Dear TfL: Please consider my freedom of information request as follows: • Please forward to me copies of all emails sent to TfL from any email address with the extension of "....IWGB.co.uk" where the names of either XXXX or XXXX or the organisation name of 'United Private Hire Drivers' or 'UPHD' is mentioned in the content or title portions of the email. You may restrict the scope of my request to the period from January 15, 2020 to the current date. You may also restrict your search to email traffic to the TfL Taxi and Private Hire directorate and the office of the Commissioner. You should include but must not limit the search to traffic to or from email accounts including : • Dan Maskell • Helen Chapman • Graham Robinson • TPHLicensing • TPHEnquiries • any other taxi and private hire trade communications and stakeholder engagement channels.or personnel

---

Our ref: FOI-0325-2021/GH

Thank you for your request received by Transport for London (TfL) on 2 June 2020 asking for copies of emails.

Your request for emails sent to TfL from any email address with the extension of "....IWGB.co.uk" where your name is mentioned is being handled as a Subject Access Request, and separate to this FOI request.

The remainder of your request has been considered under the requirements of the Freedom of Information Act 2000 and our information access policy.

I can confirm that we do hold the information you require. However, we are refusing your request under section 14(1) of the Act. Our email search facility does not determine searches by department and so we cannot run a remote search on the TfL Taxi and Private Hire directorate and the office of the Commissioner as requested.

We have therefore run a search for relevant emails, which identified almost 400 emails. Each of these would need to be manually reviewed to ascertain if they are relevant to your request, and then any personal information redacted, which would place an unreasonable burden on us. From a brief review of these emails, it was apparent that most, if not all, were likely to have been caught by the search because “UPHD” featured in the email signature of one or more individuals within the email chain, rather than because it featured as the subject or content of the email. Further, many of the emails appeared to be of a regulatory nature regarding individual licensing matters and so it is clear that a significant amount of time would be needed to review all of the emails and then consider whether one or more exemptions might apply.

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.

By their nature, emails contain a significant amount of personal data such as phone numbers and email addresses and so, whilst this process of redaction does not feature as part of our considerations on whether the cost limit might apply, the burden created by non-specific requests for emails is significant and this should be borne in mind before submitting requests of this nature.

Additionally, the Information Commissioner describes requests which ask for ‘all emails’ as “fishing expeditions” as the requesters “have no idea what information, if any, will be caught by the request”. Such requests are likely to be vexatious if they:

• Impose a burden by obliging the authority to sift through a substantial volume of information to isolate and extract the relevant details;
• Encompass information which is only of limited value because of the wide scope of the request;
• Create a burden by requiring the authority to spend a considerable amount of time considering any exemptions and redactions;
• Be part of a pattern of persistent fishing expeditions by the same requester.

We therefore strongly recommend that if you wish to submit a revised request that you outline, as clearly and concisely as possible, precisely the information you require. Requests that lack a clear focus are more likely to lead to concerns about the processing time required to meet our obligations under the FOI Act.

Please note, the Government has announced a series of measures to tackle the coronavirus. It is essential for London, that we continue to provide a safe transport network for essential journeys.

In current circumstances, we are not able to answer FOI requests readily and we ask that you please do not make a request to us at present.

Answering FOI 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

Graham Hurt

FOI Case Officer

FOI Case Management Team

General Counsel

Transport for London

Back to top

---