Transparency data

24 February 2023: International Law Enforcement Alerts Platform (I-LEAP) Programme accounting officer assessment

Updated 2 April 2024

Project stage

The second iteration of the full business case was approved by the Home Office Finance and Investment Committee (FIC) on 15 September 2022.

Objectives

The I-LEAP programme will provide new alerting digital platform capabilities to police and Border Force officers in the UK, and to their equivalents in partner countries, enabling increased opportunities at the national border or within country to identify persons and objects of interest to law enforcement agencies.

It will do so by first enhancing the UK’s connectivity with INTERPOL by providing law enforcement agencies with connectivity to the fixed INTERPOL’s network database (FIND) system, providing real-time access to INTERPOL nominal data to UK policing, whilst also expanding access to other INTERPOL datasets. These services are being rolled out nationally to policing, the UK Border Force, and the National Crime Agency (NCA). This is the current priority of the programme.

In the longer-term, the I-LEAP service will expand to provide reciprocal access to international alert data exchange with international partners, initially focussing on a potential multilateral solution with the EU followed by bilateral agreement with other partner countries who share the UK’s interest in further strengthening alert-sharing capabilities.

Background and context

Following the UK’s departure from the EU and the end of the transition period in December 2020, the UK disconnected from the EU SIS II system (Schengen Information System, generation 2). The UK had been a participant in SIS II since April 2015 and, whilst we sought to retain access during negotiations, the EU took the position that it was legally impossible for them to offer SIS II to a third country outside of the Schengen area.

SIS II is the system by which 26 EU member states^{[footnote 1]} and 4 Schengen associated states exchange law enforcement alerts across Europe on persons and objects/documents of interest to law enforcement agencies, such as police forces, counter terrorism, and borders agencies.

The UK has returned to using INTERPOL for systematic exchanges of alerts with law enforcement agencies in the EU. INTERPOL is a tried and tested mechanism for alert exchange which the UK already used for cooperation with rest of the world partners and which the UK used with EU member states before joining SIS II. In preparation for EU exit and transition, the UK undertook work to further improve INTERPOL utilisation. The speed by which INTERPOL circulations are made available on UK domestic law enforcement systems has consequently increased, as well as the number of INTERPOL circulations available to the UK and its partners, including at the UK Border. This is in addition to UK efforts to improve INTERPOL’s wider capabilities and governance, including through investment in the I-CORE programme^{[footnote 2]} to enhance INTERPOL’s ability to share and use law enforcement data.

The I-LEAP programme will seek to enhance international cooperation through improved access and use of INTERPOL data, providing increased operational value to border and law enforcement agencies. The Programme will deliver the following benefits:

1. Direct and real-time connection to INTERPOL data at the point this is made available to INTERPOL member states.

2. Provision of facial images on subjects of interest associated with INTERPOL notices and diffusions.

3. Access to additional data fields on subjects of interest than would otherwise have been available through the police national computer (PNC) record search.

4. Increased availability to law enforcement officers at the frontline.

The I-LEAP programme will be delivered through 2 distinct phases:

Phase 1: will deliver connectivity to the fixed INTERPOL’s network database (FIND) system, providing real-time access to INTERPOL nominal data to UK policing, whilst expanding access to other INTERPOL datasets. These services are being rolled out nationally to policing, the UK Border Force, and the National Crime Agency (NCA).

Phase 2: will expand the I-LEAP service to provide reciprocal access to international alert data exchange with international partners, initially focussing on a multilateral solution with the EU followed by bilateral agreement with other partner countries.

The current priority of the programme is delivering Phase 1. Phase 2 is a longer-term objective to enhance mutual capabilities for alert exchange with trusted international partners.

In April 2022, the I-LEAP programme successfully concluded 2 operational pilots with a limited number of users from Surrey, Sussex, and counter terrorism policing. The pilots were able to evidence the operational value of direct and real-time access to INTERPOL data by frontline police officers, alongside identifying opportunities to further improve the design of the service.

