Hi Uber informed TFL in writing of changes to their operating model on 31/08/17 07/09/17 30/10/17 06/11/17 (ref foi 2944 1718) Can you now please supply all copies of the correspondence between TFL and Uber that relate to the changes of ubers operating model on those dates please?

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TfL Ref: FOI-4582-1718

Thank you for your request received by Transport for London (TfL) on 19 February 2018 asking for correspondence between TfL and Uber.

Regulation 9(13) of the Private Hire Vehicles (London) (Operators' Licences) Regulations 2000 provides that: 'The operator shall notify the licensing authority of any material changes to its operating model that may affect the operator's compliance with the 1998 Act, these Regulations or any conditions of that operator's licence, before those changes are made.'

We consider an operating model to be the means by which an operator offers, accepts and delivers private hire vehicle services.

A material change is something which has more than a minor impact on the operating model. For example, it might relate to how passengers engage with operators, how bookings are accepted, what services are delivered and how they're delivered. For more information, please visit our online guidance for private hire operators.

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

Please see the information you have requested attached. Whilst collating this information it became apparent that we had mistakenly omitted an additional date (9 January 2018) that should have been provided to your previous request (FOI-2944-1718). We have therefore processed this request to include that information. Please accept my apologies for this oversight.

Please note that, in accordance with the FOI Act, we are not obliged to supply some information as it is subject to a statutory exemption to the right of access to information under section 43(2). Specifically this relates to an internal risk assessment prepared by Uber for their own internal purposes, as well as information regarding their processes at specific locations, and shared with us to inform of the considerations made. Disclosure of information about the business processes employed by private companies is likely to prejudice the commercial interests of those companies if it is disclosed to the wider public, which would include business competitors.

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 that there is a public interest in openness and transparency, particularly in relation to Taxi and Private Hire compliance. However we feel that the balance of public interest is weighted in favour of the exemption to ensure that operators can continue to share detailed commercially sensitive information in relation to operating model changes without their interests being harmed by disclosure of this information to competitors. Application of this exemption also ensures that TfL is able to engage effectively and without hindrance with operators who need to discuss changes to their operating model and we consider this enhances the public interest in withholding the information.

Lastly, please note that in accordance with TfL’s obligations under the Data Protection Act 1998 (DPA) some personal data has been removed, as required by section 40(2) of the FOI Act. This is because disclosure of this personal data would be a breach of the DPA, specifically the first principle of the DPA 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 of Schedule 2 of the Data Protection Act which would make the processing ‘fair’.

If this is not the information you are looking for, or if you are unable to access it for some reason, please do not hesitate to contact me.

Please see the attached information sheet for details of your right to appeal as well as information on copyright and what to do if you would like to re-use any of the information we have disclosed.

Yours sincerely

Lee Hill

Information Access Manager

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