Our Ref:         FOI-3444-1819

Thank you for your request received on 17 March 2019 asking for correspondence between Transport for London (TfL) and Tottenham Hotspur FC in the last three years.
 
Your request has been considered in accordance with the requirements of the Freedom of Information (FOI) Act and our information access policy. We do hold the information you require.
 
We have identified more than 300 emails that could be relevant to your request based on a preliminary search, further searches are likely to generate more emails which would require consideration. There would be some duplication, however we would need to read each of the emails thoroughly to determine whether it is captured by your request as the proposed station naming is part of a wider ‘partnership’. Searching through such a significant volume of emails to collate them would be a significant task. Given the nature of correspondence, it is likely that it would be necessary to spend a significant amount of time considering exemptions which might be applicable to the information caught by the request.
 
Furthermore, given that a decision has not yet been made regarding the naming of White Hart Lane Station, we would be likely to need to devote considerable resource across several business areas to review the content of these emails to determine whether any exemptions would be applicable. Reviewing this information and considering the merits of exemptions across this volume of emails would inevitably require the diversion of specialist resources at a time when their efforts are required for the purposes of negotiating the terms of any possible renaming.
 
We are therefore refusing your request under section 14(1) of the FOI Act. After reviewing a sample of the requested correspondence 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 managing the TfL network, 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.
 
We consider the burden of retrieving, reviewing and redacting the information covered by your request would be disproportionate to the benefit of providing it. Therefore, we are refusing it under section 14(1) of the FOI Act. If you would like to re-submit a more focused, specific request then we will, of course, consider it. For example, a request for information over a narrower period of time, or on a more specific area of interest, is less likely to raise concerns about the disproportionate effort required to answer it.
 
Please note that if you were to go on to resubmit a narrowed version of this request it is likely that we would consider it necessary to withhold some information in accordance with section 43(2) of the FOI Act which relates to information that is commercially sensitive as well as section 42 of the Act which relates to legal privilege.
 
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

[email protected]