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Statistics maintained by the IOPC
Source: WhatDoTheyKnow
Authority: Independent Office for Police Conduct
Status: We're waiting for
A Maycombe
to read a recent response and update the status.
Imported path: /opt/loancharge/imports/wdtk/requests/statistics_maintained_by_the_iop
Open original request on WhatDoTheyKnow
Imported text
SOURCE: WhatDoTheyKnow
SOURCE_URL: https://www.whatdotheyknow.com/request/statistics_maintained_by_the_iop
TITLE: Statistics maintained by the IOPC
AUTHORITY: Independent Office for Police Conduct
AUTHORITY_URL: https://www.whatdotheyknow.com/body/iopc
STATUS: We're waiting for
A Maycombe
to read a recent response and update the status.
REQUEST_SLUG: statistics_maintained_by_the_iop
CAPTURED_AT: 2026-05-19T07:08:46+00:00
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ATTACHMENTS:
- 5023641_A_Maycombe_response_letter.pdf | https://www.whatdotheyknow.com/request/statistics_maintained_by_the_iop/response/2126136/attach/3/5023641%20A%20Maycombe%20response%20letter.pdf?cookie_passthrough=1 | application/pdf | 178346 bytes
- [not downloaded] | https://www.whatdotheyknow.com/request/statistics_maintained_by_the_iop/response/2126136/attach/html/3/5023641%20A%20Maycombe%20response%20letter.pdf.html | | 0 bytes
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MESSAGE 1 [outgoing]
HEADER: A Maycombe
7 July 2022
Delivered
--------------------------------------------------------------------------------
Dear Independent Office for Police Conduct,
Please supply the following information -
1. Since September 2018, how many cases of suicide have been referred by HM Revenue and Customs to the IOPC?
2. Since September 2018, how many cases of attempted suicide have been referred by HM Revenue and Customs to the IOPC?
3. Since September 2018, how many cases of suicide referred by HM Revenue and Customs to the IOPC have resulted in action, or any type of other decision against HMRC?
4. Since September 2018, how many cases of attempted suicide referred by HM Revenue and Customs to the IOPC have resulted in action, or any type of other decision against HMRC?
5. For all those numbers provided above to questions 1-4, please provide details of any which have been linked in any way to the loan charge and/or disguised remuneration.
Yours faithfully,
A Maycombe
================================================================================
MESSAGE 2 [incoming]
HEADER: !Request Info,
Independent Office for Police Conduct
7 July 2022
--------------------------------------------------------------------------------
This is an automated email please do not respond to it.
Thank you for your email.
If you have made a request for information to the IOPC, your email and any
attachments will be assessed, logged and forwarded onto the appropriate
department to prepare the response.
FOI & DPA Team
We welcome correspondence in Welsh. We will respond to you in Welsh and
that this will not lead to delay.
Rydym yn croesawu gohebiaeth yn Gymraeg. Byddwn yn ymateb i chi yn Gymraeg
ac na fydd hyn yn arwain at oedi.
This message and its content may contain confidential, privileged or
copyright information. They are intended solely for the use of the
intended recipient. If you received this message in error, you must not
disclose, copy, distribute or take any action which relies on the
contents. Instead, please inform the sender and then permanently delete
it. Any views or opinions expressed in this communication are solely those
of the author and do not necessarily represent the views of the IOPC. Only
specified staff are authorised to make binding agreements on behalf of the
IOPC by email. The IOPC accepts no responsibility for unauthorised
agreements reached with other employees or agents. The IOPC cannot
guarantee the security of this email or any attachments. While emails are
regularly scanned, the IOPC cannot take any liability for any virus that
may be transmitted with the internet. The IOPC communication systems are
monitored to the extent permitted by law. Consequently, any email and or
attachments may be read by monitoring staff.
