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Custody Image Database (205A/23)


  1. The number of individuals’ images held in your forces’ custody image database. NB – If the number of individuals cannot be ascertained, please provide the number of images in the database.
  2. The number new individuals’ images [or images, if the number of individuals cannot be ascertained] uploaded to your forces’ custody image database in 2022
  3. The number of requests for the deletion of images in your custody image database received by your force in 2020, 2021 and 2022 [provided separately please]
  4. The number of these requests that were agreed to by your force, in each of those years.
  5. A copy of any leaflet or information provided to arrestees by your force “explaining their rights to have their custody image deleted under certain circumstances”, and any document/guidance given to officers on when to make this information available to arrestees.


Our data are not organised in such a way as to allow us to provide all this information within the appropriate (cost) limit of the Freedom of Information (FOI) Act (see ‘Reason for Decision’ below).

However, although excess cost removes the force’s obligations under the Freedom of Information Act, as a gesture of goodwill I have supplied information, relative to your request, retrieved before it was realised that the fees limit would be exceeded (see as follows for question 2 and see attached for questions 3, 4 and 5 ‘205A_23_attachment.pdf’). I trust this is helpful, but it does not affect our legal right to rely on the fees regulations for the remainder of the request.

For question 2, the closest information we are able to provide is the total number of custody records where an image was taken in 2022 and is as follows:

2022 = 33,068

This figure was obtained by piecing together results from multiple searches for the first and second half of each month as our system (CONNECT) cannot bring back more than 2,500 hits at once.

It is important to note though that this is the number of custody records (which includes BOTH detainees and voluntary attendees) where an image was taken, and not the number of people who have had their image taken, as some people get arrested or voluntarily attend an interview several times in a year. It is also not the total number of images for 2022 (as some records will have multiple images taken, e.g. with and without glasses, etc). Therefore, these figures do not relate to either of the specific points contained in question 2, but hopefully they give at least some indication of the volumes of detainee and voluntary attendee records held in CONNECT where photos were taken. Finally, this search only looked for the date the image was taken, not the date of arrest / attendance / record creation / etc.


With regard to questions 1 and 2, the only way to determine either the number of individuals’ images or the number of images in our custody system, would be to manually go into custody records. However, for 2022 alone, this would require us having to separately examine more than 33,000 records and even at a minimum of two minutes per record, this would equate to a search that would take over 1,000 hours, far exceeding the appropriate limit (FOIA, s.12).

This means that the cost of compliance with the whole of your request is above the amount to which we are legally required to respond, i.e. the cost of locating and retrieving the information would exceed the appropriate costs limit under section 12(1) of the FOI Act 2000. For West Midlands Police, the appropriate limit is set at £450, as prescribed by the Freedom of Information and Data Protection (Appropriate Limit and Fees) Regulations 2004, S.I. 3244.

Further information on Section 12 is available here.