FOI - Brand Guidelines (Sep 2023)

Copy of request:

I would like to request copies of the following two files, which used to be on your website but have recently been deleted.

https://www.london.gov.uk/sites/default/files/gla_brand_guidelines_crea…
https://www.london.gov.uk/sites/default/files/gla-brand-guidelines-feb-…

Our response:

I can confirm that the GLA holds the information you have requested.

These branding guidelines have been published on the GLA website for many years.

The document has now been taken off the GLA website as a photo caption was added by a staff member in error which doesn’t reflect the view of the Mayor or the Greater London Authority. The Mayor is not involved in the review of GLA branding and design guideline documents.

Please find attached copies of the archived brand guidelines March 2021 and February 2022, which are no longer in use.

Please note that copyright applies to the photographs in these documents. See How to apply to re-use information.

We have redacted a very small amount of information from both copies.

Personal data

Some names of members of staff and suppliers are exempt from disclosure under s.40 (Personal information) of the Freedom of Information Act. This information would identify specific individuals and as such constitutes 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 under the Act 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.

Security pass

The redacted information is described below: 

• Image showing GLA security pass
• Security pass dimensions
• Description of specific elements of pass design

We consider this information to be exempt under the provisions of the Act - Section 31(1)(a) - the prevention or detection of crime; and Section 38(1)(b) – endangering the safety of any individual. Please see Annex A for more information about how these exemptions are engaged.

If you have any further questions relating to this matter, please contact me, quoting the reference MGLA210823-4628.

Yours sincerely

Information Governance Officer

If you are unhappy with the way the GLA has handled your request, you may complain using the GLA’s FOI complaints and internal review procedure.

Annex A

Exemptions

Section 31(1)(a) - the prevention or detection of crime 

31.—(1) Information which is not exempt information by virtue of section 30 is exempt information if its disclosure under this Act would, or would be likely to, prejudice -   (a) the prevention or detection of crime

Section 38(1)(b) – endangering the safety of any individual 

(1) Information is exempt information if its disclosure under
 this Act would, or would be likely to-

(a) endanger the physical or mental health of any individual, or

(b) endanger the safety of any individual.

The redacted information is described below: 

• Image showing GLA security pass
• Security pass dimensions
• Description of specific elements of pass design

How the exemptions apply to this information 

Section 31(1)(a) covers 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 in that it could be used by those intent on committing criminal acts to undermine, plan against, or counteract security arrangements at GLA events.  The design and dimensions of the standard security pass are withheld as they could be used by people intent on causing harm to bypass security or stewarding controls. Even though a copy has previously been published on the GLA website, this has now been removed. Any new versions may share certain features.  Further disclosure would create additional weakness. The terrorist attacks in London, Paris and across Europe in the last decade highlight the heightened risk to the public and crowds at high profile events and major cities. 

Section 38(1)(b) of the Act is engaged as because of the potential risk to public safety of those attending events as set out above. As we have established, there is a significant risk to public safety. Releasing information which would potentially aid the commission of criminal or terrorist acts would increase the risk posed to the safety of those attending or working at the event - Section 38 is engaged alongside the provisions of Section 31.

Public Interest test

Considerations favouring disclosure

The GLA is mindful of the general presumption in favour of disclosure under the Act.

The GLA acknowledges there is a legitimate interest in the release of this document given the general media interest and interest from members of the public.

The redacted information has been in the public domain previously.

Considerations favouring non-disclosure

The GLA is releasing the document as a whole, with only the most minimal redactions, which satisfies the public interest to a very great degree. The redactions we made remove only the most sensitive information where it is felt there is a strong link to prejudicial or harmful effects occurring.

It is not in the public interest to release information that could be used directly to plan criminal activity / harm to the public

It is not in the public interest to release information that makes it more difficult to differentiate between genuine staff/stewards/security/guests and others.

The above issues might lead to a need for more staff to be on duty to mitigate against this. This would take resources away from other areas, this would also increase the cost to the public purse.

Even though this information has been in the public domain previously, the GLA has removed copies from our website to prevent further access and as above, it is not in the public interest to create a more permanent copy on the GLA’s FOI disclosure log (and on the website WhatDoTheyKnow.com).

We have determined that avoiding prejudice to measures to prevent and detect crime, and protecting the safety of the public attending the event is of paramount importance.   In all circumstances of the case, the public interest favours maintaining the exemption provisions of s.31(1)(a) and s.38(1)(b) in relation the redacted and withheld information.