Gall y neges hon gynnwys gwybodaeth gyfrinachol, freintiedig neu
hawlfraint. Dim ond y derbynnydd arfaethedig ddylai eu defnyddio. Os ydych
chi wedi derbyn y neges hon trwy gamgymeriad, peidiwch â dosbarthu, copïo
neu gymryd unrhyw gamau sydd yn dibynnu ar y cynnwys. Yn lle, rhowch wybod
i’r anfonwr ac wedyn dileu’r neges yn barhaol os gwellwch yn dda. Barn yr
awdur yn unig yw’r safbwynt a barn a fynegir hyn ac nid o reidrwydd yn
cynrychioli barn yr IOPC. Dim ond staff penodol sydd ag awdurdod i wneud
cytundebau rhwymol ar ran yr IOPC trwy e-bost. Nid yw’r IOPC yn derbyn
unrhyw gyfrifoldeb am gytundebau diawdurdod y daethpwyd iddynt gyda
gweithwyr neu asiantau eraill. Ni all yr IOPC sicrhau diogelwch yr e-bost
hwn nac unrhyw atodiadau. Er bod e-byst yn cael eu sganio’n rheolaidd, ni
all yr IOPC gymryd unrhyw gyfrifoldeb am unrhyw firws y gellir ei
drosglwyddo gyda’r rhyngrwyd. Mae systemau cyfathrebu IOPC yn cael eu
monitro i’r graddau a ganiateir gan y gyfraith. O ganlyniad, gall unrhyw
e-bost a neu atodiadau gael ei ddarllen gan staff monitro.
================================================================================
MESSAGE 3 [incoming]
HEADER: !Request Info,
Independent Office for Police Conduct
8 July 2022
--------------------------------------------------------------------------------
Dear A Maycombe
Thank you for information request received on 7 July 2022. This request is being considered under the Freedom of Information Act 2000 (FOIA). We will now consult with the relevant department to gather the response to your request.
We propose to respond to you on or before the 8 August 2022 in line with the timescales prescribed by the FOIA.
If you have any questions about this request please contact us. Please remember to quote reference number 5023641 in any future correspondence about this matter.
Yours sincerely
The FOI and DPA Team
Independent Office for Police Conduct (IOPC)
PO Box 473
Sale
Manchester
M33 0BW
Tel: 0300 020 0096
www.policeconduct.gov.uk
Follow us on Twitter at: @policeconduct
Find out how we handle your personal data.
The IOPC is proud to have achieved Customer Service Excellence accreditation
show quoted sections
================================================================================
MESSAGE 4 [incoming]
HEADER: !Request Info,
Independent Office for Police Conduct
8 August 2022
--------------------------------------------------------------------------------
Dear A Maycombe
Thank you for your email in which you make a request for information.
As required under parts 1, 2 and 5 of your request, we may be able to establish the number of HMRC referrals relating to suicides and attempted suicides, and the number of these that concerned loan charges or disguised remuneration, but we would have to consider how much work would be involved in identifying and retrieving this data by means of manual searches of the referrals received in this period.
We can confirm that the IOPC has not carried out a directed investigation or an investigation of its own into any cases of this type. This means that only HMRC would be able to answer parts 3 and 4 of your request, assuming that there were some relevant cases. We would therefore recommend that you redirect your request to HMRC since only they would be able to answer all of your questions.
If, however, you would like us to consider further whether we may be able to respond to parts 1, 2 and 5 within the 18 hour FOIA cost limit, please let us know and we will make enquiries with the relevant IOPC department.
Yours sincerely
Freedom of Information & Data Protection Team
Independent Office for Police Conduct
PO Box 473
Sale
M33 0BW
0300 020 0096
www.policeconduct.gov.uk
Follow us on Twitter at: @policeconduct
Find out how we handle your personal data.
The IOPC is proud to have achieved Customer Service Excellence accreditation
show quoted sections
================================================================================
MESSAGE 5 [outgoing]
HEADER: A Maycombe
18 August 2022
Delivered
--------------------------------------------------------------------------------
Dear FOI and DPA Team,
Thank you for the response you sent on 8th August.
My own understanding of the time frames for responses under the Freedom of Information Act is that this reply should have been made by 4th August, as that would have been the 20th working day following receipt of my request, and therefore the statutory time limit set by section 10 of that Act. Based on this information, I am uncertain why you proposed 8th August in your message dated 8th July, unless this was perhaps an error in your own calculations - or would you consider this a mistake or miscalculation on my part?
