GIDS Active Patients per Financial & Calendar Year, by each of 6 age bands

Reference: 25-26187

Date response sent: 06/08/2025

Details of enquiry

Three FOI requests submitted individually:

A. File Ref: 25-26187 GIDS Active Patients per Financial Year, by each of 6 age bands:

For each financial year in which you hold data, please provide the number of patients active in GIDS during that financial year whose age (in whole years, rounded down) on 31st March of that financial year fell into each of the following categories:

B. File Ref: 25-26193 GIDS Active Patients per Calendar Year, by each of 6 Age Band:

For each calendar year in which you hold data, please provide the number of patients active in GIDS during that calendar year whose age (in whole years, rounded down) on 31st December of that calendar year fell into each of the following categories:

Please provide these data separately for patients assigned male at birth and those assigned female at birth, and in combination regardless of sex assigned at birth. Please provide these data in a spreadsheet (CSV) file to make it easier to analyse them.

C. File Ref: 25-26194 GIDS Waiting Times to First Appointment – all years held

Please provide the following information regarding the waiting times of patients referred to the Gender Identity Development Service (GIDS):

For each calendar year in which data are held, please provide the following statistics on the number of days referred patients were on the GIDS waiting list before having their first GIDS appointment (of those patients who received their first appointment in that calendar year):

Mean
Mode
Standard deviation
Skewness (per the SKEW function in Excel)
Kurtosis (per the KURT function in Excel)
Minimum
Maximum
First quartile (Q1)
Median
Third quartile (Q3)
Interquartile range (IQR)

Response sent

Your most recent three requests for information, received 23rd July 2025, and 29th July 2025 as set out above, have been handled under the Freedom of Information Act 2000. They have been logged as

25-26187 GIDS Active Patients per Financial Year, by each of 6 age bands

25-26193 GIDS Active Patients per Calendar Year, by each of 6 age bands

25-26194 GIDS Waiting Times to First Appointment – all years held

We have aggregated these requests, as permitted under the Freedom of Information and Data Protection (Appropriate Limit and Fees) Regulations 2004 section 5(2) as they meet the regulatory conditions for doing so:

They were received by the Trust four working days apart. The Trust has already answered another request you submitted on 22/07/25 – also about former GIDS patients statistics. The Trust notes that:

two of these requests, logged by us as 25-26187 and 25-26193 relate to the same subject matter, differing only in count of years by financial and by calendar years respectively.
the third request logged by us as 25-26194 relates to the same subject matter as a previous request answered on 14/01/25 (logged as 24-25407) differing only in count of years by financial and by calendar years respectively
you wrote to us, separately, on 23/07/25 highlighting discrepancies in our response of 14/01/25 to request 24-25407. This is currently receiving our separate attention, we will write to you about this in due course

Please refer to appendix 1 at the end of this response which lists and cross-references your requests and to which this refers.

Over the past six months you have submitted 18 requests for annual statistics on former GIDS patients for all years in which data is held – (a period of 22 years) from 2001 to 2023 which included, to date, 9 responses to be reworked, from the originally requested financial years into calendar year data and/or vice versa

After careful consideration of the nature, volume, and frequency of your recent requests the Trust has engaged exemptions under the Freedom of Information Act 2000 (FOIA) to withhold the data requested in your above-listed three latest requests, as follows:

Section 12(1) and Section 12(4)(a) of FOIA the cost of compliance exceeds the appropriate limit
Section 14(1) and Section 14(2) of FOIA – Vexatiousness, and burdensome on the Trust

Explanation of the Exemptions Engaged.

Section 12(4)(a) of FOIA applies if two or more requests are made to a public authority within a short space of time, on a narrow subject range by one person, or several persons who appear to be acting together or as part of a campaign/project, the estimated cost of complying with any of the requests is to be taken to be the estimated total cost of complying with all of them.

These limits are calculated based on the estimated cost of locating, retrieving, and extracting information. Your series of 8 requests since 24/06/24 fall into this category.

Section 12(1) of FOIA provides for refusal of requests for information where the cost of dealing with them would exceed the appropriate limit of 18 hours of officer time, ie £450, equivalent to 18 hours at a generic £25 per hour of officer time. The per hour figure is set by Regulations (The Freedom of Information and Data Protection (Appropriate Limit and Fees) Regulations 2004, specifically Regulation 4, rather than actual salary paid to any officers handling requests.

This means that under the terms of Section 12 of FOIA, the Trust is not obliged to comply with your latest three requests which are all on a narrow subject range and requiring more than an accumulative 18 hours of officer time, as described in the above paragraph, whether submitted as a single request or as multiple requests and within a 60 day period of each other.

