FOI request detail

London Underground passenger counts and incident data.

Request ID: FOI-2501-1819
Date published: 21 January 2019

You asked

Follow on from FOI- 2071-1819 Thank you for your response. I understand that a significant amount of effort may be required to extract the data I requested, mainly because it involves going through millions of lines of passenger usage data and the need to write new code to extract the data. My (doctoral) research involves machine learning on big data, hence the scope of my requirement. Ideally, the bigger the data, the better the research, results, conclusions etc. Navigating the publications and reports link you have provided, I came across the WiFi data collection programme TfL ran between Nov-Dec 2016. The report (http://content.tfl.gov.uk/review-tfl-wifi-pilot.pdf) indicate the data collection was depersonalised (therefore can be released publicly – to me) . More than 509 million probing requests were collected at 54 stations from 5.6 million devices. Could I please kindly request a copy of the dataset, as was collected and untouched (hopefully eliminating the need for efforts with extracting or writing new codes).

We answered

TfL Ref: 2501-1819

Thank you for your email received by us on 19 December 2018 asking for a copy of the dataset used in the WiFi data collection programme to assist with your studies on London Underground passenger statistics following your previous request for information (reference 2071-1819).

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

In accordance with the FOI Act, TfL is not obliged to supply the requested information as it is subject to a statutory exemption to the right of access to information under section 40(2).
This is because the Media Access Control (MAC) addresses of wifi routers at stations could be used, in combination with other available data to enable individuals to be identified, or mobile devices used by those individuals to be tracked.

Personal data as defined under Data Protection legislation is data which relate to a living individual who can be identified from the data, or from those data and other information which is in the possession of, or is likely to come into the possession of, the data controller. Given the possibility that the MAC address data could, if it was matched against other data sets, in certain circumstances enable the identification of an individual, it needs to be considered in this context to be personal data. The likelihood of this identification of an individual occurring would be increased by a disclosure of the data into the public domain, which would increase the range of other data sets against which it could be matched. Personal data is exempt from disclosure under section 40(2) of the FOI Act because disclosure of the personal data would be a breach of Article 5 (1)(a) of the General Data Protection Regulation, which requires personal data to be processed lawfully, fairly and transparently. It would not be fair to disclose this personal information when the individuals have no expectation it would be disclosed and TfL has not satisfied one of the conditions in Article 6 necessary to determine that the processing is ‘lawful’.
This exemption to the right of access to information is an absolute exemption and not subject to an assessment of whether the public interest favours use of the exemption.
If this is not the information you are looking for, or if you are unable to access it for any reason, please do not hesitate to contact me.

Please see the attached information sheet for details of your right to appeal as well as information on copyright and what to do if you would like to re-use any of the information we have disclosed.

Yours sincerely

Jasmine Howard
FOI Case Officer
Information Governance
Transport For London

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