FI15986
Request
Details of motor vehicles registered for public hire (i.e., Chauffeur, Taxi, Private Hire, Hackney Carriage) that are registered to, operated by a company, or licensed operator and were either issued a new or renewal licence during the period from 1 January 2024 to 1 January 2025.
Specifically, I am requesting the following information for these vehicles:
- Vehicle Registration Number
- Manufacturer (Make)
- Model
- Licence Issue Date
- Licence Expiry Date
Response
The information you have sought is attached. Following a review of how the Council deals with requests for this type of information, we no longer provide vehicle registration numbers as this information is considered to be personal data and therefore exempt from disclosure under Section 40(2) of the Freedom of Information Act. In making this decision, the Council has taken into consideration a decision notice issued by the Information Commissioner in relation to a request for this information in respect of another local authority. The decision notice can be found here: https://ico.org.uk/media/action-weve-taken/decision-notices/2019/2614512/fs50793373.pdf. The information provided includes information for all new and renewal applications in the period. All private hire vehicles are operated by a licenced operator, hackney carriage licences are held by proprietors.
Attachments
Attached
Internal Review Documents
Internal Review Request
I would like to clarify that the VRMs I have requested relate only to vehicles operated by companies or licensed operators, rather than those registered to private individuals.
As such, these vehicles are not owned by identifiable individuals, and the associated VRMs do not constitute personal data as defined under the UK GDPR.
I understand the importance of protecting personal information; however, this request has been framed specifically to avoid the inclusion of any personal data. The information requested pertains solely to commercial or organisational entities, which are not afforded the same protections under data protection legislation.
Internal Review Response
Your request was received on 12 June 2025, and you were seeking the following data:
Specifically, I am requesting the following information for these vehicles:
- Vehicle Registration Number
- Manufacturer (Make)
- Model
- Licence Issue Date
- Licence Expiry Date
The response sent to you on 16 June 2025, included the majority of the data you were seeking however the vehicle registration number was omitted under the exemption Section 40(2) of the Freedom of Information Act, advising it was considered personal data.
Section 40(2) of the FOIA provides that information is exempt from disclosure if it is the personal data of an individual other than the requester and where one of the conditions listed in section 40(3) or 40(4) is satisfied. In this case the relevant condition is contained in section 40(3A)(a). This applies where the disclosure of the information to any member of the public would contravene any of the principles relating to the processing of personal data set out in Article 5 of the General Data Protection Regulation (GDPR)
The initial step is to determine whether the withheld information constitutes personal data as defined by the DPA 2018. If this is established, I then need to consider whether disclosure of the data would breach any of the data protection principles.
The definition of personal data in section 3(2) of the DPA18 is: “any information relating to an identified or identifiable living individual. “Identifiable living individual” means a living individual who can be identified, either directly or indirectly, in particular by reference to –
- An identifier such as a name, an identification number, location date or an online identifier, or
- One or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the individual.
To establish if the requested information is personal data I have had to consider if the information is about them, linked to them, has biographical significance for them, is used to inform decisions affecting them or has them as its main focus.
In respect of hackney carriages, Councils are required to maintain a record containing the name and address of the vehicle proprietor, the granted licence number, any convictions in respect of the proprietor or driver which is open for public inspection. For private hire vehicles, local authorities are required to maintain a register of driver’s licensed to drive private hire vehicles which includes the name of the driver, the granted licence period and the licence number. This register must be kept at the main offices for inspection by members of the public. Neither of the Acts that require the information to be retained in this format, require the VRM data to be published in the register, however the Council does process this information together with the required information in order to identify the driver, registered keeper or both and to enable verification checks to take place. The VRM will therefore relate to an identifiable individual and falls within the definition of “personal data” for the purposes of the Data Protection Act. In addition, it maybe that the vehicle has since been sold to a private individual, and in disclosing this information we would be providing their personal data.
In establishing that the VRM is personal data I need to consider the public interest in disclosure against that of withholding the information. I can see that the public may have an interest in whether a vehicle they’ve purchased, or are about to purchase, has been used as a private hire vehicle or taxi. However, although the owners of the vehicles realise their details will be retained in a publicly available record, the law does not require the VRM to be published with this information. In considering disclosure, we must take into consideration that disclosure is to the world at large, not just the person requesting the information. Individuals who complete the taxi/private hire registration application would have a certain expectation as to what information is made available to the public. I therefore conclude the disclosure of the information would not fall within the expectations of the individuals and there is no statutory requirement for the council to obtain or publish VRM information for inspection, or to publish this data. I believe the legitimate interests of yourself, as the requestor, and that of the public as a whole, do not outweigh the rights and interests of the individual, given their lack of expectation this information may be published or provided and the potential impact disclosure could have.
I therefore conclude that the application of the exemption contained within Section 40(2) of the FOIA is correct in this case and the information is exempt from disclosure.