Information Access Manager
Information Management Services
Mr Ian Watters
Direct line / Direct fax
020 7601 2279 / 020 7601 2088
Your ref: / Our ref:
26 September 2014
Dear Mr Watters
REQUEST FOR INFORMATION REF: COL/14/361
I write in connection with your request dated 7 May 2014 for an Internal Review of request COL/14/281:
I am writing to request an internal review of City of London Police's handling of my FOI request 'PIPCU Infringing Website List'.
I agree absolutely that "Disclosure would allow the public to assess the scale of the fraud, the effectiveness of the investigation and allow individuals to make more informed choices in respect of any dealings they may have with the identified companies."
The reasons given for favouring non-disclosure fail to acknowledge that any sites which cooperate with the investigation will already be known to those involved in copyright offences - they will have stopped accepting their business for long enough to be removed from the list!
Equally, if the sites were going to be attacked for cooperating, it would be happening regardless of disclosure, because the people most affected already know about it.
On the other hand, if it were known more widely, such sites will be freed from the risk of cyber attack by a variety of means (such as removal of their domain registrations) from those seeking to end copyright infringements. The City of London Police is aware that this happens, not least because it acknowledges that it has done it itself, and it knows that it is not the only one doing it.
Similarly, increasing the public profile of sites that have stopped infringing copyright as a result of the City of London Police's action cannot be said to be against the public interest. The force has not been shy about promoting the effectiveness of their investigations in the past, including saying that others engaged in the same activities should take note of them.
Already this month, it has named a chain of launderettes stopped from engaging in insurance fraud, and a golfer engaged in a different insurance fraud. The press releases include phrases like "this case highlights that these types of crime will be uncovered, resulting not only in a court sentence but a damaged reputation."
Another recent City of London Police press release gives the number of websites said to have been suspended in the past eight months as a result of PIPCU's actions and I would also consider accepting an answer that simply said how many websites had been removed from the Infringing Website List.
By not naming any of them, it would clearly be impossible to raise the profile of any sites that have allegedly unlawfully provided copyright material, or enable anyone to assess which organisations have cooperated, or put such organisations under any risk of harm.
It would, on the other hand, allow the public to assess the scale of the fraud and the effectiveness of the investigation, both of which are rightly agreed to be desirable and which have been actively promoted in the other ongoing investigation by giving out the equivalent number.
Firstly, please accept my apologies for the delay in providing a full response to your request for an Internal Review.
Having consulted the information owner, I can confirm that at the time your request was received, no websites had been removed from the IWL. The question of disclosing the name of any such sites does not therefore arise and the original reply should have made this clear. However, I would point out that websites have been removed from the IWL since your request was received and should a new request be submitted, it will be considered in the context of the information held at the time the request is received. I appreciate that this may appear somewhat bureaucratic, but the right of access is to information held at the time the request is received.
Should you have any further questions regarding your request, please contact me via e-mail, letter or telephone, quoting the reference number above.
Yours sincerely
Dave Lockyear
Information Access Manager
Bishopsgate Police Station182 Bishopsgate, London EC2M 2NP
Tel 020 7601 2279 Textphone 020 7601 2906
www.cityoflondon.police.uk