Dear Transport for London, I write in request for information about Transport for London's use of ANPR (automated number plate recognition) cameras and derived data for uses other than the Congestion Charging scheme. Please can you release to me the following information: 1) How many ANPR cameras does TfL operate which are not part of the Congestion Charge scheme? 2) Where are these cameras located? 3) What is the data gathered from non-CC ANPR cameras used for? 4) What are the operating principles used by TfL for managing data gathered from the non-CC ANPR cameras? 5) How long does TfL retain data from the non-CC ANPR cameras, and what format is this data stored as? (e.g. License plate numbers, plate images, whole vehicle images etc.) (With the understanding that this information may be covered by the answer to question 4.) 6) Who can access this data within TfL? 7) What other agencies or organisations outside TfL can access this data? 8) Which agencies or organisations outside TfL have accessed this data within (a) 2014, (b) 2013, (c) 2012, where such information is available? 9) Are non-CC ANPR cameras also covered by the Certificate of Access provided for the Metropolitan Police for access to the CC ANPR camera data, and if so, is this the non-CC ANPR routinely transferred with CC data to the Metropolitan Police? 10) How is the non-CC ANPR data stored separately by TfL, if this is the case, or are the two datasets stored together? If you have any queries about any of these questions which may assist you in generating your response, please do not hesitate to contact me. I look forward to your reply.

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Our ref: FOI-2256-2021/GH

Thank you for your request received by Transport for London (TfL) on 8 February 2021 asking for information about Transport for London's use of ANPR (automated number plate recognition) cameras and derived data for uses other than the Congestion Charging scheme.

Your request has been considered under the requirements of the Freedom of Information Act 2000, Environmental Information Regulations and our information access policy. I can confirm that we do hold some of the information you require.

We do not use separate camera networks to monitor and enforce different Road User Charging (RUC) schemes, therefore the information we have provided in this response applies to all RUC schemes, including the Congestion Charge.

1. How many ANPR cameras does TfL operate which are not part of the Congestion Charge scheme?

We operate a network of 1,544 ANPR cameras to monitor and enforce the following RUC schemes:

The Central London Congestion Charging Scheme which was implemented in February 2003.

The Central London Ultra Low Emission Zone (ULEZ) which was implemented in April 2019 and which occupies the same area as the CC zone.

The Greater London Low Emission Zone (LEZ) which was implemented in February 2008 and which covers the whole of Greater London.

Direct Vision Standards (DVS) and the HGV safety permit schemes which starts on 1 March 2021 and which covers the whole of Greater London.

While the cameras located in the central London zone were originally installed to monitor and enforce Congestion Charging, they are now used to monitor and enforce all RUC schemes. Additional cameras are located outside the central London zone to cover LEZ and DVS, and further additional cameras will be installed when the ULEZ expands to the North Circular Road and South Circular Road from 25 October 2021.

981 cameras are used for enforcement of the schemes and 563 are used for monitoring.

1. Where are these cameras located?

Please see the attached spreadsheet for details of the locations of camera sites in the central London zone.

The locations of the cameras outside the central London zone are exempt from disclosure. Whilst we make no suggestion that you would use this information for anything other than you own personal interest, disclosure of this information to you has to be regarded as a disclosure to ‘the public at large’.

In accordance with the FOI Act, we are not obliged to supply the location of DVS cameras as it is subject to statutory exemptions to the right of access to information, under Section 38(1)(b) of the Act. DVS is a safety permit scheme which forms a key part of the Mayor’s Vision Zero plan to eliminate all deaths and serious injuries on London’s transport network by 2041 by reducing the risk posed by the most dangerous vehicles. Releasing information on the location of these cameras could allow those who wish to avoid detection to enter the zone and therefore cause danger to the public.

The use of this exemption is subject to an assessment of the public interest in relation to the disclosure of the information concerned. We recognise the need for openness and transparency by public authorities, but in this instance the public interest in safety outweighs the public interest in disclosure.

The aim of the LEZ and ULEZ schemes is to improve air quality in London by deterring the most polluting vehicles from driving in the area. Releasing the location of these cameras could enable those who wish to avoid detection to enter the zone. This information is therefore exempt under the Environmental Information Regulations exception 12(5)(g).

Unlike the central London zone, it is not possible to have cameras on every single entry and exit point due to the sheer scale of the zones.

1. What is the data gathered from non-CC ANPR cameras used for?

This information is available on our website at https://tfl.gov.uk/corporate/privacy-and-cookies/road-user-charging#on-this-page-5 and https://tfl.gov.uk/corporate/privacy-and-cookies/direct-vision-standard-and-the-hgv-safety-permit-scheme.

1. What are the operating principles used by TfL for managing data gathered from the non-CC ANPR cameras?

Please refer to the links provided in Q3 above.

1. How long does TfL retain data from the non-CC ANPR cameras, and what format is this data stored as? (e.g. License plate numbers, plate images, whole vehicle images etc.) (With the understanding that this information may be covered by the answer to question 4.)

Please refer to the links provided in Q3 above.

1. Who can access this data within TfL?

Please refer to the links provided in Q3 above. In addition, general traffic journey time data can be accessed by staff in the Operational Analysis department of our Network Management directorate.

1. What other agencies or organisations outside TfL can access this data?

Please refer to the links provided in Q3 above.

1. Which agencies or organisations outside TfL have accessed this data within (a) 2014, (b) 2013, (c) 2012, where such information is available?

We do not hold this information as records of this type are only retained for three years. It may be helpful to explain that the only external agency or organisation which has direct access to TfL ANPR cameras is the Metropolitan Police Service – more detail in relation to this can be found here: Road User Charging - Transport for London. At our discretion we may disclose information (including personal data) in response to valid requests from third parties. These requests would not be for full access to all information held, rather for specific information only (eg relating to a specific vehicle, dates, times, etc). All third party requests are assessed on a case-by-case basis to ensure that any disclosure is lawful and in accordance with data protection legislation. Before we authorise any disclosure the requester will need to demonstrate how the information requested will assist them and also to be clear under which exemption of the Data Protection Act 2018 they are making their request.

1. Are non-CC ANPR cameras also covered by the Certificate of Access provided for the Metropolitan Police for access to the CC ANPR camera data, and if so, is this the non-CC ANPR routinely transferred with CC data to the Metropolitan Police?

The Certificate refers to data from Congestion Charging cameras and traffic management cameras in the Greater London area operated by TfL. For information about how the data is shared with the MPS, please refer to the links provided in Q3 above.

1. How is the non-CC ANPR data stored separately by TfL, if this is the case, or are the two datasets stored together?

As advised, all of the information given above applies to all RUC schemes, including the Congestion Charge.

If this is not the information you are looking for, or if you are unable to access it for some reason, please do not hesitate to contact me.

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.

If you are not satisfied with this response please see the attached information sheet for details of your right to appeal.

Yours sincerely

Graham Hurt

FOI Case Officer

FOI Case Management Team

General Counsel

Transport for London

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