Request ID: FOI-1172-2122 Date published: 28 September 2021
You asked
tiDear Transport for London,
Please furnish the following:
All up to date training materials that a Revenue Inspector (both uniform and plain clothes staff) would attend to qualify. Not limited to training on the law, personal safety, tactical communication, tickets and the conducting of an interview under PACE, including completion of statements. This list of training is not exhaustive, if there is any modules missed, these are to be included.
In relation to exempons, there should be none as there would be no publication of personal information or any disclosure that if faced in the same situation the police would not exempt under law enforcement.
This request is for all the training materials used on the courses that is described in that presentation. For the avoidance of doubt, it includes, but is not limited to:
- presentations and PowerPoint slides
- handbooks used on the course
- law books
- course handouts and reference materials
- exercises
- asessment materials
We answered
Our ref: FOI-1172-2122/GH
Thank you for your request received by Transport for London (TfL) on 30 August 2021 asking for revenue staff training materials.
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.
We have not trained any new London Underground Revenue Control Inspectors (RCIs) since 2011. The training material held is therefore out of date and as there is not a view to recruit new RCIs in the future, we currently have no plans to update this material.
RCI’s have a RCI Local CDP day. This is a locally delivered course by our in house trainer trainers given to all staff on a 2 yearly cycle, to upskill/refresh staff within their substantive role that they are fully trained to do. It reaffirms the best practices and refreshes the knowledge to enable a consistent approach. The course content is:
Demonstrate the skills knowledge and behaviour needed to carry out thorough investigations.
Describe the tools and techniques available to manage challenging behaviours.
List current laws relating to RCI role.
Explain the protocols for effective report writing.
EIRF refresher & How to guide.
Demonstrate the skills and knowledge to secure and record good evidence.
Describe the behaviours and protocols for court attendance.
Legislation overview Refresh on all byelaws and Quiz re byelaws.
Points to aid a successful prosecution.
PACE, Investigation (Interviewing) and note taking protocols. Evidence continuity.
EIRF – Electronic Incident Report Form PACE – Police and Criminal Evidence Mercury – Forms based Application software run on a Smartphone - used to issue Penalty Fares, report ticket checking and officer duty activities/duties and submit irregularity reports to TfL for Enforcement action CPC – Contactless Payment Card PFN – Penalty Fare Notice GLA – Greater London Authority Act ITAP – Intelligent Ticketing Analyst Programme TOC – Train Operating Company RID – Revenue Inspection Device Bus Revenue Protection Inspectors attend the Public Transport Operations Officer (RPI) course, the content is shown below:
PT Course Content
Provisions of bus services
Working practices
Irregularity procedures
Ticket & Passes used
Passenger & staff irregularities
Passenger questioning techniques when dealing with an irregularity
RID – Revenue Inspecting Device
Phonetic Alphabet
Ital – Virtual credit payment – taking payment from customer
ETM- Electronic ticket machine
Code 5 – Lone worker device
Bus driver – Duty & Log cards
Security Brief – Corrosive Substances
Conflict Management – Theory and Physical Intervention
Wheel chair briefing – dealing with passenger alighting a bus with a wheelchair
Presuppositions
Health & Safety at a Bus Garage – Bus garage visit
Staff question techniques – dealing with staff reports revenue related and miscellaneous
Principles of staff report writing
TaTTs – Temporary Authority to travel
Counter Terrorism
Suicide Prevention
IAP – Enforcement and Penalty fare team
Diversion duties – Risk management
WVA Team – Workplace violence and aggression
Supervisory imposed suspensions and refusal of duty for staff
Garage disciplinary attendance
Safe Guarding and Hatecrime
Simulations – role plays for customer interaction
Hand outs
Polices
Suspect person & Packages procedure
Irregularities procedures booklet
Blue Book – working practices
Risk assessments
Revenue Protection Inspector enforcement powers work book
Staff report templates
Assessments
RID – Revenue inspection device
Staff report writing
Conflict management and physical intervention
Health & Safety
Irregularity procedures
Simulations – role play with an assigned actor/actress
You have requested “All up to date training materials that a Revenue Inspector (both uniform and plain clothes staff) would attend to qualify. Not limited to training on the law, personal safety, tactical communication, tickets and the conducting of an interview under PACE, including completion of statements. This list of training is not exhaustive, if there is any modules missed, these are to be included” and “all the training materials used on the courses that is described in that presentation. For the avoidance of doubt, it includes, but is not limited to: - presentations and PowerPoint slides - handbooks used on the course - law books - course handouts and reference materials - exercises - assessment materials"
However we are refusing your request under section 14(1) of the Act. The training documents you have requested run into the hundreds of pages, and we would need to collate all relevant information and then manually review everything identified within the scope of your request to assess whether disclosure is appropriate or whether redactions are required. This would place an unreasonable burden on us.
The purpose of the roles of London Underground Revenue Control Inspectors (RCIs) and Bus Revenue Protection Inspectors is to safeguard our fare revenue, and to deter and apprehend those who try to avoid paying fares. The training material contains information on activities and methods used, and this information could be used by those wishing to avoid fares, and so significant scrutiny would need to be given to the documentation to ascertain whether one or more exemptions might be applicable to prevent this. Whilst we make no suggestion that you would use this information for anything other than you own personal interest, disclosure of this information to you has to be regarded as a disclosure to ‘the public at large’. This information could potentially be obtained and utilised by individuals who may wish to use this information to avoid paying fares and could have a negative effect the ability of inspectors to carry out their duties.
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 Information Commissioner’s Office (ICO) guidance states that one of the indicators of a request which may fall under section 14(1) is that it “appears to be part of a completely random approach, lacks any clear focus, or seems to have been solely designed for the purpose of ‘fishing’ for information without any idea of what might be revealed.”
The ICO guidance provides the following examples of a ‘fishing expedition’ 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.
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