Request ID: FOI-3156-2324 Date published: 13 February 2024
You asked
I hope you are well. I am writing under the Freedom of Information Act to request the following information. All of the information relates to fare evasion detection using artificial Intelligence, which is briefly described in this news article: https://www.standard.co.uk/news/london/tfl-ai-fare-dodgers-london-underground-artificial-intelligence-b1124563.html
Please would you be able to provide me with the following information:
1. The Privacy Impact Assessment created ahead of the pilot project, which is described in the article
2. A copy of any final report(s)/evaluation, or information of a similar nature, that provides the conclusions of the pilot project.
3. Any Privacy Impact Assessment created for the next phase of this project, the "in-station trial"
4. The name of any company TfL has contracted to provide the artificial intelligence technology in this case, plus any contract and memorandum of understanding between TfL and the company that exists for providing the work on the project.
We answered
Our Ref: FOI-3156-2324
Thank you for your request received on 6 December 2023 asking for information about the artificial intelligence (AI) fare evasion trial at Willesden Green. I apologise for the delay in my response.
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 that we hold some of the information you require.
The smart technology trial at Willesden Green station used existing CCTV images, AI algorithms and numerous detection models to detect patterns of behaviour. Examples include person(s) leaning over the platform edge, person(s) with a wheelchair, person(s) jumping over a closed gate, customers accessing unused platform. By providing station staff with insights and notifications on customer movement and behaviour they will hopefully be able to respond to any situations more quickly. The Willesden Green Station trial, while initially designed to alert front line teams of possible safety incidents, has provided insight into fare evasion which is building upon our current understanding and will assist us in our future approaches and interventions. The pilot used image detection AI to monitor the movement of customers through station gatelines in order to identify instances where customers may have evaded paying a fare, or the correct fare, for their journey. This was tracked for analytical purposes and did not result in real-time alerts to station staff. This was not used as a facial recognition tool. All data gathered by the Smart Stations trial is in line with TfL’s data retention policies. Images captured by the CCTV technology shall be retained for 14 days, in alignment with LU policy concerning retention of CCTV data.
Please find the requested documents attached.
In accordance with the FOI Act, we are not obliged to supply some of the information as it is subject to a statutory exemption to the right of access to information under section 24 – national security, section 38(1)(b) – health and safety, and section 43(2) – commercial interests. While we make no suggestion that you would use this information for anything other than your own personal interest, disclosures made under the FOI Act are deemed to be a ‘disclosure to the world at large’. It is in this context that we have to consider the wider implications that disclosure of this information could have on the network.
Sections 24 - national security and 38(1)(b) – health and safety has been applied to information that could potentially be obtained and utilised by individuals who may wish to use this information to cause disruption or harm to the London Underground network and/or themselves. The London Underground system is an attractive terrorist target for several reasons including, its importance to London and the knock on effect to the nation’s economy if it is disrupted, the publicity gained from attacking an iconic transport system and the attractiveness of the system for a mass casualty attack due to its open, mass transport nature. It is also part of the nation’s critical infrastructure by virtue of its central importance to the functioning of London and its economy. Disclosure of information could compromise security and safety preparedness on London Underground’s network and would place members of the public and TfL staff at risk by highlighting areas on the network which could be susceptible to being targeted.
Section 43(2) has been applied as disclosure would, or would be likely to, prejudice our commercial interests. While the trial utilised existing contracts, disclosure of information relating to the details around the cost associated with the trial could affect our ability to get the maximum value for TfL from future commercial partnerships.
The use of these exemptions is 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, but in this instance we consider that there is greater public interest in ensuring the protection of passengers and staff, as well as discouraging fare evaders from using our network, and protecting our commercial interests, puts the balance in favour of withholding the information.
In addition, and in accordance with our obligations under Data Protection legislation, some personal data has been removed, as required by section 40(2) of the FOI Act. This is because disclosure of this personal data would be a breach of the legislation, specifically the first principle of Article 5 of the UK General Data Protection Regulation which requires all processing of personal data to be fair and lawful. 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 which would make the processing ‘fair’.
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.
Integration Wizards and Telent have supported this work. We do not have a contract with Integration Wizards as our contract is with Virgin Media. Telent maintain all of our comms assets. In line with the February 2015 Local Government Transparency Code we publish details of tenders and contracts with a value over £5,000. Copies of contracts are published on the Contracts Finder website: https://www.contractsfinder.service.gov.uk/Search.
Under section 21 of the Freedom of Information Act, we are not obliged to provide you with information which is reasonably accessible by other means.
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.
Yours sincerely
Gemma Jacob Senior FOI Case Officer FOI Case Management Team General Counsel Transport for London