Moving on to the response itself, you say that (for parts 1, 2 and 5 of my request) you would have to consider how much work would be involved in identifying and retrieving this data by means of manual searches of the referrals received in this period. Again, my own understanding of the Freedom of Information Act is that this analysis should already have been performed within the 20 working days following receipt of my request, and that the recorded information you hold should either have been provided as requested, or else refused based on an exemption within Part I or Part II of the Act. Is that not correct?
In response to your inquiry as to whether I would like you to consider providing this information within the cost limit set by section 12 of the Act, the answer is yes - but as described above, I would have expected this to be completed within the 20 working days between 7th July and 4th August, so perhaps you would be kind enough to explain why this was not carried out during that time?
You explain that manual searches would need to be conducted to provide that information, but one would hope that the IOPC already has in place a system of recording information that can readily identify the referring authority, and with the numbers expected to be relatively small for HM Revenue and Customs, it could be reasonably anticipated that the cost limit would not be breached.
For parts 3 and 4 of my request, you inform me that the IOPC has not carried out a directed investigation or an investigation of its own into any cases of this type. I am unclear as to what this actually indicates as I do not know what the term 'directed investigation' might mean in this instance, so if you could kindly elaborate on what exact process and action that description covers by providing the relevant procedural documentation you hold, I would be most grateful. Also, you inform me that the IOPC has not carried out any investigation (directed or otherwise) of its own, so does that mean that NONE of the cases which HM Revenue and Customs have referred have been investigated at all by the IOPC?
Without better knowledge of the process which takes place following a referral of suicide or attempted suicide by HM Revenue and Customs to the IOPC, it would be reasonable for the public to expect that the act of referral itself would lead to an initial investigation of cause, potential liability, and any action which would need to be taken as a result of the conclusion formed by the IOPC following such an investigation. If the IOPC has in fact carried out zero investigations - as you seem to be confirming here but which I would ask you to clarify for the avoidance of doubt - then is that the reason why you state that you cannot answer parts 3 and 4 of my request?
You also recommend that I redirect my request for information on parts 3 and 4 of my request to HM Revenue and Customs, since you suggest that only they would be able to answer all of my questions. If the IOPC has not carried out any investigations following a referral of suicide or attempted suicide from HM Revenue and Customs, then without such an investigation, how then could any action, or indeed any type of other decision have been taken against the authority?
I would very much appreciate you providing clarity on the above, and the recorded information you hold, as requested.
Yours sincerely,
A Maycombe
================================================================================
MESSAGE 7 [incoming]
HEADER: !Request Info,
Independent Office for Police Conduct
25 August 2022
--------------------------------------------------------------------------------
Dear A Maycombe
Thank you for your email of 18 August 2022 in which you ask for
clarification on a number of matters and confirm that we should consider
your entitlement under the FOIA to the information we hold under your
request of 7 July.
Information about the process we follow when receiving and assessing
referrals is available on [1]this page of our website. The IOPC must
determine whether or not the subject matter of the referral, which may be
a complaint, conduct matter or Death or Serious Injury matter, should be
investigated. If the IOPC decides that an investigation is needed it will
go on to decide on the mode of investigation. There are three different
types of investigation:
• independent – the IOPC investigates the matter using our own
investigators
• directed – the IOPC directs and control the investigation using
external resources
• local – the appropriate authority (HMRC in the case of your request)
investigates, with no involvement from us
A directed investigation is an investigation conducted by the appropriate
authority under the direction and control of the IOPC. This is defined in
[2]paragraph 18, Schedule 3 Police Reform Act 2002.
If the IOPC decides that the subject matter of the referral does not need
to be investigated it refers the matter back to the appropriate
authority. If the matter is already under investigation by the
appropriate authority it must complete the investigation. Otherwise it
must handle the matter in whatever reasonable and proportionate matter it
determines, which may be an investigation. Therefore, the appropriate
authority must decide on what may be reasonable and proportionate handling
in the individual case. The IOPC does not make this decision and does not
give directions on subsequent handling.
IOPC involvement in the subject matter of the referral normally ceases
when it is returned to the appropriate authority.
If we received any referrals in respect of the matters you describe in
parts 1 and 2, these were not determined as requiring a directed or
independent investigation by the IOPC, with the result that we do not hold
information under parts 3 and 4 of your request. You would have to
contact HMRC for information about the handling and outcomes of any such
matters as this information would not be held by the IOPC.
