Received: 4 February 2024

REQUEST 1: In the calendar year 2015 - 2016 how many members of staff working for PFEW have left the organisation
having received a financial settlement? Please note members of staff refers to persons who are not
police officers?
Of the above number, how many were female?
Of the total number how many of the members of staff were required to sign a non disclosure
agreement?
What was the total amount of those financial settlements

The same request was made in relation to the calendar years 2016, 2017, 2018, 2019, 2020, 2021, 2022, 2023 and 2024.  The responses for these are referred to as "Response 2, Response 3, Response 4" etc. 

Responded: 15 March 2024

RESPONSE 1 (for 2015): 

The Police Federation of England and Wales ("PFEW") relies on section 12 of the Freedom of Information Act 2000 ("FOIA") in response to the above request. This allows public authorities to refuse to comply with a request for information where the cost of compliance exceeds a statutory limit (known as the "Appropriate Limit"). At present the Appropriate Limit is set at £450 by the Freedom of Information and Data Protection (Appropriate Limit and Fees) Regulations 2004 (see Reg. 3(3)). The cost
of compliance is to be calculated based on a rate of £25 per person per hour (Reg. 4(3)). This means that the Appropriate Limit will be exceeded if it would require more than 18 hours of work in order to respond to a request.

For context, since 2015 there has been more than one change to the HR system that the PFEW uses.  There are in excess of 160 leaver files which may relate to the years 2015-2018 (inclusive), however this does not represent a complete record of leavers from this period, since some files have been corrupted and are therefore inaccessible.
The PFEW estimates that it would take at least 10 minutes to go through each individual file to determine whether it falls within the relevant period, and whether or not the requested information can be extracted. This does not include the additional time required to compile the statistics in order to present the response to this request.  The PFEW estimates that the time required to conduct the file review alone (not including any further checks/compiling the statistics) would exceed 26 hours which exceeds the Appropriate Limit.  In addition, as a result of certain files being corrupted, the required exercise would not result in an accurate answer to this request. On this basis, the PFEW does not hold the information sought in this request. 

RESPONSE 2 (For 2016): Please see the response to the first question

RESPONSE 3 (For 2017): Please see the response to the first question.

RESPONSE 4 (For 2018): Please see the response to the first question

RESPONSE 5 (For 2019): 

The PFEW confirms it does hold some of this data:

Please note: The PFEW employs more female members of staff than male.

RESPONSE 6 (For 2020): 

The PFEW confirms it does hold this data:

Please note: The PFEW employs more female members of staff than male.

The figures for settlement payments include (where applicable): payments in respect of annual leave, notice periods, sick pay, private medical insurance and contractual payments.

RESPONSE 7 (For 2021): 

The PFEW confirms that it does hold this data:

Please note:  The PFEW employs more female members of staff than male.

The figures for settlement payments include (where applicable): payments in respect of annual leave, notice periods, sick pay, private medical insurance and contractual payments.  The PFEW has not included details of one payment made. This is because we consider that individual would be identifiable from the information (by anyone 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 subject 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

Response 8 (For 2022):

The PFEW confirms it does hold this data:

Please note: The PFEW employs more female members of staff than male.

The figures for settlement payments include (where applicable): payments in respect of annual leave, notice periods, sick pay, private medical insurance and contractual payments.

RESPONSE 9 (For 2023):

The PFEW confirms it does hold this data:

Please note: The PFEW employs more female members of staff than male.

The figures for settlement payments include (where applicable): payments in respect of annual leave, notice periods, sick pay, private medical insurance and contractual payments.

RESPONSE 10 (For 2024): 

The data considered in response to this part of the request is taken from 01/01/2024 until the date that the PFEW received this request on 04/02/2024:

Due to the very low number of leavers during this short period, the PFEW considers that the information sought would constitute "personal data". This is because we consider that individuals would be identifiable from the information (by anyone 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.