FOI request detail

WiFi Data Connectivity pilot project

Request ID: FOI-2247-1617
Date published: 07 June 2017

You asked

I wish, under the Freedom of Information Act 2000, to get access to any responsive document AND processing notes to any Freedom of Information request received by Transport for London concerning their WiFi Data Connectivity pilot project. In particular I know of two such requests: - one lead to the Gizmodo article: http://www.gizmodo.co.uk/2017/02/heres-what-tfl-learned-from-tracking-your-phone-on-the-tube/ - the second one was actually a request under the Data Protection Act 1998 and the EU Data Protection Directive, but your office treated it as a FOI request: http://www.personaldata.io/request/privacy-impact-assessment-opt-out-for-wifi-mac-tracking-project/ Since the second was mine, feel free not to send me the responsive documents for that particular request (already received them), but do send the processing notes.

We answered

TfL Ref: FOI-2247-1617

 

Thank you for your request received by Transport for London (TfL) on 20 February 2017 asking for information about previous FOI responses.

 

Your request has been considered in accordance with the requirements of the Freedom of Information Act and our information access policy. I can confirm we do hold the information you require.

 

Please see the attached file for the documents disclosed in relation to the Gizmodo WiFi request.

 

However, we are refusing your full request under section 14(1) of the Act. After reviewing a sample of our records we consider that providing the requested information would place an unreasonable burden on us. Our principal duty is to provide an effective transport service for London and we consider that answering this request would represent a disproportionate effort. It would be a significant distraction from our work managing the TfL network, requiring re-allocation of already limited resources and placing an unacceptable burden on a small number of personnel. We do wish to clarify that whilst we consider that your request falls under section 14(1) of the FOI Act, this does not reflect a conclusion that it has been your intention to deliberately place an undue burden on our resources.

 

We have received 17 individual requests relating to the WiFi data trial (excluding this request). The process of logging, acknowledging, gathering the requested data, considering any potentially applicable exemptions and finalising a response will vary in length between requests. However, we expect that your request is likely to incorporate around 200 emails, many of which would be duplicates due to the overlapping theme of the requests. We would need to manually extract and compile them all which would, in itself, be a significant task. However, there would be additional burden in the essential process of redacting exempt information from emails in which there is very limited public interest but which are caught by your request, as well as the personal data that would feature repeatedly in almost every one of the emails covered by your request.

 

We consider the burden of retrieving, reviewing and redacting the entirety of the information requested would be disproportionate to the benefit of providing it. Therefore, we are refusing it under s.14 of the FOI Act.

 

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

 

Yours sincerely

 

Lee Hill

FOI Case Officer

 

FOI Case Management Team

General Counsel

Transport for London

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