The complaints and misconduct functions of HMRC are defined in section 28
of the [3]Commissioners for Revenue and Customs Act 2005 and [4]the
associated Regulations
As you have confirmed that you require the information under parts 1, 2
and 5 from the IOPC, even though you would still have to contact HMRC for
the remainder, we will now consult with the relevant department and
provide a formal decision concerning your right of access under the FOIA.
We decided not to carry out this work on receipt of your request because
we did not believe that this information would be useful to you when we
could not answer parts 3 and 4 as well. Instead we recommended that you
contacted HMRC because they would be likely to hold all of the information
you required. We aim to let you know the outcome of your request as soon
as we can and in any event no later than 16 September 2022.
Your request was received on 7 July and the twentieth working day
following receipt was the 8 August. This took into account the bank
holidays in Northern Ireland on 12 July and in Scotland on 1 August. For
further information about how the 20 working day period for compliance
should be calculated, we would refer you to [5]the Information
Commissioner’s guidance on time for compliance.
We hope you find this helpful.
Your sincerely
Freedom of Information & Data Protection Team
Independent Office for Police Conduct
PO Box 473
Sale
M33 0BW
0300 020 0096
[6]www.policeconduct.gov.uk
Follow us on Twitter at: [7]@policeconduct
Find out how we [8]handle your personal data.
The IOPC is proud to have achieved [9]Customer Service Excellence
accreditation
show quoted sections
================================================================================
MESSAGE 8 [incoming]
HEADER: !Request Info,
Independent Office for Police Conduct
16 September 2022
--------------------------------------------------------------------------------
1 Attachment
5023641 A Maycombe response letter.pdf
174K
View
Download
Dear Mr Maycombe
Further to our previous emails as below, please find attached our response
to your request of 7 July 2022 (our reference 5023641).
Yours sincerely
Freedom of Information & Data Protection Team
Independent Office for Police Conduct
PO Box 473
Sale
M33 0BW
0300 020 0096
[1]www.policeconduct.gov.uk
Follow us on Twitter at: [2]@policeconduct
Find out how we [3]handle your personal data.
The IOPC is proud to have achieved [4]Customer Service Excellence
accreditation
_____________________________________________
From: !Request Info
Sent: 25 August 2022 14:22
To: '[FOI #876752 email]'
<[FOI #876752 email]>
Subject: RE: Freedom of Information request - Statistics maintained by the
IOPC - IOPC ref 5023641
Dear A Maycombe
Thank you for your email of 18 August 2022 in which you ask for
clarification on a number of matters and confirm that we should consider
your entitlement under the FOIA to the information we hold under your
request of 7 July.
Information about the process we follow when receiving and assessing
referrals is available on [5]this page of our website. The IOPC must
determine whether or not the subject matter of the referral, which may be
a complaint, conduct matter or Death or Serious Injury matter, should be
investigated. If the IOPC decides that an investigation is needed it will
go on to decide on the mode of investigation. There are three different
types of investigation:
• independent – the IOPC investigates the matter using our own
investigators
• directed – the IOPC directs and control the investigation using
external resources
• local – the appropriate authority (HMRC in the case of your request)
investigates, with no involvement from us
A directed investigation is an investigation conducted by the appropriate
authority under the direction and control of the IOPC. This is defined in
[6]paragraph 18, Schedule 3 Police Reform Act 2002.
If the IOPC decides that the subject matter of the referral does not need
to be investigated it refers the matter back to the appropriate
authority. If the matter is already under investigation by the
appropriate authority it must complete the investigation. Otherwise it
must handle the matter in whatever reasonable and proportionate matter it
determines, which may be an investigation. Therefore, the appropriate
authority must decide on what may be reasonable and proportionate handling
in the individual case. The IOPC does not make this decision and does not
give directions on subsequent handling.
IOPC involvement in the subject matter of the referral normally ceases
when it is returned to the appropriate authority.
If we received any referrals in respect of the matters you describe in
parts 1 and 2, these were not determined as requiring a directed or
independent investigation by the IOPC, with the result that we do not hold
information under parts 3 and 4 of your request. You would have to
contact HMRC for information about the handling and outcomes of any such
matters as this information would not be held by the IOPC.
