Based on request FOI-2347-1920, it is my understanding that your advertising partner "Global" has been provided aggregated data for footfall estimations: "The aggregated data is also being used by TfL’s advertising partner, Global, to improve where it positions advertising to help raise revenue for reinvestment in the transport network. The aggregated data will also be used in the future to help highlight the effectiveness and accountability of the advertising estate, based on measured footfall, which should also improve commercial revenue." I would like to request a copy of this data-set to be published, more specifically, as mentioned on the aforementioned FOI request: "Data shared consists only of estimated numbers of people (e.g. walking past an advert at different times of the day)." It is my understanding that this data-set does not contain PI or any other DPA/GDPR sensitive information, since it has already been shared with a third party. Publishing the data-set as provided to Global should not incur extraordinary costs.

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TfL Ref: FOI-3696-1920

Thank you for your request received by Transport for London (TfL) on 2 March 2020 asking for information about aggregated WiFi data.

Your request has been considered under the requirements of the Freedom of Information Act 2000 and our information access policy.

I can confirm that we do hold the information you require. However, we are not obliged to provide you with the data requested 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 as disclosure would, or would be likely to prejudice our commercial interests, as well as those of Global. Global are our partners and we (TfL and Global in partnership) wouldn’t want other advertising companies to have access to this data set as it would undermine our commercial position in the advertising market and would lead to TfL losing advertising revenue.

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 we are able to maximise revenue to invest in public transport outweighs the general public interest in increasing transparency of our processes.

If you are not satisfied with this response please see the attached information sheet for details of your right to appeal.

Yours sincerely

Graham Hurt

FOI Case Officer

FOI Case Management Team

General Counsel

Transport for London

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