Request ID: FOI-2750-2122 Date published: 22 March 2022
You asked
I am just wondering if I can request a copy of the Rulebook for the underground infrastructure as I am going to be doing all my competences for the underground infrastructure
We answered
TfL Ref: FOI-2750-2122
Thank you for your request received by Transport for London (TfL) on 1 March 2022, asking for a copy of the LU Rulebook.
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 have requested. Specifically you asked:
I am just wondering if I can request a copy of the Rulebook for the underground infrastructure as I am going to be doing all my competences for the underground infrastructure.
I can confirm that we hold the information you require. However, the rule books are exempt from disclosure under sections 24 (National Security) and 38 (Health and Safety) of the Freedom of Information Act. The rules books are internal documents designed to be used by operational staff in the running of the London Underground. The books detail various rules, instructions, protocols and procedures which LU operational staff are governed by. This material would be of use to any persons wishing to disrupt London’s transport infrastructure by placing into the public domain information which would otherwise not be available via other means. Whilst we make no suggestion that you would use this information for anything other than you own interest, disclosure of information under FOI has to be regarded as a disclosure to the public at large. As you will no doubt be aware, the transport system in London has been the target of attacks in the past. The information requested contains sensitive information about the operation and infrastructure of the network which could be of use for anyone seeking to research or plan for such an attack or to actively cause disruption to the network. Further, there is no meaningful way in which the material can be redacted. While some sentences or passages may appear innocuous in isolation, taken together across the suite of documents it would still allow somebody to build up a detailed picture of operational processes and the language used in the operation of the network.
The Information Commissioner’s Office has previously issued a Decision Notice regarding the application of sections 24 and 38 to withhold information in relation to security at transport hubs. Whilst the information requested in this case is different to the information you have requested, we believe the same arguments can be applied:
The use of the section 24 and 38 exemptions are 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, and acknowledge that there may be some interest in the information in question.
However, as we believe this information could potentially be obtained and utilised by individuals who may wish to use it to cause disruption or harm to London’s transport infrastructure, in this instance we believe that minimising the risk to that infrastructure and protecting the safety and welfare of members of the general public and our staff outweighs the limited public interest in disclosure.
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
