FOI request detail

CCTV footage at Uxbridge Bus Station

Request ID: FOI-3519-1819
Date published: 15 April 2019

You asked

Following on from this [FOI-3510-1819] I request CCTV footage at Uxbridge Bus Station on 17/3/19 from 21:30 to 22:15 and as before as the timings are tight please ask your CCTV colleagues not to delete the requested information from their storage facility until you have retreived this Regards

We answered

TfL Refs: FOI-3510-1819 and FOI-3519-1819

Thank you for your Freedom of Information requests received by TfL on 20th and 21st March 2019 asking for CCTV footage from Uxbridge bus station.

Your requests have been considered in accordance with the requirements of the Freedom of Information Act and our information access policy. 

Your requests were specifically for footage from:

  • 14th March 2019 between 21.30 and 22.20 showing the buses parked at bus stops K L M  N and O in Uxbridge Bus Station in Bakers Road Uxbridge Middlesex with no drivers in  the driver’s seat, and;


  • 17th March 2019 between 21:30 and 22:15 (presumably for the same view as above).

I can confirm that we hold the information you require. However, the information is being withheld under section 14(1) of the FOI Act. This section of the Act applies where a request, or its impact on a public authority, cannot be justified. In this instance the exemption applies because of the impact complying with the request would have on in TfL, in regard to the length of time that would have to be spent redacting the footage to make it suitable for publication.

Section 40(2) of the FOI Act requires information that would allow a third party to be unfairly identified to be withheld from release. In the case of CCTV footage, guidance from the Information Commissioner’s Office (ICO - states that images of third parties captured on CCTV “…would be considered personal information and it is likely they would be exempt from the Freedom of Information Act”. In your email of 20th March 2019 you accept this principle, stating that: “No id is sent as I only require the pictures of the buses people's faces are to be blurred out”. TfL agrees that it would be unfair on the individuals concerned for images of themselves to be released when they may not have realised they were being captured on CCTV at that precise moment in time. This is particularly true given that release of material under FOI has to be considered as release to the world at large - rather than to the individual applicant - and hence potentially accessible to anyone. Therefore, if we were to comply with your request, we would have to redact the footage to ensure that no third parties caught on film could be identified. This is not a quick process.

The footage you have requested equates to 95 minutes in total. We estimate that to review and then redact this much footage would take somewhere in the region of 32-35 hours as a minimum (redaction would need to be carried out frame by frame). For this reason we believe that complying with your request would be manifestly unreasonable. This judgment has been steered by the ICO guidance on the use of section 14, which can be found online here:

As you can see, the guidance includes the following advice to public authorities:

“….the key question to ask is whether the request is likely to cause a disproportionate or unjustified level of disruptionthis will usually be a matter of objectively judging the evidence of the impact on the authority and weighing this against any evidence about the purpose and value of the request”;

“The Information Commissioner recognises that dealing with unreasonable requests can place a strain on resources and get in the way of delivering mainstream services or answering legitimate requests”;

“….public authorities should not regard section 14(1) as something which is only to be applied in the most extreme circumstances, or as a last resort. Rather, we would encourage authorities to consider its use in any case where they believe the request is disproportionate or unjustified”.

The guidance also provides a number of specific indicators to take into account when judging whether or not the exemption should apply. These include the following:

Burden on the authority: The effort required to meet the request will be so grossly oppressive in terms of the strain on time and resources, that the authority cannot reasonably be expected to comply, no matter how legitimate the subject matter or valid then intentions of the requester”;

Disproportionate effort: The matter being pursued by the requester is relatively trivial and the authority would have to expend a disproportionate amount of resources in order to meet their request”.

TfL’s principal duty is to provide an effective transport service for London and we consider that answering requests of this nature would represent a disproportionate effort, requiring re-allocation of already limited resources and placing an unacceptable burden on a small number of personnel. From the information provided in your requests it is not clear what purpose or value release of this footage would serve, nor can we see any discernible wider public interest in its release. Taking this into account, along with the burden it would put on TfL to comply and noting the advice provided from the ICO as quoted above, we believe that it is reasonable for section 14(1) to apply and for your requests to be refused on that basis.

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

Yours sincerely,

David Wells

FOI Case Officer

FOI Case Management Team

General Counsel

Transport for London

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