Information about Customer Service Software

Dear R Benckiser,

TfL Ref: 1410-2223

Thank you for your email received by us on 9 September 2022.

We will aim to issue a response by 7 October 2022 in accordance with the Freedom of Information Act 2000 and our information access policy.

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
FOI Case Management Team
General Counsel
Transport for London
 

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Dear R Benckiser,

TfL Ref: 1410-2223

Thank you for your email received by us on 9 September 2022 asking for
information about software used by ticket office staff at TfL stations
from 1990-2022.

Your request has been considered in accordance with the requirements of
the Freedom of Information Act and our information access policy.  I can
confirm that we hold some of the information you require. You asked for:

the software used by ticket office staff at TfL stations. Please cover the
period 1990-2022.

For example, if a customer had an issue with an Oyster card c.2015, they
would go to a ticket window, present their Oyster Card and the customer
service assistant would then use a computer to triage the issue/sell
tickets etc. What software would staff have been using?

I would be particularly interested in the System Functional Design
document for the customer service platform and/or software. Areas of
interest will include the operating system and point-of-sale hardware in
use.

Whilst we only hold data going back to 2003, when the current Oyster
software applications in place were deployed, we can advise that the
information you are seeking is exempt from disclosure under section 43(2)
of the FOI Act. In this instance the section 43(2) exemption has been
applied as disclosure would, or would be likely to prejudice the
commercial interests of Transport for London and those participating in
our smart ticketing revenue collection bidding process. The unique Proteus
procurement bidding process, which this revenue collection tendering
process refers to, takes place in tightly controlled conditions, where
information is displayed solely on screen with no electronic devices
allowed in the room due to the highly sensitive commercial nature of these
proceedings.

Disclosure of the information you have requested would damage the
commercial interests of both bidders and TfL since it would enable
competitors in this market to access content relating to, for example,
system functional design, inclusive of the operating system and
point-of-sale hardware in use, which could then be used to develop similar
specialist technology without incurring many of the set-up and development
costs. If public authorities were unable to offer some protection for
third party intellectual property, the likely outcome of releasing this
information to their competitors could compromise and prejudice the
commercial interests of market participants in this field which in turn
would have a detrimental effect on future tender opportunities and the
overall outcome for the public purse.

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,
particularly where the expenditure of public money is concerned, but in
this instance the public interest is in ensuring TfL can attract bids from
the best companies, and that these companies are able and willing to bid
for contracts without their intellectual property being shared. This in
turn outweighs the general public interest in increasing transparency of
our processes.

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 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

FOI Case Management Team

General Counsel

Transport for London

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TfL Ref: IRV-057-2223

Thank you for your email which was received by Transport for London (TfL) on 3 October 2022.

You have expressed that you are dissatisfied with the handling of your request for information under the Freedom of Information Act.

A review will be conducted by an internal review panel in accordance with TfL’s Internal Review Procedure, which is available via the following URL:
https://tfl.gov.uk/corporate/transparenc...

Every effort will be made to provide you with a response by 31 October 2022. However, if the review will not be completed by this date, we will contact you and notify you of the revised response date as soon as possible.

In the meantime, if you would like to discuss this matter further, please feel free to contact me.

Yours sincerely
Emma Flint
Principal Information Access Adviser
FOI Case Management Team
Transport for London

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Dear R Benckiser

I am contacting you regarding your request for an internal review
concerning the response provided to FOI-1410-2223. Following your email of
3 October 2022 a review has been carried out by an Independent Review
Panel (‘the panel’) consisting of individuals who were not involved in the
handling of your request. During the course of this review the panel have
liaised with Head of Payments Products Transformation regarding the
information that you seek.

To confirm you asked for the following -

I would like to request information regarding the software used by ticket
office staff at TfL stations. Please cover the period 1990-2022.

For example, if a customer had an issue with an Oyster card c.2015, they
would go to a ticket window, present their Oyster Card and the customer
service assistant would then use a computer to triage the issue/sell
tickets etc. What software would staff have been using?

I would be particularly interested in the System Functional Design
document for the customer service platform and/or software. Areas of
interest will include the operating system and point-of-sale hardware in
use.

Firstly the panel agree that in the first instance when you made your FOI
request on the 9 September it was wide in scope and vague as to what
specific information and / or documentation you were seeking, as you were
alluding to ‘areas of interest’ leaving it open to interpretation as to
what information would be of importance to you.

Section 8 of the FOIA outlines the following –

To be valid under Section 8 a request must:

o be in writing;

o include the requester’s name and an address for correspondence; and,

o describe the information being requested.

A description will be valid if it contains sufficient detail for the
requested information to be distinguished from other information held by
the authority. However if the description of the information is unclear or
ambiguous, the authority must ask the requester for further clarification
in accordance with Section 1(3) of the Act.

As your request was vague and ambiguous as to what specific documentation
you were seeking and covered a period of 22 years, this alone immediately
warranted further clarification to be sought by the FOI Case Management
Team from you regarding what you were specifically requesting, as
essentially your request was ‘a needle in a haystack’ scenario. Therefore
the panel agree that without the required clarification in this instance
s43 was applied somewhat erroneously due to the fact that is was unclear
as to what you were actually seeking leaving it open to a wide
interpretation.  Clarification should have been sought from you and the
panel apologises that this was not done straight away and for any
inconvenience caused..

Given the above explanation regarding more specificity around what you are
seeking, if you are considering a revised request it should be noted that
following discussions with the Head of Payments Products Transformation as
part of this review, it is also clear that there are significant
confidentially issues concerning information disclosure about the software
used at TfL’s stations and the Intellectual Property Rights (IPR) that
surround it. Post 2003 the system we currently use is not actually owned
by TfL. The IPR for the underlying system is owned solely by the
contractor and we only make the documentation available on a ‘need to
know’ basis under very controlled circumstances (usually in a data room
with no access to IT) due to our obligations to protect the IPR of our
contractor. This heavily restricted access has been the process since its
installation in 2003 and whilst the software has been modified since this
date, it is underpinned on the same system as was installed then.

Attached is an extract from the current contract regarding IPR on the
proprietary system. As disclosures made under the Freedom of Information
Act are deemed to be ‘disclosures to the world at large’ any request for
this information will require serious consideration as to whether
disclosures regarding the detailed design of this system would likely
result in legal action being taken against TfL by the system owner and
that any form of legal defence would be done so at the cost of the public
purse.

With regards to the name of the software used, it is proprietary software
that was provided by our third party service provider Cubic. We are
unaware of what name is given to the software specifically.

I hope the above response has provided a better clarity regarding the
information you seek, however if you are dissatisfied with the internal
review actions to date please do not hesitate to contact me or alternately
you can refer the matter to the independent authority responsible for
enforcing the Freedom of Information Act, at the following address:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire SK9 5AF

A complaint form is also available on the ICO’s website
([1]www.ico.org.uk).

Yours sincerely

Emma Flint

Principal Information Access Adviser

FOI Case Management Team

Transport for London

[2][TfL request email]

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