FI17248
Request
Please provide a list of all vehicles that are licensed by the council as at the date this request is processed, including both:
* Hackney Carriage vehicles; and
* Private Hire Vehicles (PHVs).
For each currently licensed vehicle, please provide the following information:
1. Vehicle registration mark (VRM) / registration number.
2. Vehicle make.
3. Vehicle model.
4. Licence type (Hackney Carriage or Private Hire Vehicle).
5. Licence commencement date (valid from).
6. Licence expiry date (valid to).
Response
The information you have sought is set out below. 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. Please note that we are unable to provide the date a particular vehicle was first licenced, we have included on the document the date the most recent licence was issued.
Attachments
Attachment
Internal Review Documents
Internal Review Request:
I am writing to request an internal review of the decision to withhold the vehicle registration marks (VRMs) of currently licensed Hackney Carriage and/or Private Hire Vehicles. I respectfully submit that the public interest and legitimate purpose of disclosure have not been fully considered.
The purpose of my request is to create a searchable database that enables motor traders and consumers to identify whether a vehicle has previously been licensed as a taxi or private hire vehicle. Knowledge of a vehicle’s previous use is a relevant factor when assessing a vehicle’s history, condition, value, and suitability for sale. Disclosure would support compliance with consumer protection obligations and industry guidance, including:
- Trading Standards Business Companion guidance for motor traders, which emphasises the importance of obtaining and disclosing material information about vehicles to consumers.
- The CAP Code administered by the Advertising Standards Authority, which requires advertisers to avoid misleading omissions and to provide material information where relevant to consumers’ transactional decisions.
Without the vehicle registration mark, it is impossible to identify the vehicle to which the licensing record relates, significantly reducing the usefulness of the information for these legitimate purposes. I would also ask the council to consider:
- Whether the vehicle registration mark itself constitutes personal data in the circumstances of this request.
- Whether disclosure would identify any individual licence holder, driver, or proprietor.
- Whether the council already publishes, or has previously published, vehicle licence registers containing vehicle registration marks or information capable of identifying licensed vehicles.
- Whether disclosure of vehicle registration marks, without any associated personal information relating to proprietors, would result in any actual prejudice to the rights and freedoms of individuals.
The information requested relates to vehicles licensed to undertake a regulated public transport function and does not seek the names, addresses, contact details, or any other personal information relating to proprietors, operators, or drivers.
If the council continues to rely upon a personal data exemption, I would be grateful if the internal review could specifically address:
- The precise basis upon which a vehicle registration mark is considered personal data.
- The lawful basis relied upon for refusing disclosure.
- How the balancing exercise was undertaken between the legitimate interests served by disclosure and any potential impact upon individuals.
I would be grateful if the internal review could be conducted by an officer not involved in the original decision and if the outcome could be provided in writing.
Internal Review Response:
I can see a response was sent to you on 6 August 2026, and in that response, you were provided with details of the Licence Type, Vehicle Description and Name (Make), Vehicle Model Description, Expiry Date and Last Issue Date for the Licence.
I have undertaken a review of the remainder of the information requested and undertaken further research as to whether a registration is classed as personal data. The exemption within Section 40(2) of the Freedom of Information Act 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 in section 40(3) or 40(4) is satisfied. In this instance I believe the condition contained within Section 40(3A)(a) applies. This condition is applicable where the disclosure of information to any person would contravene any of the data protection principles relating to the processing of personal data, as set out in Article 5 of the General Data Protection Regulation (GDPR). In establishing if the requested data constitutes personal data, I have had to consider what is actually classed as personal data. Section 3(2) of the DPA 2018 defines personal data as “any information relating to an identified or identifiable living individual”. To identity an individual it can be either directly or indirectly. Information relates to a person if it is linked to them or about them. The information being sought is about vehicles that have been licensed by the council as either private hire vehicles or taxis.
Under the Town Police Clauses Act 1847 a Council is required to maintain a ‘book’ with the name, address, licence number and any convictions of the vehicle owner/driver which is open to public inspection. For private hire vehicles section 51(3) of the Local Government (Miscellaneous Provisions) Act 1976 requires a local authority to maintain a ‘register’ of all drivers licensed to drive private hire vehicles. This details the driver’s name, licence period and licence number. Under the legislation, the register must be available at an authority’s main offices for inspection by members of the public. Neither Act requires the local authority to publish the vehicle registration number, but this information is collected to enable the identification of the driver, registered keeper, tax, MOT and insurance match the licensed vehicle. Based on this I must conclude that the VRN does relate to an identifiable individual and therefore falls within the classification of personal data as defined within the Data Protection Act.
In applying this exemption consideration must be given to the legitimate interest in providing this information. I can see the public would have legitimate interest in being able to access this information. However, the data subject would not reasonably expect that their information would be made publicly available. They would already be aware and have expectation that their details and the vehicle details would be made available within a public register as the law requires this to be maintained. But there is no statutory requirement to include the Vehicle registration number or to making this information available via the internet. This makes it widely accessible, rather than restricting information to those who have to physically visit the council offices to view the register.
As such I do not believe the legitimate interests of yourself or the public do not outweigh the rights and interests of the taxi/PHV driver/keeper. I therefore agree with the original decision, in that the exemption under section 40(2) applies, by way of section 40(3A)(a).