Dear Transport for London,
you approved miwhip to launch an app in london , do you have a record of the app presentation doduments which they submitted to you before their approval? can you please share this.
Dear Mr King
TfL Ref: 0736-1920
Thank you for your request received by Transport for London (TfL) on 10
June 2019 asking for information about Miwhip.
Your request will be processed in accordance with the requirements of the
Freedom of Information Act and our information access policy.
A response will be sent to you by 8 July.
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.
FOI Case Management Team
Transport for London
Dear Mr King
Our Ref: FOI-0736-1920 / FOI-0747-1920
Thank you for your requests received on 10 and 12 June 2019 asking for
information about the ride-hailing apps, miwhip, Kapten, and Bolt.
Your request has been considered in accordance with the requirements of
the Freedom of Information (FOI) and our information access policy. We do
hold the information you require.
We have met with Bolt on four occasions, two of which related to the
technical review of their proposed solution. We met with Kapten on five
occasions, one of which related to the technical review of their proposed
We have not discussed either Bolt or Kapten with Uber.
In accordance with the FOI Act, we are not obliged to supply the
communications we have had with Kapten or Bolt, or the presentation
materials that Kapten, Bolt, or miwhip have shared with us as it is
subject to a statutory exemption to the right of access to information
under section 31(1)(g), which relates to information where disclosure
would be likely to prejudice the exercise by any public authority of its
functions for any of the purposes listed in subsection 31(2) of the FOI
Act, specifically, ‘(2)(c)the purpose of ascertaining whether
circumstances which would justify regulatory action in pursuance of any
enactment exist or may arise’.
In this instance the exemption has been applied as the information is held
only for the purposes of ascertaining whether a Private Hire operator is
complying with the regulations, in accordance with our responsibility for
regulating the private hire trade in London. This information contains
details which otherwise would not have been made available to us and the
exemption applies to protect our ability to clarify and confirm details on
specific issues regarding general licensing concerns. The prejudice would
be caused by disclosure because it would affect our ability to engage with
the taxi and private hire trade and would inhibit the free flow of
information, particularly where there is disclosure of information about
confidential and commercially sensitive data. Effective working between
the trade and the regulator relies on a safe space where information can
be shared at a sufficiently early stage to avoid the need for formal
Additionally, disclosure of information about the business processes
employed by private companies is also likely to prejudice the commercial
interests of those companies if it is disclosed to the wider public, which
would include business competitors. This information would also therefore
be covered by section 43(2) of the FOI Act which exempts information where
disclosure would be likely to prejudice commercial interests. Provision of
commercially sensitive information that was provided to us in the context
of our position as licensing authority would provide business competitors
with an insight into the management and commercial processes of Kapten,
Bolt, and miwhip which would place them at an unfair disadvantage.
We recognise that there is a large amount of interest from the public and
the taxi and private hire trade. Our decisions potentially affect the
livelihoods and choices of many people who live and work in London, and as
a public authority with a regulatory role, we expect our decision making
to be transparent and open to scrutiny. Although there is considerable
interest in this matter, it should be borne in mind that this information
is held by us in the context of our role as the licensing authority of
London’s taxi and private hire trade.
Disclosure in these circumstances would be likely to prejudice our ability
to exercise our regulatory functions efficiently and effectively,
particularly in the context of investigations, as the investigated party
would be less likely to co-operate if a running commentary or detailed,
commercially sensitive material were to be given out through FOI
disclosures. Effective working between the trade and the regulator relies
on a safe space where information can be shared at a sufficiently early
stage, which may avoid the need for formal enforcement action. Even if
enforcement action is required, the relatively free exchange of
information is useful to all parties.
These exemptions benefit the public as it enables greater oversight of the
trade and better scrutiny of services by the regulator and our benefit
because proactive discussion avoids costly enforcement activity, delayed
access to information and increased bureaucracy. Finally, the taxi and
private hire trade benefit from being able to share information in
confidence because it allows them to provide full answers to regulatory
matters whilst protecting their commercial interests.
We acknowledge that there is a public interest in understanding the scope
of regulatory activity, and whether concerns have been sufficiently
addressed, we consider that the balance of the public interest supports
the use of these exemptions in order to enable the effective and timely
sharing of information between TfL and the taxi and private hire trade.
There is also a very strong public interest in preserving TfL’s ability
to act as an effective regulator (through the sharing of information),
which ensures that the services offered by the trade are safe and
Please see the attached information sheet for details of your right to
Senior FOI Case Officer
FOI Case Management Team
Transport for London
[TfL request email]
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