It has already been the case that the cumulative cost of complying and responding to the five requests submitted between 26/06/25 and 22/07/25 exceeded the appropriate limit of 18 hours by more than double, and whilst the Trust was not obliged to do so, it complied with them all, to satisfy your requests at no charge to yourself.

At that time the thinking was that two of the five requests would be satisfied by providing a link to the data where previously provided (as permitted under FOIA under exemption 21 – requested data is accessible by other means). This proved not to be the case, as you subsequently pointed out that these links related to financial year data you requested in December 2024 but now required by calendar year over the 22 years instead. Accordingly, the Trust has spent additional time and resources to provide new data for these two requests, having originally responded and closed them in June 2025.

At the time, the Trust did not expect further requests to be submitted in regards to the frequency and duplicity of narrow range of subject matter, and did not advise you that you were approaching a threshold where the Trust might engage exemption from disclosure on the grounds of the high volume of complex requests submitted over a very short period.

Section 14(1) of FOIA – Vexatiousness. (this is a regulatory term related directly to requests submitted, and does not in any way constitute a personal adjective attributed to applicants)

This is one occasion under FOIA when public authorities are permitted to take into account the applicant’s requests history and their motive for requesting information. In doing so the Trust considered issues of proportionality.

Section 14(1) permits the Trust to refuse requests where responding would impose a cumulative burden in terms of officer time and resources, caused by the applicant’s pattern of frequent requests on a narrow range of subject matter, even if individual requests might appear reasonable in isolation.

In assessing whether your series of requests is vexatious, we have taken into account guidance from the Information Commissioner’s Office (ICO), including the factors that public authorities should consider, which include:

The burden on staff and disruption to service caused by the volume and frequency of the requests. We have estimated that the officer time required to fulfil just these three requests would amount to around 21 hours
The cumulative nature and overlapping scope of the requests,
The disproportionate effort required to process them, which has often exceeded the 18 hours resources provisioned under the Freedom of Information Act 2000. These three new requests, in quick succession, continue to exceed this threshold and are a disproportionate use of the Freedom of Information Act 2000.

It is for the reasons stated above that data requested in this latest series of three requests is being withheld on the grounds of vexatiousness, and exemption from disclosure under section 14(1).

Section 14(2) of FOIA Whenever the Trust has supplied data in response to a request under the Freedom of Information Act 2000, , it is not obliged to comply with a subsequent identical or substantially similar request from that person or group of persons working together unless a reasonable interval has elapsed between date of response provided and making a subsequent request.

The GIDS service closed at the end of March 2024, its data can be considered to be static and not to have changed since its closure. Therefore data supplied in January 2025 can be considered to be unchanged in July 2025. Nevertheless, the finite detail and frequently requested cross comparisons between financial years and calendar years, ages and genders suggests the conducting of an in-depth analysis which resources under the Freedom of Information Act 2000 cannot support in terms of the volume of requests and volume of data being requested by you under the Freedom of Information Act 2000..

Section 14 of FOIA places limits on multiple requests on a narrow/limited range of subject matter within a reasonable period, such as 60 days.

While we respect your right to request information under FOIA, the frequency and repetitiveness of your recent submissions indicate that they have reached a level that is unreasonable and require resources adversely affecting the efficient operation of this Trust.

The Public Interest Test

We have carried out a public interest test (PIT) prior to engaging exemption under section 14(1) of FOIA – Vexatiousness

Arguments in favour of releasing further data

The Trust recognises the high public interest in gender services, and that whilst reports on GIDS are in the public domain, there is appetite from the public to gain more detail at a granular level.
For transparency and greater public awareness of GIDS matters by disclosure of detailed statistics on the (now closed) GIDS service.
To facilitate comparison to other published data, through the provision of various detailed statistics covering a 22 year period.

Arguments in favour of withholding further data

To prevent disruption to other work in the Trust when resources required to fulfil requests exceed the appropriate limit.
Submission of multiple requests on a common and narrow range of subject matter within a 60 day period from one or more applicants working together is considered as grounds for vexatiousness and exemption under section 14(1) of the Freedom of Information Act 2000. (Please note that vexatiousness is a regulatory term under the Freedom of Information Act 2000 and is not an adjective related in any way to an individual), and is thereby exempt from disclosure
Whilst the Trust continues to meet its regulatory obligations under the Freedom of Information Act 2000, it can no longer afford, as it has done in the past, to voluntarily exceed the appropriate limit of resources provisioned under the Act in order to fulfil frequent and/or voluminous requests – such as your three request which are defined by their common and narrow range of subject matter– irrespective of how legitimate the subject matter or valid the intentions of the requester. For this reason alone the Trust will no longer process requests which are estimated to take longer than the ‘appropriate limit’.

