Correspondence
Request ID: FOI-1187-1718
Date published: 13 September 2017
You asked
Dear sir , madam
Could you please send me any correspondence between tfl and onfido limited between Jan 2016 and Jan 2017
Thank you in advance
We answered
TfL Ref: FOI-1187-1718
Thank you for your request received by Transport for London (TfL) on 16 August 2017 asking for information about correspondence.
Your request has been considered in accordance with the requirements of the Freedom of Information Act and our information access policy. I can confirm we do hold the information you require.
However, we are refusing your request under section 14(1) of the 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 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. We have found that there are in excess of 1000 emails that potentially meet the requirements of your requests. In order to process this, we would need to manually review each of these messages one by one. Given the unfocussed nature of your request, it is likely that it would be necessary to spend at least some time, and possibly a significant amount of time, considering exemptions which might be applicable to the information caught by the request, including in relation to personal data. This is likely to include redacting exempt information from emails in which there is very limited public interest but which are caught by your request because they are simply emails exchanged between TfL and Onfido. A review of the results has shown that the vast majority of these emails are likely to be in relation to building and facilities management of office space that is utilised by Onfido.
By its nature, we feel this wide ranging and non-specific request will very likely encompass information which is only of limited value. In that respect, it is relevant to our decision that your request is not for information on any specific subject or issue.
We consider the burden of retrieving, reviewing and redacting the information would be disproportionate to the benefit of providing it. Therefore, due to the wide and unfocused scope of your request, we are refusing it under s.14 of the FOI Act. If you would like to re-submit a more focused, specific request then we will, of course, consider it. For example, a request for information on a particular, specific, subject or issue contained in correspondence exchanged between named individuals over a limited period of time is less likely to raise concerns about the disproportionate effort required to answer it.
Please see the attached information sheet for details of your right to appeal.
Yours sincerely
Lee Hill
Senior FOI Case Officer
FOI Case Management Team
General Counsel
Transport for London
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