Dear sir or madam. I am requesting that you provide me with a full list of each and every email address that TFL has. Please include each and every email address you have including old ones that still work and multiple ones that go through to the same places and ones that redirect to another inbox etc. For each email address please advise where exactly it goes through to (ie your standard customer service team or a specific department or somewhere else etc). I understand that there may be some personal email addresses and internal ones that are exempt from the FOI Act so that is fine but please do still give me all of the other email addresses that are not except. Also could you please kindly replace the "@" symbols with the word "AT" for all of the email addresses that you provide as the What Do They Know website annoyingly blocks email addresses. Many thanks in advance for your help and assistance with this enquiry. I look forward to your response to this FOI Act request.

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TfL Ref: FOI-1649-1920

Thank you for your request received by Transport for London (TfL) on 30^th August 2019 asking for a list of our email addresses.

Your request has been considered in accordance with the requirements of the Freedom of Information Act and our information access policy.

Specifically you asked:

“I am requesting that you provide me with a full list of each and every email address that TFL has. Please include each and every email address you have including old ones that still work and multiple ones that go through to the same places and ones that redirect to another inbox etc. For each email address please advise where exactly it goes through to (ie your standard customer service team or a specific department or somewhere else etc). I understand that there may be some personal email addresses and internal ones that are exempt from the FOI Act so that is fine but please do still give me all of the other email addresses that are not except. Also could you please kindly replace the "@" symbols with the word "AT" for all of the email addresses that you provide as the What Do They Know website annoyingly blocks email addresses. Many thanks in advance for your help and assistance with this enquiry.”

I can confirm that we hold the information you require. However, 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’.

TfL has tens of thousands of live email addresses. The organisation currently employs around 27,000 members of staff, each of which are designated an email address, and there are vast numbers of group/team email addresses in addition. As you acknowledge in your request, there are some addresses that may well be exempt from release - for example, individual staff addresses may be exempt under the section 40(2) “personal data” exemption, particularly where staff have no particular need to send external emails from their own account. However, it is not the case that all email addresses would be exempt – an obvious example being where an address is already in the public domain, which may include some individual staff addresses. In order to determine which email addresses should be released and which would fall under an exemption we would need to consider what each and every such address is for and what the ramifications of release would be, either on the individual concerned or the business area to which it relates, or to TfL more generally. Given the numbers involved we believe that this would require an excessive and disproportionate amount of work.

In reaching this conclusion we have drawn on guidance from the Information Commissioner’s Office (ICO) on the application of section 14(1), that can be found on its website here: https://ico.org.uk/media/1198/dealing-with-vexatious-requests.pdf

You will note that the 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 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 requests 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”;

And;

“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.”

If we were to comply with your request it would require the re-allocation and diversion of already limited resources, placing a burden on a small number of personnel. We also believe that the purpose and value of your requests is not necessarily obvious, which brings into question whether it is a justified and proportionate use of our time to comply. Note that TfL advertises various ways by which the public can contact the organisation, as set out on our website here:

https://tfl.gov.uk/help-and-contact/

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: https://ico.org.uk/your-data-matters/official-information/

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

Yours sincerely,

David Wells

FOI Case Officer

FOI Case Management Team

General Counsel

Transport for London

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