Balance of Public Interest

The argument to withhold the requested data, on the grounds of FOIA section 14 Vexatiousness, outweighs the argument for providing the data, and so the balance of argument rests in withholding the Trusts responses to these three requests.

In Conclusion, the Trust has aggregated and refused these three requests and has engaged exemptions under Section 12 of FOIA – The cost of compliance exceeds the appropriate limit and Section 14 of FOIA – Vexatiousness.

This decision does not prevent you from submitting future requests, which we will consider on their individual merits. However, if the current pattern of overlapping and resource-intensive requests on a narrow range of subject matter continues, future requests may also be refused under Section 14(1) of FOIA

We trust that you are satisfied with this response. If you are dissatisfied then please write to us at FOI@tavi-port.nhs.uk within 40 working days, quoting the reference details in the header of this email, and explaining the reason for your dissatisfaction. The Trust would then appoint a senior manager, not previously involved in these cases, to conduct an internal review of this response and advise you of their findings, within 20 working days, which would include either a revised response, or a rationale for upholding the original response.

Appendix 1

Item	Request Received Date	FOI Ref No	Case File Allocated Name	Date Response Submitted	Cross Ref Details
1	17/12/2024	24-25405	GIDS Referrals by Year and by SAAB By Financial Year.	14/01/2025	Same as Q1 only in: 24-25409 answered on 14/01/25 By Financial Year
2	17/12/2024	24-25406	GIDS Referral Ages Analysis – all years held By Financial Year	14/01/2025	Same as 25-26132 By Calendar Year Corrected response submitted on 30/07/25
3	17/12/2024	24-25407	GIDS Waiting Times to First Appointment – all years held By Financial Year	14/01/2025	Same as 25-26194 By Calendar Year Request in Process
4	17/12/2024	24-25408	GIDS Waiting List Size per Quarter – all years held By Fin Year Qtrs	14/01/2025
5	17/12/2024	24-25409	GIDS Referral & Discharge Numbers – all years held By Financial Year	14/01/2025	Q1 is same as 25-26131 By Calendar Year Corrected response submitted on 29/07/25
6	23/12/2024	24-25413	GIDS Puberty Blockers Prescribed, Taken, Not Taken By Financial Year	03/01/2025	Data not held
7	23/12/2024	24-25414	GIDS Patients Prescribed Puberty Blockers NHS & Privately, and not taking them By Financial Year	03/01/2025	Data not held
8	23/12/2024	24-25415	GIDS Patients treated by other NHS MH Services By Financial Year	14/01/2025	Data stats supplied related only to Patients both open and not open to other TPNHSFT services Answered on 14/01/25
9	23/12/2024	24-25416	GIDS Patients Socially Transioned by end of each year By Financial Year	08/01/2024	Refused s12, as data wd need to be manually extracted.
10	24/06/2025	25-26131/2	GIDS Referrals: All Years Held By Calendar Year	Corrected response submitted 29/07/25	Same data as 25-26409 By Financial Year Answered on 14/01/25
11	24/06/2025	25-26132/2	GIDS Referral Ages Analysis – all years held By Calendar Year	Corrected response submitted 30/07/25	Same data as 25-26406 By Financial Year Answered on 14/01/25
12	24/06/2025	25-26133	GIDS Referrals: All Years Held, by Age Band Percentage By Calendar Year	21/07/2025
13	24/06/2025	25-26136	GIDS Referrals to Endo for PB Assessment, All Years Held	18/07/2025	Request aggregated with 25-26137 and refused S12 (can’t collate electronically)
14	24/06/2025	25-26137	GIDS Referrals to Endo for Cross Sex hormone Assessment, All Years Held	18/07/2025	Request aggregated with 25-26136 and refused S12 (can’t collate data electronically
15	22/07/2025	25-26186	GIDS Referrals to Endocrinology Clinics	25/07/25	Follows refusal to 25-26136 and 25-26137
16	23/07/2025	25-26187	GIDS Active Patients per Financial Year, by each of 6 age bands		Same as 25-26193 Calendar Years Request Rec’d 29/07/25
17	29/07/25	25-26193	GIDS Active Patients per Calendar Year, by each of 6 age bands		Same as 25-26187 By Financial Year Request Rec’d 23/07/25
18	29/7/25	25-26194	GIDS Waiting Times to 1^st Appointment, All Years Held Calendar Year		Same data as 24-25407 By Financial Year Answered on 14/01/25