MPS position on Home Office data hub requirements

Report: 6
Date: 15 October 2009
By: Ailsa Beaton on behalf of the Commissioner

Summary

The Home Office is implementing a Data Hub that will hold detailed record level data from force crime and HR systems for statistical and research purposes. The Home Office sees significant benefits to the government in having a richer source of police information to support research and publication of statistics.

However, there remain data protection concerns in the MPS regarding the level of data to be held by the Home Office. Home Office and other researchers will have access to a wide set of detailed data and there are cost and other implications for forces arising from implementing links to the Data Hub and how the data may be used in practice. Discussions are continuing with the Home Office regarding these concerns.

A. Recommendation

That members approve the approach taken by the MPS.

B. Supporting information

The Home Office Data Hub (HODH)

1. The Home Office is currently running a project to implement the ‘Home Office Data Hub’ (HODH). The project aims to:

• Take a regular feed of record level data from force IT systems – crime and HR data have so far been requested from all forces (see Appendix 1 for list of data).
• Import this data from each force into one data warehouse - the Home Office Data Hub.
• Use this data to produce regular HO statistics, replacing the Annual Data Requirement (ADR) returns from forces where possible and providing Home Office, government office and other researchers with access to a detailed data set for more extensive analysis. The existing ADR consists of summary data rather than record level data. For example the current ADR shows total numbers of offences per borough per month and separately total numbers of victims by ethnicity, whereas the data hub would hold every offence as a single record, linked to the ethnicity of victims, enabling more detailed analysis of crime and victim information.

2. To implement the HODH, the Home Office has:

• Negotiated a Memorandum of Understanding (MoU) with the Association of Chief Police Officers (ACPO) in May 2007 to allow detailed, record level force data to be held in the Data Hub. The MoU is currently being reviewed by ACPO and the Home Office.
• Developed the Data Hub technology, and is currently implementing this in the Home Office.
• Developed an electronic data extract routine to take HR and Crime data from force NMIS systems (the National Management Information System – MetMIS in the MPS). Those forces that do not use NMIS have been asked to develop their own electronic data extract to transfer data into the HODH.
• Requested forces to provide test data and historic data – around 30 forces have provided at least test data for crime so far.

3. The MPS has had initial discussions with the Home Office but has not yet provided any test data due to the need for agreement on how MPS data will correctly be represented in the Data Hub (the HODH data model is different to the MetMIS data model, which reflects CRIS in some complex but significant areas) and because of discussions regarding data protection aspects of the HODH.

Detailed data required by the Home Office (see Appendix 1)

4. The Home Office would like to hold the following information about all recorded crimes:

• Crime & location data, including crime reference number, recorded date, grid reference and crime location type, crime type, aggravating factors.
• Offender & victim data, including details of individuals but not the name of the individual, eg ethnic origin of the offender/victim, the role played in connection to the offence i.e. suspect/victim, the detection method, relationship between victim and offender.

5. The Home Office would also like to hold the following for HR records:

• HR person data: details of police officers and police staff including unique reference number (not necessarily pay/warrant number - can be a unique IT system reference number), ethnic origin, gender, marital status, disability class and the competency class of an individual. An individual’s name, salary and national insurance number will not be held.
• Other HR information: Including employment data, absence data, recruitment data, training and fitness data and information held about assaults on police workers.

6. Following discussions, the HO has told the MPS that some of the HR data fields are not mandatory (eg some training and assault details, fitness level information, marital status). However, holding this level of detail requires that Data Protection Act issues are addressed for both crime and HR data, and presents both benefits and implications for the Home Office and Forces.

Providing data: practical considerations, costs and timescales

7. Providing data to the HODH requires:

• Accurate and up-to-data on the crime reporting system (CRIS), the MPS’s main HR system (MetHR) and other HR systems.
• An electronic data transfer taking this data into the HODH, in the MPS probably via the MetMIS system.
• HODH system and business processes set up to take and count MPS data correctly.

8. In practice, for MPS crime data this requires adding some additional crime data fields to MetMIS and changes either to the HODH or to the data extract routine to take account of differences between MetMIS and the HODH (differences which allow MetMIS to count crime correctly in line with CRIS).

9. For HR data, this requires adding some additional HR data to MetMIS. It will also be necessary to put in place new data quality processes on MetHR to ensure that the data fed into the HODH is up-to-date (there are currently some delays in updating MetHR by local HR units, although the Transforming HR programme is likely to improve this). This effort could be offset, however, against current data cleansing processes carried out in HR Directorate for completion of Home Office annual data requirement returns: these processes ensure ADRs are correct but do not in themselves correct details on MetHR.

10. Broad estimates put the cost of providing the link to the HODH at around £100,000, but could be higher depending on how the HO agrees to resolve issues regarding differences between CRIS/MetMIS and the HO Data Hub. This will also affect ongoing costs of maintaining a link with the HODH as crime codes and other system changes take place each year.

