FOI request detail

GDPR plans

Request ID: FOI-2705-1718
Date published: 24 January 2018

You asked

*A copy of all plans, reports, and strategy documents detailing TfL preparations for the General Data Protection Regulation. *A copy of your information management strategy *A copy of your information asset register *A list of data processors (those who process personal data on behalf of TfL) *The total number of FOI requests received in 2017 to date *The total number of Subject Access Requests received in 2017 to date * Contact details of TfL's Data Protection Officer

We answered

Dear

TfL Ref: FOI-2705-1718

Thank you for your request received by us on 21 December 2017 asking for information about Information Governance.

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

You Requested:
*A copy of all plans, reports, and strategy documents detailing TfL preparations for the General Data Protection Regulation.
*A copy of your information management strategy
*A copy of your information asset register
*A list of data processors (those who process personal data on behalf of TfL)
*The total number of FOI requests received in 2017 to date
*The total number of Subject Access Requests received in 2017 to date
* Contact details of TfL's Data Protection Officer

Unfortunately, to provide the information you have requested would exceed the ‘appropriate limit’ of £450 set by the Freedom of Information (Appropriate Limit and Fees) Regulations 2004.

Under section 12 of the FOI Act, we are not obliged to comply with a request if we estimate that the cost of determining whether we hold the information, locating and retrieving it and extracting it from other information would exceed the appropriate limit. This is calculated at £25 per hour for every hour spent on the activities described.

The task of identifying all data processor agreements to update the Data Protection clauses is ongoing, and the cost of identifying all data processors would currently exceed the appropriate limit on its own.

Some information held in relation to part one of your request has recently been published on the TfL website, following a Freedom of Information request answered on 26 September 2017. You can view this response on our website at https://tfl.gov.uk/corporate/transparency/freedom-of-information/foi-request-detail?referenceId=FOI-1018-1718

The changes to Data Protection legislation are evolutionary in nature but implementation requires substantial, detailed, effort to identify, review and adapt business processes and practices across nearly all areas. This means that locating and extracting all plans reports and strategies is not a straightforward task. The organisation does not hold an overarching information management strategy, and work on our information asset register is ongoing.

The other parts of your request can be answered without significant cost.

3013 FOI requests were received in 2017.

Subject Access Requests are recorded by reporting period. Between 11 December 2016 and 9 December 2017 TfL received 345 Subject Access requests.

Richard Bevins is the Data Protection Officer and he can be contacted by post sent to Information Governance, Room 291, 2nd floor, Petty France, 55 Broadway, London SW1H 0BD email [email protected]

To help bring the cost of responding to your request within the £450 limit, you may wish to consider narrowing its scope so that we can more easily locate, retrieve and extract the information you are seeking. If you want to refine your request or make a Freedom of Information Act request in future, please bear in mind that the Freedom of Information Act allows you to request recorded information held by us. You should identify the information that you want as clearly and concisely as you can, specifying the types of document that you are looking for. You might also consider limiting your request to a particular period of time or specific departments of the organisation.

Although your request can take the form of a question, rather than a request for specific documents, we do not have to answer your question if it would require the creation of new information or the provision of a judgement, explanation, advice or opinion that was not already recorded at the time of your request.

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


Paulina Tuffour
FOI Case Officer

FOI Case Management Team
General Counsel
Transport for London

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