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3 - What evidence, research and other relevant data was obtained from:
         
a)       The telephone regulator, Ofcom;
         
b)       The service provider(s) of the non-geographic number 0843 2221234;
           
c)        Any other source;

relating to the ability and cost of terminating internationally-originated calls to the non-geographic number 0843 222 1234 prior to the introduction of this number.

The percentage of callers using the Travel Information Call Centre from abroad is fairly low in relation to the high volume of calls we receive in a year from the UK. We are unable to control the costs of terminating internationally originated calls as this is dependent on the local and international network providers and are subject to change. There are still effective alternative means to interact with the Journey Planner service whilst abroad via the internet. As stated above, we tested a number of different European locations with the service provider in terms of access.

The transition to a 0843 number has been necessitated by operational issues that require the extra capacity offered by the 0843 number.

The number of calls to TfL travel information continues to increase and is still rising as a consequence of Oyster pay as you go being extended to National Rail.
There is a capacity restriction on 020 numbers as it is correlated directly to the number of channels we have in our telephony system. This limits the number of calls we can handle at any one time. On the contrary, by moving onto 0843 number we have opened up this capacity using network routing, thus enabling us to enhance our at-once call handling to better serve our customers fast and efficiently. Additionally, the new non-geographic number will not only provide much needed extra capacity but will also allow callers to get through (even at the busiest of times) and their query dealt with immediately during major incidents or at times of severe travel disruption.

Moreover, TfL’s strategy also aims at allowing our customers to simply call one number to reach a variety of services e.g. Oyster helpline, Travel Information Contact Centre (TICC), Buses etc.  The new 0843 number connects customers to an automated natural language service that provides 24-hour travel information on all our services. Customers will no longer have to wait to speak to someone to find out the information they need. That does not mean our customers will no longer get the personal touch of an actual human being because they still have the option of speaking to an adviser.

The natural language service, which is only possible with an 08xx number (it cannot work on 020 number), has freed up capacity within our call centres, which means on average, the wait time for an agent has been reduced ensuring the customer reduced handling time.  It is this added value that we aim for because all accrued savings will be passed on to you - our customers - through better service.

We are fully aware of the cost implications, especially for mobile phone users, but our customers still have access to other options that are free such as the TfL website, stations, maps etc. You can also sign up for other TfL travel tools including free email and text alerts at http://www.tfl.gov.uk/tfl/livetravelnews/mobileservices/

[...] [end]

TfL or one of its subsidiary companies states that is the copyright owner of the above text.

Fair use doctrine asserted [17 U.S.C. § 107]

The internal review of your Freedom of Information request has been completed. The review was conducted by an internal review panel (‘the Panel’) in accordance with TfL’s internal review procedure.

The Panel assessed TfL’s application of section 43 of the Freedom of Information Act and agreed that it was engaged since the release of this information would be likely to prejudice TfL’s commercial interests.

The Panel thought it would be helpful to explain that, when a member of the public dials the 0843 number, the Oyster Interactive Voice Response (IVR) technology then routes their call to one of 22 different geographic telephone numbers across multiple sites, depending on the nature of the enquiry. Each of these call centres is run by one of several different suppliers on behalf of TfL, each of whom may deal with different aspects of London travel (e.g. bus enquiries, London Underground, refunds etc). Each supplier is paid according to the number of calls handled.

It is important that calls are routed to the correct area as this is tied in with revenue paid to suppliers. If the numbers were distributed, and the public used these numbers to call into the centres, TfL would have to pay the supplier for taking the call. However, if callers dial the wrong department, TfL would not only have to pay the supplier who initially received the call, but also pay any other suppliers involved if that call had to be re-rerouted or transferred to another company. The central number allows TfL to determine how many calls have actually been received and ensure that we are only billed for the correct amount, particularly that we are not billed multiple times for the same call.

In addition, if TfL could not route calls via its IVR system, all customer service agents would have to receive significant additional training at TfL’s expense. They would have to be trained in handling and routing a much wider variety of query, which would greatly add to TfL’s costs for providing the service.

With regard to the point about TfL running a geographic number for international callers in addition to the 0843 number, this would have a further impact on TfL’s commercial interests. There would be a significant cost in running the IVR technology concurrently on a geographic number, which would require the diversion of TfL’s limited resources from other areas.

In considering the impact that providing this information would have on TfL’s commercial interests, I think it is relevant to note that the 0843 number does not generate income for TfL. It does help defray some of the cost of running the telephone query service but the savings would be reduced, the efficiencies lost and the cost of running the service commensurately higher if TfL were to make geographic numbers available.

Having established that the exemption is engaged, the Panel assessed the public interest in disclosing the geographic numbers and agreed that there is a public interest in providing customers with a choice of number to dial, particularly in terms of possible cost savings when calling our service. The Panel noted, however, that the importance of this factor is mitigated by the fact that TfL makes travel information available without cost through other sources, notably via the TfL internet and directly at its stations and other services.

The Panel assessed the public interest in maintaining the exemption and agreed that it is in the public interest for TfL to manage expenditure and where possible make efficiency savings to protect investment in vital public transport programmes. Over the last few years TfL has delivered one of the largest efficiency programmes anywhere in the UK public sector. The reduction in costs brought about by the use of the 0843 number contributes to TfL being able to manage its budget effectively.

