FOI request detail

Freedom of Information Act – LGBTQ+

Request ID: FOI-3844-2324
Date published: 21 February 2024

You asked

I am making the following request under the Freedom of Information Act; 1. Within your organisation, what policies exist to support staff members who identify as transgender and are transitioning? 2. With respect to the question above, could you please provide a copy of the policies to support staff who identify as transgender? 3. Do you have any information publications or presentations available to staff regarding LGBTQ+ and Transgender, if so please could you provide details and copies of the information. 4. How many persons who identify as transgender are employed or volunteer with your organisation, and at what grade or position are they employed? 5. What advice and information do you supply to managers and staff regarding Transgender? Do you provide any specialist training in dealing with colleagues or clients who identify as transgender? If so, please provide copies of the relevant policies and material. 6. Does your organisation have any connections with Stonewall or similar organisations to support employees from the LGBTQ+ and Transgender community, and if so, please could you provide further details and copies of any documents or policies? 7. Do you have any specific policies to support staff members transitioning/transgender in where they are deployed or employed in the organisation and in dealing with members of the public, if so please could you provide further information? 8. Do you have a specific lead or individual(s) who deal with LGBTQ+ issues or liaison within the organisation? If so, please could you provide details? 9. Do you have specific policies regarding keeping female, LGBTQ+ and transgender staff safe? If so, could you please provide details and copies of any relevant policies?

We answered

Our ref: FOI-3844-2324

Thank you for your request received by Transport for London (TfL) on 25 January 2024 asking for information about LGBTQ+ policies and material.

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 some of the information you require.
 
1. Within your organisation, what policies exist to support staff members who identify as transgender and are transitioning?
2. With respect to the question above, could you please provide a copy of the policies to support staff who identify as transgender?

We do not have a policy on this, however we do have guidance for line managers and colleagues.

3. Do you have any information publications or presentations available to staff regarding LGBTQ+ and Transgender, if so please could you provide details and copies of the information.

A number of internal support sites exist with information on LGBTQ+ matters, including pages on the protected characteristics of ‘sexual orientation’ and ‘gender reassignment’, a page on Support for Trans and Non-Binary Colleagues, and a variety of pages, publications and presentations available on OUTbound (our LGBTQ+ colleague network group). We are unable to share internal support sites or presentations available on OUTbound as it is clear who forms the membership/attendance of OUTbound and their events. While participants have consented to this being shared internally they have not consented to this being shared externally. Therefore in accordance with our obligations under Data Protection legislation this information is exempt from disclosure as required by section 40(2) of the FOI Act because by its very nature it would identify individuals. Disclosure of this personal data would be a breach of the legislation, specifically the first principle of Article 5 of the UK 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’.

However, please see attached resources we can share externally. Please note that in accordance with our obligations under Data Protection legislation some personal data has been removed from the attached documents, as required by section 40(2) of the FOI Act to ensure all processing of personal data to be fair and lawful.

4. How many persons who identify as transgender are employed or volunteer with your organisation, and at what grade or position are they employed?

In accordance with our obligations under Data Protection legislation information on positions where there are five or fewer people in these posts has been withheld, 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 UK 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.

5. What advice and information do you supply to managers and staff regarding Transgender? Do you provide any specialist training in dealing with colleagues or clients who identify as transgender? If so, please provide copies of the relevant policies and material.

The advice and information supplies would be that already listed above. There is no specialist training on supporting colleagues or customers who identify as transgender but we do provide more general inclusion training modules and work with our external memberships to provide resources.

6. Does your organisation have any connections with Stonewall or similar organisations to support employees from the LGBTQ+ and Transgender community, and if so, please could you provide further details and copies of any documents or policies?

We have a membership with Trans in the City and have mentioned our Colleague Network Group for our LGBTQ+ community.

7. Do you have any specific policies to support staff members transitioning/transgender in where they are deployed or employed in the organisation and in dealing with members of the public, if so please could you provide further information?

Please see response to question 1 and 2.

8. Do you have a specific lead or individual(s) who deal with LGBTQ+ issues or liaison within the organisation? If so, please could you provide details?

We have an OUTbound (LGBTQ+) Colleague Network Group who support our colleagues and customers, these network groups report into our Diversity and Inclusion specialist teams across Transport for London.

9. Do you have specific policies regarding keeping female, LGBTQ+ and transgender staff safe? If so, could you please provide details and copies of any relevant policies?

As part of our White Ribbon accreditation we have launched the attached Domestic Abuse Policy and we also have further guidance available to support our staff.

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


Yours sincerely,



Tahsin Prima
FOI Case Officer
General Counsel
Transport for London

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