Police policy documents

Mark Hanna made this Official Information request to New Zealand Police

The request was successful.

From: Mark Hanna

Tēnā koutou,

Several NZ Police policy documents have been released under the Official Information Act in the past. However, as time passes the details of active policies will understandably change, so documents that were released in the past may no longer be current.

I am interested in understanding both the degree to which these policy documents released in the past are out of date, and the scope of which other NZ Police policy documents might exist without having been made publicly available. I am also interested in understanding the different types of policy documents used by NZ Police and how they are organised.

In 2012, NZ Police released a list of all policy documents broken down by name and type. The response was published on fyi.org.nz here: https://fyi.org.nz/request/new_zealand_p...

As well as providing a list of chapters of the Police Manual, this policy list also included General Instructions and Commissioner’s Circulars.

Some of the Police Manual chapters that have subsequently been released under the OIA have been accompanied by version numbers. For example, the “Arms” chapter of the Police Manual released in January 2017 was annotated with “Version : 16.0”:

Other Police Manual chapters have instead been released under the heading “Police Instructions” and have not had a version number. For example, the Fleeing Driver Policy document released here in September 2020:

The Police Manual chapter “Police investigations of complaints and notifiable incidents”, published on the NZ Police website, also has the heading “Police Instructions” and no version number:

Please release the following information regarding NZ Police policies that are currently in effect, excluding local orders:

1. A list of current NZ Police policy documents, including Police Manual chapters, General Instructions, and Commissioner’s Circulars. Please include:
a) The name of the policy
b) The type of the policy
c) The date at which the current version of the policy came into effect
d) Where applicable, the version of the current policy (e.g. “12.0”)
e) If the policy belongs to one or more groups of similar policies, e.g. “Intelligence”, what group or groups does it belong to?
f) If the policy has been published online by NZ Police, a URL where it is available

2. What legal authority underpins the Police Manual and its chapters? For example, is it a type of Commissioner’s circular as referred to by section 30(1)(b) of the Policing Act 2008?

3. How does NZ Police manage different versions of policy documents? For example, are all policy documents assigned a version number?

Please also explain any relevant caveats that should be kept in mind when analysing this information.

Please provide this information in an accessible, searchable format without a watermark. I would prefer that the response to part 1 of my request be provided in a spreadsheet format, such as CSV or XLSX.

If any part of my request is unclear, please don't hesitate to contact me.

I understand that several hundred documents will fall within the scope of my request. If any of the information that I have requested in part 1 of my request would be difficult to retrieve, I would be happy to discuss altering or refining my request.

Ngā mihi,
Mark Hanna

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From: Ministerial Services
New Zealand Police

Tēnā koe Mark

I acknowledge receipt of your Official Information Act (OIA) request below, received by NZ Police on 23 April 2022.

Your request is being actioned pursuant to the Act.

You can expect a response to your request on or before 23 May 2022.

Ngā mihi
Ministerial Services
Police National Headquarters

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Mark Hanna left an annotation ()

Since having made this request, I've noticed that three General Instructions regarding firearms that were previously published on the NZ Police website have been removed between December 2020 and April 2021. I'll be interested to see what their response says about these General Instructions.

F061 - Use of Firearms by Policie
F062 - Fire Orders
F063 - Police Firearms

An archived copy of these General Instructions from December 2020 can be found here: https://web.archive.org/web/202012011438...

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James Murdoch left an annotation ()

Ahah Police Late

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Mark Hanna left an annotation ()

I have laid a complaint with the Office of the Ombudsman:


Tēnā koe,

I would like to lodge a formal complaint regarding an overdue response to a request for official information.

NZ Police received a request for official information from me on 23 April 2022. The final day of the 20 working days allowable by the Official Information Act was 23 May 2022, however this date has now passed and I have not yet received a response.

Here is a timeline of all correspondence regarding this request to date:

23 April 2022
NZ Police received my request

26 April 2022
I received an acknowledgement of receipt of my request from NZ Police

There has been no further correspondence to date.

I have attached a zip file containing all correspondence I have had with NZ Police regarding this request.

I have observed several recent public OIA responses from NZ Police on FYI.org.nz in which the PNHQ (Police National Headquarters) OIA team have contacted the requester several days after the legal due date of a request has passed only to retroactively inform the requester that the missed the due date, apologise, and give little to no information about when a response could be expected. NZ Police often blames its internal review process for these unlawful delays.

I anticipate NZ Police has been planning on sending exactly such a message to me in the coming days.

I’m sure you will be aware that this is not the first time I have written to you regarding a pattern of unlawful behaviour regarding unlawfully delayed OIA responses by NZ Police. This is simply the latest of many years of this practice.

