Dear Transport for London, I would like to request the following information, please: 1.) The activities of all RTEOs as shown on Crown on the following days: 23rd April, 23rd May, 23rd June, 23rd July and 23rd August 2019. This report should show all the activities of staff, including patrols, breaks, etc. and the exact time of these activities. For anonymity, I am happy if you assign numbers to the individuals (e.g. RTEO1, RTEO2, etc.). 2.) The number of emails sent by RTEO team leaders (including acting team leaders on development opportunity) on the aforementioned days. If possible, please also include the time when the emails were sent. For anonymity, I am happy if you assign numbers to the individuals (e.g. TL1, TL2, etc.). If processing my request would exceed the appropriate cost limit, please only provide data for as many dates as possible.

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TfL Ref: FOI-1589-1920

Thank you for your email received by Transport for London (TfL) on 24 August 2019.

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. You asked:

1.) The activities of all RTEOs as shown on Crown on the following days: 23rd April, 23rd May, 23rd June, 23rd July and 23rd August 2019. This report should show all the activities of staff, including patrols, breaks, etc. and the exact time of these activities.

For anonymity, I am happy if you assign numbers to the individuals (e.g. RTEO1, RTEO2, etc.).

2.) The number of emails sent by RTEO team leaders (including acting team leaders on development opportunity) on the aforementioned days. If possible, please also include the time when the emails were sent.

For anonymity, I am happy if you assign numbers to the individuals (e.g. TL1, TL2, etc.).

However, we are refusing your request under section 14(1) of the Act. This is because we consider that providing the requested information, particularly to your second question, would be significantly burdensome with limited public interest in its disclosure.  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 provides the following examples of a request which may fall under section 14(1):

- 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 the first and second of these examples apply in this instance.

We have located 67 emails sent by the Roads and Transport Enforcement Officers (RTEOs) concerned on just one of the days you have listed. Therefore, we estimate that to do this over 5 days would result in approximately 335 emails that we would need to manually type out in a list form to provide the times it was sent against each individual. There is going to be duplication so we would need to read the content of the emails to determine whether it is a unique email which needs recording or a duplicate one which can be disregarded. To further provide the activities of the RTEOs concerned, would create additional work to an already significant task. The crown reports contain personal data and therefore we would have to review them all and redact anything that could be used to identify an individual officer. Whilst this process of considering and applying redactions does not feature as part of our considerations on whether the the ‘appropriate cost limit’ of £450 set by the Freedom of Information (Appropriate Limit and Fees Regulations 2004) might apply, the burden created by this further activity isn’t insignificant.

We also believe that 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. Whilst we recognise the requested information will be of interest to you, we do not consider that the wider public interest is served by the diversion of resources that would be necessary to answer your request.

If you would like to revise and re-submit your request then we will, of course, consider it.

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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