Lu bulletins.
Request ID: FOI-1765-2021
Date published: 17 December 2020
You asked
Could I have a copy of London Underground ticketing and revenue (t&r) and The red hot bulletin from January 2020- august 2020 as I believe due to security these may be withheld up to 3 months from release.
We answered
TfL Ref: FOI-1765-2021
Thank you for your request received by Transport for London (TfL) on 4th December 2020 asking for copies of LU bulletins.
Your request has been considered in accordance with the requirements of the Freedom of Information Act and our information access policy.
Specifically you asked:
“Could I have a copy of London Underground ticketing and revenue (t&r) and The red hot bulletin from January 2020- august 2020 as I believe due to security these may be withheld up to 3 months from release.”
I can confirm that we hold the information you require.
The Ticketing and Revenue Updates covering the period January 2020 to August 2020 are attached. Note that redactions have been made under two Freedom of Information Act exemptions - sections 40(2) and 43(2). Section 40(2) protects against the unfair release of personal data. Section 43(2) applies where release of the information would prejudice TfL’s commercial interests. In this instance, the section 43(2) redactions relate to material about fare evasion and measures to combat it which, if released, could be exploited by individuals looking to evade fares. As a “qualified” exemption, the use of section 43 is subject to the ‘public interest test’, meaning consideration has been given to whether the greater public interest lies in applying the exemption and withholding the information, or in releasing it anyway. We recognise the need for openness and transparency in the operation of our business and the fact that the material has been requested is in itself an argument for release. However, TfL is largely funded by public money (via fares, and taxes in the form of grants) and we have a duty to protect the public purse. In this instance, we believe that protecting our fares income (and by extension public funds) is paramount and that the greater public interest lies in applying the exemption. As you will see, the exemptions apply to only a small amount of content overall.
In relation to the Hot Issues publication (which we presume is what your request for the “red hot” bulletins refers to), this is being refused under section 14 of the Freedom of Information Act. Section 14 applies where meeting a request is likely to cause a disproportionate or unjustified level of disruption, irritation or distress, and where its impact on a public authority cannot be justified. In this case, the exemption applies given the amount of effort that would be required to review the material in question in contrast to its limited public interest. The Hot Issues is a weekly bulletin, written for an internal audience, and which contains a lot of sensitive material that would likely have to be redacted (for example, in relation to security matters). There are around 34 issues that would need to be considered in detail, with more than one member of staff / team involved (colleagues who produce the bulletin would need to review each edition to highlight what they consider to be sensitive material, and the FOI team would then need to consider what exemptions rightfully apply in liaison with those colleagues. Any exempt material would then need to be redacted). This would be a burdensome task. Furthermore, I understand that material contained within these bulletins that is of particular interest is often included in the Ticketing and Revenue Updates in any case, with the more sensitive elements removed, meaning the public interest is largely served by the release of those monthly bulletins. Given this, we do not believe it is a proportionate use of our resources to comply with this element of your request.
If you are considering submitting a further FOI request please think carefully about whether the request is essential at this current time, as answering FOI requests will require the use of limited resources and the attention of staff who could be supporting other essential activity. Where requests are made, please note that our response time may be impacted by the current situation.
Please see the attached information sheet for details of your right to appeal as well as information on copyright and what to do if you would like to re-use any of the information we have disclosed.
Yours sincerely,
David Wells
FOI Case Officer
FOI Case Management Team
General Counsel
Transport for London
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