As far as I am aware, it is restricted to those OIA requests handled by the team at PNHQ, whereas other requests handled by other teams within NZ Police (such as insurance requests) are adequately resourced and often do receive prompt responses.

I believe this is the reason for the apparently discrepancy between the statistics NZ Police reports to the State Services Commission, in which NZ Police reports about 98% of OIA requests receive responses within the legislated timeframe, compared experiences of members of the public like myself who request official information from NZ Police and find that many or even most requests do not receive a response before the legal due date.

I am concerned that this general pattern of unlawful behaviour by NZ Police has effectively been forced on the PNHQ OIA team due to their chronic under-resourcing by NZ Police as an organisation.

I believe NZ Police has been abusing the fact that they do not fall within the jurisdiction of the Ombudsmen Act, and that the IPCA is unwilling or unable to investigate matters related to NZ Police’s unlawful behaviour under the OIA, to continue this pattern of disregard for the law.

I understand that you are only able to investigate NZ Police’s response to my request specifically, but for completeness here are some links to some of these apology messages that have been sent by NZ Police within just the past week:


I would like to be clear that I would not consider an apology from NZ Police to settle this complaint. I do not think such apologies can be meaningful unless they are accompanied by a commitment to do better in the future.

I hope that you will consider making a recommendation in this case, as I believe this form of pressure may be necessary before NZ Police would consider providing adequate resources for the PNHQ OIA team to be able to meet their legal obligations.

Please don’t hesitate to contact me if any part of my complaint is unclear, or if you require any more information from me.

Ngā mihi,
Mark Hanna

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From: Ministerial Services
New Zealand Police

Tēnā koe Mark

I refer to your request of 23 April 2022 for the below information.

Unfortunately we were not be able to meet the due date of 24 May 2022.

I can confirm that your request has been compiled and is currently progressing through our internal consultation process. Although I am unable to confirm a release date at this stage, I expect you will receive a response within three days.

Please accept our apologies for the delay in providing you with a response to your query. We are endeavouring to provide this to you as soon as possible.

Many thanks, Brittany
Ministerial Services, PNHQ

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From: Ministerial Services
New Zealand Police

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Attachment Hanna Mark IR 01 22 11586 Response.pdf
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Tçnâ koe Mark                                  

Please find attached the response to your Official Information Act
request, received by New Zealand Police on 23 April 2022.


Please accept our apologies for the delay in providing you with this
response. This delay was attributable to an error, in particular – your
request was overlooked and not on-forwarded to a relevant team.

Thank you, and apologies again for the delay that this has caused.

Ngâ mihi



Ministerial Services |

Strategy & Partnerships |PNHQ

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Mark Hanna left an annotation ()

I see NZ Police has entirely ignored the section of my request regarding s16(2) of the OIA.

I asked explicitly that information regarding part 1 of my request be released as a spreadsheet, but NZ Police provided it instead embedded within a PDF.

I also asked explicitly that all information be provided without a watermark, but NZ Police has applied a "Released pursuant to Official Information Act (1982)" watermark to the copy of the Police Instructions Policy they have released. I find this particularly confusing given the large number of other Police Manual chapters which have been released without a watermark in the past.

There is no mention in NZ Police's response letter of any reason why the information released was not provided in the way I preferred. Providing such a reason in this case is an explicit legal requirement under section 16(3) of the OIA. Though I suspect none of the reasons allowed under section 16(2) apply, and NZ Police simply disregarded that section of my request as a matter of course.


I will be lodging a further complaint with the Ombudsman regarding these issues. This is not the first time NZ Police has failed to make information available in an appropriately accessible format even when they were asked explicitly to do so, and I think changes in the way PNHQ processes and responds to requests for official information will be necessary to address this pattern of unlawful behaviour.

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From: Mark Hanna

Tēnā koe,

Thank you for releasing this information. However, it looks like part of my request was not considered. In particular, I specified that I would prefer the information to be released in a particular way:

“Please provide this information in an accessible, searchable format without a watermark. I would prefer that the response to part 1 of my request be provided in a spreadsheet format, such as CSV or XLSX.”

However, the Police Instructions Policy was provided with a “Released pursuant to Official Information Act (1982)” watermark, and the information I requested in part 1 of my request was provided as a 9 page table embedded in a PDF.

I’d like to reiterate my request that this information be provided in the formats I requested.

I’m sure you can understand that it is frustrating to have had to wait over two weeks since the legal due date for my request passed, only to find that an important part of my request appears not to have been considered. I specified this preferred way to receive the information because I wanted to pre-empt any potential accessibility and usability concerns that may arise from some fairly common practices in OIA responses.

