Information about the A20 speed limit reduction

Freedom of information request reference no: 01.FOI.24.038474

I note you seek access to the following information:

In an FOI request made of Transport For London regarding the A20 speed limit reduction, TFL have stated that the Metropolitan Police reviewed the traffic signs & road markings plan.

To confirm, my enquiry relates to the temporary speed limit reduction on the A20 eastbound carriageway east of cookham road leading to average speed cameras near the BP garage.

I request the following information please:

1. Other than the document titled 'RE-A20 nr Cookham_Reacted.PF' as provided in the TFL request referenced above. Is there any other communications/emails/assessment forms produced by MPS providing an opinion on compliance and enforcement capability of the traffic signage? If so please provide copies of these documents.
2. Please confirm the process followed as part of any assesments of the revised traffic signs. Was it a 'desk based' review of TFL's traffic signs plan and did it also include a site visit and inspection of final signage in-situ?
3. In reviewing the road signage scheme documentation supplied by TFL can you please confirm which plan you reviewed? It's important to note that TFL have shared a number of their plans in various FOI requests and they are different with no clear updates of document version controls for revisions. Please confirm the design number and date of the reviewed traffic plan document and provide a copy as was supplied to MPS for your review.

Decision

A Freedom of Information Act request is not a private transaction. Both the request itself, and any information disclosed, are considered suitable for open publication. This is because, under Freedom of Information, any information disclosed is released into the wider public domain, effectively to the world and not just to one individual.

Section 40(2)(3A)(a) - Personal Information - The requested information contains personal information; these are of named individuals, direct email addresses and phone numbers. We believe that the public release of this information on the MPS internet site via our Publication Scheme would provide persons intent on disrupting the work of the MPS with information that would assist them to do so. In this regard, a person with this intent would be likely to use this information to make inappropriate contact with these areas of the MPS which would impede upon the resources of these members of staff and cause disruption to the work of the MPS.

The provision to refuse access to information under Section 40(2)(a)(b) and (3A)(a) of the Act is both absolute and class based. When this exemption is claimed, it is accepted that harm would result from disclosure. There is accordingly no requirement to demonstrate what that harm may be in refusing access to information.

Section 40(2)(a)(b) of the Act provides that any information to which a request for information relates, is exempt information if the first condition of Section 40(3A)(a) is satisfied. The first condition of Section 40(3A)(a) states that personal information is exempt if its disclosure would contravene any of the data protection principles. If the disclosure of the requested personal data would not contravene the data protection principles, the disclosure must also not contravene Sections 3A(b) and 3B of the Act.

There are six principles that are set out in Article 5(1)(a) of the General Data Protection Regulations (UK GDPR) that dictate when the processing of personal data is lawful. The first principle requires that any processing of personal data must be lawful, fair and transparent. Under Article 6(1)(f) of the UK GDPR, the disclosure of personal data is considered to be lawful if:

a. There is a legitimate interest in the disclosure of that personal data.
b. The disclosure of the personal data is necessary to meet that legitimate interest.
c. The disclosure would not cause unwarranted harm to the data subject.

Whilst some individual members of the public may feel there is to some degree a legitimate interest in the disclosure of personal information, there is not an overwhelming legitimate interest in the full disclosure. The rationale for non-disclosure is therefore based on the fact there is little necessity to disclose these to meet a legitimate interest and that disclosure would cause unwarranted harm to the individual.

TfL provided drawings of road signage changes to us via email, document named as:

XXXXX-TFL-120-19-DRG-TR-0001
XXXXX-TFL-120-19-DRG-TR-0002
XXXXX-TFL-120-19-DRG-TR-0003
XXXXX-TFL-120-19-DRG-TR-0004
XXXXX-TFL-120-19-DRG-TR-0005
XXXXX-TFL-120-19-DRG-TR-0006
XXXXX-TFL-120-19-DRG-TR-0007
XXXXX-TFL-120-19-DRG-TR-0008

These documents contain personal information (named persons) that has been redacted.

In addition, names, email addresses and telephone numbers from the chain mail has been redacted.

Q1 - Other than the document titled 'RE-A20 nr Cookham_Reacted.PF' as provided in the TFL request referenced above. Is there any other communications/emails/assessment forms produced by MPS providing an opinion on compliance and enforcement capability of the traffic signage? If so, please provide copies of these documents.

Please see below a redacted chain mail titled ‘Redacted Emails.'

Q2 - Please confirm the process followed as part of any assessments of the revised traffic signs. Was it a 'desk based' review of TFL's traffic signs plan and did it also include a site visit and inspection of final signage in-situ?

A visit to the site and a video assessment was carried out by Police Officers in line with the Metropolitan Police’s Safety Camera Operations teams commissioning process. A review of the site is undertaken back in the office based on the video run through and allows the Police Officers to check the signage installed to see if it meets the requirements/guidance set out in The Traffic Signs Regulations and General Directions 2016 (TSRGD).

Q3 - In reviewing the road signage scheme documentation supplied by TFL can you please confirm which plan you reviewed? It's important to note that TFL have shared a number of their plans in various FOI requests and they are different with no clear updates of document version controls for revisions. Please confirm the design number and date of the reviewed traffic plan document and provide a copy as was supplied to MPS for your review.

TfL provided drawings of road signage changes to the Metropolitan Police via email, document named as XXXXX-TFL-120-19-DRG-TR-0001, XXXXX-TFL-120-19-DRG-TR-0002, XXXXX-TFL-120-19-DRG-TR-0003, XXXXX-TFL-120-19-DRG-TR-0004, XXXXX-TFL-120-19-DRG-TR-0005, XXXXX-TFL-120-19-DRG-TR-0006, XXXXX-TFL-120-19-DRG-TR-0007, XXXXX-TFL-120-19-DRG-TR-0008. The Metropolitan Police would still do a run through of the site to determine if the signage installed meets TSRGD.

Please find below a redacted copy.