FOI request detail

Wifi data

Request ID: FOI-1631-1819
Date published: 21 March 2019

You asked

• What is the budget of the TfL unit looking at wifi tracking? Please break this down per year since the introduction of the unit until the most recent date. • Please share any internal reports/ emails sent between the wifi tracking unit and the advertising unit since the introduction of the unit until the most recent date. • How much revenue has been made by TFL from passenger wifi data in the last five years (2014, 2015,2016,2017,2018 so far)? Please break this down by year and state how this revenue was generated. • Please can you provide any data protection assessment done since 2015 relating to WiFi tracking and also any prospective revenue analysis.

We answered

TfL Ref: FOI-1631-1819

Thank you for your email received on 16 September 2018. I apologise for the delay in replying to you.

Your request has 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. You asked:

What is the budget of the TfL unit looking at Wi-Fi tracking? Please break this down per year since the introduction of the unit until the most recent date.

TfL ran a four-week pilot between November and December 2016 to study how depersonalised Wi-Fi connection data from customers' mobile devices could be used to better understand how people navigate the London Underground network. We collected WiFi connection data from mobile devices using the station Wi-Fi at 54 Tube stations in central London. We did not use the data to identify individuals or monitor browsing activity. We tested whether this could be used to provide benefits in four areas:

Customer information: could Wi-Fi connection data help us provide better customer information for journey planning and avoiding congestion?

Operations and safety information: could understanding customer movements in stations help us deploy our people to best meet customer needs, and manage disruptions and events more effectively?

Transport planning: by better understanding how our customers use the Tube network, could we plan timetables, and our station designs and upgrades, more efficiently?

Prioritising investment: by measuring customer footfall and movements through and around stations, could we assess the effectiveness of our poster sites and retail units?

We published a report that explained our pilot and our findings in ‘Review of the TfL Wi-Fi Pilot’, which is available on this link: http://content.tfl.gov.uk/review-tfl-wifi-pilot.pdf. As noted on page 9 of the report, we delivered this pilot in-house at a cost of less than £100k.

As noted in our report on page 9, “In view of the clear benefits to us and our customers, we are now planning to formally roll out network-wide WiFi data collection, so we can better understand travel patterns, provide enhanced information for our customers, and improve our planning and operations.”

We are currently planning the requirements for a technical delivery for a roll-out of Wi-Fi data collection, and we do not yet have a proposed launch date for this activity. We have a project team that work on this alongside other projects as well and so we do not have a centralised unit that is solely and wholly responsible for this, as input is also provided by other subject matter experts from around the organisation. From the start of this project team’s work at the beginning of April 2018, TfL has spent £94,121 on chargeable project resource.

In addition to the Wi-Fi Data Collection Pilot report above, we have information on our website on the following link: https://tfl.gov.uk/corporate/privacy-and-cookies/wifi-data-collection-pilot

Please share any internal reports/ emails sent between the Wi-Fi tracking unit and the advertising unit since the introduction of the unit until the most recent date.

As explained above, we do not have a centralised Wi-Fi tracking unit and so we do not hold any emails relevant to your request.

Please find internal reports attached. The attached Gate 0 Document sets out the rationale for setting up the Wi-Fi Data Collection Project.

In accordance with the FOI Act, some financial information has been redacted as it is subject to a statutory exemption to the right of access to information under section 43(2) – commercial sensitivity.

In this instance the exemption has been applied as disclosure of the information you have requested is commercially sensitive. Disclosing commercial information would prejudice our commercial interests as it would be likely to prejudice our ability to conduct future negotiations with commercial partners for this and other projects.

The use of this exemption is subject to an assessment of the public interest in relation to the disclosure of the information concerned. TfL recognises the need for openness and transparency by public authorities, particularly where the use of public assets, but in this instance the public interest in ensuring that TfL is able to obtain the best value from public assets, outweighs the general public interest in increasing transparency of TfL’s processes.

Additionally, in accordance with TfL’s obligations under Data Protection legislation some personal data has been removed, as required by section 40(2) of the FOI Act. This is because disclosure of this personal data would be a breach of the legislation, specifically the first principle which requires all processing of personal data to be fair and lawful. It would not be fair to disclose this personal information when the individuals have no expectation it would be disclosed and TfL has not satisfied one of the conditions which would make the processing ‘fair’.

How much revenue has been made by TFL from passenger Wi-Fi data in the last five years (2014, 2015,2016,2017,2018 so far)? Please break this down by year and state how this revenue was generated.

Wi-Fi data collection rollout has not been introduced and no revenue has been made. No revenue was generated from the WiFi Data Connection Pilot.

Please can you provide any data protection assessment done since 2015 relating to WiFi tracking and also any prospective revenue analysis.

Please find attached data protection assessment from the WiFi data collection pilot.

Our Data Protection Impact Assessment (DPIA) will be published on the TfL website when it has been completed. In accordance with section 22 of the FOI Act, we are not obliged to provide our DPIA as it is intended for future publication. This exemption is subject to a public interest test, which requires us to assess whether the public interest in applying the exemption outweighs the public interest in disclosure. In this instance, it is considered that the public interest favours the publication of this information, in context and according to the pre-determined schedule, rather than in response to your request, to ensure the information is provided accurately and in an accessible manner.

We cannot release any prospective revenue analysis due to commercial sensitivities.

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

Yours sincerely

Melissa Nichols

FOI Case Officer

FOI Case Management Team

General Counsel

Transport for London

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