Request ID: FOI-1855-2324 Date published: 19 October 2023
You asked
Please could you release the details of any agreements with mobile network operators (eg, EE, O2, Vodafone, Three) to share movement data of people in London with TfL? Both individual data or in aggregate form. And agreements that are both currently ‘live’ or any similar agreements that have been agreed since 2019?
Please could you also release:
• Any data protection impact assessments relating to such agreements?
• Any further documents agreeing what data is collected/shared, and how TfL uses such data?
• Any reports produced summarising key data insights gained from cellular movement tracking about how people are moving around London since 2019?
• Any maps produced illustrating movement patterns around London, based on cellular data, made since 2019?
We answered
Our Ref: FOI-1855-2324
Thank you for your request received on 1 September 2023 asking for information about mobile data.
Your request has been considered in accordance with the requirements of the Freedom of Information (FOI) Act and our information access policy. I can confirm that we hold some of the information you require. You asked:
Please could you release the details of any agreements with mobile network operators (eg, EE, O2, Vodafone, Three) to share movement data of people in London with TfL? Both individual data or in aggregate form. And agreements that are both currently ‘live’ or any similar agreements that have been agreed since 2019?
Project EDMOND (Estimating Demand from Mobile Network Data) was commissioned primarily to provide new and up-to-date multi-modal demand matrices for transport model development at TfL. Work started on the project in March 2017 and the core deliverables were completed in 2018. A number of data sources were used on the project but the main source of data was aggregated and anonymised mobile network data from Telefonica. This consisted of time stamped mast locations generated when mobile devices connect and interact with the Telefonica network. The data used on this project was collected in September to November 2016. The use of mobile network data for this project required detailed consideration of the potential privacy implications associated with this. In its raw form this data is personal data, however none of the raw data has been provided to TfL. Any outputs provided to TfL have been depersonalised and aggregated. This means that we are not able to identify any individuals or individual travel patterns or other personal information in the data. It is a requirement of data protection legislation that the outputs from the project are not used to attempt to undertake any such identification.
In 2022 a variation to the previous contract was made to update the previous multi-modal demand matrices using post-pandemic datasets, including aggregated and anonymised mobile network data from Telefonica. This project is currently ongoing and is subject to the same privacy terms as the original project.
TfL have also recently gained access to mobile network data procured by Network Rail from BT and made available to rail industry partners such as TfL. TfL are currently exploring use-cases for this data source. TfL only has access to the processed, anonymised data outputs. Data protection assurance on this data is carried out by BT and Network Rail.
Please could you also release:
• Any data protection impact assessments relating to such agreements?
Please find attached the Project EDMOND Data Protection Impact Assessment (DPIA) completed in 2017.
• Any further documents agreeing what data is collected/shared, and how TfL uses such data?
Please find attached the ‘Statement of works’ - please note that this is between Jacobs (who are providing services to TfL) and Telefonica rather than between TfL and Telefonica.
In accordance with the FOI Act, we are not obliged to supply the cost information contained in this document as it is subject to a statutory exemption to the right of access to information under section 43(2) – prejudice to commercial interests. In this instance the section 43(2) exemption has been applied as disclosure would, or would be likely to, prejudice the commercial interests of Jacobs and Telefonica.
These costs form part of a contract that is subject to regular competitive tenders and subsequent negotiations. Disclosure of the current cost of creating the cards could hinder their ability to negotiate the best value for money in the future.
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 but in this instance the public interest in ensuring that any such negotiations remain competitive outweighs the general public interest in increasing transparency of our processes.
In accordance with our 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 of Article 5 of the UK General Data Protection Regulation 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’.
This exemption to the right of access to information is an absolute exemption and not subject to an assessment of whether the public interest favours use of the exemption.
• Any reports produced summarising key data insights gained from cellular movement tracking about how people are moving around London since 2019?
The current project has not reached the stage of reporting data insights.
• Any maps produced illustrating movement patterns around London, based on cellular data, made since 2019?
The current project has not reached the stage of reporting movement patterns If this is not the information you are looking for, or if you are unable to access it for any reason, please do not hesitate to contact me.
Please see the attached information sheet for details of your right to appeal.
Yours sincerely
Gemma Jacob Senior FOI Case Officer FOI Case Management Team General Counsel Transport for London
