Dear Northern Ireland Transport Holding Company,

This is a Freedom Of Information Act 2000 request.

I would like to request copies of the sound files of all of your automated announcements that are used at your stations and onboard your trains please.

This should include all of the following automated announcements sound files:

• Station Announcements - Atos Worldline - current station announcements used at Translink Northern Ireland Railways stations - voiced by Anne Jermy

• Onboard Announcements - current announcements used onboard the Class 3000 and Class 4000 and Enterprise Loco Hauled Set trains - voiced by Kathy Clugston

If you have them in MP3 or WAV format or as ZIP files containing MP3 or WAV format that would be the best but any other format you have is fine too.

Thank you in advance for your help and i hope to hear back within twenty working days.

Yours faithfully,

David Smith

Dear FOI,

Thank you for your reply to my request. I would like to please request an Internal Review in to my request and your refusal of it. I would like to point out two different parts the i would like to dispute in regards to your decision to refuse this request.

Firstly in regards to your onboard announcements i do not believe that S43(2) could be used here as i believe that the sound files are owned by yourself. Your station announcements are provided by Atos Worldline and i believe the files are owned by them so i can sort of see why you have used S43(2) as the files are not owned by yourself. But this is only your station announcements and Atos Worldline have nothing to do with your onboard announcements. So for the sound files of your onboard announcements these are owned by you so i believe that you should be able to release your onboard files without issue. I do not think S43(2) can apply to your onboard files.

Secondly in regards to your station announcements i do not believe that S43(2) is really valid here either. Yes the announcements are owned by Atos Worldline however i fail to see how releasing the sound files could prejudice commercial interests. This is because these sound files are specific to Translink and could not be used by any other company other than Translink so there is really no way that any prejudice to commercial interests could possibly occur. There is nowhere else that these sound files could be used because they are specific to your company only. Additionally should a competitor want to copy announcements you should note that they can be heard playing over the speakers at railway stations so they are sort of in the public domain already. So it is not exactly hidden. The announcements can be heard by the public but it is just the actual individual files that are not available. Plus also as i say these are specific to you so no competitor would have any reason to copy the sound files as they would have no use for them. I do not believe that there is any possible way that releasing the station announcement sound files could cause a prejudice of commercial interests to occur to Atos Worldline at all.

I would also like to point out that in England and Wales and Scotland many train operators (including, Network Rail, London North Eastern Railway, Caledonian Sleeper, Scotrail, Trans Pennine Express, Northern, Southeastern, Transport For Wales, Transport For London, Manchester Metrolink, Tyne & Wear Metro, etc) have released many sound files (both onboard files and station files) under the FOIA and this includes files that are owned by third party contractors. Some of these files are owned by the train companies but many of the files that were released are owned by other suppliers. So the fact that so many other of these train operators have released their sound files indicates that the risk of commercial prejudice occurring to suppliers by releasing sound files is basically zero.

I believe that you should be able to release all of your onboard announcement files and station announcement files without issue. If you could please kindly carry out an Internal Review in to this that would be very much appreciated. I look forward to hearing back from you once the Internal Review has been carried out.

Yours sincerely,

David Smith

Dear FOI,

Please could i get an update on this Internal Review that you are carrying out. I was supposed to get a reply by yesterday at the latest as yesterday was the last day of the twenty working days. No worries if you are still looking in to it but just wondering if you had an update please. Thank you very much.

Yours sincerely,

David Smith

Dear FOI,

Thank you very much for your Internal Review response in regards to my request.

It is disappointing you have now introduced a new S38 exemption. Originally you only used S43 and my Internal Review request was therefore solely to dispute your S43 exemption. It was pointless for me to request an Internal Review because instead of looking in to S43 and why it is not valid you have just issued a new S38 exemption instead. So now you have only introduced S38 after conducting an Internal Review it means that i have had no opportunity to dispute S38 directly to you. I have no way to dispute S38 directly to you now. So my one and only option is to go to the Information Commissioner Office to dispute your S38 application.

I have now written a formal complaint to the Information Commissioner Office as i strongly disagree with the S38 exemption and do not believe that it is valid. A copy of my complaint to the Information Commissioner Office is attached below where i set out the reasons on why i disagree with your S38 application. I shall now await the response of the Information Commissioner Office so they can look in to this.

Thank you and i shall now await to hear back from the Information Commissioner Office regarding this so that they can make a decision as an independent authority to this request.

