Request ID: FOI-2074-2425 Date published: 24 October 2024
You asked
Please can you provide the following information relating to Transport for London's 'Mind the Gap' podcast series:
• How much of TfL's budget has been allocated to producing and publishing the Mind the Gap series?
• How many times has it been listened to? Please provide all audience data up to 1st October 2024.
• Please provide details of any business case related to the Mind The Gap series.
• Please provide all internal correspondence since 1st January 2023 that mentions 'Mind The Gap' and 'podcast' and '18Sixty'.
We answered
Our Ref: FOI-2074-2425
Thank you for your request received on 2 October 2024 asking for information about the ‘Mind the Gap’ podcast.
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:
• How much of TfL's budget has been allocated to producing and publishing the Mind the Gap series? • How many times has it been listened to? Please provide all audience data up to 1st October 2024
Last year, TfL launched an official podcasts series titled 'Mind the Gap' to celebrate 160 years of the Tube network. The first four-part series featured interviews with people who have helped shape it, such as Wayne Hemingway who designed the London Underground uniform and London's former Night Czar Amy Lamé. Presenter Tim Dunn also interviewed famous TV and radio personality Rylan, about his love of the Tube.
These 'Mind the Gap' episodes reached number one in Apple Podcasts 'Places and Travel' chart, number three in Apple Podcasts 'Society and Culture' chart and number 34 in all podcasts in the UK (Apple), receiving hugely positive feedback from listeners.
All the contributors who featured in the podcast volunteered and were not paid a fee for their involvement, including presenter Tim Dunn.
18sixty produced all episodes of the podcast. The total cost for series one of the 'Mind the Gap' podcast was £5,150.
Following the success of the Tube 160 series, TfL launched six new ‘Mind the Gap’ episodes this year dedicated to the historic change for the six London Overground lines. Each episode is presented by Secrets of the Underground presenter Tim Dunn and delves into the history behind the six new names for the London Overground lines, which will launch later this year.
The London Overground podcast episodes aim to engage people into the reasons behind the new names for each London Overground line and their historic importance to London.
The six London Overground ‘Mind the Gap’ episodes series include special guests for each episode who all contributed their time for free. This included Lionesses Leah Williamson and Chloe Kelly, comedian Cally Beaton and former Dragon's Den contestant and Reggae Reggae sauce creator Levi Roots.
This 'Mind the Gap' London Overground episodes once again reached number one in Apple Podcasts 'Places and Travel' chart and has received (to date) more than 32,000 downloads over the six episodes, with the Lioness line episode proving the most popular. Listener feedback has once again been very positive, and the vast majority (almost 90 per cent) of listeners are from within the UK, the majority of those being from within London. Once again, all the contributors who featured in the podcast volunteered and were not paid a fee for their involvement and volunteered their time to share with listeners the historical importance of the London Overground line names and what it meant to them. Presenter Tim Dunn was paid a fee to present these six episodes. 18sixty produced all episodes of the podcast. The total cost for of the 'Mind the Gap' London Overground six episodes was £12,000. Podcasts are continually growing in popularity and are a great tool for engaging with TfL’s customers about important milestones and changes for London’s transport network, such as the new names and colours for the six London Overground lines. TfL is currently introducing 4G and 5G mobile coverage across the whole of the London Underground and Elizabeth line, including within the tunnels, which makes listening to podcasts on the transport network easier than ever. Following the success of the ‘Mind the Gap’ podcast series, which to date has more than 70,000 downloads and gained significant media coverage, TfL will continue to look at opportunities for future podcasts that provide beneficial insight for our customers.
• Please provide details of any business case related to the Mind The Gap series
We do not hold a business case specifically for the podcast. Ahead of its launch, the podcast was included as part of meetings and discussions around the Tube160 overall series of events in 2023.
• Please provide all internal correspondence since 1st January 2023 that mentions 'Mind The Gap' and 'podcast' and '18Sixty'
This part of your request is being refused under section 14(1) of the FOI Act, which provides an exemption to the disclosure of information where a request is considered to be ‘vexatious’. In reaching this conclusion we have drawn on guidance from the Information Commissioner’s Office (ICO), both in relation to the specific application of section 14 and in relation to FOI-handling more generally.
On the specific application of section 14(1) we have been steered by the ICO guidance on the use of that exemption that can be found on its website here: https://ico.org.uk/media/1198/dealing-with-vexatious-requests.pdf
You will note that this 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 public authority may take into account the context and history of the request, where this is relevant”;
“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 request 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”;
“Frequent or overlapping requests: the requester submits frequent correspondence about the same issue or sends in new requests before the public authority has had an opportunity to address their earlier enquiries”.
“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.”
The guidance from the ICO makes it clear that public authorities should take into account the ‘context and history’ in which a request is made, and that this will “…often be a major factor in determining whether the request is vexatious”. This part of the guidance goes on to say that:
“In practice this means taking account of:
- Other requests made by the requester to that public authority (whether complied or refused). - The number and subject matter of those requests”, and;
“A request which would not normally be regarded as vexatious in isolation may assume that quality once considered in context. An example of this would be where an individual is placing a significant strain on an authority’s resources by submitting a long and frequent series of requests, and the most recent request, although not obviously vexatious in itself, is contributing to that aggregated burden”.
Through a manual search we have identified 46 emails that are captured by your request. While this is not a large number, the content of these emails totals over 350 pages which would all need to be reviewed before they could be disclosed to determine whether any exemptions applied. I have carried out an initial review of the emails and the vast majority consist of press releases or draft press releases regarding the podcast. However, due to the time it would take to review the captured material we believe the threshold for applying section 14(1) has been met.
It should be noted that currently we are unable to do company-wide searches for emails. Therefore the emails we have identified and are basing our decision on the application of section 14, have been provided by the business area who would have corresponded on this issue and who are most likely to hold the requested information. It is probable that additional emails are held in other areas of the organisation that were not identified through this manual search which would increase this burden further.
Requests such as this create a burden and disruption to our colleagues across the organisation whose principal function is the running of transport services or the support services required to make that happen.
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/
You will note that the table halfway down that page includes the following advice to FOI applicants:
Do….“Give the authority ample opportunity to address any previous requests you have made before submitting new ones”; Don’t… “Submit frivolous or trivial requests; remember that processing any information request involves some cost to the public purse”; Don’t… “Disrupt a public authority by the sheer volume of information requested. Whether you are acting alone or in concert with others, this is a clear misuse of the Act and an abuse of your ‘right to know’”, and; Don’t…”Deliberately ‘fish’ for information by submitting very broad or random requests in the hope it will catch something noteworthy or otherwise useful.”
We would therefore encourage you to prioritise any future requests around the information that is of most importance to you to ensure that you are able to make the best use of our resources under the FOI Act.
If you want to make a FOI Act request in future, please bear in mind that the FOI Act allows you to request recorded information held by us. You should identify the information that you want as clearly and concisely as you can.
Although your request can take the form of a question, rather than a request for specific documents, we do not have to answer your question if it would require the creation of new information or the provision of a judgement, explanation, advice or opinion that was not already recorded at the time of your request.
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
