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Data Breaches Since 2011


1)      The number of data breaches at the Force during the last four years.

2)      A breakdown of that information into the date and a short description of each breach.

On 23rd January you clarified that:

By data breach you mean ‘It means any situation where data has been leaked or breached. This could be data protection breaches as you say, or possibly online hacking for example.



A search was carried out of the records held by the Corporate Information Management Department, which provided the following:

We have had 2 data protection breaches reported to the ICO.

October 2011 – Following a visit to a home address of a member of the public, an officer left his daybook at the premises.

January 2012 – A number of letters were sent inviting persons to take part in a customer satisfaction survey, and unfortunately due to a processing error a number were sent to incorrect addresses.   The letter contained no personal data other than the addressees name and a reference to the fact that the addressee had reported an incident of anti-social behaviour to the police within the previous twelve months. No details of any of the reported incidents were included in any of these letters.

We have 14 information security incidents. Please see the table below for the breakdown of these:  



April 2011

Encrypted force memory stick stolen

October 2011

Loss of police data held and lost by Local Authority

2011 (Date   not recorded)

Case conference paperwork found, returned to Force.

January 2012

3 pages of operational data lost in station yard.

June 2012

Encrypted memory stick lost.

September 2012

Encrypted memory stick containing operational information lost.

October 2012

Police information viewed by an unconnected member of public in error.

November 2012

Encrypted memory stick lost.

July 2013

Force PDA lost & recovered – no data loss.

October 2015

Police log found in Council car park

September 2016

Live proxy/ID card found and handed to local station.

October 2016

Encrypted body worn camera stolen – no data enclosed.

December 2016

Encrypted body worn camera lost.

January 2017

Lost encrypted body worn camera – no footage.

In addition in respect of ransomware attacks, Avon and Somerset Constabulary can neither confirm nor deny that information is held relevant to your request as the duty in Section 1(1)(a) of the Freedom of Information Act 2000 does not apply by virtue of the following exemptions:

Section 23(5) Information supplied by or concerning certain Security Bodies

Section 24(2) National Security

Section 30(3) Investigations

Section 31(3) Law Enforcement

Section 23 is a class based absolute exemption and there is no requirement to consider the public interest.

Section 30 is a class based qualified exemption which requires the public interest in the appropriate of neither confirming nor denying information is held to be considered.

With Sections 24 and 31 being prejudice based qualified exemptions, both evidence of harm and public interest considerations need to be articulated to the applicant.

Harm in Confirming or Denying that Information is held 

Policing is an information-led activity, and information assurance (which includes information security) is fundamental to how the Police Service manages the challenges faced.  In order to comply with statutory requirements the College of Policing Authorised Professional Practice for Information Assurance has been put in place to ensure the delivery of core operational policing by providing appropriate and consistent protection for the information assets of member organisations, see below link: <

To confirm or deny whether ransomware attacks have occurred would identify vulnerable computer systems and provide actual knowledge, or not, that these incidents have taken place within individual force areas.

In order to achieve this goal, it is vitally important that information sharing takes place with other police forces and security bodies within the UK to support counter-terrorism measures in the fight to deprive terrorist networks of their ability to commit crime.

To confirm or deny specific details of any ransomware attacks would be extremely useful to those involved in terrorist activity as it would enable them to map vulnerable information security databases.

Public Interest Considerations

Section 24(2) National Security

Factors favour complying with Section 1(1)(a) confirming that information is held 

The public are entitled to know how public funds are spent and how resources are distributed within an area of policing.  To confirm where ransomware attacks have occurred would enable the general public to hold this Force to account ensuring all such breaches are recorded and investigated appropriately.  In the current financial climate of cuts and with the call for transparency of public spending this would enable improved public debate.

Factors against complying with Section 1(1)(a) confirming or denying that information is held 

Security measures are put in place to protect the community we serve. As evidenced within the harm to confirm where ransomware attacks have occurred would highlight to terrorists and individuals intent on carrying out criminal activity vulnerabilities within (force name).

Taking into account the current security climate within the United Kingdom, no information (such as the citing of an exemption which confirms information pertinent to this request is held, or conversely, stating ‘no information is held’) which may aid a terrorist should be disclosed.  To what extent this information may aid a terrorist is unknown, but it is clear that it will have an impact on a force’s ability to monitor terrorist activity.

Irrespective of what information is or isn’t held, the public entrust the Police Service to make appropriate decisions with regard to their safety and protection and the only way of reducing risk is to be cautious with what is placed into the public domain.

The cumulative effect of terrorists gathering information from various sources would be even more impactive when linked to other information gathered from various sources about terrorism.  The more information disclosed over time will give a more detailed account of the tactical infrastructure of not only a force area but also the country as a whole.

Any incident that results from such a disclosure would, by default, affect National Security.

Section 30(3) Investigations

Factors favouring complying with Section 1(1)(a) confirming that information is held 

Confirming or denying whether information exists relevant to this request would lead to a better informed general public by identifying that this Force robustly investigates ransomware attacks.  This fact alone may encourage individuals to provide intelligence in order to assist with investigations and would also promote public trust in providing transparency and demonstrating openness and accountability into where the police are currently focusing their investigations.

The public are also entitled to know how public funds are spent, particularly in the current economic climate.

Factors against complying with Section 1(1)(a)

Modern-day policing is intelligence led and this Force shares information with other law enforcement agencies as part of their investigation process.  To confirm or not whether this Force has alerted other agencies of ransomware attacks could hinder the prevention and detection of crime as well as undermine the partnership approach to investigations and enforcement.

Should offenders take evasive action to avoid detection, police resources may well be diverted from frontline duties and other areas of policing in order to locate and apprehend these individuals.  In addition, the safety of individuals and victims would also be compromised.

Section 31(3) Law Enforcement

Factors favouring complying with Section 1(1)(a) confirming that information is held 

Confirming that information exists relevant to this request would lead to a better informed public which may encourage individuals to provide intelligence in order to reduce these attacks.

Factors against complying with Section 1(1)(a) neither confirming nor denying that information is held

Confirmation or denial that information is held in this case would suggest this Force takes their responsibility to protect information and information systems from unauthorised access, destruction, etc., dismissively and inappropriately.

Balancing Test

The points above highlight the merits of confirming or denying the requested information exists.  The Police Service is charged with enforcing the law, preventing and detecting crime and protection the communities we serve.  As part of that policing purpose, information is gathered which can be highly sensitive relating to high profile investigative activity.

Weakening the mechanisms used to monitor any type of criminal activity, and specifically terrorist activity would place the security of the country at an increased level of danger. 

In order to comply with statutory requirements and to meet NPCC expectation of the Police Service with regard to the management of information security a national policy approved by the College of Policing titled National Policing Community Security Policy has been put in place.  This policy has been constructed to ensure the delivery of core operational policing by providing appropriate and consistent protection for the information assets of member organisations.  A copy of this can be found at the below link:

In addition anything that places that confidence at risk, no matter how generic, would undermine any trust or confidence individuals have in the Police Service.  Therefore, at this moment in time, it is our opinion that for these issues the balance test favours neither confirming nor denying that this particular information is held.

FOI reference: 086/17.

Date of request: 20.01.17.