As of December 2022, the I-LEAP capability has been fully adopted across police service Northern Ireland, Surrey, Sussex and counter terrorism policing, alongside new users from Avon and Somerset and Wiltshire police. This represents over 12,000 users across these forces with over half a million searches carried out. Feedback received from frontline police officers has reinforced the importance of real-time connection to INTERPOL circulations, including images, in protecting public safety and tackling criminality.

In 2023, additional INTERPOL data on stolen motor vehicles and stolen, lost and fraudulent travel documents will also be accessible through the I-LEAP capability.

By April 2024, the I-LEAP programme will have delivered real-time access to INTERPOL data to all UK territorial police forces and to the UK Border.

Phase 2 of the programme is still at a very early stage. Since the previous full business case (FBC) was approved by the Home Office FIC in November 2021, we have pivoted the approach for Phase 2 from securing individual bilateral data sharing agreements to focus on a potential multilateral agreement with the EU (and in the longer term, bilateral agreements with non-EU international partners). This follows the announcement by the EU Commission at the end of 2021 to bring forward a proposal for “a framework for reciprocal access to security-related information for front-line officers between the EU and third countries”. We now understand the EU Commission proposal may be published in late 2023. If adopted, this approach would offer considerably greater benefit than the previous approach as an EU-wide solution could offer reciprocal, direct and real-time access to security-related alerts between the UK and all EU member states.

The Home Office has overall responsibility for improving capabilities to reduce the risks to the UK from international criminality. I-LEAP aligns with and directly delivers to this public safety priority as captured within:

1. Strategy and Outcome Delivery Plan 2021 to 2022^{[footnote 3]}

2. The Beating Crime Plan^{[footnote 4]}

3. UK Border Strategy 2025^{[footnote 5]}

4. The Drugs Strategy^{[footnote 6]}

1. CONTEST – the UK’s strategy for countering terrorism^{[footnote 7]}

This assessment is made by the Permanent Secretary (and Accounting Officer), Home Office.

Assessment against the Accounting Officer standards

Regularity

The I-LEAP programme is assessed as compliant against this standard with regard to the provision of INTERPOL data to UK law enforcement agencies. I-LEAP will enhance the provision of data that is already supplied by INTERPOL and that is already accessible to UK law enforcement agencies (e.g., via INTERPOL’s I-24/7 service). This data is provided to and used by UK law enforcement agencies in accordance with their functions.

• The NCA’s functions are set out in Part 1 of the Crime and Courts Act 2013.

• Border Force powers and functions derive from a combination of statutory provisions in the Immigration Acts^{[footnote 8]} and common law powers, including in particular, section 2 UK Borders Act 2007, section 4 of the Immigration Act 1971 and Schedule 2 to that Act.

• Policing functions are derived from a combination of common law powers and statutory provisions.

This is in compliance with Part 3 of the Data Protection Act 2018, which ensures the lawful processing of data for law enforcement purposes in accordance with INTERPOL’s rules on data processing.

Phase 1 of I-LEAP therefore requires no new legal powers or agreements. Phase 2 is a longer-term objective and is still at a very early stage. In October 2021, the EU Commission announced plans for a framework enabling reciprocal access to security-related information for front-line officers between the EU and key third countries, to counter shared security threats. The EU Commission is currently carrying out an internal impact assessment followed by a public consultation to inform the detail of the draft legislation, with a new timetable to publish its draft proposal in late 2023. The EU Commission’s proposal may provide both the legal framework and technical platform to facilitate the exchange of data between the EU and third countries.

Phase 2 of I-LEAP will therefore focus in the first instance on a potential multilateral solution with the EU, followed by bilateral agreements with other trusted partners outside the EU.

An appropriate power will be identified to enable the implementation of multilateral agreements that are entered into with the EU (and any bilateral agreement with international partners), to enable the exchange of alert data with key partners. As per the Constitutional Reform and Governance Act 2010, where necessary the agreements will be scrutinised by Parliament before their ratification and commencement. All required enabling UK legislation will need to be in place prior to any agreement’s entry into force, including the enactment of any new powers required to implement these agreements. This will ensure that there is a clear legal basis domestically for the implementation of I-LEAP multilateral and bilateral agreements.