11. Work to implement the link will commence when issues regarding data protection etc are resolved, and may take at least 6 months to develop, test and implement.

Legal basis for the HODH and MPS concerns regarding data protection

12. The Home Office has advised the MPS that they have received legal advice which says that the Secretary of State has the power to require forces to provide the detailed record level data for the HODH under Sections 43 and 44 of the Police Act 1996. The Home Office further say that any Data Protection Act issues fall to them to resolve and will not reflect on forces. The memorandum of understanding (MoU) negotiated between the Home Office and ACPO will determine how data protection issues will be addressed and this document is currently under review.

13. The MPS has concerns about the data requested by the HO and the potential Data Protection Act issues that may arise from processing that data. Consequently, the MPS has drawn the HO’s attention to its concerns. External legal advice has been obtained by the MPS which presents an opposing view to that of the HO in terms of whether the proposed data is within the Secretary of States powers under the Police Act 1996. If the Police Act 1996 does not apply, then the Commissioner must only process information that amounts to personal data in accordance with the Data Protection Act 1998. In respect of processing personal information under the Data Protection Act 1998, the MPS is likely to be able to rely upon exemptions under the Act. However, in order to apply the exemption the MPS must ensure that it is able to fulfil any conditions attached under the Act, and ensure that suitable safeguards are provided and the MoU is adequate to cover any data protection issues.

14. The MoU does offer reassurance around how the data will be handled. It says that:

• The information held in the HODH will not be used to identify any individuals and will not be used for operational management purposes: it will only be used for statistical research. Unique reference numbers related to people or crimes will only be stored for system purposes and will not be available to any researchers or other users of the HODH.
• Access to detailed data from the HODH will be controlled. Data protection issues will be addressed when considering any request for data. Requests for record level data will only be granted on the basis that the information is used for statistical purposes, and requests from external researchers must be sponsored by a ‘relevant organisation or referee’. These will be considered on a case by case basis. External and private researchers will sign a declaration relating to data protection.
• Any misuse of the data will be thoroughly investigated and treated seriously. Staff in government departments who misuse the data will be subject to disciplinary procedures.

15. However, the MPS still has significant concerns regarding the data protection aspects of the HODH, for example:

• The MoU lacks a privacy impact assessment for the HODH.
• There are concerns that the level of data required is excessive with regard to the purpose to which it will be put - in essence is record level data needed by the Home Office in order to provide statistical reports?
• The level of detail held amounts to the holding of personal data (even without recourse to supplying pay/warrant numbers with records but using other unique identifiers). Is this necessary for the purposes of the HODH?
• Is it clear what the intended purpose of the data will be, how long it will be held for, who will have access to it, how long it will be retained for?
• Onward transfer of data from the system - process for agreeing who will be provided with record level data from the system.

16. If the HO’s legal powers do enable them to request record level data then there is still a requirement under the Data Protection Act for forces to ensure that staff and members of the public are made aware that record level crime and HR data will be sent to the Home Office for the HODH (eg via the internet, intranet).

17. These concerns have been raised with ACPO and the Home Office as part of the review of the MoU. The MPS has recommended that the Home Office and ACPO consults with the Information Commissioner’s Office to ensure that they are happy that the necessary data protection safeguards are in place: this will reassure forces and in turn enable forces to reassure staff and the public about use of the data.

Benefits and implications of implementing a link to the HODH

18. The main benefits of the HODH accrue to the Home Office, giving them access to a wider range of force data for research purposes. Benefits to the MPS include reduced time to produce regular and urgent ad hoc data for the Home Office. We estimate a saving of around 10 days effort (for one person) per month for PIB. For HR, processing of ADRs requires around 10 days (for one person) every six months, although some of this time is spent on data cleansing activities which would need to continue on MetHR. For both crime and HR data any savings may well be offset against an additional need to manage the data feeding into the Hub to ensure data quality.

19. While benefits arise from the Home Office Data Hub, the provision of a much larger and more detailed set of data to the Home Office presents a new way of working with implications that forces will need to be aware of.

20. Potential for publication of data without force input: HO analysts will need to have expert knowledge and very strong links with forces to ensure they are clear about what data can reliably be compared across forces - force crime and HR systems feeding the HODH can be used differently and forces’ performance context needs to be understood. The MoU includes some controls on publication of data from the HODH. We have requested that the MPS be consulted on any request for data from the HODH where MPS performance could be presented. We have also asked for clarification on how standard statistical publications will be checked with forces once the HODH is in place.