The complaints and misconduct functions of HMRC are defined in section 28
of the [7]Commissioners for Revenue and Customs Act 2005 and [8]the
associated Regulations
As you have confirmed that you require the information under parts 1, 2
and 5 from the IOPC, even though you would still have to contact HMRC for
the remainder, we will now consult with the relevant department and
provide a formal decision concerning your right of access under the FOIA.
We decided not to carry out this work on receipt of your request because
we did not believe that this information would be useful to you when we
could not answer parts 3 and 4 as well. Instead we recommended that you
contacted HMRC because they would be likely to hold all of the information
you required. We aim to let you know the outcome of your request as soon
as we can and in any event no later than 16 September 2022.
Your request was received on 7 July and the twentieth working day
following receipt was the 8 August. This took into account the bank
holidays in Northern Ireland on 12 July and in Scotland on 1 August. For
further information about how the 20 working day period for compliance
should be calculated, we would refer you to [9]the Information
Commissioner’s guidance on time for compliance.
We hope you find this helpful.
Your sincerely
Freedom of Information & Data Protection Team
Independent Office for Police Conduct
PO Box 473
Sale
M33 0BW
0300 020 0096
[10]www.policeconduct.gov.uk
Follow us on Twitter at: [11]@policeconduct
Find out how we [12]handle your personal data.
The IOPC is proud to have achieved [13]Customer Service Excellence
accreditation
show quoted sections
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ATTACHMENT TEXT EXTRACTION / OCR
================================================================================
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ATTACHMENT: 5023641_A_Maycombe_response_letter.pdf
TEXT_FILE: 5023641_A_Maycombe_response_letter.pdf.txt
METHOD: pdf_native
OCR_USED: False
PAGES: 4
--------------------------------------------------------------------------------
--- PDF page 1 ---
OFFICIAL
Our reference: 5023641
A Maycombe
By email to:
request-876752-80ae7257@whatdotheyknow.com
16 September 2022
Dear A Maycombe
We refer to our previous correspondence concerning your request of 7 July 2022. This
was as follows:
“1. Since September 2018, how many cases of suicide have been referred by HM
Revenue and Customs to the IOPC?
2. Since September 2018, how many cases of attempted suicide have been
referred by HM Revenue and Customs to the IOPC?
3. Since September 2018, how many cases of suicide referred by HM Revenue and
Customs to the IOPC have resulted in action, or any type of other decision against
HMRC?
4. Since September 2018, how many cases of attempted suicide referred by HM
Revenue and Customs to the IOPC have resulted in action, or any type of other
decision against HMRC?
5. For all those numbers provided above to questions 1-4, please provide details of
any which have been linked in any way to the loan charge and/or disguised
remuneration.”
The IOPC holds the information you have requested under parts 1 and 2. However, we
have decided to withhold the information for the reasons we will explain below.
In regard to parts 3 and 4, we have explained in our previous emails that only in certain
circumstances will the IOPC hold information about the outcome of an investigation
following a referral. It is clear that we do not hold information about the outcomes of all
matters referred to us by HMRC, whether or not these related to suicide or attempted
suicide. In addition, some referrals do not result in any investigation. The IOPC has not
carried out a directed or independent investigation into a case of apparent suicide or
attempted suicide referred by HMRC since September 2018. We cannot therefore
provide the data you require under 3 and 4.
If, under part 5, you are seeking the outcomes of all referrals identified under parts 1 and 2
that also relate to loan charges and/or disguised remuneration, we could not provide this
for the same reasons.
--- PDF page 2 ---
OFFICIAL
We recommend that you make a separate request to HMRC for information about the
outcomes, including decisions or other action, of all completed investigations falling within
the scope of your request, as they are likely to have the more complete data set.
We have decided not to disclose the information you have requested under parts 1 and 2
because it is exempt under section 44(1)(a) of the FOIA. This provides:
44
Prohibitions on disclosure
(1)Information is exempt information if its disclosure (otherwise under this Act) by
the public authority holding it -
(a)
is prohibited by or under any enactment,
(b) …..
