Suspicious transaction report human trafficking data

The request was refused by 香港警務處 刑事部.

Dear Hong Kong Police Force Crime Wing,

I'm interested in the data the Joint Financial Intelligence Unit provide on suspicious transaction reports (STRs), see:

http://www.jfiu.gov.hk/en/statistics_str...

It seems human trafficking is one of the criminal offences in the proforma for reporting STRs, so can you provide the numbers on how many of these STRs are for human trafficking? I just need historic yearly aggregated data on the number of reported human trafficking cases contributing to this dataset, and there therefore should not be any issues with identification of any particular cases. Being able to break this down per sector would be useful, but if you don't have that then yearly data should suffice. The 2016 data would be perfect, and if you have yearly going back to 2012 that would help put things in context.

Please let me know if you have any problems gathering this, or if there is a different department I should be contacting for it.

Yours faithfully,

Scott Edmunds

香港警務處 刑事部

Dear Mr. Scott Edmunds,

Your request dated 2017-09-22 refers. Your enquiry was referred to this
office on the same day.

Please be informed that we are now processing your query and will reply to
you soon.

For enquiry, please contact me at 852-2860 4079.

Regards,
Miss Elaine HO
for Commissioner of Police
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香港警務處 刑事部

Dear Mr. Scott Edmunds,

Your request dated 2017-09-22 refers.

Confidentiality is strictly safeguarded to maintain the integrity of the
suspicious transaction reporting regime in accordance with the relevant
provisions of Laws of Hong Kong. Please be informed that your request is
refused in accordance with 2.13(a) in Part 2 of the Code on Access to
Information Request ("the Code") that your requested information falls
under the category of "Information relating to incomplete analysis,
research or statistics, where disclosure could be misleading or deprive the
department or any other person of priority of publication or commercial
value".

Please note that an applicant for Access to Information may request review
of a decision if he believes that the Police have failed to comply with any
provision of the Code. The request for review will be considered by the
Major Formation Commander concerned. You may also lodge a complaint to the
Ombudsman.

Should you have any enquiry, please contact the undersigned at 852-2860
4079.

Regards,
Miss Elaine HO
for Commissioner of Police
*** This e-mail message (together with any attachments) is for the
designated recipient only. It may contain information that is privileged.
If you are not the intended recipient, you are hereby notified that any
use, retention, disclosure, copying, printing, forwarding or dissemination
of the message is strictly prohibited. If you have received the message in
error, please erase all copies of the message (including attachments) from
your system and notify the sender immediately. ***

*** 此電郵訊息(連同任何附件)只發送給指定收件人。訊息可能包含享有特權資
料。謹此通知,如你並非預定收件人,嚴禁使用、保留、披露、複製、列印、轉發或
發布此訊息。如收到誤發的訊息,請把訊息的所有副本(包括附件)從系統內清除,並
立即通知發件人。***

Dear Hong Kong Police Force Crime Wing,

Please pass this on to the person who conducts Freedom of Information reviews, and if necessary please pass this to the Major Formation Commander concerned.

I am writing to request an internal review of Hong Kong Police Force Crime Wing's handling of my FOI/access to information request 'Suspicious transaction report human trafficking data'.

I asked for aggregated data on the Joint Financial Intelligence Unit provide on suspicious transaction reports (STRs), and how many of these were for human trafficking as this data is collected on the reporting forms. I was told that my request was refused to protect confidentiality. As I am asking for aggregate historical data then there is absolutely no possibility of identifying individual cases. For example in 2016 there were 76590 STRs received - how can telling me that x number of these were for human trafficking potentially provide any sensitive information or incriminate anyone? As the STR reports are already provided publicly and include detailed breakdowns by sector I also cannot see how one additional category of information has any commercial value.

I would therefore like to appeal this rejection and ask again for the aggregated data on the number of yearly STRs for human trafficking. If you once again decline my request I would like to know exactly how this aggregated, anonymised and purely historical data will breach any confidentially or deprive the department or any other person of priority of publication or the data's commercial value.

A full history of my FOI request and all correspondence is available on the Internet at this address: https://accessinfo.hk/en/request/suspici...

Yours faithfully,

Scott Edmunds

香港警務處 刑事部

Dear Mr. Scott Edmunds,

Your correspondence dated 9 Oct 2017 refers.

Please be informed that your request for review is being processed. A
reply will be made to you soon in accordance with the Code on Access to
Information.

For enquiry, please contact me at 852-2860 4079.

Regards,
Miss Elaine HO
for Commissioner of Police
*** This e-mail message (together with any attachments) is for the
designated recipient only. It may contain information that is privileged.
If you are not the intended recipient, you are hereby notified that any
use, retention, disclosure, copying, printing, forwarding or dissemination
of the message is strictly prohibited. If you have received the message in
error, please erase all copies of the message (including attachments) from
your system and notify the sender immediately. ***

*** 此電郵訊息(連同任何附件)只發送給指定收件人。訊息可能包含享有特權資
料。謹此通知,如你並非預定收件人,嚴禁使用、保留、披露、複製、列印、轉發或
發布此訊息。如收到誤發的訊息,請把訊息的所有副本(包括附件)從系統內清除,並
立即通知發件人。***

香港警務處 刑事部

Dear Mr. Scott Edmunds,

Your request for Internal Review dated 2017-10-09 refers.

Please be informed that your request has been reviewed by the Major
Formation Commander of Crime Wing, Hong Kong Police Force. After
examination of the grounds presented, decision has been made to uphold the
original decision of refusal.

The ground of our refusal was made in accordance with 2.13(a) in Part 2 of
the Code on Access to Information Request ("the Code") that your requested
information falls under the category of "Information relating to incomplete
analysis, research or statistics, where disclosure could be misleading".
You may wish to note that there is no mandatory requirement for the
reporting entity to identify the possible crime that may be related to a
Suspicious Transaction Report ("STR"). We therefore do not possess reliable
statistics in respect of STR that are related to Human Trafficking. As a
result, it is considered that the release of such statistics could be
misleading.

If you are not satisfied with the review decision, you may lodge a
complaint with The Ombudsman.

Should you have any further enquiries, please do not hesitate to contact
us.

Regards,
Miss Elaine HO
for Commissioner of Police
*** This e-mail message (together with any attachments) is for the
designated recipient only. It may contain information that is privileged.
If you are not the intended recipient, you are hereby notified that any
use, retention, disclosure, copying, printing, forwarding or dissemination
of the message is strictly prohibited. If you have received the message in
error, please erase all copies of the message (including attachments) from
your system and notify the sender immediately. ***

*** 此電郵訊息(連同任何附件)只發送給指定收件人。訊息可能包含享有特權資
料。謹此通知,如你並非預定收件人,嚴禁使用、保留、披露、複製、列印、轉發或
發布此訊息。如收到誤發的訊息,請把訊息的所有副本(包括附件)從系統內清除,並
立即通知發件人。***

Guy Freeman 新增了一個註解。 ()

After this response, Scott complained to the Ombudsman, who after investigating upheld the Hong Kong Police Force's response. With Scott's and the Ombudsman's permission, you can find the Ombudsman's report here: https://www.dropbox.com/s/l9u94vvw2an7p6...