Propriety

The proposed course of action complies with managing public money (3.3.3 value for money). Expenditure on the I-LEAP programme can be made under section 169 of the Criminal Justice and Public Order Act 1994.

I-LEAP development is being funded by the Home Office International Criminality Directorate (ICD) for the duration of the I-LEAP programme. An appropriate long-term funding model will be agreed between the Home Office, HM Treasury and UK law enforcement partners.

The effective management of these funds is overseen by robust governance and reporting arrangements that fully meet Home Office requirements. All governance structures are appropriately operated by a combination of representatives from the Home Office, across HMG and law enforcement partners, ensuring all stakeholders are appropriately represented.

I-LEAP funding made available to law enforcement partners for work necessary to deliver I-LEAP is governed under appropriate grant agreement controls. These controls and governance structures ensure the proper use of public funds given that I-LEAP is recognised as a ministerial priority and a key mechanism for meeting Home Office and wider HMG commitments, including those within the UK Border Strategy 2025, the Beating Crime Plan, and the Home Office Outcome Delivery Plan 2021 to 2022.

Accordingly, the Home Office FIC reviewed and approved the I-LEAP programme’s FBC on 15 September 2022.

It is anticipated that the programme will continue to remain compliant with Parliamentary control procedures and expectations. In line with these expectations, the programme’s funds are being managed with impartiality, honesty, and with the avoidance of personal gain, waste, and extravagance. The programme continues to have due regard for the Public Sector Equality Duty at section 149 of the Equality Act 2010 and is complying with data protection legislation, overseen by the Home Office assurance boards.

Given the I-LEAP programme’s robust governance framework, compliance with required standards and Parliamentary expectations, and importance to UK government commitments to keep the public safe, bring criminals to justice, and forge a new place for the UK on the world stage, continued funding for I-LEAP constitutes proper and effective use of public funds.

Value for money

Phase 1 will deliver considerable benefits to law enforcement and Border Force through provision of real-time INTERPOL circulations, access to facial images for persons of interest and access to additional INTERPOL data sets. Delivery of Phase 2 over the longer term will build on this and enable direct, real-time exchange of alerts with international partners to further enhance the UK’s and international partners’ ability to keep the public safe.

The value of the potential harm averted or reduced as a consequence of those additional alerts is derived from historic operational data from the UK’s previous use of the Schengen Information System (SIS II) along with estimates of the harm avoided from the Economic and Social Costs of Crime. This approach has been reviewed by the Home Office Analysis and Insights team, who are content with the figures and the methodology used.

In terms of the business benefit this represents^{[footnote 9]}, the I-LEAP full business case estimates the programme will deliver benefits of the order of £125.1m with economic costs of £74.4m and costs avoided of £10.3m^{[footnote 10]} over a 10-year whole life appraisal period, with a positive NPSV (net present social value) of £60.9m, over 10 years. There are also potentially significant non-monetised benefits including providing access to INTERPOL nominals data including facial images, providing access to additional counter terrorism diffusions, providing additional opportunities to identify international offenders and improved public confidence/international reputation. Total programme development cost requirements to FY 2027 to 2028 have been identified as £36.3m excluding optimism bias. Costs over a 10-year whole life period to FY 2031 to 2032 including optimism bias are estimated at £90.2m.

As noted above, I-LEAP development is being funded by the Home Office International Criminality Directorate (ICD) for the duration of the I-LEAP programme. An appropriate long-term funding model will be agreed between the Home Office, HM Treasury and UK law enforcement partners.

In view of the dependencies on a range of factors for its future benefits, the I-LEAP programme team undertook sensitivity analysis to provide range estimates of costs and benefits on some of the key areas of uncertainty within the programme.

On presentation of this sensitivity analysis and its impact on I-LEAP’s NPSV as part of the I-LEAP FBC, the Home Office FIC were satisfied with the conclusions and confirmed that I-LEAP offered sufficient value for money to proceed.