In this case the enactment prohibiting disclosure is the Commissioners for Revenue and
Customs Act 2005 (CRCA) which should be read together with the Regulations to which it
refers.
Section 29(3) of the CRCA sets out the position as regards the confidentiality of
information provided to the IOPC in connection with the complaints and misconduct
functions of HMRC:
(3)Where the Director General of the Independent Office for Police Conduct or a
person acting on the Director General’s behalf obtains information from the
Commissioners or an officer of Revenue and Customs, or from the Parliamentary
Commissioner for Administration, in the course of exercising a function by virtue of
section 28—
(a)the Director General or person shall comply with any restriction on disclosure
imposed by regulations under that section (and those regulations may, in particular,
prohibit disclosure generally or only in specified circumstances or only without the
consent of the Commissioners), and
(b)the Director General or person may not use the information for any purpose other
than the exercise of the function by virtue of that section.
Sub-section (4) of section 29 CRCA provides:
(4)A person commits an offence if he contravenes a provision of this section.
The effect of section 29 is to prohibit the IOPC from disclosing information received from
the HMRC under its complaints and misconduct functions, except where the release of
such information is expressly allowed by Regulations.
The relevant Regulations are the Revenue and Customs (Complaints and Misconduct)
Regulations 2010. Regulation 13 provides:
Disclosure of information
--- PDF page 3 ---
OFFICIAL
13. Where the IPCC, or any person acting on its behalf, obtains information in the
course of performing a function under these Regulations, that information may not
be disclosed except as permitted under these Regulations or as otherwise
prescribed by law.”
The Regulations do not contain any exceptions permitting disclosure under the FOIA.
Having consulted the Information Commissioner’s guidance on the exemption under
section 44 we can confirm that FOIA disclosure does not fall within the category of
disclosure “as otherwise prescribed by law” specified in Regulation 13. This is because the
FOIA is excluded as a disclosure gateway for these purposes by the words “otherwise
than under this Act” in section 44 itself. We would refer you, in particular, to the discussion
at paragraphs 32 and 33 (pages 11- 12) of the Commissioner’s guidance.
The complaints and misconduct functions of HMRC include the referral to IOPC of
complaints, conduct matters and Death or Serious Injury matters, as provided in the
Revenue and Customs (Complaints and Misconduct) Regulations 2010. Compliance with
your request would involve the disclosure of information about the subject matter of
referrals received from HMRC (specifically, as to whether they related to suicides and the
circumstances of any suicides), when such information could only have been obtained by
the IOPC in the course of performing its functions under the Regulations.
We conclude, therefore, that the effect of the prohibition under section 29(3) of the CRCA
is to make this information exempt from disclosure by virtue of section 44(1)(a) of the
FOIA.
While you have not specified the “details” that you require under part 5, it is clear that case
details would be exempt under section 44(1)(a) to any extent that they had been obtained
in the course of our functions in relation to HMRC. This exemption would also apply to
confirmation of the number of referrals we have received relating to matters involving the
loan charge / disguised remuneration and apparent suicide or attempted suicide.
As this is an “absolute” exemption, there is no requirement to consider whether the
balance of the public interest is in favour of non-disclosure before refusing the request.
This means that the exemption applies regardless of whether it may be arguable that the
public interest would be served by the release of this particular information.
We are sorry we are unable to give you a fuller response on this occasion, but hope you
understand the reasons as set out above.
Please remember to quote reference number 5023641 in any future correspondence
about this matter.
If you are not satisfied with this response you may request an internal review. If you wish
to complain about any aspect of this decision, please provide your representations and
grounds for complaint within 40 working days of this response to the following address:
FOI Internal Review
--- PDF page 4 ---
OFFICIAL
Independent Office for Police Conduct
PO Box 473
Sale M33 0BW
All emails requesting a review should be sent directly to: dpo1@policeconduct.gov.uk.
Should you remain dissatisfied after this internal review, you will have a right of complaint
to the Information Commissioner; however we should point out that under section 50(2)(a)
of the Freedom of Information Act, you are normally obliged to exhaust the IOPC’s own
internal complaint mechanism before complaining to the Information Commissioner.
Yours sincerely
pp
Freedom of Information & Data Protection Team
Independent Office for Police Conduct (IOPC)