Cost of making TfL adverts compliant with 'junk food' advertising ban

Request ID: FOI-3484-1819
Date published: 20 May 2019

You asked

Under the Freedom of Information Act, I would like to know how much money, if any, TfL has spent making its own adverts on public transport compliant with its recently introduced rules against 'junk food' (HFSS food) appearing on adverts on public transport. If money has been spent for this purpose, please also provide any correspondence related to the reworking of TfL advertisements.

We answered

Our Ref: FOI-3484-1819

Thank you for your request received on 19 March 2019 asking for information about the cost of making TfL adverts compliant with 'junk food' advertising ban.

Your request has been considered in accordance with the requirements of the Freedom of Information Act and our information access policy. I can confirm we do hold the information you require.

There were three advertisements that we updated plus a series of poster based maps, each featuring great places to go along the Underground lines, DLR etc. The costs were as follows:

1. London Underground air conditioning ad. The cost to amend poster artwork was £1,580.
2. London Buses real time information ad. The cost to amend posters and press advertising was £4,820.
3. The ‘Off Peak’ campaign covering all modes of public transport. The cost to update across twelve different formats for print and on line was £6,355.
4. Updating nine ‘cultural maps’ costing a total £3,400. These maps were for the Bakerloo, Circle, District, Northern, Piccadilly and Victoria lines plus the London Overground, DLR and London Borough of Culture (Waltham Forest).

Please see the attached correspondence, including the original request to under take this work from TfL’s Head of Customer Marketing & Behaviour Change and the follow up correspondence across the team and with suppliers.

In accordance with the FOI Act, we are not obliged to supply some of the information contained in the attached documents as it is subject to a statutory exemption to the right of access to information under section 43(2).

In this instance the section 43(2) exemption has been applied to information regarding the rates charged by our suppliers as disclosure would be likely to prejudice our commercial interests, as well as those of the companies concerned. Prejudice would be likely to occur when we go out to tender for this and similar services in the future, because it would be likely to result in a clustering of bids based on how much we are prepared to pay. Disclosing this information could also be prejudicial to our supplier’s ability to compete for tendering opportunities with TfL and other companies in the future, as their competitive edge would inevitably be prejudiced by disclosure of a detailed breakdown of their price.

The use of this exemption 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 the public interest in ensuring that TfL is able to obtain the best value for public money outweighs the general public interest in increasing transparency of our processes.

Additionally, in accordance with our obligations under Data Protection legislation some information has been withheld from the attached correspondence, 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 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.

If this is not the information you are looking for, or if you are unable to access it for some reason, please feel free 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

[email protected]

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