Received: 12 December 2023

The information requested is:

1. The number of female members of staff at PFEW HQ.
2. The number of male members of staff at PFEW HQ.
3. The numbers and demographic breakdown of PFEW HQ staff who have resigned/retired/been dismissed from PFEW from 1st September 2015 to 31st August 2019. 
4. The numbers and demographic breakdown of PFEW HQ staff who have resigned/retired/been dismissed from PFEW from 1st September 2019 to 30th September 2023.

I am aware that there was a cyber-attack during these dates. Therefore, I have been informed that paper copies can be checked and payroll, including HMRC, will be able to provide data for this request. 

5. The number of PFEW HQ staff who are currently exempt from the mandatory 2 or 3 days Return to Office policy. 
6. Copies of any, and all, policies relating to working from home. The dates the policies were written, the review dates of the policies and in what format they were delivered to staff and in what forum in these policies were circulated. 
7. The number of staff who have contracts that do not require them to work at PFEW HQ.
8. Do members of staff have to cover their own costs if, for example, if they live elsewhere in the country but attend at PFEW to adhere to the Return to Work policy? An example of this could be someone from the North of the UK, employed by PFEW on a contract.  Do they need to attend 2 to 3 days per week at PFEW HQ and if so, do they subsidise their own accommodation and meals? 
9. The number of Compromise/Non-Disclosure Agreements issued for staff at PFEW HQ who left the organisation from 1st September 2015 to 31st August 2019. 
10. The number of Compromise/Non-Disclosure Agreements issued for staff at PFEW HQ who left the organisation from 1st September 2019 to 30th September 2023. 
11. The number of staff from the 43 Branches of PFEW who work from home on a permanent basis.
12. The number of staff from the 43 Branches of PFEW who work a mandatory period within their office environment. 
13. The total number of PFEW staff who work within the 43 Branches and the gender breakdown. 
14. The salary range of the CEO.
15. The salary range across the Senior Management Team.
16. The number of qualified HR personnel dedicated to HR matters.

Responded: 2 February 2024

QUESTION:
The number of female members of staff at PFEW HQ.
RESPONSE:
There are 66 female members of Police Federation of England and Wales (PFEW) staff at HQ,
excluding contractors and those working in the hospitality/hotel side of the organisation at
Federation House.

QUESTION:
The number of male members of staff at PFEW HQ.
RESPONSE:
There are 43 male members of PFEW staff at HQ, excluding contractors and those working in the
hospitality/hotel side of the organisation at Federation House.

QUESTION:
The numbers and demographic breakdown of PFEW HQ staff who have resigned/retired/been
dismissed from PFEW from 1st September 2015 to 31st August 2019.
RESPONSE:
The PFEW does not hold data from this period in electronic form, as it was not migrated across to
the PFEW's new HR system which came into operation in January 2022. It is not possible to
determine this data from available data such as payroll records.

QUESTION:
The numbers and demographic breakdown of PFEW HQ staff who have resigned/retired/been
dismissed from PFEW from 1st September 2019 to 30th September 2023.
RESPONSE:
The PFEW does not hold information in electronic form pre-dating the HR system which came into
operation in January 2022.
Accordingly the PFEW could only provide the relevant information from January 2022 – 30
September 2023 (the "Information").
Due to the relativity low numbers of relevant staff members who have resigned, retired or been
dismissed during the period January 2022 to 30 September 2023, the PFEW considers that the
Information would constitute "personal data". This is because we consider that individuals would
be identifiable from the Information (by the requestor and/or others with knowledge of PFEW
staff members) even if they are not expressly identified by name.
The PFEW does not consider that it has any legitimate interest in providing the personal data in
the Information. Furthermore it considers that the need to protect the interests/fundamental
rights and freedoms of the affected data subjects militates in favour of not disclosing the personal
data. As such, the PFEW considers that there is not a lawful basis for it to process the relevant
personal data by providing it in response to this request, and to do so would contravene Article
5(1)(a) of the UK GDPR, namely the principle that personal data "shall be processed lawfully, fairly
and in a transparent manner in relation to the data subject".
Accordingly, the PFEW relies on the exemption set out in section 40(3A)(a) of the Freedom of
Information Act 2000 ("FOIA") which provides that information which constitutes personal data is
"exempt information" if disclosure of the information to a member of the public otherwise than
under FOIA would contravene any of the data protection principles.

