Dear Senior Coroner Griffin, I write on behalf of the National Police Chiefs Council (NPCC) in relation to paragraph 7, Schedule 5 of the Coroners and Justice Act 2009, and regulations 28 and 29 of the Coroners (Investigations) Regulations 2013, in relation to the prevention of future deaths report sent via email to the NPCC dated 30th March 2026. The notice sets out concerns that arose from the information received during the inquest into the death of Oliver Roberts. I am very sorry to read of the circumstances of Oliver’s death. My sympathies are with his family and friends. I understand that the matters of concern raised are as follows:
1. There is a perceived lack of practical guidance to support police officers in the application of their powers to obtain communications data, whether under Grade 1, 2 or 3 requests.
2. Communications data is obtained pursuant to the Investigatory Powers Act 2016 (IPA). The Home Office issued the Communications Data Codes of Practice in November 2018, a comprehensive document of approximately 144 pages addressing the exercise of functions under Parts 3 and 4 of the Act.
3. Requests for communications data are submitted by operational officers to Communications Data Investigation Teams, with processes varying depending on the grading of the request.
4. Grade 1, 2 and 3 requests are defined within the Codes of Practice, with Grade 1 relating to an immediate threat to life, Grade 2 to exceptionally urgent matters (including serious concern for the welfare of a vulnerable person), and Grade 3 relating to non-urgent but time-critical issues.
5. While sections 5 and 6 of the Codes of Practice address the application and authorisation processes, there is concern that more practical guidance—similar to Authorised Professional Practice—does not exist to support officers in decision-making.
6. In this case, a Grade 2 application was submitted almost 24 hours after Oliver was reported missing, following which he was located within just over two hours. Evidence was heard that urgent Grade 2 requests may be made verbally, yet there is no clear national guidance setting out when verbal or written applications should be used.
7. The Court is concerned that, without clearer guidance, similar circumstances could arise again. In providing a response to these matters of concern, various portfolios within the NPCC have been consulted. While Oliver was reported as a missing person, the concerns identified relate more broadly to the use of communications data where there is serious concern for the welfare of a vulnerable person. This applies regardless of whether the individual has been formally reported missing. From the perspective of the NPCC Missing People Working Group, operational guidance already directs investigating officers to seek advice from their Communications Data Investigators or Single

Points of Contact (SPoCs). These specialists are trained experts in the Investigatory Powers Act 2016 and are best placed to advise whether a Grade 1 or Grade 2 application is appropriate. I am not aware of any national guidance that prescribes when an operational officer must submit a communications data request. Decisions regarding grading, urgency, and whether a request should be made verbally or in writing properly sit with communications data SPoCs. In making those decisions, SPoCs are expected to undertake a risk assessment, apply the statutory thresholds, and fully document their decisions and actions. The Communication Data Codes of Practice clearly describe the grading structure, as well as the circumstances in which urgent oral authorisation may be appropriate. SPoCs are expected to consider all relevant factors set out within the Codes when determining how best to proceed. It is also relevant to note that force capabilities vary. For example, West Yorkshire Police operate a 24/7 Communications Data Investigation Unit with an on-duty SPoC at all times, accessible to operational staff. Other forces may still operate on an on-call basis, which can affect local processes but does not alter national legal thresholds. Due to the difference in processes across force areas, each force remains responsible for ensuring that suitable risk-based training is provided for staff. This would be especially true for officers at the rank of Sergeant or Inspector, who would normally undertake a risk assessment and set relevant investigative actions – including the consideration to request communications data. In providing this response, we have worked closely with the College of Policing, who lead in areas such as setting national policing standards, including the provision of Authorised Professional Practice (APP). I will not seek to repeat the information that they have provided to you, other than to support their comments around the training and national guidance that already exists and is readily available to officers and staff. I welcome their ongoing process of developing further training specifically for the communications data SPoC community, focused on fast-time decision-making. I am also reassured that the College are in the process of reviewing the Missing Persons Authorised Professional Practice and whether it can be further strengthened. The NPCC remains committed to supporting Forces and other stakeholders to continually improve the wider policing response with respect to investigations where communications data is pertinent. I hope that this response provides reassurance and addresses the concerns raised by the Court. Please do not hesitate to contact me should you require any further information or clarification.

Dear HM Coroner Griffin,

Thank you for your report into the tragic death of Mr Oliver John Roberts and I acknowledge the concerns that you have outlined in section 5 and our duty to respond.

While you kindly outline the circumstances of Mr Roberts’ passing within your report, I thought it may be helpful to contextualise the below response with a succinct chronological narrative. As I understand it, Mr Roberts was reported missing on 27th January 2024 at 13:48. The Force Incident Manager classified this report as ‘medium risk,’ at 16:00 on that same date. The last time that Mr Roberts was known to be alive was provided as 19:39. At 23:05 on that same date, the missing report was upgraded to ‘high risk.’ At 12:32 on 28th January 2024, a Grade 2 application was sent to the CDI Team. Tragically, Mr Roberts was found deceased at 14:40. I have provided a reply under each point that you have referenced as matters of concern.

