Connected Vehicle Data Contracts/Correspondence (Metropolitan Police Department)

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Dear Peter Andringa,
Request Number 2024-FOIA-05868 has been assigned to the request you submitted.
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This is an automated message from the DC Government FOIA system. Dear Peter Andringa, The status for your request is below. Please log into https://foia-dc.gov/palMain.aspx and go to Request Status. If you have any questions regarding the status of your request, please contact the agency's FOIA office that you had submitted your FOIA request to. You can communicate directly with the FOIA office by clicking on Inbox, search the request number, and then click Compose Message. OR, visit to see a list DC Government FOIA Office’s/officer’s contact information and have your Request ID ready. (https://dc.gov/node/818962) Contact FOIA Office Request status: Assigned for Processing Request ID: 2024-FOIA-05868 Description: To Whom It May Concern:My name is Peter Andringa and I'm a reporter with the Financial Times.Pursuant to the DC Freedom of Information Act, I hereby request all records relating to relationships between Metropolitan Police Department and any of the following providers of vehicle data aggregators, which provide data products or services using information derived from internet-connected vehicles:1. Otonomo Inc (https://otonomo.io)2. Wejo (https://wejo.com)3. LexisNexis Risk Solutions (https://risk.lexisnexis.com/law-enforcement-and-public-safety)4. The Ulysses Group (https://theulyssesgroup.com/)For *each* of the above companies, I request any and all:A. Invoices, purchase orders, and/or contracts for use, training, or access to company products and servicesB. Training materials and/or internal policies relating to the use of company products or servicesC. Public safety and/or privacy reviews related to the company products or servicesD. Written correspondence and/or attachments sent by email between staff of Metropolitan Police Department and representatives of the company. (For the purposes of searching email records, you can query on the following sender or recipient domains: @otonomo.io, @wejo.com, @lexisnexis.com, or @theulyssesgroup.com)If it is helpful to narrow my request, you can focus the time window of your search for records from January 1, 2021 to the present day.The requested documents will be made available to the general public, and this request is not being made for commercial purposes.In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 15 business days, as the statute requires.Sincerely,Peter AndringaUpload documents directly: https://www.muckrock.com/ Regards,
DC Government FOIA Portal

Dear Mr./Mrs. Andringa, This e-mail is to acknowledge receipt of yourFOIA request assigned: 2024-FOIA-05868. Your assigned FOIASpecialist is: Robert Eckert If you have any questions regarding your request, please contact yourassigned FOIA Specialist who is included in this e-mail.  Be advised, ouroffice operates on a hybrid onsite/remote work schedule.  Therefore, ifyou are unable to reach your specialist when calling our office, please makecontact via e-mail.  For ease of reference, we ask that you have your FOIARequest Number available when you contact our office. Once the requesteddocuments are received, please be advised of the following notations below: RESPONSE TIME Pu rsuant to D.C. Official Code §2-532(c), there is a 15 business day statutory allotted time, subject tothe possibility of a ten (10) business day extension from the date of receiptto respond to a FOIA request. If your request is for Body Worn Camera (BWC) footage, there is a25 business day statutory allotted time, subject to the possibility of 15working-day extension from the date of receipt to respond to a Body Worn Camera (BWC) request. REQUEST FOR EXPEDITED SERVICE If you seek expedited service relating to your FOIA request,please be advised, there is no provision or authority under the District ofColumbia Freedom of Information Act laws, to provide expedited service. Therefore, your request will be processed under the provision of the D.C.Official Code §§ 2-531 et seq. Regards, Latrina Crumlin Staff Assistant Freedom of Information Act(FOIA) Office Metropolitan Police Department 441 4 th St NW, RM 1100South Washington, DC 20001

April 18, 2024

Peter Andringa

MuckRock News

Department MR162218

263 Huntington Avenue

Boston, Massachusetts 02115

requests@muckrock.com

RE: FOIA Request No. 2024-FOIA-05868

Dear Mr. Andringa:

