1. One set of the most recent London Underground T&R Books (Ticketing & Revenue), all eight series and updates, with redactions if necessary. 2. One set of the current Staff Guide to Fares & Tickets (All parts of TfL), all books and appenxdixes.

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TfL Ref: FOI-3936-1920

Thank you for your email received by Transport for London (TfL) on 2 April 2020, asking for eight London Underground Ticketing & Revenue books and Staff Guide to Fares & Ticketing.

Your request has been considered under the requirements of the Environmental Information Regulations and our information access policy. I can confirm that we do hold the information you require. You asked for:

1. One set of the most recent London Underground T&R Books (Ticketing & Revenue), all eight series and updates, with redactions if necessary.

2. One set of the current Staff Guide to Fares & Tickets (All parts of TfL), all books and appendixes.

However, in accordance with the FOI Act we are refusing your request under section 14(1) of the FOI Act. After reviewing a sample of our records we consider that providing the requested information would place an unreasonable burden on us. Our principal duty is to provide an effective transport service for London and we consider that answering this request would represent a disproportionate effort. It would be a significant distraction from our work managing the TfL network, requiring re-allocation of already limited resources and placing an unacceptable burden on a small number of personnel. We do wish to clarify that whilst we consider that your request falls under section 14(1) of the FOI Act, this does not reflect a conclusion that it has been your intention to deliberately place an undue burden on our resources.

The ICO guidance provides the following examples of a request which may fall under section 14(1) if it:

• Imposes a burden by obliging the authority to sift through a substantial volume of information to isolate and extract the relevant details;

   

• Encompasses information which is only of limited value because of the wide scope of the request;

   

• Creates a burden by requiring the authority to spend a considerable amount of time considering any exemptions and redactions.

Our view is that all three of these examples apply in this instance. Additionally, Paragraph 71 of the guidance on section 14(1) (https://ico.org.uk/media/for-organisations/documents/1198/dealing-with-vexatious-requests.pdf ) states the following:

71. However, we consider there to be a high threshold for refusing a request on such grounds. This means that an authority is most likely to have a viable case where:

· The requester has asked for a substantial volume of information AND

· The authority has real concerns about potentially exempt information, which it will be able to substantiate if asked to do so by the ICO AND

· Any potentially exempt information cannot easily be isolated because it is scattered throughout the requested material.

Having reviewed the information captured by your request, it became obvious most of the documents contain security sensitive information, covering security and cash processing arrangements. It would be necessary to spend a significant amount of time considering exemptions which might be applicable to the information caught by the request. Reviewing this information and considering the merits of exemptions across hundreds of pages would inevitably require the diversion of specialist resources.

Furthermore, the latest editions of the Ticketing and Revenue books are not completely up to date.  Amendments to these are published separately in a weekly Hot Issues Bulletins which indicate sections that have been amended, but not necessarily the full detail of the change. So we would have to review these for updates which would of course increase the processing time required to complete your request and impose a burden on our staff time and resources.

We believe that the wider purpose and value of your request is not necessarily obvious and does not hold any current transport-user value. This brings into question whether it is a justified and proportionate use of our time to comply. We consider the burden of retrieving, reviewing and redacting the information covered by your request would be disproportionate to the benefit of providing it. Therefore, we are refusing it under s14 of the FOI Act.

I would ask that you consider carefully what information is of most importance to you, and to take into account the guidance and advice provided by the ICO such as the “dos and don’ts” published on its website here: https://ico.org.uk/your-data-matters/official-information/

You will note that the table halfway down that page includes the following advice to FOI applicants:

Do….“Give the authority ample opportunity to address any previous requests you have made before submitting new ones”;

Don’t… “Submit frivolous or trivial requests; remember that processing any information request involves some cost to the public purse”;

Don’t… “Disrupt a public authority by the sheer volume of information requested. Whether you are acting alone or in concert with others, this is a clear misuse of the Act and an abuse of your ‘right to know’”,

Please note the Government has announced a series of measures to tackle the Coronavirus. It is essential for London, and in particular for all critical workers, that we continue to provide a safe transport network that enables them to make the journeys they need to. In current circumstances, we are not able to answer FOI and EIR requests readily and we ask that you please do not make a request to us at present.

Answering requests will require the use of limited resources and the attention of staff who could be supporting other essential activity. In any event, please note that our response time will be affected by the current situation.

If you are not satisfied with this response please see the attached information sheet for details of your right to appeal.

Yours sincerely

Eva Hextall

FOI Case Officer

FOI Case Management Team

General Counsel

Transport for London

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