Mr Ganesh Sittampalam
[FOI #11837 email]
9 June 2009
Dear Mr Sittampalam,
Request for Information – RFI20090686
Thank you for your email of 11 May 2009, requesting information under the auspices of the Freedom of
Information Act 2000 (“the Act”).
The wording of your request was as follows:
“I request a copy of all contracts currently in force relating to the collection of television licence fees and
enforcement of the television licensing system.”
While we are required to supply information contained in contracts (or parts of contracts) except where
that information is exempted under the Act, it has become clear to us that compiling this information
would be a lengthy activity likely to take well in excess of two and a half days. This conclusion has been
reached only after a significant amount of work has already been undertaken by both ourselves and our
contractors, and takes account of the wide-ranging nature of your request when ‘all contracts’ is
interpreted literally.
Under section 12 of the Freedom of Information Act, we are not required to comply with a request if we
estimate that the cost of doing so would exceed the “appropriate limit”. The appropriate limit has been set
(by the Freedom of Information and Data Protection (Appropriate Limit and Fees) Regulations 2004) as
being £450 – equivalent to two and a half days work, at an hourly rate of £25. On that basis, we are
declining to handle your request as currently framed. However, if you would care to narrow the scope of
your request, so that it becomes possible to comply with it within the specified timeframe, we would be
happy to revisit this response.
We are mindful of our duty (under section 16 of the Act) to provide reasonable advice and assistance to
you, and specifically to advise how you might narrow your request so that it complies with the time limit.
We are however concerned that, because the scope of your request as currently framed is so very broad
and because we have no way of knowing (unless you wish to tell us) what your reason is for requesting the
information, to provide such suggestions here might be counter-productive (i.e. it could be considered that
we are leading you toward a particular course of action or conclusion). Therefore on this occasion we are
not offering you advice in this regard, but will be happy to consider your narrowed response.
We would, however, advise you that some of the individual contracts held by us (or held by others on our
behalf) may in themselves take time to collate (due, for example, to the number of contract variations held
in separate documents), and accordingly we would strongly advise you to limit the scope of your revised
request to just those documents (or sections of documents) that you are particularly interested in having
sight of.
To confirm, ‘TV Licensing’ is a trade mark of the BBC and is used under licence by companies contracted
by the BBC to administer the collection of television licence fees and enforcement of the television
licensing system. The majority of administration is contracted to Capita Business Services Ltd., with cash
related payment schemes contracted to Revenues Management Services Ltd. Over-the-counter services
are provided by PayPoint plc. Marketing and public relations activities are contracted to the AMV
Consortium. This consortium is made up of the following four companies: Abbott Mead Vickers BBDO
Ltd., Fishburn Hedges Boys Williams Ltd., PHD Media Ltd. and Proximity London Ltd.
For the avoidance of any doubt, I would add that any documents supplied will most likely be subject to
redaction, in accordance with the exemptions specified in the Act. In particular Section 43 (commercial
prejudice) is likely to apply to some sections of the contract.
Your appeal rights
This enquiry has been dealt with under the terms of the Freedom of Information Act (as indicated above).
If you are not satisfied that we have complied with the Act in responding to your request, you have the
right to an internal review by a BBC senior manager or legal adviser. Please contact us at the address
above explaining what you would like us to review and including the reference number given at the start of
this letter. If you are not satisfied with the internal review, you may appeal to the Information
Commissioner, whose contact details are as follows: Information Commissioner's Office, Wycliffe House,
Water Lane, Wilmslow, Cheshire, SK9 5AF; telephone: 01625 545700; www.ico.gov.uk.
Yours sincerely,
Neil Gardner
Senior Policy Adviser, TV Licensing Management Team