This concerns your Freedom of Information Act (FOIA) request for:

"To Whom It May Concern: My name is Peter Andringa and I'm a reporter with the Financial Times. Pursuant to the DC Freedom of Information Act, I hereby request all records relating to relationships between Metropolitan Police Department and any of the following providers of vehicle data aggregators, which provide data products or services using information derived from internet-connected vehicles: 1. Otonomo Inc (https://otonomo.io) 2. Wejo (https://wejo.com) 3. LexisNexis Risk Solutions (https://risk.lexisnexis.com/law-enforcement-and-public-safety) 4. The Ulysses Group (https://theulyssesgroup.com/) For *each* of the above companies, I request any and all: A. Invoices, purchase orders, and/or contracts for use, training, or access to company products and services B. Training materials and/or internal policies relating to the use of company products or services C. Public safety and/or privacy reviews related to the company products or services D. Written correspondence and/or attachments sent by email between staff of Metropolitan Police Department and representatives of the company. (For the purposes of searching email records, you can query on the following sender or recipient domains: @otonomo.io, @wejo.com, @lexisnexis.com, or @theulyssesgroup.com) If it is helpful to narrow my request, you can focus the time window of your search for records from January 1, 2021 to the present day. The requested documents will be made available to the general public, and this request is not being made for commercial purposes. In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not. Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 15 business days, as the statute requires."

In summary, this request asks for "...all records relating to relationships between Metropolitan Police Department and any of the following providers of vehicle data aggregators ...", and then lists several companies/entities, and goes on to ask for "... any and all: A. Invoices, purchase orders, and/or contracts for use, training, or access to company products and services B. Training materials and/or internal policies relating to the use of company products or services C. Public safety and/or privacy reviews related to the company products or services D. Written correspondence and/or attachments sent by email between staff of Metropolitan Police Department and representatives of the company. (For the purposes of searching email records, you can query on the following sender or recipient domains: @otonomo.io, @wejo.com, @lexisnexis.com, or @theulyssesgroup.com) If it is helpful to narrow my request, you can focus the time window of your search for records from January 1, 2021 to the present day."

Upon review, this request does not provide a request for (a) specific records, but asks for research to locate and release entire groupings, or categories, of records---it asks for a largely undefined or open-ended sets of ("all records" and "any and all") business records and e-mail messages that may have been created or received, and may have been sent between the Metropolitan Police Department (MPD) employees and any of several external entities over an undefined period, or at the least over a multi-year/over three-year period. It includes a request for e-mail searches over an undefined or multi-year period to locate records that may be identified by using only the external entities' e-mail domain names, with unspecified external senders'/recipients' identities and unspecified/unidentified MPD recipients/senders, i.e., unspecified employees of an agency/organization of thousands of employees.

Therefore, the description of this request is deemed to constitute an "inadequate description", as it does not adequately describe specific records or specifically-identified subject matter that may be reasonably located and processed within a reasonable period of time---again, it describes only a category or categories of records. Further, it, in effect, without greater specificity, asks for research on behalf of the requester, and as such we are not able to further process this request. That is, we are not able to perform a "reasonable and adequate" search for specific documents relative to specifically-identified subject matter/records. Therefore, this is not a "perfected" request, and the file on this request is closed.

The District of Columbia (DC) FOIA specifies that a FOIA request must reasonably describe records sought such that agency staff familiar with the records may reasonably ascertain exactly which records are being requested, and to locate them. See 1 DCMR § 402.4 ("A request shall reasonably describe the desired records. Where possible, specific information regarding names, places, events, subjects, dates, files, titles, file designation, or other identifying information shall be supplied"); Dale v. IRS, 238 F. Supp. 2d 99, 104 (D.D.C. 2002) (a request for "any and all" records does not describe the records sought with reasonably sufficient detail). "[T]he rationale for this rule is that FOIA was not intended to reduce government agencies to full-time investigators on behalf of requesters." Assassination Archives & Research Ctr. v. CIA, 720 F.Supp. 217, 219 (D.D.C.1989). "FOIA creates only a right of access to records, not a right to personal services." Hudgins v. IRS, 620 F. Supp. 19, 21 (D.D.C. 1985). See also Brown v. F.B.I., 675 F. Supp. 2d 122, 129-130 (D.D.C. 2009).