Matters of Concern

1. There is a lack of guidance to assist Police Officers in the practical application of their powers to obtain communications data, whether that be under a Grade 1, 2 or 3 application.

There is eLearning training that is available for investigators on our national ‘College Learn,’ platform. These learning packages “Introduction to Communications Data,” sit within the Digital Media Investigators (DMI) modules. Within this training there is emphasis on Grade 1’s requiring an ‘immediate threat to life, and Grade 2’s requiring …” a serious concern for the welfare of a vulnerable person where urgent provision of the communications data will have an immediate and positive impact on the investigation or operations.” This training is available for all police officers and staff across England and Wales. (Please also see my response to point five, for additional available training).

2. Communications data can be obtained by Police forces in England and Wales pursuant to the Investigatory Powers Act 2016 (the Act). In November 2018 the Home Office issued the Communication Data Codes of Practice (the Codes of Practice) which is a document that extends to 144 pages and relates to the exercise of functions conferred by virtue of Parts 3 & 4 of the Act.

Although I recognise that the June 2025 Home Office Communications Data Code of Practice publication postdates Mr Roberts’ passing, I would hope that you are also reassured by section
5.47, which outlines the circumstances in which an urgent authorisation may be appropriate, reading, “an immediate threat of loss or serious harm to human life - this may include those situations where, for example, there is serious concern for the welfare of a vulnerable person including children at imminent risk of being abused or otherwise harmed.”

3. Requests are submitted by police representatives to their Communication Data Investigation Teams to access data, and this will be done in different ways depending on the grading of the request.

All communications data (CD) applications are requested by an applicant using the force workflow system. The UK has three workflow platforms, ‘Charter,’ ‘Cycomms,’ and ‘Optica.’ The authorisation body, which is the Investigatory Powers Commissioners’ Office- Authorisations (IPCO-A) has access to each of these systems to review and authorise individual applications and all can facilitate urgent oral applications.

4. Grade 1 requests are made when there is an immediate risk to life. Grade 2 requests are made when there is an exceptionally urgent requirement for the prevention or detection of serious crime; a credible and immediate threat to national security; or a serious concern for the welfare of a vulnerable person where urgent provision of the communications data will have an immediate and positive impact on the investigation or operation. Grade 3 requests are made when matters that are not urgent but, where appropriate, will include specific or time- critical issues such as bail dates; court dates; where persons are in custody; or where there is a specific line of investigation into a serious crime and early disclosure by the telecommunications operator or postal operator will directly assist in the prevention or detection of that crime.

Acknowledging the grading criteria, and the available training (referenced in my response to point 1 and 5 below), we are also in the process of developing further training for the ‘CD Single Point of Contact (SPoC) community; particularly with the development of a Hydra (immersive learning) exercise around fast-time decision making in this space. We anticipate that this will be piloted in Summer 2026.

5. Section 5 of Codes of Practice refers to the application process and Section 6 deals with the authorisation of the application, however there is no practical guidance, such as Authorised Professional Practice Guidance, to assist Forces and their officers, as to how and when applications should be made and authorisations should be given.

In addition to the referenced College training, in collaboration with the National Action Fraud Network, IPCO-A, HMRS and Home Office, we have produced a further training product, “Standardising Communications Data Applications,” which is available on the NCDS website. Some organisations have taken the decision to mandate this training for staff.

6. In this case a Grade 2 application was submitted almost 24 hours after Ollie was reported missing. Once submitted, Ollie was found within 2 hours and 9 minutes. This application was submitted in writing, however evidence was given that in some circumstances a verbal application for a Grade 2 request can be made if the Grade 2 application is urgent. There is a lack of guidance to police officers nationally as to what would constitute a Grade 2 urgent application and what should be done in writing and what should be done verbally.

The training for communications data specialists provides guidance for what constitutes the specific purposes for communications data, and the priority grading for the disclosure of the data by telecommunications operators. The training also details how quickly the IPCO-A can consider a written application regarding its authorisation. Grade 2 authorisations can be approved by IPCO at short notice during 08:00 – 22:00hrs daily. A Grade 2 application would not be processed outside of these times, so the grading could have had an impact if requested outside of their working hours. There is no guidance as to precisely when an application must be written (most are), but the communications data SPoC will act as a guardian and date keeper for applications, and for Authorising Individuals to authorise or otherwise.

7. I am concerned that the circumstances of Ollie’s death could occur again as a result of the lack of practical guidance to Police Forces and their staff as to when and how to make data communication requests pursuant to the Investigatory Powers Act
2016.

While I am not privy to any further detail of the investigation, (and cede to any new information that could cast light on the following) the concern here may be around the initial risk assessment and speed of application submission, rather than the grading or guidance. According to the IPCO Service Level Agreement, Priority two data, has a six-hour turnaround, for example.

I have tasked my team with examining where the Missing Persons Authorised Professional Practice could be further strengthened in this area to provide greater clarity and direction around communications data and tracking, during the current review process.

Finally, I wanted to extend my condolences to Mr Roberts family and friends and reassure you that we will continue to review where and how we can strengthen training and guidance to ensure that policing is better equipped to help vulnerable people in their times of need.