Dear S. Deane

TfL Ref: 1018-1718

Thank you for your request received by Transport for London (TfL) on 31 July 2017.

Your request will be processed in accordance with the requirements of the Freedom of Information Act and our information access policy.

Your request will be processed by the Greater London Authority, TfL and its subsidiaries to provide you with a response in accordance with the Freedom of Information Act 2000 and our information access policy.

A response will be sent to you by 29 August 2017. We publish a substantial range of information on our website on subjects including operational performance, contracts, expenditure, journey data, governance and our financial performance. This includes data which is frequently asked for in FOI requests or other public queries. Please check http://www.tfl.gov.uk/corporate/transpar... to see if this helps you.

We will publish anonymised versions of requests and responses on the www.tfl.gov.uk website. We will not publish your name and we will send a copy of the response to you before it is published on our website.

In the meantime, if you would like to discuss this matter further, please do not hesitate to contact me.

Yours sincerely

Jasmine Howard
FOI Case Officer
Information Governance
Transport For London

show quoted sections

Dear S. Deane

TfL Ref: 1018-1718

Thank you for your email received by us on 29 July 2017 asking for
information about our preparations for the General Data Protection
Regulation.

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

However, in accordance with Section 17 of the Freedom of Information Act
we are still considering the balance of the public interest in relation to
a qualified exemption that applies to some of the requested information
and have not yet reached a conclusion. The exemption under consideration
is section 43’s commercial interests. It is estimated that a decision will
be reached by 26 September 2017 and I will write again to inform you of
that decision.

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

Jasmine Howard

FOI Case Officer

Information Governance

Transport For London

Dear S. Deane

TfL Ref: 1018-1718

Further to my previous email providing the covering letter to your Freedom
of Information request, please find attached the fourth file as part of my
response, with more to follow.

Yours sincerely

Jasmine Howard

FOI Case Officer

Information Governance

Transport For London

Dear S. Deane

TfL Ref: 1018-1718

Thank you for your email received by us on 29 July 2017 asking for copies
of documents created as part of our preparations for the General Data
Protection Regulation (GDPR).

Your request has been considered in accordance with the requirements of
the Freedom of Information (FOI) Act and our information access policy. We
do hold the information you require. You asked for:

any documents created as part of your organisation's preparations for the
General Data Protection Regulation.

For example, papers relating to any formal working/steering groups,
programme/project boards. This might include but is not limited to:

- minutes of meetings held;

- terms of reference;

- project/programme plans;

- gap analysis

Also, any guidance produced for staff, including information published on
Intranet sites.

Please find attached the requested documentation about how we our
preparing for the GDPR, which replaces the Data Protection Act 1998 (DPA)
from 25 May 2018. As a large ‘data controller’, we have already
disseminated a substantial volume of information in readiness for this new
legal framework. This includes tailored briefings and presentations, email
updates, intranet content and external guidance from the Information
Commissioner’s Office. Due to the volume of information, it is necessary
to send copies of these to you in more than one email.

Please note that in accordance with TfL’s obligations under the Data
Protection Act 1998 (DPA) we are not able to disclose some personal
information (including contact details) in the attached materials produced
by NCC Group and Herbert Smith Freehills, in accordance with 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’.

Additionally, information not covered by your request has been removed
from PDF file ‘2016-06-21-Exco GDPR paper’ located in zip file J.

In addition, exemptions S43(1) & S43(2) (Prejudice to Commercial
Interests) have been applied to some information in the attached NCC
Group papers, as disclosure of intellectual property and pricing
information would be likely to affect both TfL’s ability to secure best
value in any future procurement exercise for the associated services and
NCC Group’s pricing strategies and competitive advantage. The use of this
exemption is subject to an assessment of the public interest in relation
to the disclosure of the information concerned. In this instance, factors
in favour of disclosure, such as the general public interest in
transparency and openness are outweighed by the potential damage to the
effective operation of TfL’s procurement process leading to increases in
the cost to the public, either through taxation or increased fares. There
are a limited number of companies able to bid for such contracts and NCC
Group are likely to find themselves competing for similar contracts in the
future. Please note that in this instance, TfL did not chose to pursue the
attached data mapping proposal put forward by NCC Group.

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

Jasmine Howard

FOI Case Officer

Information Governance

Transport For London

Dear S. Deane

TfL Ref: 1018-1718

Further to my previous email in response to your Freedom of Information
request, please find attached the sixth file as part of my response, with
more to follow.

Yours sincerely

Jasmine Howard

FOI Case Officer

Information Governance

Transport For London

Dear S. Deane

TfL Ref: 1018-1718

Further to my previous email in response to your Freedom of Information
request, please find attached the fifth file as part of my response, with
more to follow.

Yours sincerely

Jasmine Howard

FOI Case Officer

Information Governance

Transport For London

Dear S. Deane

TfL Ref: 1018-1718

Further to my previous emails in relation to your Freedom of Information
request, attached are the remaining files for your response.

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

Jasmine Howard

FOI Case Officer

Information Governance

Transport For London