The ICO has recently said that it is satisfied that the Metropolitan Police Service (MPS) has complied with its 2018 enforcement notice concerning the Gangs Matrix, following the deletion of 374 entries on the database.
In a statement, a spokesman for the ICO announced that the MPS had met the requirements of the enforcement notice, saying: “After reviewing the evidence provided by the MPS regarding the steps required by the enforcement notice, we are satisfied the terms of the enforcement notice have now been met."
According to reports, since last autumn 374 people have been removed from the Gangs Matrix database.
In 2018 the ICO issued an enforcement notice following an investigation that found that:
- The Gangs Matrix did not clearly distinguish between the approach to victims of gang-related crime and the perpetrators;
- The operating model was unclear and inconsistently applied across the London boroughs, with some good practice in some areas but poor practice elsewhere;
- Some boroughs operated informal lists of people who had been removed from the Gangs Matrix, meaning that the MPS continued to monitor people even when intelligence had shown that they were no longer active gang members;
- Serious breaches of data protection laws occurred with the potential to cause damage and distress to the disproportionate number of young, black men on the Matrix;
- The Matrix lacked an Equality Impact Assessment that would enable MPS to show it had considered in this context the issues of discrimination or equality of opportunity;
- There was an absence, over several years, of effective central governance, oversight or audit of data processed as part of the Gangs Matrix, resulting in risk of damage or distress to those on it.
The Met said: “An enforcement notice was served on the Metropolitan Police Service by the Information Commissioner’s Office (ICO) in November 2018, following its review of the Gangs Violence Matrix (GVM). This notice relates to the contravention of data protection principles.
“We are obliged to comply with the findings. We assert that the rationale to continue to use and to operate the GVM is compliant with the Human Rights Act and it is monitored to ensure that it is used proportionately and fairly to reduce serious crime in London.
“The GVM has assisted in preventing many gang members from committing, or being the victims of, serious violent crimes, so we view this as a very effective intelligence tool to direct our activity.”
James Dipple-Johnstone, the ICO’s Deputy Commissioner (Operations), added: “The ICO will continue to monitor how gangs data is used by MPS and partner agencies such as London borough councils.
“Data protection legislation should not be seen as a barrier to the MPS’ vital work in tackling violent youth and gang crime or to data sharing more broadly.
“We will continue to work with the MPS, the Mayor's Office for Policing and Crime (MOPAC) and London boroughs, so that data sharing can take place in a way that maintains that confidence.”