Guidance relating to the policing of protests concerning Palestine Action

Response

Avon and Somerset Police holds information on the subject you have requested. Some information identified from our searches so far has been provided, as described below. However, we will not be able to answer your request in full without exceeding the appropriate limit. This is because the information is not centrally recorded and would involve an extensive search of our files to find and collate. 

 

We have identified some documents held that fall within the scope of parts 1 and 3 of your request. However, we would not be able to confirm that all relevant information had been identified without an extensive review of our systems. The second part of your request in particular is so broad as to encompass any communications recorded individually by officers. There is no single location where all communications within the scope of your request would be held. A response to this question would require an extensive review of our systems including email inboxes for all officers, which we estimate would take more than 18 hours to complete. 

  

Section 12 of the Act makes provision for public authorities to refuse requests for information where the cost of dealing with them would exceed the appropriate limit, which for police authorities is set at £450 or 18 staff hours. This represents the estimated cost of one person spending 2.5 working days in determining whether the department holds the information, and locating, retrieving and extracting it. 

  

This letter represents a Refusal Notice under the Act. 

 

To assist further, I have provided the following documents identified from our searches in relation to parts 1 and 3 of your request: 

 

1. Palestine Action (PAG) – Single briefing slide redactions for FOIA 
2. S11 12 13 TACT 
3. Mono easy print leaflet 
4. Protest leaflet – Keep on the right side of the law 
5. Easy print protest leaflet 
6. External comms lines PAG proscription 
7. Palestine Action Proscription Q&A  

The following documents have also been identified as falling within the scope of your request, relating to a specific protest in Bristol on 19 July 2025: 

 

8. Operation Brie – Presentation slides 

9. Briefing Note 

  

Within some of these documents, redactions have been made to withhold some information, in accordance with the following exemptions: 

 

• Section 23(1) – Security Bodies (applies to document 7) 

• Section 24(1) – National Security (applies to document 1 and 8) 

• Section 31(1) – Law Enforcement (applies to documents 1, 6, 8 and 9) 

• Section 40(2) – Personal Information (applies to documents 8 and 9) 

 

In addition to the above, we have identified a further five Counter Terrorism Policing documents held by Avon and Somerset Police, the content of which has been withheld in full, under the following exemptions: 

 

Section 24(1) and 31(1) relating to National Security and Law Enforcement. 

 

 

Section 23 is an absolute class-based exemption and therefore there is no requirement to conduct a harm or public interest test.  

 

As sections 24 and 31 are qualified and prejudice-based exemptions, there is a requirement to evidence the harm in confirming or denying that information is held, and to consider the public interest. 

 

Evidence of harm – Sections 24 and 31 

  

Disclosure of the information would reveal specific strategies, rationale, intelligence and tactics in relation to the identification and policing of proscribed terrorist groups. This could be used by criminals, those with criminal intent, members of proscribed organisations, and terrorists to undermine and obstruct operational policing, as well as amend their current practices to evade detection. This would consequently be detrimental to the police’s ability to ensure the law is enforced, offenders apprehended, public safety is maintained and threats to the security of the UK are identified and prevented.  

 

Disclosure of information from multiple forces would result in patterns of police activity, tactical capabilities and operational planning in respect of terrorist proscription and operational planning in relation to the policing of proscribed groups, being identified. Identification via this mapping effect of what may appear less resourced or actively policed areas risks those areas becoming targets for individuals with criminal intent, to exploit. This undermines policing, increasing the risk of crime and threatens public safety. Given the information in question is directly relevant to counter terrorism strategy and policing of proscribed terrorist groups, this in turn impacts upon the overall security of the UK.  

 

Disclosure of information captured by this request would undermine the effectiveness of current and future police operations and proceedings. It would reveal details of police intelligence and strategy used to counter criminal activity and apprehend offenders.  

 

Public Interest Test:  

  

In favour of disclosure s24:  

  

The pubic are entitled to know public money is spent in areas of operational policing. Release of the information would facilitate transparency. It would also encourage public debate about how the police prevent and detect crime and uphold the law in terms of proscription of terrorist groups in order to protect the security interests of the UK.  

  

In favour of exemption s24:  

  

To disclose information would render security measures less effective by revealing details of individual force capabilities which could be put together to formulate a national picture of operational counter terrorism strategy. Taking into account the current security climate within the United Kingdom, no information that may aid a criminal, terrorist or proscribed organisation should be disclosed. To what extend this information may aid terrorism in the UK is not precisely known, but it is clear that a disclosure of information will have an impact on the force’s ability to monitor and police proscribed terrorist groups and terrorists effectively; compromising the security of the UK.  

  

In favour of disclosure s31:  

  

Disclosure of information would provide the pubic with better understanding of operational policing, increase public debate and provide information which may allow the public to take steps to better protect themselves. This awareness may also lead to more information being passed to police by the public as they become more alert to suspicious activity.  

  

In favour of exemption s31:  

  

By disclosing the information, law enforcement tactics would be compromised which would hinder the prevention and detection of crime specific to terrorism. More crime would be committed because members of proscribed terrorist organisations as well as terrorists more widely, would have knowledge of operational capability, tactics, strategy and intelligence which would allow then to operate more effectively as well as avoid detection. This places the public at a significant risk of harm, particularly in areas which may have been perceived to be more vulnerable than others because of the mapping effect explained within the harm. Any information which undermines operational law enforcement or places the public at risk is not in the public interest to disclose.  

  

Balance test:  

  

The security of the country is paramount, and the police service will not divulge any information if to do so would place the safety of an individual, the public at large of the national security of the UK at risk. Whilst there is a public interest in transparency of policing and promotion of public debate to improve response, there is a far stronger public interest in safeguarding national security, the integrity of operational policing and keeping the public safe. For these reasons we believe that the balancing test for disclosing the information is not made out in this case.