21. Cost of responding to new analyses: The HO has indicated that a limited number of staff will have direct access to detailed record level data within the HODH. However, other agencies will be able to request data from the HODH. There is potential for the HO and other government researchers to carry out a broader range of analyses than at present, for example highlighting areas where forces appear to be out of kilter with each other, before forces are aware of these issues themselves. This could lead to an additional burden on forces in assessing and dealing with the consequences of these issues.

22. Cost of correcting wrong or inconsistent data on CRIS and MetHR: The Home Office may find incorrect or inconsistent records in the detailed dataset and may ask for these to be corrected (as happens with Courts results data currently). The cost of dealing with all inaccuracies in complex systems such as CRIS and MetHR is difficult to estimate.

23. Ongoing cost of data provision to the HODH: If the HO requires additional data then there is potential for additional costs to be incurred in amending data feeds for the HODH. Again these costs may rise depending on how the HO wishes to deal with differences between the CRIS/MetMIS and HODH data structures.

Conclusions

24. The Home Office has made a large investment in creating the HODH and sees significant benefits to government in having a richer source of police information to support research and publication of statistics.

25. However, there remain data protection concerns in the MPS regarding the level of data to be held and processing of data by the Home Office. The HODH gives rise to other implications and costs to forces. Discussions regarding the MPS’s concerns are continuing with ACPO and the Home Office.

C. Race and equality impact

There are no specific race or equality issues; however the implementation of the data hub would increase the range of race and equality data available to the government.

D. Financial implications

While the Home Office is willing to part-fund some aspects of the cost of the HODH to forces, there are likely to be some costs to the MPS to ensure that MPS data is correctly represented in the HODH. Costs have been estimated at around £100,000, but could be higher depending on the approach the HO wishes to take in matching the MetMIS/CRIS crime data to the HODH data structure. Provision for this funding has been made available within the DoI 2009/10 capital allocation.

Revenue costs, currently estimated at approximately £30k per annum to potentially add new ADR data to the HODH in subsequent years will be funded from within the DoI budget allocations for application support and Projects into Service (PINS) from 2010/11 onwards.

E. Legal implications

1. The legal implications have been addressed within the body of the report.

2. The data requested by the Home Office is considered likely to amount to “personal data”, which requires the data controller to observe the principles set out in the Data Protection Act 1998 (“The Act”).

3. Dependent on the nature of the data, the appropriate data controller may be either the Commissioner or MPA.

3. The Act does provide for various exemptions in respect of the processing (or further processing) of personal data, however, the MPA or Commissioner, whichever is the appropriate data controller must observe any conditions attached to those exemptions before information can be shared.

4. Sharing information can bring many benefits, but also present risks if there are no controls in place. In order to ensure compliance with the principles of the Data Protection Act 1998, and reduce any risk of legal challenge under that Act, the MPS will await further guidance from the Information Commissioners Office and amendments to Memorandum of Understanding.

F. Background papers

• None

G. Contact details

Report authors: Helen Dean ~ DoI1(7) – Performance Information Development; Carol McDonald ~ DoI1(6) – Performance Information Bureau

For information contact:

MPA general: 020 7202 0202
Media enquiries: 020 7202 0217/18

Appendix 1

 Information to be held within the HODH

The following is sourced from the Home Office/ACPO MoU, July 2007/Draft revised MoU July 2009.

Crime Data – to be taken as record level data extracts from forces

• Crime & location data: Includes offence details including the crime reference number, crime recorded date, the grid reference of where the crime took place, crime location, crime type (counting rules classification), whether there were any aggravating factors and police geography i.e. whether BCU, CDRP.
• Offender & victim data: Holds details of individuals but not the name of the individual. This includes the unique reference number of the offender/victim, the ethnic origin of the offender/victim, the role played in connection to the offence i.e. suspect/victim, the clear up detection method of the crime and the relationship between the victim and the offender.

HR Data – to be taken as record level data extracts from forces

• HR person data: Holds details of individuals including unique reference numbers such as collar numbers and unique references for individuals of interest to the police including police workers and civilian staff. Ethnic origin, gender, marital status, disability class and the competency class of an individual will be held. An individuals name and national insurance number will not be held.
• Employment data: Holds details of a police worker’s employment class e.g. whether full or part-time, and assignment data e.g. on secondment, post, rank.
• Absence data: Includes details of reasons for absence including sick leave, maternity leave, career breaks, types of leave including reasons for leaving the police service and suspensions.
• Recruitment data: Holds details of job applicants to join the police force including police workers wanting to transfer to another force, people rejoining the service and specials applying to join the police. Job application status identifies the different stages that a job application passes through with associated dates.
• Training data: This entity holds details of training courses held, training received and person competency e.g. dog handling.
• Fitness data: Holds a history of the fitness levels of a police worker and for a change of fitness levels e.g. placed on restricted duties.
• Assault details: Holds details of an assault on a police worker whilst on or off duty and the role played by the police worker.

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