QUESTION:
The number of PFEW HQ staff who are currently exempt from the mandatory 2 or 3 days Return
to Office policy.
RESPONSE:
There are currently nine members of staff exempt from the mandatory return to office policy.

QUESTION:
Copies of any, and all, policies relating to working from home. The dates the policies were
written, the review dates of the policies and in what format they were delivered to staff and in
what forum in these policies were circulated.
RESPONSE:
The introduction of the direction that PFEW employees should work from PFEW HQ for a minimum
of 2 days per week was communicated to all staff via an email from the PFEW CEO, Mukund
Krishna, on 30 January 2023 (to take effect from 6 February 2023).
Updates on office plans and returning to the office were shared via the monthly staff newsletter
(Keep Connected) and our all staff meetings (In the Loop).
We have withheld disclosure of PFEW's "Get Tech Ready for Home Working" policy (2020). This is
a policy "relating to working from home" but contains details regarding PFEW's IT systems which
we consider could be misused by third parties if published. This would prejudice PFEW's
commercial interests and therefore we rely on the exemption under s.43 of FOIA. In applying, we
consider that the public interest in PFEW protecting its IT infrastructure outweighs any, limited,
public interest in the disclosure of this policy.

QUESTION:
The number of staff who have contracts that do not require them to work at PFEW HQ
RESPONSE:
There are currently 8 members of staff who have contracts that do not require them to work at
PFEW HQ.

QUESTION:
Do members of staff have to cover their own costs if, for example, if they live elsewhere in the
country but attend at PFEW to adhere to the Return to Work policy? An example of this could be
someone from the North of the UK, employed by PFEW on a contract. Do they need to attend 2
to 3 days per week at PFEW HQ and if so, do they subsidise their own accommodation and
meals?
RESPONSE:
Only employees who are subject to a contract which does not require them to work at PFEW HQ
or who are exempted from the Return to Work policy are not subject to the requirement to attend
HQ 2 days a week. Only employees whose contract states that their main place of work is their
home address are eligible to claim expenses for travel and accommodation, irrespective of home
location.

QUESTION:
The number of Compromise/Non-Disclosure Agreements issued for staff at PFEW HQ who left
the organisation from 1st September 2015 to 31st August 2019.
RESPONSE:
The PFEW does not hold this data because it pre-dates the introduction of the new HR system in
January 2022.

QUESTION:
The number of Compromise/Non-Disclosure Agreements issued for staff at PFEW HQ who left
the organisation from 1st September 2019 to 30th September 2023
RESPONSE:
As stated above, the PFEW does not hold information pre-dating the HR system which came into
operation in January 2022. Accordingly it could only provide the number of agreements entered
into from January 2022 – 30 September 2023.
Due to the low numbers of agreements entered into during the period January 2022 - 30
September 2023, the PFEW considers that the information would constitute "personal data". This
is because we consider that individuals would be identifiable from the Information (by the
requestor and/or others with knowledge of PFEW staff members) even if they are not expressly
identified by name.
The PFEW does not consider that it has any legitimate interest in providing the personal data in
the information. Furthermore it considers that the need to protect the interests/fundamental
rights and freedoms of the affected data subjects militates in favour of not disclosing the personal
data. As such, the PFEW considers that there is not a lawful basis for it to process the relevant
personal data, by providing it in response to this request, and to do so would contravene Article
5(1)(a) of the UK GDPR, namely the principle that personal data "shall be processed lawfully, fairly
and in a transparent manner in relation to the data subject".
Accordingly, the PFEW relies on the exemption set out in section 40(3A)(a) of FOIA which provides
that information which constitutes personal data is "exempt information" if disclosure of the
information to a member of the public otherwise than under FOIA would contravene any of the
data protection principles.

QUESTION:
The number of staff from the 43 Branches of PFEW who work from home on a permanent basis
RESPONSE:
The below data is taken from 42 of the 43 Branches.
There is 1 member of staff who works from home on a permanent basis.

