FOI request detail

Road User Charging

Request ID: FOI-0650-2223
Date published: 07 July 2022

You asked

1. Is Road user Charging part of TFL group of companies? 2. Is Road User Charging an agent of TFL? 3. If Road User Charging are an agent of TFL do they comply with the data protection act 2018 regarding the exchanging of personal data. 4. If Road user Charging are apart of TFL do they obtain personal data contrary to the data protection act 2018 from the DVLA group of companies. 5. Do the DVLA Group of companies supply personal data for a fee to TFL group of companies? 6.I require full company incorporated details of TFL. 7. Is the Mayor of London the head-CEO of TFL? 8. I requires full incorporation detailed the corporation headed by the Mayor of London. 9. Does TFL abide by the fraud act 2006? 10. Does TFL abide by the companies act and all updates? 11. Do TFL and their agent comply with Section 1 Forgery Act 1981? 12. Are TFL aware of the Clearfield Doctrine? 13. Are TFL aware that all previous correspondence received is in direct violation of the Universal Postal Union Convention 1929, under Article 9 Violations? 14. Are TFL aware that all contracting parties must provide their name doing business as, who they work for and their job title, which you have failed to do previously. 15. Are TFL aware that Contracting parties based in Darlington must also have a mailing location; a PO Box address being a non-contracting venue as it is not landbound to anything. This evidences further acts of committing fraud under Sections 2 (1) False Representation and Section 11, obtaining services dishonestly, of the Fraud Act 2006. 16. Are TFL aware that and accused man-women has the right to question their accuser prior to a fine being imposed and only a court of one’s pipes can impose such a fine? 17.Can TFL prove an obligation that a Traveller is subject to a charge levied by an authority-corporation? 18. Are TFL aware of Uttering which is a crime involving a person with the intent to defraud that knowingly sells, publishes, or passes a forged or counterfeited document. More specifically, forgery creates a falsified document and uttering is the act of knowingly passing on or using the forged document? 19. Are TFL of the law of con-tract law and commerce? 20. I require you to provide TFL’s jurisdiction and authority together with details as how this was received? 21. I require full details of all members within TFL who are under oath? 22. Are TFL aware and do they include within their company policy that Man gave authority to those that serve? Put simply; man created corporations and the ‘created’ can never be greater than its ‘creator’. In the same way that we are not greater than our creator. Man-kind is the authority, over all ‘Persons’. 23. Are TFL-The Mayor of London aware that Councils have ‘delegated’ authority; who delegated authority to them? (We did; ergo, who is the authority? - We are! ) ? 24.Do TFL together with their agent comply with the Bill of Exchange Act 1882? 25. Do TFL together with their agents comply with regulation 13 paragraph 5 of the VAT regulations 1995?

We answered

Our Ref:         FOI-0650-2223

Thank you for your request received on 13 June 2022 asking for information Transport for London (TfL).

Your request have been considered in accordance with the requirements of the Freedom of Information Act and our information access policy. I can confirm that we hold the information you require.

Your request is being refused under section 14(1) of the Freedom of Information Act, which provides an exemption to the disclosure of information where a request is considered to be ‘vexatious’. In reaching this conclusion we have drawn on guidance from the Information Commissioner’s Office (ICO), both in relation to the specific application of section 14 and in relation to FOI-handling more generally.

On the specific application of section 14(1) we have been steered by the ICO guidance on the use of that exemption that can be found on its website here:

You will note that this guidance includes the following advice to public authorities:

“Section 14(1) may be used in a variety of circumstances where a request, or its impact on a public authority, cannot be justified. Whilst public authorities should think carefully before refusing a request as vexatious they should not regard section 14(1) as something which is only to be applied in the most extreme circumstances”;

“Sometimes a request may be so patently unreasonable or objectionable that it will obviously be vexatious….In cases where the issue is not clear-cut, the key question to ask is whether the request is likely to cause a disproportionate or unjustified level of disruption, irritation or distress…This will usually be a matter of objectively judging the evidence of the impact on the authority and weighing this against any evidence about the purpose and value of the request”;

“The public authority may take into account the context and history of the request, where this is relevant”;

“The information Commissioner recognises that dealing with unreasonable requests can place a strain on resources and get in the way of delivering mainstream services or answering legitimate requests.”

“Section 14(1) is designed to protect public authorities by allowing them to refuse any request which have the potential to cause a disproportionate or unjustified level of disruption, irritation or distress”.

“…the concepts of ‘proportionality’ and ‘justification’ are central to any consideration of whether a request is vexatious”;

The guidance includes some specific indicators to help public authorities judge whether or not a case should be considered vexatious. This includes the following:

“Burden on the authority: the effort required to meet the request will be so grossly oppressive in terms of the strain on time and resources, that the authority cannot reasonably be expected to comply, no matter how legitimate the subject matter or valid the intentions of the requester”;

“Frequent or overlapping requests: the requester submits frequent correspondence about the same issue or sends in new requests before the public authority has had an opportunity to address their earlier enquiries”.

“Disproportionate effort: the matter being pursued by the requester is relatively trivial and the authority would have to extend a disproportionate amount of resources in order to meet the request.”

The guidance from the ICO makes it clear that public authorities should take into account the ‘context and history’ in which a request is made, and that this will “…often be a major factor in determining whether the request is vexatious”. This part of the guidance goes on to say that:

“In practice this means taking account of:

-           Other requests made by the requester to that public authority (whether complied or refused).
-           The number and subject matter of those requests”, and;

“A request which would not normally be regarded as vexatious in isolation may assume that quality once considered in context. An example of this would be where an individual is placing a significant strain on an authority’s resources by submitting a long and frequent series of requests, and the most recent request, although not obviously vexatious in itself, is contributing to that aggregated burden”.

Given the wide-ranging and unfocused nature of your request we believe the threshold for applying section 14(1) has been met. Requests such as this create a burden and disruption to our colleagues across the organisation whose principal function is the running of transport services or the support services required to make that happen. We do not believe that there is a wider public interest for the information you have requested. Our website contains a large amount of information on TfL and how it is governed, including our corporate social responsibilities and the legislative framework under which we operate:

In addition, the purpose and value of your request is not necessarily obvious, which brings into question whether it is a justified and proportionate use of our time to comply.

Please be assured that our application of the section 14 exemption does not reflect a conclusion that it has been your deliberate intention to place an undue burden on TfL, and we will consider any future request for information on its merits and in accordance with the requirements of the FOI Act and the expectations of the ICO. However, in making any future request 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:

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’”, and;
Don’t…”Deliberately ‘fish’ for information by submitting very broad or random requests in the hope it will catch something noteworthy or otherwise useful.”

We would therefore encourage you to prioritise any future requests around the information that is of most importance to you to ensure that you are able to make the best use of our resources under the FOI Act.

If you want to make a FOI Act request in future, please bear in mind that the FOI Act allows you to request recorded information held by us. You should identify the information that you want as clearly and concisely as you can.

Although your request can take the form of a question, rather than a request for specific documents, we do not have to answer your question if it would require the creation of new information or the provision of a judgement, explanation, advice or opinion that was not already recorded at the time of your request.

Please see the attached information sheet for details of your right to appeal.

Yours sincerely

Gemma Jacob
Senior FOI Case Officer
FOI Case Management Team
General Counsel
Transport for London

[email protected]

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