This page contains information relating to some specific questions I asked about the
==== Background ====
In trying to find facts about the OysterCard, I found that the TFL website (and so-called FAQ section) had very little information about privacy, or lack thereof. It didn't seem to have any details about how Oyster information is used, or indeed what privacy one loses in using the card. A few other news sites, and private blogs seemed to have anecdotal evidence of various things, but nothing I was able to verify.
I decided to do something about it. I sent a letter (on the 10th March) the Oyster Central Customer Services asking a series of questions. Today (20th April), I received a response (dated 13th April), which has been dealt with under the Freedom of Information Act, 2000. Unlike the Home Office, TFL were very forthcoming with information.
==== Request and Response ====
I've listed my request and their response to each below:
====== Question 1. ======
It has been reported in the Press that TFL has given the Police (and presumably MI5, MI6 etc.) travel information for Oyster Card holders. Is this True?
You have asked if Transport for London (TfL) has provided the police with customer travel information, specifically collected via their Oyster cards. I can confirm that we have released Oyster card information to the police. TfL's disclosure of personal information is carried out in accordance with the requirements of the Data Protection Act 1998 and assessed on a case by case basis. All police requests must be submitted in accordance with guidance from the Association of Chief Police Officers and are coordinated by TfL's Information Access and Compliance Team.
Any public sector organisation can request access to Oyster card information if they are able to cite appropriate statutory authority. However any such requests would, again, be assessed strictly in accordance with the requirements of the Data Protection Act on a case by case basis.
Please note that a limited number of authorised individuals within TfL can access Oyster card data and no external organisations have direct access to the data. There are no bulk disclosures of personal data to any public sector or commercial organisations.
====== Question 2 ======
If so, to what extent? (e.g. How many times in the last year?)
Between August 2004 and March 2006 TfL's Information Access and Compliance Team received 436 requests from the police for Oyster card information. Of these, 409 requests were granted and the data was released to the police. Please note that before September 2005, some requests may have been received and answered without detailed statistical information being recorded.
====== Question 3 ======
In how many cases was this as a result of a Court Order of some kind (e.g. Search Warrant, etc.)?
You also enquired as to how many times TfL has released Oyster card information as a result of a court order, requiring it's disclosure. I have been advised that this situation has never arisen.
====== Question 4 ======
How long is the usage history of an Oyster card retained?
The usage history of each card is retained on an eight week rolling basis. The information held covers all journeys made using the card, including National Rail journeys (for which an Oyster card is valid), provided that the customer has 'touched in' and/or 'touched out' as appropriate (for bus and tram journeys customers only need to touch in, for tube, DLR and trains customers need to both touch in and out).
====== Question 5 ======
Is there a way to expunge this history?
You also asked if there was a way to expunge this travel history. There is not. However, after an eight week period (during which it is used for customer service purposes, to check charges for particular journeys, or for refund enquiries) has passed, the travel information recorded against an individual Oyster card is disassociated from it and can no longer be linked to either the card or customer concerned.
The anonymised journey information is retained for research purposes (eg after eight weeks, TfL would be able to tell that a monthly Travelcard had been used to make a particular journey at a specific time, but would not know which Oyster card or customer was oassociated with that journey).
====== Question 6 ======
1)When replacing an unregistered Oyster card (because it is inoperative), the holder has to provide extensive personally identifying information (despite never having had to do so in the past). As all this information is captured on a single form, it is clearly used to 'tie' the card to it's owner's name, address etc. Indeed, the replacement card's serial number is also tied to this information. This appears to be 'surreptitious registration'. Can you explain why it would be necessary for TFL to capture extensive identifying information to replace an otherwise unregistered card?
(Please note: I understand that there is no way for TFL to verify the person presenting the card is the person who bought it, or paid for any credit, so do not expect to be told that this is the reason for ID being sought).
When an unregistered Oyster card has to be replaced because it is inoperative, the replacement is usually issued at the ticket office in a tube station. Tube station ticket offices do not have direct access to Oyster card details, and as there is often a queue of customers, the staff do not usually have time to contact the Oyster card helpdesk.
Therefore, the station staff will load onto a replacement Oyster card the period ticket and/or 'pay as you go' amount that the customer states was on their inoperative card. Station staff then return the inoperative card to the Oyster card helpdesk.
Your personal details are requested in case a discrepency is subsequently found between the value of your inoperative card and what was loaded onto your replacement card. For example, if £5.00 was credited to your replacement card, but the Oyster card helpdesk discover that you actually had £8.00 credit on your original card, then a refund would be due to you.
====== Question 7 ======
Seemingly the only way to retrieve the £3 deposit paid for an Oyster card (registered or otherwise) is to return the card to TFL and request a cheque payment. Again, this provides TFL with personally identifying information about Oyster card holders. Once again, this appears to be 'surreptitious registration'. Can you explain why it is not possible to obtain a £3 refund from a ticket window (which of course was quite happy to take the deposit in the first place)?
Regarding the refund of the£3.00 card deposit, I can advise that as from 19 March 2006, these deposits can be refunded at a tube station ticket office. The deposits were previously processed via the central refunds department because they were classified as 'anonymous funds'.
Consequently, refunds had to meet anti money-laundering regulations which required that deposits be refunded in this way, rather than through individual tube station ticket offices. However, as the deposit is no longer defined as anonymous funds, we can now process deposit refunds at ticket windows.
This isn't quite what it seems, see
====== Question 8 ======
What 'resolution' do TFL routinely use when analysing Oyster usage? That is, TFL may be able to tell ?X thousand people arrive at Bank between the hours of 7am and 9am?, but do TFL routinely attempt to work out where those people came from, where else they may go, how long they stay, and where they return to, etc.? In other words, does TFL use the fact they can identify travellers uniquely to analyse traffic patterns, or does TFL only use statistical information, such as the number of travellers passing through a given location?
(Here I am attempting to ascertain how prominently an individual appears in TFL traffic patterns. Clearly Oyster offers far more scope for this than paper tickets. I simply want to understand to what extent TFL currently do this. I'm expecting a subjective response to this subjective question).
Finally, you asked what information TfL uses when analysing Oyster card usage. Apart from the limited purposes referred to in point 1 of this letter, at present TfL uses Oyster card data to:
- count how many people pass through the ticket barriers at London Underground stations;
- contruct origin destination marices of the number of people travelling from one station to another at different times of day; and
- examine the time it takes for customers to travel from the start station to the end station of their journey.
This information is used for planning future services and calibrating our estimated journey times. Analysis is also carried out to identify ticket irregularities relating to 'unstarted' or 'unfinished' journeys.
===== Epilogue =====
The letter goes on to state that I can follow a review procedure if I'm unhappy with the way my request has handled. The letter was signed by Shiela Sachania, Transport for London, Central Customer Services.
My apologies for typos (particularly in the responses), as I had to transcribe the paper letter!