London Underground Wifi Data Trial

Mark Reynolds made this Freedom of Information request to Transport for London

This request has been closed to new correspondence from the public body. Contact us if you think it ought be re-opened.

The request was successful.

Dear Transport for London,

In relation to the recently announced Wifi Data Trial (the "Trial") to take place on London Underground, please could TfL provide me with any information held relating to:
- any impact assessments or other documentation held considering the privacy and human rights impacts of engaging in the Trial;
- any documentation held considering the Trial's compliance with applicable laws and regulations;
- any decision (and any related correspondence or documentation) made by TfL in deciding to proceed with the Trial; and
- any correspondence with external stakeholders, such as the Wifi service provider, or with external regulators, including the ICO.

Yours faithfully,
Mark Reynolds

FOI, Transport for London

Dear Mr Reynolds

 

TfL Ref: FOI-1676-1617

 

Thank you for your email received by Transport for London (TfL) on 23
November 2016.

 

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

 

A response will be provided to you by 22 December 2016.

 

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
[1]http://www.tfl.gov.uk/corporate/transpar... to see if this helps you.

 

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

 

Yours sincerely

 

Eva Hextall

FOI Case Officer

 

FOI Case Management Team

General Counsel

Transport for London

 

 

 

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FOI, Transport for London

1 Attachment

Dear Mr Reynolds

 

TfL Ref: FOI-1676-1617

 

Thank you for your email received by Transport for London (TfL) on 23
November 2016.

 

Your request his 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 the requested information and have
not yet reached a conclusion. The exemption under consideration is section
43. It is estimated that a decision will be reached by 25 January and I
will write again to inform you of that decision.

 

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

 

Yours sincerely

 

Lee Hill

Senior FOI Case Officer

 

FOI Case Management Team

General Counsel

Transport for London

 

 

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FOI, Transport for London

11 Attachments

Dear Mr Reynolds

 

TfL Ref: FOI-1676-1617

 

Thank you for your email received by Transport for London (TfL) on 23
November 2016.

 

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.

 

Between Monday 21 November and Monday 19 December 2016 (inclusive), we
collected WiFi connection data from mobile devices using the station WiFi
at 54 Tube stations in central London
[1]https://tfl.gov.uk/campaign/station-wifi. We will not use this data to
identify individuals or monitor browsing activity. More information about
this pilot is available at the dedicated website we have launched for the
pilot
[2]https://tfl.gov.uk/corporate/privacy-and...
and in the press release
[3]https://tfl.gov.uk/info-for/media/press-....

 

The WiFi pilot is an internal initiative and has been developed by an
in-house TfL team using our existing infrastructure. For the pilot we
developed our own method and software for collecting data from our the
access points. We store the pseudonymised and encrypted MAC addresses, the
date and time of the connection, the device connection status and the
individual access point they connected to, and therefore the London
Underground station and location within a station where the device
connected. A high level technical document “WiFi Pilot Data Capture and
Storage” is attached. A number of products are available that offer a
similar functionality.

 

We met the Information Commissioner’s Office (ICO) to brief them on the
proposal in August. I have attached both the paper we sent to the ICO
prior to the meeting and the poster that we discussed with them. This
poster was in development when we met the ICO and we have since changed
some wording whilst maintaining the same approach that we presented to the
ICO. The hardware and networks for the assets that enable this WiFi
connectivity are supported by contracted external organisations (Fujitsu
and Halo). We held a meeting with representatives of these service
providers to discuss the technical ability of collecting data using our
current infrastructure. No documentation on the project was shared with
these organisations and no meeting minutes taken.

 

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’.

 

Additionally, in accordance with the FOI Act, we are not obliged to supply
some of the information as it is subject to a statutory exemption to the
right of access to information under section 43(2).

