Surrey Police FOI Section 11 Breach Upheld by ICO
Summary
The Information Commissioner's Office has upheld a complaint against Surrey Police finding a breach of section 11 of the Freedom of Information Act 2000. The breach arose from Surrey Police's failure to provide requested dash-cam report data in the complainant's preferred editable spreadsheet format. The ICO also determined that Surrey Police did not provide a valid explanation for why it was not reasonably practicable to comply with the format preference. The decision requires Surrey Police to either supply the information in an editable spreadsheet or provide a lawful explanation for non-compliance.
“The Commissioner requires Surrey Police to reconsider the complainant's preferred format under section 11 of FOIA and either provide the information in an editable spreadsheet format or explain why doing so is not reasonably practicable.”
Public authorities receiving FOIA requests should review their procedures for handling format preferences under section 11: if the requested information already exists in an accessible electronic format, a bare assertion that reformatting is impractical is unlikely to satisfy the ICO without concrete justification. Forces with dash-cam or similar automated reporting systems should audit whether their standard output formats can satisfy section 11 preferences without disproportionate effort.
About this source
The Information Commissioner's Office is the UK's data protection and freedom of information authority. Decision notices are the formal written outcomes of ICO investigations into complaints against public authorities for Freedom of Information Act compliance. Around 230 decisions a month, each naming the authority, request details, whether the request was upheld, partially upheld, or rejected, and any remedial action ordered. Decision notices are a rich vein of information about UK government transparency and often reveal what specific requests ICO considers legitimate. Watch this if you file FOI requests in the UK, advise public authorities on disclosure obligations, or research information rights case law.
What changed
The ICO found that Surrey Police breached section 11 of FOIA by failing to provide the requested dash-cam report information in the complainant's preferred editable spreadsheet format, without establishing that it was not reasonably practicable to do so. The section 40(2) exemption claim was not upheld for all withheld data. Affected public authorities should review their obligations under section 11 of FOIA to accommodate requesters' preferred formats where reasonably practicable, and ensure that any refusal to do so is supported by documented justification.
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Apr 28, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
Chief Constable Surrey Police
- Date 24 April 2026
- Sector Police and criminal justice
- Decision(s) FOI 11: Upheld, FOI 40(2): Not upheld The complainant asked Surrey Police for a spreadsheet recording third‑party dash‑cam reports of alleged driving offences between January 2023 and February 2025. Surrey Police disclosed some information but withheld some details under section 40(2) of FOIA. The Commissioner’s decision is that Surrey Police was entitled to rely on section 40(2) of FOIA to withhold some of the requested information. However, Surrey Police breached section 11 of FOIA by not providing the information in the complainant’s preferred format and did not provide a valid explanation for why it was not reasonably practicable to do so. The Commissioner requires Surrey Police to reconsider the complainant’s preferred format under section 11 of FOIA and either provide the information in an editable spreadsheet format or explain why doing so is not reasonably practicable.
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