Request ID: FOI-3654-2324 Date published: 08 February 2024
You asked
1) Are the security guards hired to protect ULEZ vans in house security or contracted? If contracted what security company?
2) Is TFL aware that various guards protecting the ULEZ vans don't appear to be displaying SIA badges which is potentially a criminal offence contrary to section 9(4) of the Private Security Industry Act 2001?
3) If yes to the above question have any communications been sent out regarding this? If so please provide this.
4) Are TFL security guards protecting ULEZ vans permitted to hide their faces under masks and hoodies? Often these are the people also not displaying an SIA license.
5) If no to above question have any communications been sent out about this? If so please provide.
6) Are staff members driving the vans permitted to hide their faces under masks and hoodie while on duty? Presumably you have some kind of appearance policy.
7) If no to the above have any communications been sent out? If so please provide these.
8) Do you have a body worn camera policy in relation to the ULEZ van staff and guards? If so please provide this.
9) What is the retention period of body worn footage?
10) Do you have any policies/guidance issued in relation to the ULEZ camera vans? If so please provide. I understand you may have to redact some of it.
11) How many reports have been made to the police about ULEZ vans? If possible break this down by type of offence being reported.
We answered
TfL Ref: FOI-3654-2324 Thank you for your request which we received on 14 January 2024. Your request has been considered in accordance with the requirements of the Environmental Information Regulations and our information access policy. I can confirm that we hold some of the information you require. You asked:
Are the security guards hired to protect ULEZ vans in house security or contracted? If contracted what security company?
TfL has deployed mobile units as part of our extensive camera network to support the effective operation of the ULEZ scheme. Licensed security workers are used to support the mobile ANPR cameras as required.
In accordance with the EIR, we are not obliged to supply the name of the company providing this service as it is subject to a statutory exception to the right of access to information under regulations R12(5)(a) – international relations, defence, national security & public safety (in this instance, specifically public safety).
Is TFL aware that various guards protecting the ULEZ vans don't appear to be displaying SIA badges which is potentially a criminal offence contrary to section 9(4) of the Private Security Industry Act 2001?
Where security personnel are used to support the vans, they operate as Close Protection Officers and are suitably licensed by the Security Industry Authority (SIA). They are currently required to wear their SIA badge whilst on duty. This is a change in policy position.
If yes to the above question have any communications been sent out regarding this? If so please provide this.
Please see response below.
Are TFL security guards protecting ULEZ vans permitted to hide their faces under masks and hoodies? Often these are the people also not displaying an SIA license.
They wear plain, dark clothes suitable for the work they undertake. Our security workers are directed not to wear face coverings unless they feel threatened by being closely filmed. Wearing of medical masks is permitted. We regularly remind our contractors of the situations when they can be worn.
If no to above question have any communications been sent out about this? If so please provide.
Please see response below.
Are staff members driving the vans permitted to hide their faces under masks and hoodie while on duty? Presumably you have some kind of appearance policy.
See answer to question 3 above.
If no to the above have any communications been sent out? If so please provide these.
Please see response below.
Do you have a body worn camera policy in relation to the ULEZ van staff and guards? If so please provide this.
What is the retention period of body worn footage?
Body Worn Video is retained for 30 days unless marked as required by the Police or the security personnel due to an incident.
Do you have any policies/guidance issued in relation to the ULEZ camera vans? If so please provide. I understand you may have to redact some of it.
The scheme is enforced in the same way as our other road user charging schemes, using a mix of existing ANPR cameras, together with newly installed cameras in the expanded zone and mobile ANPR camera vehicles. The mobile ANPR camera vehicles have clear signage on the sides and rear. The vehicles are deployed within the areas covered by roadside signage ('in-zone repeater signs') that inform individuals they are within the ULEZ and LEZ and that cameras are in use. Our Data Protection Impact Assessment of the use of these cameras is published at the following link: https://content.tfl.gov.uk/london-wide-ulez-use-of-mobile-anpr-vehicles-dpia-august-2023.pdf The use of mobile camera vans will be reviewed continually by TfL to ensure the effective enforcement of the scheme.
How many reports have been made to the police about ULEZ vans? If possible break this down by type of offence being reported.
We do not hold this information. I would recommend you contact the Police for this information. Communications Regarding your three questions for communication, given the extent of the information you are looking for, we are applying Regulation 12(4)(b) as we believe that the questions are ‘manifestly unreasonable’ because providing the information you have requested would impose unreasonable costs on us and require an unreasonable diversion of resources. It would take an excessive amount of staff time and resources to identify and locate all the different teams and people across TfL who may have exchanged emails about this. When we receive requests asking for email communication, we are able to conduct a companywide email search using keywords, dates and email addresses. The more specific a requester can be, 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. We would then need to manually review all of the emails identified by the search in order to extract and collate the relevant information and disregard duplicates and unrelated material. The use of this exception is subject to a public interest test, which requires us to consider whether the public interest in applying the exception outweighs the public interest in disclosure. We recognise that the release of information would promote accountability and transparency in public services and may help address your concerns. However, the time it would take to provide the information you have requested would divert a disproportionate amount of our resources from its core functions, on balance we consider that the public interest currently favours the use of the exception. We will consider this part of your request again, if you are able to narrow its scope so that we can more easily locate, retrieve and extract the information you are seeking.For example, rather than a blanket request for all communication, if you ask for specific documents or have particular questions, we may be able to provide a more helpful response. Yours sincerely Eva Hextall FOI Case Management Team General Counsel Transport for London