 

In this instance the exemption has been applied as disclosure of pricing
information, as well as details regarding our own software development, is
likely to negatively affect our commercial interests. The scheme is
currently only a pilot and the costs are just indicative, rather than
actual, and so disclosure of costs at this stage would negatively affect
the procurement process if this is rolled out more widely. Provision of
the information would be likely to lead to suppliers making their decision
whether to bid, and if so at what price-point, based on information that
is not likely to be representative of the true market value. Provision of
these costs would hinder our ability to obtain best value for money in any
future tendering process.

 

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,
but in this instance feel that balance lies in favour of withholding the
information you have requested to ensure that we are in the best position
possible to obtain best value for money for similar schemes, as well as
for any future tender processes that may occur as a result of decisions
taken at the conclusion of this pilot.

 

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

Senior FOI Case Officer

 

FOI Case Management Team

General Counsel

Transport for London

 

 

 

 

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FOI, Transport for London

1 Attachment

  • Attachment

    2016 11 17 TfL WiFi data connectivity pilot Data Privacy Impact Assess....pdf

    8.0M Download View as HTML

 

 

From: FOI
Sent: 24 January 2017 09:24
To: '[FOI #373181 email]'
Subject: FOI-1676-1617 - Part 1 of 2

 

Dear Mr Reynolds

 

TfL Ref: FOI-1676-1617

 

Thank you for your email received by Transport for London (TfL) on 23
November 2016.

 

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.

 

Between Monday 21 November and Monday 19 December 2016 (inclusive), we
collected WiFi connection data from mobile devices using the station WiFi
at 54 Tube stations in central London
[1]https://tfl.gov.uk/campaign/station-wifi. We will not use this data to
identify individuals or monitor browsing activity. More information about
this pilot is available at the dedicated website we have launched for the
pilot
[2]https://tfl.gov.uk/corporate/privacy-and...
and in the press release
[3]https://tfl.gov.uk/info-for/media/press-....

 

The WiFi pilot is an internal initiative and has been developed by an
in-house TfL team using our existing infrastructure. For the pilot we
developed our own method and software for collecting data from our the
access points. We store the pseudonymised and encrypted MAC addresses, the
date and time of the connection, the device connection status and the
individual access point they connected to, and therefore the London
Underground station and location within a station where the device
connected. A high level technical document “WiFi Pilot Data Capture and
Storage” is attached. A number of products are available that offer a
similar functionality.

 

We met the Information Commissioner’s Office (ICO) to brief them on the
proposal in August. I have attached both the paper we sent to the ICO
prior to the meeting and the poster that we discussed with them. This
poster was in development when we met the ICO and we have since changed
some wording whilst maintaining the same approach that we presented to the
ICO. The hardware and networks for the assets that enable this WiFi
connectivity are supported by contracted external organisations (Fujitsu
and Halo). We held a meeting with representatives of these service
providers to discuss the technical ability of collecting data using our
current infrastructure. No documentation on the project was shared with
these organisations and no meeting minutes taken.

 

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’.

 

Additionally, in accordance with the FOI Act, we are not obliged to supply
some of the information as it is subject to a statutory exemption to the
right of access to information under section 43(2).

 

In this instance the exemption has been applied as disclosure of pricing
information, as well as details regarding our own software development, is
likely to negatively affect our commercial interests. The scheme is
currently only a pilot and the costs are just indicative, rather than
actual, and so disclosure of costs at this stage would negatively affect
the procurement process if this is rolled out more widely. Provision of
the information would be likely to lead to suppliers making their decision
whether to bid, and if so at what price-point, based on information that
is not likely to be representative of the true market value. Provision of
these costs would hinder our ability to obtain best value for money in any
future tendering process.

 

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,
but in this instance feel that balance lies in favour of withholding the
information you have requested to ensure that we are in the best position
possible to obtain best value for money for similar schemes, as well as
for any future tender processes that may occur as a result of decisions
taken at the conclusion of this pilot.

 

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

Senior FOI Case Officer

 

FOI Case Management Team

General Counsel

Transport for London

 

 

 

 

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