Philip Swift v Information Commissioner & Anor

Facts

Philip Swift has a longstanding interest in vehicle crime and had corresponded with the National Police Chiefs' Council (NPCC) over a period from 2023 about lost or stolen vehicle markers on the Police National Computer, disclosure practices, governance and the activities of the National Vehicle Crime Intelligence Service. On 4 April 2025 he made a multi-part request, reference 2233/2025, seeking vehicle-level data on submissions to the Police National Computer lost or stolen register for 2023 and 2024, together with the offence categories, the NPCC's criteria and policies for recording and seizure, and the number of complaints received. The NPCC refused it on 11 April 2025 under section 14(1) of the Freedom of Information Act 2000, relying on the cumulative burden of the history of requests and correspondence. It upheld that refusal on internal review on 20 May 2025. Mr Swift complained to the Information Commissioner under section 50 of the Freedom of Information Act 2000. By Decision Notice IC-387981-N0T4 dated 5 November 2025 the Commissioner upheld the NPCC's reliance on the exemption, accepting that the request had some public value but that the cumulative burden had reached a tipping point. Mr Swift appealed to the First-tier Tribunal under section 57 of the Freedom of Information Act 2000 on 30 November 2025. The Tribunal heard the appeal on 22 September 2026, with Mr Swift in person, counsel for the NPCC as Second Respondent, and oral evidence from the NPCC's Head of the National Police Freedom of Information and Data Protection Unit. The Commissioner did not attend.