Humberside Police outcome letter of 7 March 2019 (ref: CO/632/18) which was dealt with unlawfully in just about every way imaginable. This matter concerns a police conduct complaint submitted inadvertently on 10 October 2018 which was deemed appropriate to be proportionately investigated. The force had – so it claimed – sent a letter to the wrong address thereby failing to provide sufficient safeguard against unauthorised access, loss or damage to someone’s personal data. The letter contained details of the criminal record of the person whose data protection rights were infringed upon and the reason for his arrest. The data breach (if the letter had in fact been sent) was more severe/unfair due to the disclosed details of the criminal record relating to a wrongful conviction contributed by witnesses committing perjury (the arresting officer is suspected to have incited them). The correspondence to the police on 10 October was not intended as a formal complaint but was handled as one by the force in accordance with the complaint’s procedure under the police reform Act. The communication was predominantly to alert the force of its obligations to refer the personal data breach to the Information Commissioner and to obtain some preliminary information in anticipation of submitting a complaint (to the force) in case it was a prerequisite to raising the issue with the Commissioner. The queries were never answered and the Investigating Officer just ploughed on with the process regardless ignoring the complainant. Consequently the complainant was unable to feed into the process in respect of the information he was denied throughout the course of the investigation because it was not until it was too late when the investigation had completed that the questions he had asked were answered. The Investigation outcome revealed that ‘the matter was referred to the Information Commissioners Office as a data security breach’ and the believed recipient of the letter stated that she did not receive it. The complainant's case was severely prejudiced in respect of both the police conduct complaint and that of the Information Commissioner. The force's unlawful and deliberate mishandling of the complaint ensured that the Commissioner’s conclusions were based on hopelessly inadequate information as well as its own investigation failing to reach a conclusive outcome. The Investigating Officer clearly failed to carry out her investigation in line with the vast majority of the rules and standards for how the police should investigate complaints. All the anomalies were identified in the appeal to the IOPC and appropriately cited (the rules and standards) for every occurrence, yet the Casework Manager deliberately handled the appeal unlawfully knowing that if the complainant was misguided enough to take the matter to the high court he would simply be asking to be fleeced in the casino justice system which always falls on the side of the crooked public body.

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Humberside Police
Professional Standards Department
Police Headquarters
Priory Road
Hull HU5 5SF
Switchboard: 101
This matter is being dealt with by:
Superintendent 5505 ROE
Professionalstandardsadmin@humberside.
pnn.police.uk
www.humberside.police.uk
CO 632/18 07 March 2019
Mr .
Grimsby
North East Lincolnshire
DN32
Proportionate Investigation Outcome Letter
Dear Mr
I am writing about the complaint you made on 10th
October 2018 against members
of Humberside Police.
Your complaint has been investigated in accordance with the terms outlined in the
Investigation Agreement and the investigation is now complete. All reasonable and
necessary enquiries have been made to address the issue(s) which you have
raised. The enquiries conducted are proportionate to the nature of the allegation(s)
made and are sufficient to justify the outcome.
ALLEGATIONS IN BRIEF
1-. Improper disclosure of information
The complainant alleges that a Proportionate Investigation letter was sent to an
address which is not his, and that this amounts to an unauthorised disclosure of
personal data. He states that this is exacerbated by the content of the letter.
BACKGROUND CIRCUMSTANCES LEADING TO THE COMPLAINT
You wrote to Humberside police on 8th November 2015 with regards to an incident
at the front of Grimsby Police Station. Following an appeal by yourself to the IPCC,
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a determination directed a proportionate investigation which was allocated to Chief
Inspector Harrison. You sent CI Harrison an email on 8th
October 2018 an update
and you were advised a letter was sent to you on 12th
September 2018. Following
email correspondence you queried why an incorrect address was shown on the
letter. You allege that this amounts to an unauthorised disclosure of personal
information and references referral of the case to the Office of the Information
Commissioner.
INVESTIGATION DETAILS
Information either provided to me or that I have collated as follows
Professional Standards Department documentation
Emails from Mr .
Conversation with CI Harrison 10th
January 2019
Email from Mr Heatley ICU re findings of referral to ICO.
ACCOUNTS
Conversation with CI Harrison 10/01/2019, she was specifically asked about the
Proportionate Investigation letter that she had completed. The Chief Inspector
stated she had used a template to record the letter to Mr on and sent it to
Professional Standards Department as standard practice who she believed would
check for accuracy, print off and send to the complainant.
I am unable to speak to the PSD colleague the letter was sent to as the individual
has since left the organisation.
The matter was referred to the Information Commissioners Office as a data security
breach.
CONCLUSION – The allegation is upheld as quite clearly the letter was sent to an
incorrect address.
The ICO carefully considered the information provided and decided that no further
action by the ICO is necessary on this occasion.
This decision was based on the information they have recorded about the breach
and reasons for the decision are:-
The incident relates to a single individual;
The incident appears to be a result of human error;
Humberside Police have informed the ICO that they have now implemented
remedial measures, namely making procedural changes in Professional Standards
to ensure the address on outcome letters will be double checked by a Caseworker.
They did however recommend Humberside Police considered:-
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