QUESTION:
The number of staff from the 43 Branches of PFEW who work a mandatory period within their
office environment.
RESPONSE:
The below data is taken from 42 of the 43 Branches.
In the case of the majority of Branches, there is no prescribed mandatory period which staff need
to spend in their office environment, however the custom is for staff to work from the office.
There are 3 Branches which prescribe a mandatory period for working in the office. The number
of staff members covered by these mandatory requirements across the 3 Branches is 11.

QUESTION:
The total number of PFEW staff who work within the 43 Branches and the gender breakdown
RESPONSE:
The below data is taken from 42 of the 43 Branches.
There are a total of 95 female staff members and 31 male staff members.

QUESTION:
The salary range of the CEO.
RESPONSE:
The PFEW does hold this data but withholds it under section 22 of the FOIA: information intended
for future publication.
1. The CEO (Mukund Krishna) assumed his role in July 2023. This was a wholly new role, with
no previous incumbent.
2. The PFEW decided that, in the interests of transparency, it would be appropriate to
publish the details of Mr Krishna's salary, alongside details of the salary ranges of other
senior members of staff within the organisation.
3. The PFEW is currently in the process of determining what information to publish in this
regard, and in particular which other individuals' compensation details to publish
alongside this information, and which other contextual information. The precise
information to be published has not yet been determined, nor has the date for publication.
4. The requested information therefore falls within the scope of Section 22, and accordingly
the PFEW is required to determine whether it would be "reasonable in all the
circumstances that the information should be withheld from disclosure until the date [of
publication]".
5. The PFEW considers that it is reasonable to withhold the requested information until it is
formally published. This is on the basis that:
a. The PFEW intends to publish the requested information alongside other information,
including the salary ranges of other senior members of staff and other contextual
information. The PFEW believes that it is reasonable to withhold the requested
information until such time as it has been determined what information to publish
alongside this, and that the PFEW should be given appropriate time to determine this. This
is particularly so in light of the fact that the CEO role was only created upon Mr Krishna's
appointment in July 2023. This is not a case of the relevant information having gone
unpublished for a long period of time.
b. Furthermore, it is reasonable for the PFEW to control the publication of information, out
of fairness to those whose information is due to be revealed.
c. The PFEW does not rely on the exemption in section 40 of FOIA (personal information) in
response to the request yet this exemption remains a live consideration. A request for Mr
Krishna's salary is undoubtedly a request for personal data relating to Mr Krishna within
the meaning of Article 4(1) of the UK General Data Protection Regulation ("UK GDPR") (as
supplemented by the Data Protection Act 2018). Information about other individuals'
salaries also constitutes their personal data. Whilst there is an ongoing process within the
PFEW to determine the process for publishing details of Mr Krishna's salary (and other
senior members of staff within the organisation), it would be unfair to those individuals to
disclose such details until that process has taken its proper course.
6. Accordingly, the PFEW considers that the grounds for withholding the requested
information under Section 22 are made out.
7. As to the question of "public interest": that is, whether the public interest in maintaining
the exemption is greater than the public interest in disclosing the information now, the
PFEW considers that the public interest in maintaining the Section 22 exemption
outweighs the public interest in disclosure. This is on the basis that:
a. Whilst it is accepted that, in general terms, there is a public interest in the details of
certain salaries/ salary ranges being known, the public interest is best served by this
information being published in a fair and contextualised manner, as the PFEW intends.
There is also a public interest in allowing public bodies to rely on Section 22,
particularly in circumstances where this allows them further time to determine how to
present the relevant information (as the PFEW is now in the process of deciding).
b. The PFEW also considers that the factors relied on in paragraph 5 above add weight to
the public interest in it being able to rely on Section 22, in particular that the PFEW
does intend on publishing the Requested Information at a future date.

QUESTION:
The salary range across the Senior Management Team.
RESPONSE:
The PFEW does hold this data but withholds it under section 22 of the Freedom of Information
Act 2000: information intended for future publication. In support of this, please see the points
made above in response to the request for "the salary range of the CEO".

QUESTION:
The number of qualified HR personnel dedicated to HR matters.
RESPONSE:
There are currently four members of HR staff at HQ and, whilst there are no mandatory
qualifications required to work in HR, all of the staff working in the department have relevant
professional experience and training to fulfil their roles.