Transport Focus Consultation on GTR (Southern) Ticket Office Closures

Transport Focus is running a consultation on Southern’s proposal to close ticket offices and introduce “station hosts”.  You can have your say by clicking here.

My response is below.


Dear Sir/Madam,

I write to you in relation to your Govia Thameslink Railway ticket offices consultation to express concern about the introduction of “station hosts” on the Southern/GTR network.  As this email includes concerns about potential fraud, I am also copying in British Transport Police.

Whilst I can see an argument for getting staff out from behind a ticket office counterS onto the platform, where in addition to selling tickets they can assist customers in other ways, this proposal  does introduce some concerns in regard to the fair treatment and security of passengers.


As background to these concerns, I would remind you (I have raised such concerns with both Transport Focus and BTP before) that Southern has a dodgy policy with regard to the identification of their staff: specifically, Southern tries to pass off as identification a “recognised uniform” + a name badge bearing first name only.   [The only exception to this policy is specifically for Revenue Protection Officers, who do have proper IDs and are instructed to show them on request.]

This falls short of the legal requirement under section 24.3 of the Railway Byelaws to produce identification, as there is no photo to demonstrate it belongs to the bearer and it fails to identify which member of staff the passenger is dealing with.   Someone who refuses to produce identification, other than relying on a (stolen?) jacket/jumper and/or a (stolen?) name badge, fails to comply with their legal obligation to identify him/herself and may be a staff member … or equally may be a criminal posing as a staff member.   Without seeing ID, the passenger is unable to distinguish between these 2 scenarios.

There are many instances where staff are seen in just their shirt sleeves or a jumper with nothing more than a name badge and possibly a Southern logo to identify them.  This makes it easy for criminals to pose as staff using a stolen jacket/jumper complete with name badge, or even by just wearing a smart suit.  Members of the public often assume they are seeing more uniform that is actually the case and it is not uncommon for them to assume a fellow passenger wearing a uniform from a different company, such as TfL or one of the airlines, is in fact a member of staff.


I see the following risks arising from the introduction of “station hosts”:

  • Fraud Risk: Fraudsters may pose as “station hosts” in order to sell passengers fake railways tickets, possibly using obsolete rail ticket machines purchased through sites such as eBay, or a generic ticketing device.  In these circumstances, not only is the fraudster able to clone details of any card used to pay for the “ticket” but the passenger ends up boarding the train without a valid ticket, placing them at risk of a Penalty Fare or even prosecution for fare evasion.  This sort of fraud is particularly easily imaginable at isolated stations such as Southease or Glynde, but might also be attempted at large, crowded stations like Victoria.
  • PIN Exposure: It is harder for customers to shield their PIN when entering it on a hand-held device than on a fixed device at a ticket office.
  • Unfair/Illegal Penalty Fares:  Where there is no means to purchase a ticket before boarding the train, Penalty Fares are prohibited under Section 7.3 of the 2002 Penalty Fare Rules.  However, Southern’s dodgy incentive scheme that allows Revenue Protection Officers to keep up to 5% of their takings may motivate less scrupulous employees to defraud passengers by issuing Penalty Fares even when they know they are not allowed to do so, or fail to exercise appropriate discretion in less clear-cut cases.  Under the SRA Penalty Fares Policy they are also required to check whether there was means to purchase a ticket or, if they are unsure, give the passenger the benefit of the doubt.  This could arise at stations with no ticket machine available if:
    • The “station host” is unavailable, e.g. using the facilities for any extended period of time, or away from the station on an authorised or unauthorised break.
    • The “station host” refuses to produce identification, meaning the passenger is unsure whether or not they are an authorised individual.


The following measures may help to protect passengers against the above risks and I would recommend these should be introduced prior to the implementation of the “station hosts” proposal:

  • Proper Identification:  Southern/GTR should ensure that all customer-facing staff have a photo ID on display at all times when carrying out their duties.  Specifically, this should:
    • Bear an up-to-date photo from which the staff member can clearly be identified.
    • Southern’s logo.
    • A means of identifying the individual staff member: this would either be a unique employee ID (best practice) or first name + last name.  It cannot be first name only, as per Southern’s current dubious policy, as this fails to identify them.
    • Their authorised role, e.g. station host, conductor, revenue protection officer.
  • Education:  Posters at stations and in trains could remind passengers to:
    • Always check for ID rather than just assuming someone is a staff member.
    • Never part with money, hand over a ticket or give access to a contactless card, mobile phone or smart watch to someone who refuses to show ID.
    • Contact British Transport Police if someone claiming to be a staff member refuses to show ID.
    • Shield their PIN even when entering it on a hand-held device.
    • Always get a receipt for their train ticket.
    • Know their rights when it comes to Penalty Fares:
      • A penalty fare is unlawful if there was no means to purchase a ticket before boarding the train (Penalty Fare Rules 7.3).
      • This applies to the original station where they boarded, not any station where they might have subsequently interchanged (Penalty Fare Rules 2.o).
      • If the revenue protection officer does not know whether there was means to purchase a ticket, they must give the passenger the benefit of the doubt (Penalty Fare Policy 4.15).
  • Overhaul the Dodgy Appeals Process:  As you will be aware, Penalty Fare Appeals are carried out by IPFAS, as subsidiary of Southeastern that is widely considered to be biased towards the train companies and to lack true independence.   The perception is that asking a train company to run the appeals service is like asking the banks to investigate the LIBOR fixing scandal.  A year ago the DfT has a public consultation on overhauling this appeals process and make it truly independent, stop the clock when passengers appeal and put in a final appeals panel to oversee this process.  This overhaul is more desperately needed than ever, particularly in the light of the above.  Perhaps Transport Focus could chase up with the DfT for a resolution in this area.