Hello there, Under the FoI Act, could you please supply me with the following information: 1) Has TfL had any discussions with technology companies about the possibility of implementing facial recognition on its bus or rail services? 2) Please provide any email correspondence, from January 2019 to February 2020, between TfL and external persons which concerns the use of facial recognition on either TfL's bus or rail services.

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TfL Ref: 3394-1920

Thank you for your request received by Transport for London (TfL) on 5 February 2020 asking for information about facial recognition technology.

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 do hold the information you require. You asked: 1) Has TfL had any discussions with technology companies about the possibility of implementing facial recognition on its bus or rail services? 2) Please provide any email correspondence, from January 2019 to February 2020, between TfL and external persons which concerns the use of facial recognition on either TfL's bus or rail services.

TfL has not used live facial recognition technology in the past nor do we use it at present, and there are no current plans to do so.

With regard to your request for email correspondence where facial recognition is mentioned between the dates of January 2019 and February 2020, we can advise that 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.

We have estimated that it would cost over £450 to provide a response to your current request. This is because it is estimated that it would take over 18 working hours to retrieve and compile the information you have requested.

When requests for email correspondence are received the FOI Case Management team may use a search tool called Discovery Accelerator. This allows us to conduct company wide email searches using keywords, dates and email addresses. The more specific a requester can be as to what they are looking for, the more we can narrow the search and therefore stand a better chance of a more relevant or focused result. A search will then return an amount of ‘hits’ which potentially contain information relating to the search terms used. Each ‘hit’ is a single email, although that email will often consist of a chain of emails containing the search term at least once.

We have done an initial search for all emails held by TfL sent/received by and this had returned thousands of results. A brief review of the results indicates that the vast majority of these will be internal emails such as media summaries referring to articles in the media on this subject, as well as general unsolicited marketing circulars. However, we are unable to search exclusively for external emails so we would need to manually review all of the emails identified by the search in order to extract and collate the relevant emails.

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. For example, by providing the name of a specific body/organisation that you would like our correspondence between which will enable us to conduct a more targeted search.

Although your request can take the form of a question, rather than a request for specific documents, TfL does 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 note that we will not be taking further action until we receive your revised request.

In the meantime, if you have any queries or would like to discuss your request, please feel free to contact me.

Please see the attached information sheet for details of your right to appeal.

Yours sincerely

Sara Thomas

FOI Case Management Team

General Counsel

Transport for London

[email protected]

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