Furthermore, an additional benefit of the use of the 0843 number and the IVR system is that TfL has the ability to ensure that calls are still taken and routed correctly even when geographic numbers are changed or different call centres are being used. For instance, in the event of the evacuation of a call centre or industrial action, TfL may be obliged to use different geographical locations without having a chance to take all appropriate steps to inform the public. Not only is there a risk of additional cost to TfL for callers dialling in to unstaffed phone lines, but the public interest in provision of an uninterrupted service would be compromised.

On this basis, the Panel agreed that the public interest in maintaining the exemption outweighed the public interest in disclosing the information requested.   

The Panel went on to examine TfL’s lack of response to your question 3 and agreed that in failing to answer this question TfL contravened the requirements of the Freedom of Information Act. I can now confirm that based on the Panel’s understanding of this issue, namely that there can be problems with accessing 0843 numbers when calling from abroad, no research was undertaken on this specific issue and no discussions took place with Ofcom or the service provider.

SilentCallsVictim wrote on Feb 8^th, 2011 at 7:22pm:
I am as yet undecided as to whether to refer my request to the ICO on th basis of the application of the usual s43 exemption. Previous referrals to the ICO have generally been pointless, and I suspect this one would end with the same result. I'll ponder over it until the weekend.

SilentCallsVictim wrote on Feb 8^th, 2011 at 7:22pm:


This points to the deception in the majority of thinking on this subject.  Lack of "Transparency" is not the main problem nor is "Transparency", as proposed, the whole answer.    It still does not address the fundamental dishonesty in the charging mechanism for 08 numbers.

It is reported in an earlier post on this thread that Tfl get 1.5 pence per minute from calls to their 0843 number.   So the truth is that Tfl's charge is 1.5 ppm; NOT 5 ppm.   The Tfl Telco is charging Tfl 3.5ppm   for providing this service to Tfl and it is not proposed that there is an honest and open declaration of this charge which Tfl should be paying.   Certainly this additional charge should not be imposed on the caller.   If Tfl want to charge for their information service over the telephone that is one thing.   But it is fundamentally dishonest to deceptively impose their Telco charges on the callers.

The callers have no opportunity to negotiate a better price or to seek better value for money.   There is no incentive for Tfl to seek better value for money because they are not paying the bill.   The Telco have no incentive to offer better value for money as they are not in negotiation with the callers.   Neither Tfl nor the Telco have any incentive to keep costs down by providing a faster service and shorter calls thereby lowering the cost.   Indeed the Telco are quite happy to see calls take longer and for queues to get longer because the longer the call the more they make.   This way of doing things is an incentive towards inefficiency.  Longer calls and longer queues are desirable for both Tfl and the Telco because they make more revenue.   Multiply this by the billions of calls made by millions of callers to hundreds of thousands of 08 numbers and you see a massive incentive towards inefficiency across the country and a massive fraud on the telephone calling public who can do nothing to reduce the costs.   There is no true market and therefore there are no market forces acting to drive down costs and increase efficiency.  

All these costs would very quickly be reduced if the "owners" of the 08 numbers had to pay the "service charges".    This is what is fundamentally wrong with the whole concept of 08 numbers and the imposition of these charges on callers.   This is the fundamental issue which Ofcom should be addressing in their "Consultation" on NGNs.   Instead the consultation skates all around this issue as does most of the debate on the subject in this Forum.

If there is to be a charge for HAVING a 08 non-geographic number it should be borne by the recipient not the caller.

idb wrote on Feb 8^th, 2011 at 12:05pm:


What sort of deception is this?   Of course the 0843 number generates income for Tfl !!!   He contradicts himself in the very next sentence, "It does help defray some of the cost .... "   Why can't they be honest about it?

What they have not taken into account is that in order to defray some of their costs, at the rate of 1.5ppm they are imposing a surcharge on callers of 3.5ppm which the callers cannot avoid or take action to reduce.   This is iniquitous.   Are Tfl only interested in defraying their costs regardless of any additional costs to their callers?

idb wrote on Feb 8^th, 2011 at 12:05pm:


It is very interesting that Tfl does not say that using IVR technology cannot be done on a geographic number, they say only that there would be cost implications.    I raise this point because many companies and suppliers have claimed over the years that they must have an 08 number because they cannot have these facilities with a geographic number.   This is yet another confirmation that such claims are untrue.

Regarding the cost implications for Tfl, I am sceptical about their claim that running the IVR technology on a geographic number would incur a "significant" cost.   I suspect that they could run a geo number in parallel with the 0843 number very easily and at an insignificant cost.   (Are there any members of the Forum with industry knowledge who can comment on this?).    I suspect that what Tfl are really concerned about is the potential loss of revenue if a geo number were to be offered in parallel.   Perhaps this point could be challenged in any follow-up to the FOI response?

loddon wrote on Feb 9^th, 2011 at 9:50am:

The charge levied by TfL is 5p per minute.

That is all that matters to the caller, apart from the additional charge levied by their own telephone company.

How TfL uses that money to defray the various costs it incurs in operating the service is a matter for TfL and its suppliers. Customers obviously cannot have direct influence over how a provider uses the money it receives in payment for a service.

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loddon wrote on Feb 9^th, 2011 at 10:53am:

It is surely understood that use of a 0843 number generates a subsidy that would not be available if the service were provided on a geographic number.

That is not to say that each call to the 0843 number has a positive effect on TfL's finances, per se. It may simply be less damaging than would be the case if a geographic number were used.

I see it as being of no great relevance as to whether the level of the Service Charge (ex VAT) is more or less than the costs incurred in handling the call. Arguments about whether or not there is net income may be of some interest, but this makes little difference to the caller, who has to pay a charge to access a service, in addition to that leveied by their own telephone company.