TfL/TPH (Legal Directorate) oversee the Knowledge of London -Test for Licensed Taxi Drivers- Requesting info and background relating to this dept.
Request ID: FOI-3018-2324 Date published: 19 December 2023
You asked
I request the following;
!)Final report of investigation into XXX-Knowledge of London Examiner- Dates likely to be between 01/01/2012- 12/12/2014
2)Full Report document re Knowledge of London carried out by Strategic Problem Solving Team during 2021 and 2021
3)100 random Knowledge of London exam(appearance) examiner record sheets- 10 each from years between 2013 & 2022
4)Record/email correspondence relating to meeting between meeting between Simon Buggey (driver, Operator policy manager) & Katie Chennells (Knowledge of London Manager on 12/04/2022 - Agenda- Examiner guidelines
We answered
Our ref: FOI-3018-2324/GH
Thank you for your request received by Transport for London (TfL) on 21 November 2023 asking for information about the Knowledge of London.
Your request has been considered in accordance with the requirements of the Freedom of Information Act and our information access policy.
Final report of investigation into XXX-Knowledge of London Examiner- Dates likely to be between 01/01/2012- 12/12/2014
The requested information is exempt from disclosure under section 40(2) of the Freedom of Information Act, the exemption protects against the unfair release of personal data. Under section 40(2), information is exempt from release if it relates to an identifiable third party and if its release is considered to be unfair. In this case, with an individual named in the request, the information clearly relates to an identifiable third party. The question therefore is whether the release of the material would be fair.
We do not believe that the individuals involved would expect that the records requested would be divulged in this way, and therefore conclude that the release of this information would be ‘unfair’.
Full Report document re Knowledge of London carried out by Strategic Problem Solving Team during 2021 and 2021
In accordance with the FOI Act, we are not obliged to supply the information you have requested as it is subject to a statutory exemption to the right of access to information, under Section 22 of the Act.
As we confirmed in our previous FoI response to you (Ref: FOI-0181-2324) it is our intention to publish Knowledge of London review materials once any changes to the process have been announced in the New Year.
This exemption is subject to a public interest test, which requires us to assess whether the public interest in applying the exemption outweighs the public interest in disclosure. In this instance, it is considered that the public interest favours the publication of this information, in context and according to the pre-determined schedule, rather than in response to your request, to ensure the information is provided accurately and in an accessible manner.
100 random Knowledge of London exam(appearance) examiner record sheets- 10 each from years between 2013 & 2022
We are refusing this part of 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, 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. Locating and preparing these documents for release would be a significant task. By its nature, we feel this wide ranging and non-specific request will very likely encompass information which is only of limited value. In order to provide this information we would need to:
Run the relevant reports – we would need to know the names and reference numbers of those candidates who undertook appearances up to 10 years ago
Work out what method we use to randomly select files
Locate individual appearance records as these are embedded within drivers individual records and need to be searched for
Examiner records (hand written notes – sometimes extremely detailed) would have to be read through and any information that could identify someone would have to be redacted.
The staff member sorting through would be have to be able to decipher hand written notes which have been scanned onto TOLA (not always the easiest to read).
Each record would need to be scrutinised and redacted to remove any personal information.
Record/email correspondence relating to meeting between meeting between Simon Buggey (driver, Operator policy manager) & Katie Chennells (Knowledge of London Manager on 12/04/2022 - Agenda- Examiner guidelines
We have carried out a search for the email correspondence you have requested and have not identified any information within the scope of your request – therefore we do not hold this information.
If you are not satisfied with this response please see the attached information sheet for details of your right to appeal. Yours sincerely
Graham Hurt FOI Case Officer FOI Case Management Team General Counsel Transport for London