FOI release

Reported crimes or concerns: door supervisors in Wales

Published 19 December 2023

1. Request

On your website, you have a report system which allows users to report the following options in addition to some which I have left out:

• Any risk to the public.
• SIA licence holders abusing their position.
• SIA licence holders or private security businesses involved in criminal activity
• Someone working without an SIA licence
• Individuals using a fake, out of date or stolen SIA licence

For the above options I am requesting the following information for each option, between 2019 and 2023.

• How many of these individuals were door staff, and of these, how many were individuals in Wales?
• What was the reasoning behind these reports?
• What was the outcome of these reports?

Please could you also include any additional reports which included the words: “choke holds”, “homophobic”, “homophobic language”, “transphobic”, “transphobic language”, “racism”, “racist language”, “sexism” or “sexist language”.

Please provide the total in an annual breakdown.

2. Response

This email will constitute a refusal to deal with your request for the reasons I have 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.

The SIA’s systems do not allow for intelligence logs to be searched via the trigger words mentioned in the body of your request, which means the information cannot be instantly isolated and retrieved. It would therefore mean that each intelligence log, within the 4-year period you have asked us to search, would need to be manually interrogated to pick out the intelligence logs which contain those trigger words, and then ascertain the reasoning and outcome.

Between 1 January 2019 and 1 January 2023 there were 197 intelligence logs developed in respect of door supervisors in Wales. This means we would need to manually interrogate 197 reports. We have claculated that to manually interrogate each report to retrieve the information you require would take about 15 minutes per log. 15 minutes per log would significantly exceed the appropriate time limit of 18 hours. £25 per person per hour for each log would also significantly exceed the appropriate cost limit of £450.

2.2 What information can we provide?

I can confirm that the SIA’s Intelligence department spent much time on this request – attempting to figure out ways to retrieve the information you require in a much simpler format rather than going through each intelligence log. However, due to system permissions and configuration, they concluded that this is not possible. The information our system permits us to provide is:

Between 1 January 2019 and 1 January 2023, the SIA developed 197 intelligence logs in respect of door supervisors in Wales.

2.3 Next steps

In order to assist you with the information you require, we would suggest reducing your search window to a shorter period of time so that we can limit the number of intelligence logs out of the 197 total. Once limited we will then be able to go through each of these logs manually, read through them and decipher which ones relate directly to your query. We would suggest a particular month within a particular year you are interested in. The SIA will search as many reports as possible within the appropriate cost and time limit within this timeframe. If we are able to search the reports well within the appropriate cost and time limit, we will get in touch and request that you provide us with details of a further time period that you would like us to search.

[Reference: FOI 0477]