I am writing to request information under the Freedom of Information Act 2000. In order to assist you with this request, I am outlining my query as specifically as possible. Please send me the last two Fire Risk Assessments (FRAs) for Victoria Coach Station, which is run by TFL’s subsidiary Transport Trading Limited. As the organisation has a responsibility to protect the safety of passengers, employees and anyone entering the coach station it is in the public interest to disclose the reports. It is also required by law to have a fire risk assessment to help in its safety responsibility. Additionally please provide names and business addresses of the companies or individuals which carried out the FRAs. Please also provide the rating they were given eg moderate, serious or severe. Please also provide details of any fires at Victoria Coach Station during the 2018 & 2019 calendar years and 2020 to date. I would prefer this information in spreadsheet format. I would be interested in any information held by your organisation regarding my request. I understand that I do not have to specify particular files or documents and that it is the department's responsibility to provide the information I require. If you need further clarification please contact me by telephone on xxxxxxxxx, or xxxxxxxxxxxx If my request is denied in whole or in part, I ask that you justify all deletions by reference to specific exemptions of the act. I also expect you to release all non-exempt material and to be aware that, as defined by the statute, this request should be treated purpose blind. I reserve the right to appeal your decision to withhold any information or to charge excessive fees. I would be grateful if you could confirm in writing that you have received this request. I look forward to receiving your response within 20 working days as defined by the statute. Many thanks

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Our ref: FOI-3596-1920

Thank you for your request received by Transport for London (TfL) on 21 February 2020 asking for information about Victoria Coach Station.

Your request has been considered in accordance with the requirements of the Freedom of Information Act and our Information Access Policy. You asked:

1. Please send me the last two Fire Risk Assessments (FRAs) for Victoria Coach Station, which is run by TFL’s subsidiary Transport Trading Limited.

In accordance with the FOI Act, we are not obliged to supply Fire Risk Assessments, as they are subject to a statutory exemption to the right of access to information under section 38(1)(a) – Health and Safety.

In this instance the exemption has been applied as disclosure of information relating to fire exits and station plans would be likely to adversely affect the safety and security of TfL employees and the travelling public.

Whilst we make no suggestion that you would use this information for anything other than you own interest, disclosure of this information to you has to be regarded as a disclosure to ‘the public at large’. This information could potentially be obtained and utilised by individuals with malicious intent to cause disruption and subsequent economic damage to the station, and could adversely affect the safety and security of TfL employees and members of the general public.

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 we feel that ensuring the protection of vulnerable people, passengers, staff and the public at large puts the balance in favour of withholding the information.

Furthermore, based on the detailed and operational information in the requested documents, we consider that section 24 exemption also applies to the withheld information for the purpose of safeguarding national security. Each day thousands of journeys are made to and from Victoria Coach Station and a planned attack directed at the running of the station may cause harm to national security by disrupting the operation of London’s, and more widely the UK’s transport network, with consequent economic loss. We therefore consider that disclosure of information relating to fire risk assessments, which would assist an unauthorised person to access fire exits unlawfully, should also be exempt under Section 24.

Section 24 is subject to a public interest test and we consider that there is a strong public interest in protecting national security, which would be undermined by the disclosure of the requested information.

2. Additionally please provide names and business addresses of the companies or individuals which carried out the FRAs.

The FRAs were completed by competent persons within the TfL. In accordance with the FOI Act, we are not obliged to provide names of individuals as it is subject to a statutory exemption to the right of access to information under section 40(2). This exemption to your right of access is applied in accordance with TfL’s obligations under the General Data Protection Regulation (GDPR). The exemption applies because disclosure of personal information would be a breach of the GDPR, specifically the first principle of the GDPR which requires all processing of personal data to be fair and lawful.

3. Please also provide the rating they were given eg moderate, serious or severe.

The 2019 FRA was given a Moderate risk rating.

4. Please also provide details of any fires at Victoria Coach Station during the 2018 & 2019 calendar years and 2020 to date.

There have been no fires at Victoria Coach Station within the stated dates.

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

Yours sincerely,

Melissa Nichols

FOI Case Officer

General Counsel

Transport for London

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