Yours sincerely,

David Smith

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

Dear sir or madam.

Good afternoon.

I would like to submit a complaint regarding Northern Ireland Transport Holding Company (also known as Translink or as Northern Ireland Railways in relation to their railway division) and i would like to complain about their response to my FOIA request and subsequent Internal Review request.

The link to my request is below:

https://www.whatdotheyknow.com/request/s...

My request number is FOI1347 for this FOI request and subsequent Internal Review request.

I made a request to Translink asking for the sound files of their onboard automated announcements and station automated announcements.

My full request is below:

""""

I would like to request copies of the sound files of all of your automated announcements that are used at your stations and onboard your trains please.

This should include all of the following automated announcements sound files:

• Station Announcements - Atos Worldline - current station announcements used at Translink Northern Ireland Railways stations - voiced by Anne Jermy

• Onboard Announcements - current announcements used onboard the Class 3000 and Class 4000 and Enterprise Loco Hauled Set trains - voiced by Kathy Clugston

If you have them in MP3 or WAV format or as ZIP files containing MP3 or WAV format that would be the best but any other format you have is fine too.

Thank you in advance for your help and i hope to hear back within twenty working days.

""""

Translink replied but refused them under the S43 exemption regarding information where disclosure would be likely to prejudice commercial interests.

I then submitted an Internal Review arguing that for the onboard announcements S43 is not valid at all and for the station announcements it does not meet the threshold for S43 to be used.

My full Internal Review is below:

""""

Thank you for your reply to my request. I would like to please request an Internal Review in to my request and your refusal of it. I would like to point out two different parts the i would like to dispute in regards to your decision to refuse this request.

Firstly in regards to your onboard announcements i do not believe that S43(2) could be used here as i believe that the sound files are owned by yourself. Your station announcements are provided by Atos Worldline and i believe the files are owned by them so i can sort of see why you have used S43(2) as the files are not owned by yourself. But this is only your station announcements and Atos Worldline have nothing to do with your onboard announcements. So for the sound files of your onboard announcements these are owned by you so i believe that you should be able to release your onboard files without issue. I do not think S43(2) can apply to your onboard files.

Secondly in regards to your station announcements i do not believe that S43(2) is really valid here either. Yes the announcements are owned by Atos Worldline however i fail to see how releasing the sound files could prejudice commercial interests. This is because these sound files are specific to Translink and could not be used by any other company other than Translink so there is really no way that any prejudice to commercial interests could possibly occur. There is nowhere else that these sound files could be used because they are specific to your company only. Additionally should a competitor want to copy announcements you should note that they can be heard playing over the speakers at railway stations so they are sort of in the public domain already. So it is not exactly hidden. The announcements can be heard by the public but it is just the actual individual files that are not available. Plus also as i say these are specific to you so no competitor would have any reason to copy the sound files as they would have no use for them. I do not believe that there is any possible way that releasing the station announcement sound files could cause a prejudice of commercial interests to occur to Atos Worldline at all.

I would also like to point out that in England and Wales and Scotland many train operators (including, Network Rail, London North Eastern Railway, Caledonian Sleeper, Scotrail, Trans Pennine Express, Northern, Southeastern, Transport For Wales, Transport For London, Manchester Metrolink, Tyne & Wear Metro, etc) have released many sound files (both onboard files and station files) under the FOIA and this includes files that are owned by third party contractors. Some of these files are owned by the train companies but many of the files that were released are owned by other suppliers. So the fact that so many other of these train operators have released their sound files indicates that the risk of commercial prejudice occurring to suppliers by releasing sound files is basically zero.

I believe that you should be able to release all of your onboard announcement files and station announcement files without issue. If you could please kindly carry out an Internal Review in to this that would be very much appreciated. I look forward to hearing back from you once the Internal Review has been carried out.

""""

Translink then replied to my Internal Review using a new exemption S38 which they did not use originally. So my internal review was regarding S43 but now they have issued their internal review response and are instead using a new exemption which was not originally used. So unfortunately i never had a chance to dispute S38 to them as they have only used S38 after issuing my Internal Review response which i made in regards to their S43 using.

I strongly disagree that S38 is valid in regards to my request. For S38 to apply it must be demonstrated that releasing such files would endanger the safety of any individual. I do not believe there is any evidence that releasing these files would endanger the safety of any individual.

Translink have stated the following:

"It is not difficult to envisage how these files could be used by individuals who wish to cause alarm, disruption or other harm to our customers, staff and network, for example, by broadcasting the announcements on a train or in a station."

