TfL Ref: FOI-2472-2223
Thank you for your request which we received on 2 January 2023, asking for London Underground Traffic Circulars.
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 to provide the requested information under section 14(1) of the FOI Act. 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.
There are 26 Traffic Circulars, containing between 30 to 48 pages each, captured by your request. It would be necessary to review each one in significant detail to ascertain whether an exemption might apply as they contain a lot of security sensitive information about TfL’s infrastructure and safety procedures. If disclosed, this information could be used to cause disruption to our services, commit acts of vandalism and compromise the safety of our staff and customers. Reviewing this information and considering the merits of exemptions across hundreds of pages would inevitably require the diversion of specialist resources.
Therefore, we believe that the wider purpose and value of your request is not necessarily obvious and does not hold any current transport-user value. This brings into question whether it is a justified and proportionate use of our time to comply. We consider the burden of reviewing and redacting the information covered by your request would be disproportionate to the benefit of providing it. Therefore, we are refusing it under s14 of the FOI Act.
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 ICO guidance provides the following examples of a 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.
71. However, we consider there to be a high threshold for refusing a request on such grounds. This means that an authority is most likely to have a viable case where:
· The requester has asked for a substantial volume of information AND
· The authority has real concerns about potentially exempt information, which it will be able to substantiate if asked to do so by the ICO AND
· Any potentially exempt information cannot easily be isolated because it is scattered throughout the requested material.
If you would like to re-submit a more focused, specific request then we will, of course, consider it. For example, a request for a specific information on a particular subject or issue is less likely to raise concerns about the disproportionate effort required to answer it.
Please see the attached information sheet for details of your right to appeal.
Yours sincerely
Eva Hextall
FOI Case Management Team
General Counsel
Transport for London