As described, the Metropolitan Police Department (MPD) would be required to perform an unreasonably large and open-ended search of all components and locations/facilities, all staff, and all records management systems throughout a large and complex agency of thousands of employees. Further, electronic searches for such categories or groupings of records among electronic systems and other media, as requested in the description of this request, may produce large volumes of unrelated material, and processing documents initially identified in initial searches for such a request or requests may take an inordinate amount of limited FOIA processing time. The processing of such a request would be a very time- and labor-intensive process which requires locating tentatively responsive records; re-searching through these materials to ascertain and identify records that may actually be responsive; reviewing for and redacting material that may be exempt from release under the FOIA; coordinating and consulting with components, agencies within and external to the DC government, and other external entities which may have an interest in the disposition of the records; and, the completion of further administrative processing and review. Again, the courts have said that the FOIA was not intended to reduce government agencies to be investigators or to perform research on behalf of requesters, and that the FOIA does not require agencies to conduct "unreasonably burdensome" searches for records---and again, have recognized that the legislative history of the FOIA indicates that a description of a requested record is sufficient if it enables a professional agency employee familiar with the subject area to locate the record with a "reasonable amount of effort."

Please note that the District of Columbia (DC) FOIA, DC Code §§ 2-531-539, provides that while a person has the right to request access to existing records, it does not require agencies to do research, analyze data, answer written questions, or create records to respond to a FOIA request. We strongly advise that a significantly more refined and limited description be provided for any future FOIA request(s) such that it is as specific as possible relative to (a) particular document(s) in order to allow a reasonable search to be completed.

To the extent that this request would otherwise be asking for specific records of specific incidents or certain activities that may remain under investigation, I have determined to withhold any records, in their entirety, that may otherwise have been located and may be responsive to this request under DC Official Code §2-534 (a)(3)(A)(i) and (a)(3)(B), which protects investigatory records compiled for law-enforcement purposes to the extent that the production of such records would interfere with enforcement proceedings, as some of the material covered by the scope of this request would remain the subject of open and ongoing criminal investigation(s); could interfere with enforcement proceedings by revealing the direction and pace of (the) investigation(s); lead to attempts to destroy or alter evidence; reveal information about potential witnesses who could then be subjected to intimidation as part of an effort to frustrate future investigative activities; place any witnesses in danger; and, could deprive a person of a right to a fair trial or an impartial adjudication.

In addition, the FOIA Office is unable to locate documentation, e.g., a government-issued ID along with a signed authorization to release privacy records, signed waiver of privacy interests, or signed retainer agreement, from (an) appropriate individual(s) who may be the subject of, who may otherwise be identified within, or who may have a personal privacy interest in the disposition of, such records. Much of the requested material would be or is subject to being withheld under D.C. Official Code § 2-534 (a)(2), which covers information of a personal nature, the release of which would constitute a clearly unwarranted invasion of personal privacy; and, (a)(3)(C), which protects investigatory records compiled for law-enforcement purposes to the extent that the production of such records would constitute an unwarranted invasion of personal privacy. Such privacy information includes names/personal identifiers and other personal privacy information, including that which may lead to the identity of individuals. Other FOIA exemptions may also apply.