I strongly disagree with this. In the mainland where many files have been released there is no record of any such incident happening. In addition if someone was to play these over their own speakers it would be very obvious that they were not coming from the normal speakers on the trains and at the stations. Plus anyone wanting to cause disruption could record such announcements themselves at the station or onboard the train using their phone or recording device. Or they could download the many recordings of Translink announcements on Youtube and use those. So if someone really wanted to cause disruption they could just do this. Plus there is not really anything that someone could achieve by playing these automated announcements at stations and on trains.

Their use of the S38 exemption also makes no sense when you consider that pretty much every other train company subject to FOI has released their sound files without issue.

So far the following train companies have all released their automated announcement sound files under FOI legislation:

• Blackpool Transport
• Caledonian Sleeper
• Croydon Tramlink
• Docklands Light Railway
• Edinburgh Tram
• Elizabeth Line
• Glasgow Subway
• Irish Rail
• London Buses
• London North Eastern Railway
• London Overground
• London Underground
• Lothian Buses
• Manchester Metrolink
• Network Rail
• Nottingham Express Transit
• Scotrail
• Southeastern
• Trans Pennine Express
• Transport For Wales
• Tyne & Wear Metro

These files released by the above companies contain many sensitive and security announcements such as evacuation announcements and other emergency announcements. There is a huge amount that has been released but if you want to see and review the files that other companies have released than let me know and i can attach some of them.

Also it should be noted that the security announcements used by all train operators follows the same or very similar script. So by releasing these files Translink are not exactly giving access to anything that can not be found elsewhere.

As for the claim that these announcements could be played on personal devices and speakers at stations and onboard trains to cause disruption. There is not one single record of anything like this happening. Therefore i do not believe this is a significant risk.

So the question that must be asked is how Translink is any different to these other companies who have all released such files. If all of these other companies are releasing them and not using S38 then i think that is a clear indication that S38 is not valid. I do not think that Translink can justify this refusal when a huge number of other companies have released their files. It is also worth noting that all of the files released above contain plenty of security announcements and evacuation announcements.

Now i do of course understand that Northern Ireland has a bit of a different history compared to the mainland and the railways have previously been subject to attack during the troubles. I lived in Northern Ireland during this period so i understand the issues very well. However it is 2023 now. This type of thing is no longer a significant threat as it used to be. Attacks on the railway have not happened for decades. It is 2023 and we are not in the 1980s any more but yet Translink are still acting like we are. In fact most people would say that these days the mainland rail network in England is now far more at risk than the Northern Ireland network.

I think anyone with knowledge on security and terrorism risks would understand that the Transport For London network is far more at risk these days. But yet Transport For London have released over 30,000 almost 40,000 sound files from their trains and stations across their network without issue. This includes all of their safety and evacuation announcements. This is an indication that these sound files do not pose a safety risk as they would not have been released otherwise. There is really nothing that somebody could do should they get hold of these.

I would also like to advise that Transport For Wales had also attempted to use the S38 exemption a couple years ago to refuse automated announcement sound files but after an Internal Review complaint was made this was found to not be a valid exemption and Transport For Wales subsequently removed the S38 exemption and released their TrainFX onboard announcement sound files.

Additionally if Translink are going to continue to uphold that S38 is valid (which i strongly disagree with as i do not think S38 is valid here) then they can simply just remove the files that are of concern. The vast majority of the sound files contain just the ordinary every day announcements about the trains and the calling points etc.

This is called redacting and is the same as how many authorities will redact and black out text on documents that contain sensitive and security information rather than refusing the entire document.

So they could simply just remove the small amount of sound files that are relating to security and safety and evacuations etc and this would then remove their concerns.

I strongly disagree that S38 applies and would like all files released (including the security announcements etc) but if you are going to uphold that S38 is valid then Translink can just simply remove the few files that are of concern. By removing these few files it will remove the S38 exemption. So this would be a satisfactory solution in the event that S38 is upheld as removing these few files would remove the S38 concern that Translink have.

Please could you kindly conduct a review in to their response as i would like Translink to comply with my request and release the station automated announcements sound files and the onboard automated announcements sound files as requested.

Once again the full link to my request is below:

https://www.whatdotheyknow.com/request/s...

Thank you for your help and i hope to hear back regarding a review in to their response.

Let me know if you have any other questions or clarifications regarding this.

Thank you.

Kind regards.

David Smith

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~