As I’m sure you are aware, section 16(2) of the Official Information Act requires that an agency must make information available in the way preferred by the requester unless to do so would:

- Impair efficient administration
- Be contrary to any legal duty of the department or venture or Minister of the Crown or organisation in respect of the document
- Prejudice the interests protected by section 6 or section 7 or section 9 and (in the case of the interests protected by section 9) there is no countervailing public interest.

However, I don’t believe any of these reasons are likely to apply in this instance. Rather, I expect this was just an unfortunate oversight, and I hope it’s one that will be addressed in such a way that would prevent similar oversights in the future.

If there was a deliberate decision not to provide this information in the way I prefer, section 16(3) of the Official Information Act requires that you inform me of the reason why the information was not provided in the way I prefer. If that was the case, then under section 16(3)(b) I would also ask that you please provide me with the grounds in support of that reason.

I have recently viewed 60+ Police Manual chapters that have been released under the Official Information Act in recent years, and I believe only one or two others have had a watermark. Also, Police has had no trouble releasing information to me in spreadsheet formats such as XLSX in the past.

I expect that the information released to me must have first been prepared in the formats I requested, before being transformed into the formats it was eventually released in. So I hope it will be easy for you to provide them to me in my preferred format reasonably quickly.

I would also like to draw your attention to the Ombudsman’s guide on proactive release. Though this is not exactly the same context, I think his guidance on watermarks applies equally well here:


“‘Released under the OIA’

One potential barrier to accessibility is the use of ‘watermarks’. Watermarks are sometimes attached to documents to show they have been released under the OIA, or released proactively. Watermarks can interfere with reader software, and create difficulties for people with vision or cognitive impairments.

The use of watermarks is not required. It is a practice that evolved out of a concern that information released under the OIA could be misrepresented as having been leaked... Agencies could publish information without a watermark, or use the header or footer of a document to note that it has been released proactively.”

In this case, your response is published automatically on fyi.org.nz, so I don’t expect there could be any reasonable confusion regarding how this information was made public. Even in cases where requests are not made via FYI, though, watermarks can still present an unnecessary accessibility barrier.

Likewise, converting tables from a spreadsheet into a PDF makes them difficult to use. Often, either manual or automatic conversion back from a PDF into a spreadsheet is necessary to make the information useful, and that carries with it a risk of transcription errors.

When I wrote to Minister for Disability Issues Carmel Sepuloni in 2017 regarding my concerns with accessibility practices in OIA responses across the public sector, she wrote to me that:

“Providing OIA responses in accessible formats should be standard practice as part of an open and transparent government.”

I appreciate that significant progress has been made, both by PNHQ and elsewhere in the public sector, to release official information in more accessible formats. For example, not too long ago it was common for OIA response letters to be released as wholly inaccessible image-based PDFs, whereas now it is far more common for these response letters to be text-based.

However, there is still more progress to be made in this area. I hope you will further refine your approach to release information in more accessible formats as standard practice, rather than converting them to formats that introduce unnecessary accessibility barriers.

Section 16(2) of the OIA in particular is an important accessibility provision, as it allows requesters to help agencies provide information in formats that serve their particular accessibility or usability needs. I think these parts of requests may sometimes be trimmed out when a request is processed in order to discern exactly what information has been requested. I hope you can refine your approach here, as well, to ensure that such preferences are accounted for in the future.

Ngā mihi,
Mark Hanna

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From: Ministerial Services
New Zealand Police

Kia ora Mark

Thank you for pointing out your request hadn't been interpreted as expected. I have requested the information in the formats requested from the appropriate part of the business and will send these to you as soon as possible. Our sincere apologies for the oversight.

Ngā mihi
Ministerial Services
New Zealand Police National Headquarters Wellington

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From: Ministerial Services
New Zealand Police

Attachment List of all Police Manual chapters as at May 2022 searchable.xlsx
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Attachment Police Instructions Policy.pdf
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Kia ora Mark

Our apologies for the incorrect formats you have received. Please find attached the Police Instructions Policy and list of chapters attached.

Ngā mihi
Ministerial Services
New Zealand Police National Headquarters Wellington

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From: Mark Hanna

Tēnā koe Sarah,

Thanks, I appreciate you getting this sort for me quickly.

Ngā mihi,
Mark Hanna

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Tangata Whenua left an annotation ()

Police are corrupt as! Just enter new contracts with Sarah or Brittany or God or Satan. Never know who you're dealing with and they bounce you around to other offices so that you get a new person each time to start up a new contract which just confuses people so they give up. Get the police code of conduct Mark so the public can identify what serious misconduct looks like for police.


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