My Response to GMCA: Safety Is Not a Commercial Secret



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Background

On 12 September 2025, I received notice from the Greater Manchester Combined Authority (GMCA) that my Freedom of Information request about Bee Network Bus Safety Data is being delayed under Section 43 of the Freedom of Information Act (Commercial Interests).

This means that GMCA now admits it holds the data but claims that publishing it might harm the commercial interests of private operators.

That’s deeply concerning — because:

GMCA promised in writing (December 2023) to publish this very data within 12 months;

Transport for London has released the same information quarterly since 2014 without issue; and

The Bee Network is a publicly controlled service — the public has every right to see how safe it is.


Below is my full written response to GMCA’s letter.


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My Response to GMCA (Sent 14 September 2025)

Subject: Re: FOI Request – Case 845285 – Public Interest and Section 43

Dear Information and Data Governance Team,

Thank you for your update of 12 September 2025 regarding my Freedom of Information request under case reference 845285.

I note that you are extending the response period while you consider a public interest test under Section 43 (Commercial Interests) of the Freedom of Information Act.

While I appreciate your duty to apply the exemption carefully, I must strongly state that the public interest in disclosure far outweighs any potential commercial prejudice in this case.

The GMCA and TfGM have previously confirmed in writing (December 2023) that it was their intention to publish all accident and incident data for Bee Network services and that this process would be implemented within approximately 12 months. The information I have requested therefore directly relates to a matter already acknowledged as suitable for publication by GMCA itself.

Furthermore, the claim that disclosure could prejudice commercial interests does not stand up to comparison with established national precedent. Transport for London (TfL) has published equivalent Bus Safety Data quarterly since 2014, including collisions, injuries, fatalities, and incident categories, without any evidence of harm to operators’ commercial interests.

In this context, withholding comparable Bee Network data would appear inconsistent with both GMCA’s prior commitments and the broader principles of transparency and accountability that underpin local bus franchising policy.

I therefore ask that:

1. GMCA gives full and proper weight to the public interest in safety transparency when completing the Section 43 assessment; and


2. The final response includes a clear explanation of what specific commercial interests GMCA believes would be harmed by disclosure, and how that harm would outweigh the public’s right to scrutinise bus safety performance.



I would also remind GMCA that Section 43 is a qualified exemption, not an absolute one, and that the public interest in accountability, safety, and public confidence is especially high in this case given the Bee Network’s public ownership and operational oversight by GMCA.

I look forward to your full and considered response by 4 November 2025.

Yours sincerely,
Lee Odams
(writing in a personal capacity as a private individual)


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Why This Matters

If Greater Manchester — the UK’s first city region to bring buses back under public control — refuses to release its Bus Safety Data, then transparency becomes optional, not a principle.

Safety cannot be treated as a commercial secret.
Public confidence depends on openness

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