Feasibility

The I-LEAP programme is being delivered in response to opportunities that have arisen following UK’s exit from the EU. There are no legal time limits that the Home Office is required to comply with around delivery. Whilst the proposal is targeting completion of Phase 1 (rollout of real-time connection to INTERPOL data) by April 2024, and Phase 2 (the multilateral solution with the EU) in FY 2027 to 2028, this is not a legal requirement.

The initial priority of the programme remains on track for delivery of Phase 1, which will provide improved access and use of INTERPOL data by law enforcement agencies and UK Border Force. Technical and operational feasibility for Phase 1 was demonstrated in early 2022 by adopting a pilot approach in Surrey, Sussex, and CT Policing before starting the full national rollout of the capability across UK police forces.

Following the announcement of the EU Commission proposal and consultation with EU institutions and member states, the programme has adapted its delivery approach to focus on an international alert sharing capability targeted at an EU-wide level. The timeline for delivery has been extended for Phase 2 to reflect the known complexities of engaging at an EU-wide level and the length of time it would take to negotiate and secure agreement on a potential solution with the EU. Whilst this represents an increase to the overall programme timeline, the ability to receive international alerts from all EU member states will deliver a substantially greater level of mutual benefit to both domestic and international law enforcement teams.

The programme is dependent on other law enforcement programmes within the Home Office, partner organisations and achieving international agreements with the EU and other countries. These dependencies are being tracked and managed closely to ensure delivery and assess the impact of any delay on I-LEAP delivery. Close working with a range of internal and external partners is initially focused on delivering the successful rollout of Phase 1, which has already achieved live capability with several police forces. In the longer term, attention will turn to maturing Phase 2, once a clearer picture is gained on the EU Commission proposal.

The I-LEAP programme team is adequately resourced and has established structured delivery controls, including a detailed delivery plan which is regularly monitored (with changes managed through formal change control processes). Proactive risk management is supported by a regularly updated risk log and a robust governance structure. The programme follows good practice and adheres to all internal review and approval processes.

The Home Office undertook a Gateway 0 Review in September 2022, and the Review team awarded the programme a DCA (delivery confidence assessment) rating of AMBER.

The Gateway 0 Review team found Phase 1 of the programme mature, well defined, and broadly communicated. They noted the delivery of Phase 1 as highly likely. On Phase 2, they identified that delivery is heavily dependent on the forthcoming EU Commission proposal.

The Review team noted opportunities to engage and influence EU partners at both a policy and operational level, with the aim of ensuring the forthcoming EU Commission proposal is aligned with UK requirements. The Review team made 6 recommendations that the programme accepted and are progressing. The Review team were satisfied the programme is well managed, is delivering functionality that meets business needs and can implement and manage the proposed solution.

Conclusion

The I-LEAP programme conforms to the 4 Accounting Officer standards of regularity, propriety, value for money and feasibility. As the Accounting Officer for the Home Office, I have considered and approved this assessment of the I-LEAP programme and approved it on 3 January 2023.

I have prepared this summary to set out the key points which informed my decision. If any of these factors change materially during the lifetime of this project, I undertake to prepare a revised summary, setting out my assessment of them.

This Accounting Officer assessment will be published on the government’s website (GOV.UK). Copies will be deposited in the House Library and sent to the Comptroller and Auditor General, Treasury Officer of Accounts and Chair of the Public Accounts Committee.

Matthew Rycroft

Permanent Secretary

1. Ec.europa.eu website – Schengen Information System page as at 21 June 2021. ↩

2. From INTERPOL.int site: I-CORE is a 10-year programme to reinforce INTERPOL’s function as a global police information hub. ↩

3. Home Office Outcome Delivery Plan: 2021 to 2022. ↩

4. Beating Crime Plan. ↩

5. 2025 UK Border Strategy. ↩

6. Drug strategy 2017. ↩

7. Counter-terrorism strategy (CONTEST) 2018. ↩

8. “The Immigration Acts” is defined at section 61(2) UK Borders Act 2007. ↩

9. Quantified, monetised benefits and their derivation are set out in the Economic Case to the FBC. ↩

10. Figure is discounted. ↩