Section 31 Enters the Tracker

For the first few weeks of the project, the obstacles had been varied.

One force wanted the request simplified. Another pointed us towards material already published online. The Metropolitan Police relied on the cost limit, but at least explained the problem in enough detail for us to narrow the request intelligently.

Today, something different appeared.

Lancashire Constabulary told us that it would not be providing its substantive response within the normal 20-working-day period because it was considering Section 31 — Law Enforcement.

It was the first Section 31 entry in our tracker.

Lancashire said it had not yet reached a decision on where the balance of the public interest lay and expected to need another 20 working days. Its new target date was 19 October 2026.

The notice specifically referred to Section 31(3).

At this stage, there was no reason to treat the extension as a refusal. Lancashire had not told us that the requested information would ultimately be withheld. It was saying that law-enforcement considerations were potentially engaged and that more time was required to reach a decision.

So we recorded it exactly that way.

But the appearance of Section 31 was noteworthy because of the nature of what we had asked for.

Much of the request concerned the evidence behind safeguards: records showing that required deletion had taken place, audit and assurance material, retention arrangements, incident figures and governance documents. We had deliberately excluded operational intelligence, identities, watchlists, covert tactics, security credentials, exploitable vulnerabilities and network architecture.

That did not mean Section 31 could never legitimately apply. Some apparently administrative documents can contain operational information, and each disclosure has to be considered on its actual contents.

But it did create an obvious question.

What information in this request might prejudice law enforcement if disclosed?

At the time, Lancashire looked like an isolated procedural development.

There was no indication yet that the same exemption was about to become one of the dominant features of the entire project.

For now, it was simply another line in the tracker: Lancashire — Section 31 — response extended to 19 October.

The first brick in a wall we had not yet realised was being built.