TfL Ref: FOI-2344-1617 

Thank you for your email received by us on 24 February 2017 asking for information about CSA Training material. Please accept my apologies for the delay in responding to your request.

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.

However, we are refusing your 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.

The Information Commissioner’s Office (ICO) guidance states that one of the indicators of a request which may fall under section 14(1) is that it “appears to be part of a completely random approach, lacks any clear focus, or seems to have been solely designed for the purpose of ‘fishing’ for information without any idea of what might be revealed.”

The ICO guidance provides the following examples of a ‘fishing expedition’ request which may fall under section 14(1) if it:

- Imposes a burden by obliging the authority to sift through a substantial volume of information to isolate and extract the relevant details;

- Encompasses information which is only of limited value because of the wide scope of the request;

- Creates a burden by requiring the authority to spend a considerable amount of time considering any exemptions and redactions.

Our view is that all three of these examples apply in this instance. We have conducted a search for the information you have requested and found 57 individual documents that meet the requirements of your request. Having reviewed a sample of 12 of those documents we found that the average size of these documents is 17 pages. Much of the information contained within the files will require consideration of one or more exemptions in accordance with the FOI Act which will require the input of several specialised staff members to advise and consider the risk and potential harm from disclosure.

Therefore, it is likely that it would be necessary to spend a significant amount of time considering exemptions which might be applicable to the information caught by the request. This is likely to include redacting exempt information in which there is very limited public interest but which is caught by your request because it features within internal documents used to train employees.

We consider the burden of retrieving, reviewing and redacting the information would be disproportionate to the benefit of providing it. Therefore, we are refusing it under s.14 of the FOI Act. If you would like to re-submit a more focused, specific request then we will, of course, consider it. For example, a request for information on a specific, document.

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

Yours sincerely

Paulina Tuffour
FOI Case Officer

FOI Case Management Team
General Counsel
Transport for London