under reference 3156 2026 NPCC Response Letter - BP vs Buckler. 
 
Your review request raises concerns regarding the scope of searches undertaken, the search 
methodology applied, the handling of historical and predecessor records, and the advice and 
assistance provided under section 16 of the Freedom of Information Act 2000. 
 
The purpose of an internal review is to assess whether the original response complied with the 
requirements of the Act based on the request received and the information held by the authority at 

 
 
 
the time of the request. Having reviewed the handling of request 3156/2026, I am satisfied that the 
original decision should be upheld. 
 
The review has confirmed that searches were undertaken across the areas considered most likely 
to hold information within the scope of the request, including relevant NPCC functions, Counter 
Terrorism Coordination Committee holdings, NPCC shared drives and ACPO archive listings 
available to the NPCC. No information falling within the scope of the request was identified. 
 
While your review request suggests additional search terms, repositories and historical record 
categories that could potentially exist, the Freedom of Information Act requires a public authority 
to determine whether it holds recorded information. It does not require a public authority to 
speculate as to whether information may once have existed, whether it may be held elsewhere, or 
to establish the historical provenance of records that it does not hold. 
 
I note your comments regarding predecessor organisations, including Association of Chief Police 
Officers (ACPO). The review confirms that the NPCC considered the availability of predecessor 
material accessible to it and undertook searches of ACPO archive listings available within NPCC 
holdings. No information relevant to your request was identified. 
 
I also note your submission that transfer records, disposal records, archive accession records 
and similar metadata may themselves fall within scope. The original response expressly advised 
that the NPCC does not hold information concerning the transfer, archiving, retention, disposal or 
current location of records relating to the matters specified in your request. The review has found 
no evidence that such information is held by the NPCC. 
 
In relation to section 16 advice and assistance, the NPCC informed you that requests may be 
directed to individual police forces and provided details of how force contact information may be 
obtained. Given that the NPCC does not hold information identifying an alternative authority 
known to hold the requested information, I am satisfied that the advice provided was reasonable 
in the circumstances. 
 
Having considered the scope of the request, the searches undertaken and the concerns raised in 
your review submission, I am satisfied on the balance of probabilities that the NPCC does not 
hold recorded information falling within the scope of request 3156/2026. Accordingly, the original 
response is upheld 
 
Decision  
 
Both the internal reviews are therefore concluded, and the original decisions are upheld. 
 
Right of Complaint 
 

 
 
 
If you remain dissatisfied following this internal review, you have the right to apply directly to the 
Information Commissioner's Office for a decision. Information on how to do so can be found at 
www.ico.org.uk 
 
 
Ashleigh Beney 
NPFDU Head of Unit