FOI release

Suspended licences without investigations

Published 18 September 2023

1. Request

I would like to know how many other licensed door supervisors have had their door badges suspended even with no police or authority holding any investigations into any wrong doings as has happened to me.

2. Response

I can confirm that this email will constitute a refusal to deal with your request for the reasons I will set out below.

2.1 Exceeding the appropriate cost limit

Section 12(1) – (4) of the Freedom of Information Act allows a public authority to refuse to deal with a request where it estimates that it would exceed the appropriate limit to comply with the request in its entirety or to confirm or deny whether the requested information is held. In the case of a public authority such as the SIA, the appropriate cost limit is £450.

The ICO guidance The Freedom of Information and Data Protection (Appropriate Limit and Fees) Regulations 2004 sets out how a public authority should estimate whether the work required to obtain information is reasonable and appropriate. In the case of requests that would require work on the part of public authority staff, this is estimated at a rate of £25 per person per hour. This means that 18 hours is considered the appropriate limit.

Reporting limitations within the database where this specific information you have requested about suspended licences is held means that the information cannot instantly be isolated and retrieved.

2.2 What information can we provide?

It is very important to be aware that the SIA does not have to receive information from the police or a public body in order to be able to suspend a SIA licence. The SIA typically suspends a licence when informed that a licence holder is being investigated for a relevant offence, however, we wouldn’t necessarily lift a suspension if the investigation was subsequently closed with no further action to be taken by the police. Any decision to suspend a licence is based on concerns we have about whether an individual is fit and proper to hold a licence, and whether a threat to public safety could exist if we did not suspend the licence. A suspension will remain in place until we are satisfied that there are no such concerns, which is not necessarily dependent upon the action taken by the police or person in authority.

You can find more information about why and how we suspended licences on page 60 – 62 of our licensing criteria, called Get Licensed.

To retrieve your specific information each suspended licence would need to be manually interrogated using a database with various locations to find the information you have requested. To consider each and every single suspended licence since the inception of our systems would significantly exceed the appropriate limit of 18 hours and appropriate cost limit of £450.

2.3 Next steps

In order to better facilitate your request, I suggest that you limit the scope of your request, so that we can manually search each suspended licence until the appropriate cost limit is reached. Given that this will be a very time intensive exercise to manually look at each case and filter out licences that have been suspended for reasons other than police or public body investigations, I would ask that you limit your search to a particular month within a particular year that you are interested in.

The SIA will search as many cases as possible up to the appropriate cost limit within this reduced timeframe. If we are able to search the case well within the appropriate cost limit we will get in touch and request that you provide us with details of a further month that you would like to be searched.

[Reference: FOI 0439]