Received: 26 April 2024

1. Was Mukund employed by the Pol Fed or an external contractor when he proposed the role of COO and or CEO? 
2. When was Mukund appointed from an external company to role of COO, a Pol Fed payed role?
3. Was the role of COO externally advertised?
4. How many persons applied for the role?
5. How many interviews were conducted for the role?
6. Was Mukund directly appointed the role by the then National Secretary? 
7. Did the National Secretary advertise the role for other qualified persons to apply? 
8. When Mukund had his role changed from COO to CEO did he receive a new contract or employment to reflect this change of role?
9. Did this new contract include an increase in renumeration?
10. Did Mukund put an ultimatum to the National Board that, Paraphrasing,  as he could not complete what was asked of him as COO, unless he was made CEO he would leave the Pol Fed? 
11. What was Mukund's salary and bonus package in his role of COO? 
12. What is Mukund's salary and bonus package in his role as CEO? 
13. Did Mukund declare any personal or business relationships, past or present when appointing Chris, John and Tara Phillips to their current roles? 

Responded: 15 May 2024

1. Prior to taking up the role of COO, Mukund Krishna was employed by an external contractor. He was then employed by the PFEW as COO before taking up the role of CEO.

2. November 2019

3. Mr Krishna was appointed to the role of COO by the then National Secretary of the PFEW. It is not known whether this role was externally advertised.

4. It is not known how many persons applied for the role.

5. It is not known how many persons applied for the role.

6. Yes.

7. It is not known whether the National Secretary advertised the role for other qualified persons to apply.

8. When Mr Krishna's role changed from COO to CEO Mr Krishna received a variation to his existing employment contract.

9. Yes.

10. Mr Krishna did not put an ultimatum to the National Board.

11. The PFEW holds data relating to the salary details of its former Chief Operations Officer (which is not presently an active role), but withholds it under section 22 of the Freedom of Information Act ("FOIA"): information intended for future publication.

1. The PFEW decided that, in the interests of transparency,  it would be appropriate to publish the details of its CEO's salary, alongside details of the salary ranges of other senior members of staff within the organisation. This includes details relating to the role of Chief Operations Officer (COO). 
2. 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.
3. 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]".
4. The PFEW considers that it is reasonable to withhold the requested information until it is formally published. This is on the basis that:

• 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.
• 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.
• 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 details of the an individual's salary is undoubtedly a request for personal data relating to that individual 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 salaries, it would be unfair to those individuals to disclose such details until that process has taken its proper course.

5. Accordingly, the PFEW considers that the grounds for withholding the requested information under Section 22 are made out.
6. 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:
7. 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).
8. The PFEW also considers that the factors relied on in paragraph 4 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.

12. See answer to request 11.

13. Tara Phillips is not employed or contracted by the PFEW. Mr Krishna has no personal or business relationship with her. As explained in response to Request Reference 000389, Ms Phillips is a supplier to the Sussex Police Federation. As regards Chris Elmitt and John Phelan, as explained in responses to Request Reference 000386 and 000387, Mr Krishna had no personal or business relationships with either individual prior to their engagement as contractors by the PFEW. Therefore, no such declarations were made by Mr Krishna.