I note, however, that to the extent that this request may seek specific contracts/procurement records, you may wish to submit a FOIA request for contracting/procurement records to the District of Columbia (DC) Office of Contracting and Procurement (OCP), a separate District of Columbia (DC) agency which is responsible for and serves as the custodian of such documents, by submitting a FOIA request to OCP through the District of Columbia FOIA web page/portal: https://foia-dc.gov/palMain.aspx; or, to Jeremiah Regan, 441 4th Street, N.W., Washington, DC 20001, Phone: (202) 727-0252, e-mail: jeremiah.regan@dc.gov<mailto:jeremiah.regan@dc.gov>.

Please know that, under D.C. Official Code § 2-537 and 1 DCMR § 412, you have the right to appeal this letter to the Mayor or to the Superior Court of the District of Columbia. If you elect to appeal to the Mayor, your appeal must be in writing and contain "Freedom of Information Act Appeal" or "FOIA Appeal" in the subject line of the letter as well on the outside of the envelope. The appeal must include (1) a copy of the original request; (2) a copy of any written denial; (3) a statement of the circumstances, reasons, and/or arguments advanced in support of disclosure; and (4) a daytime telephone number, an e-mail and/or U.S. mailing address at which you can be reached.

The appeal must be mailed to: The Mayor's Office of Legal Counsel, FOIA Appeal, 1350 Pennsylvania Avenue, N.W., Suite 407, Washington, D.C. 20004. Electronic versions of the same information can instead be e-mailed to The Mayor's Office of Legal Counsel at foia.appeals@dc.gov<mailto:foia.appeals@dc.gov>. Further, a copy of all appeal materials must be forwarded to the Freedom of Information Officer of the involved agency, or to the agency head of that agency, if there is no designated Freedom of Information Officer there. Failure to follow these administrative steps will result in delay in the processing and commencement of a response to your appeal to the Mayor.

Sincerely,

Bob Eckert

FOIA Specialist

Freedom of Information Act Office

Metropolitan Police Department

District of Columbia

Robert.eckert@dc.gov<mailto:Robert.eckert@dc.gov>

"Excellence is transferable."

This is an automated message from the DC Government FOIA system. Dear Peter Andringa, The status for your request is below. Please log into https://foia-dc.gov/palMain.aspx and go to Request Status. If you have any questions regarding the status of your request, please contact the agency's FOIA office that you had submitted your FOIA request to. You can communicate directly with the FOIA office by clicking on Inbox, search the request number, and then click Compose Message. OR, visit to see a list DC Government FOIA Office’s/officer’s contact information and have your Request ID ready. (https://dc.gov/node/818962) Contact FOIA Office Request status: Closed Request ID: 2024-FOIA-05868 Description: To Whom It May Concern:My name is Peter Andringa and I'm a reporter with the Financial Times.Pursuant to the DC Freedom of Information Act, I hereby request all records relating to relationships between Metropolitan Police Department and any of the following providers of vehicle data aggregators, which provide data products or services using information derived from internet-connected vehicles:1. Otonomo Inc (https://otonomo.io)2. Wejo (https://wejo.com)3. LexisNexis Risk Solutions (https://risk.lexisnexis.com/law-enforcement-and-public-safety)4. The Ulysses Group (https://theulyssesgroup.com/)For *each* of the above companies, I request any and all:A. Invoices, purchase orders, and/or contracts for use, training, or access to company products and servicesB. Training materials and/or internal policies relating to the use of company products or servicesC. Public safety and/or privacy reviews related to the company products or servicesD. Written correspondence and/or attachments sent by email between staff of Metropolitan Police Department and representatives of the company. (For the purposes of searching email records, you can query on the following sender or recipient domains: @otonomo.io, @wejo.com, @lexisnexis.com, or @theulyssesgroup.com)If it is helpful to narrow my request, you can focus the time window of your search for records from January 1, 2021 to the present day.The requested documents will be made available to the general public, and this request is not being made for commercial purposes.In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 15 business days, as the statute requires.Sincerely,Peter AndringaUpload documents directly: https://www.muckrock.com/ Regards,
DC Government FOIA Portal