EIR - NRRM Register [Jul 2024]

Your request

....access to the data from the NRMM register for academic research purposes for the years 2022, 2023, and, 2024 (so far) in an electronic format. We do not request any personal data that would identify an individual, or organisation, but require the construction site location (by postcode, borough and by Greater London and those operating inside the Central Activity Zone), machine numbers, machine type, engine size, engine stage, EU emission plate number and registered dates and duration of use. We would also like information on the machines that have been retrofitted (number and type) and exemption requests submitted to the GLA (numbers by machine type) and whether the requests have been accepted/rejected.

Our response

Please find attached a copy of the Non-Road Mobile Machinery (NRMM) register. Please note that some fields within the register have been withheld from disclosure under Regulation 12 (5)(b), The course of justice and inquiries exception, and Regulation 13, Personal information.

Regulation 12 (5)(b) The course of justice and inquiries

This exception is very wide in coverage, in this instance it is used to cover material covered by any adverse effect on law enforcement. An adverse effect in this case relates to all aspects of the prevention and detection of crime and is engaged because the release of this information would, or would be likely to, prejudice the prevention or detection of crime.

Public disclosure of exemption identification will allow persons with malintent to undermine the aims of the NRMM register by using another supplier’s identification to use retrofitted or specialist equipment without authorisation.

We also consider that data which can be linked to site or supplier specific inventories would be likely be facilitate onsite theft and/ or vandalism. The machinery found on construction sites are expensive, which means that replacing these stolen items can produce significant financial pressure.

Regulation 13 (Personal information)

Information that identifies specific employees constitutes as personal data which is defined by Article 4(1) of the General Data Protection Regulation (GDPR) to mean any information relating to an identified or identifiable living individual. It is considered that disclosure of this information would contravene the first data protection principle under Article 5(1) of GDPR which states that Personal data must be processed lawfully, fairly and in a transparent manner in relation to the data subject.

Public interest

The GLA acknowledges that there is a public interest in transparency in relation to the operation of machinery which has met the standards set out in our policies, either by original manufacture or by retrofit. This is particularly true for the construction sector which is a significant contributor to London’s air pollution.

However, the public interest is best served by ensuring withholding minimal data which would otherwise be likely to have a detrimental effect on efforts by the construction sector to prevent criminal activity. The public interest is served by releasing a sufficient volume of data to facilitate public understanding of the NRMM register and be able to draw conclusions on the impact on the environment from that data.

For further information please visit: Non-Road Mobile Machinery (NRMM) | London City Hall