FOI request detail

Red Route PCNs

Request ID: FOI-3109-2223
Date published: 10 March 2023

You asked

The Equality Act 2010 requires TFL to make reasonable adjustments for disability and you have Public Sector Equality Duty under same said Act. Where disabled persons are unable to access the TFL website to make representation and provide evidence on par with non disabled people please provide the following information: Is the team that handles all Red Route PCN matters, including appeals, a private contractor. If so provide tne name and full trading address of said contractor. Is the same Red Route PCN team bound by TFLs Diversity and Inclusion Policy? Is this team required to undergo disability awareness training either as employees of TFL or as oart of the contract with TFL? What provision has TFL made to enable equality of access and representation when the disabled person cannot access tne website independently? Specifically: Are Red Route team call agents instructed or governed by policy to take telephone representation? Please provide a copy of said policy if yes. Likewise, are Red Route team call agents instructed or governed by policy to provide an email address for evidebce such as photographs to be uploaded? There has been Royal Mail industrial action in place for over 9 mnths. What additional measures have been made to mitigate for non delivery of postal communication (and where dusabled persons have NO alternative given the current policies and practices.

We answered

TfL Ref: FOI-3109-2223

Thank you for your Freedom of Information request  of 20th February 2023.
 
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 some of the information you require. Your questions are answered in turn below.

Question 1) Is the team that handles all Red Route PCN matters, including appeals, a private contractor. If so provide the name and full trading address of said contractor.

Answer: Yes – the company is Capita. Please see the following link to the Capita website for their contact details: https://www.capita.com/contact-us

Question 2) Is the same Red Route PCN team bound by TFLs Diversity and Inclusion Policy?

Answer: We expect the same provisions to apply to any third party contractor under the contract they have with TfL. Please see our Diversity and Inclusion policy here:

https://tfl.gov.uk/corporate/about-tfl/corporate-and-social-responsibility/equality-and-inclusion

Question 3) Is this team required to undergo disability awareness training either as employees of TFL or as part of the contract with TFL?

Answer: Yes.

Question 4) What provision has TFL made to enable equality of access and representation when the disabled person cannot access the website independently?

Answer: If the recipient of a penalty is unable to make a representation online due to a disability a representation can be made via post. The full postal address to which to send such representations is listed on the Penalty Charge Notice.  Any further requests for reasonable adjustments when making a representation will be considered.

Question 5) Are Red Route team call agents instructed or governed by policy to take telephone representation?

Answer: The regulations governing the penalties we issue state that a representation must be made in writing. There is no general requirement to take representations over the phone.
However, we will consider any request for a reasonable adjustment, including taking a representation over the phone. The representations page of our website (see here) includes a dedicated telephone number.

Question 6) Please provide a copy of said policy if yes.

Answer: The consideration of reasonable adjustment is in line with the Equality Act 2010 (see here: https://www.legislation.gov.uk/ukpga/2010/15/contents)

Question 7) Likewise, are Red Route team call agents instructed or governed by policy to provide an email address for evidence such as photographs to be uploaded?

Answer: We do not have an e-mail address and there is no obligation or need to provide one. The reason for this is that we can receive representations by post, including images, and our website representation process (see here: https://tfl.gov.uk/modes/driving/red-routes/penalty-charge-notices/make-a-representationhas) has been designed to enable representations to be made and to allow the upload of evidence such as documents and/or photographs in a similar vein to the creation of an e-mail. In addition our “Contact Us” section on the website section does similar.

Question 8) There has been Royal Mail industrial action in place for over 9 months. What additional measures have been made to mitigate for non delivery of postal communication (and where disabled persons have NO alternative given the current policies and practices.

Answer: Representations need to be made within 28 days of the penalty being issued. However, we build in additional time on this to allow for postal delays.  

If this is not the information you are looking for 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,

David Wells
FOI Case Officer
FOI Case Management Team
General Counsel
Transport for London
 

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