FOI request detail

Freedom of Information request - Rail rebrand

Request ID: FOI-4195-2324
Date published: 14 March 2024

You asked

Dear Transport for London, Under the Freedom of Information Act, please provide the following details in relation to the renaming of London Overground lines in February 2023: • the long list (or long lists) of names provided to TFL by the DNCO branding agency before the final six names were selected. • for the period between 01/01/23- 16/02/24, any reports created by DNCO for TFL drawing on the former’s consultations (as stated by the company in press reports) with “leading historians, academics and transport specialists.” • for the period between 01/01/24- 16/02/24, all correspondence between DNCO and TFL

We answered

Our Ref:         FOI-4195-2324

Thank you for your request received on 16 February 2024 asking for information about the renaming of London Overground lines.

Your request has been considered in accordance with the requirements of the Freedom of Information (FOI) Act and our information access policy. I can confirm that we do hold the information you require.

When naming the London Overground lines, the aim was to develop the names in a collaborative and inclusive way, and use this as an opportunity to celebrate London, its diversity and culture, ensuring that more Londoners feel connected to the transport network they use every day. Therefore, it was integral that we engaged with communities as part of this project, as opposed to naming the lines internally.

Stakeholders, customers, historians, industry experts and communities played a key role in informing the new names through independent engagement which took place ahead of the decision on the final six names. This was key as London’s diverse history and culture has always played a significant role in shaping the city, and we wanted the names to reflect London's diverse culture and communities.

Making the network easier to navigate and more inclusive is a priority for both us and the Mayor. Naming the six routes of the London Overground aims to give customers, especially those unfamiliar with the network, more confidence to travel around London. Removing this barrier to travel could see more people choosing to travel sustainably, which would benefit the whole city.

We will be running an extensive campaign over the summer to help customers get familiar with the names. We have also enhanced our signage & wayfinding standards, so that signs include the line names and colour along with the Overground roundel.                

More information about the renaming can be found on our website:

https://tfl.gov.uk/modes/london-overground/overground-line-naming?intcmp=75262

You asked:

Under the Freedom of Information Act, please provide the following details in relation to the renaming of London Overground lines in February 2023:

•           The long list (or long lists) of names provided to TFL by the DNCO branding agency before the final six names were selected

In accordance with the FOI Act, we are not obliged to supply the requested information as this is subject to a statutory exemption to the right of access to information under section 22 of the Act. In this instance the exemption has been applied as the information you have requested is intended for future publication.

This exemption is subject to a public interest test, which requires us to assess whether the public interest in applying the exemption outweighs the public interest in disclosure. In this instance, it is considered that the public interest favours the publication of this information, in context and according to the pre-determined schedule, rather than in response to your request, to ensure the information is provided accurately and in an accessible manner.

•           For the period between 01/01/23- 16/02/24, any reports created by DNCO for TFL drawing on the former’s consultations (as stated by the company in press reports) with “leading historians, academics and transport specialists.”
•           For the period between 01/01/24- 16/02/24, all correspondence between DNCO and TFL

Unfortunately, to provide the information you have requested would exceed the ‘appropriate limit’ of £450 set by the FOI (Appropriate Limit and Fees) Regulations 2004.

Under section 12 of the FOI Act, we are not obliged to comply with a request if we estimate that the cost of determining whether we hold the information, locating and retrieving it and extracting it from other information would exceed the appropriate limit. This is calculated at £25 per hour for every hour spent on the activities described.

We have estimated that it would cost over £450 to provide a response to your current request. This is because it is estimated that it would take in excess of 18 working hours to retrieve and compile the information you have requested.

When requests for correspondence are received the FOI Case Management team may use a search tool which allows us to conduct company-wide email searches using keywords, dates and email addresses. The more specific a requester can be as to what they are looking for, 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. Each ‘hit’ is a single email, although that email will often consist of a chain of emails containing the search term at least once.

During the requested period we will have received and sent several emails regarding the renaming. The search results will likely include duplicates, as well as emails not caught by the request. However, we would need to manually review all of the emails identified by the search in order to extract and collate the relevant emails. In addition to any emails we would also have to identify and locate any other reports that we have received that relate to the renaming. This may require several teams to do a search for any information relevant to your request which would add to the time taken to process your request.

By their nature, emails contain a significant amount of personal data such as phone numbers and email addresses and so, whilst this process of redaction does not feature as part of our considerations on whether the cost limit might apply, the burden created by non-specific requests for emails is significant and this should be borne in mind before submitting requests of this nature.

The Information Commissioner describes such requests as “fishing expeditions” as the requesters “have no idea what information, if any, will be caught by the request”. Such requests are likely to be vexatious if they:
•           Impose a burden by obliging the authority to sift through a substantial volume of information to isolate and extract the relevant details;
•           Encompass information which is only of limited value because of the wide scope of the request;
•           Create a burden by requiring the authority to spend a considerable amount of time considering any exemptions and redactions;
•           Be part of a pattern of persistent fishing expeditions by the same requester.

We therefore strongly recommend you outline, as clearly and concisely as possible, precisely the information and types of document you require. Requests that lack a clear focus are more likely to lead to concerns about the processing time required to meet our obligations under the FOI Act.

To help bring the cost of responding to your request within the £450 limit, you may wish to consider narrowing its scope so that we can more easily locate, retrieve and extract the information you are seeking. If you want to refine your request or make a FOI Act request in future, please bear in mind that the FOI Act allows you to request recorded information held by us. You should identify the information that you want as clearly and concisely as you can, specifying the types of document that you are looking for. If there are specific questions you have then we may be able to provide a response to those.

Although your request can take the form of a question, rather than a request for specific documents, we do not have to answer your question if it would require the creation of new information or the provision of a judgement, explanation, advice or opinion that was not already recorded at the time of your request.
If this is not the information you are looking for, or if you are unable to access it for any reason, please do not hesitate to contact me.

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

Yours sincerely

Gemma Jacob
Senior FOI Case Officer
FOI Case Management Team
General Counsel
Transport for London

[email protected]

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