Mr Michael Jones
[FOI #17517 email]
25 September 2009
Dear Mr Jones,
Request for Information – RFI 2009 1266
Thank you for your email of 30 August, submitted via the ‘
whatdotheyknow.com’ website, making a request
for information about TV Licensing under the terms of the Freedom of Information Act 2000 (‘the Act’).
It may be helpful if I first explain the nature of the relationship between TV Licensing and the BBC. ‘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, which is
comprised of the following four companies: Abbott Mead Vickers BBDO Ltd., Fishburn Hedges Boys
Williams Ltd., PHD Media Ltd. and Proximity London Ltd. The BBC is a public authority in respect of its
television licensing functions and retains overall responsibility.
In your email, you made the following request:
Please tell me how much (BBC licence payers) money has been spent by the BBC in the past 5 years on
electronic TV detection equipment.
By this I mean only the cost of electronic tv detection equipment, not the vans that the equipment may be
installed into, or other such general items, nor do I want included in the total any installation costs, or
running costs etc - just the cost of the equipment.
I can confirm that we do hold the information you have requested. However, I am withholding this
information under subsections 31(1)(a), (b), (d) and (g) of the Act which relate to law enforcement,
specifically that disclosure would, or would be likely to, prejudice the prevention or detection of crime.
I am satisfied in terms of section 2(2) of the Act that in all the circumstances of the case, the public interest
in maintaining the exemption outweighs the public interest in disclosing the information. I have considered
the public interest test in the section headed ‘
Why information has been withheld’, below.
I can, however, provide some figures that have been released previously relating to the cost of our
detection equipment.
- The cost of a new detector van is £108,474.59. This figure includes the cost of the vehicle prior to
it being modified (£14,900.36). The figure does not include all the BBC’s internal costs for
researching and developing the technology involved. These costs are not quantifiable as they are
incorporated in non-specific costs such as staff salaries, which cover their work on a number of
projects.
- The cost of a hand-held device is around £600. This figure does not include all the BBC’s internal
costs for researching and developing the technology involved. These costs are not quantifiable as
they are incorporated in non-specific costs such as staff salaries, which cover their work on a
number of projects.
Why information has been withheld
It is a criminal offence to install and use television-receiving equipment to watch or record television
programme services without a valid licence. TV Licensing investigates and prosecutes such unlicensed use
of television receiving equipment. It uses detection equipment to assist in this activity.
(For the avoidance of doubt, may I confirm that we are not suggesting that you would use the information
for the above purpose – merely that we consider that there is a strong likelihood that others who could
gain access to the information would do so. All information disclosed under the Act is considered to be
effectively placed in the public domain).
I am required under section 2(2) of the Act to assess whether the public interest in maintaining the
exemption outlined in the sections above outweighs the public interest in disclosing the information.
The following factors are in favour of disclosure:
1. Ensuring that public funds are being appropriately applied, and specifically that:
a. the TV Licensing system is being efficiently run; and
b. that value for money is being obtained.
I consider that the above public interest factors in favour of disclosure are already served by the following:
2. The BBC has a duty to enforce the television licensing system and it is essential that effective
deterrents against evasion are maintained for this purpose. Without an effective deterrent, evasion
would invariably increase. This would be to the detriment of the honest majority of people who
are properly licensed and to the overall amount of revenue available to the BBC. It would also
increase detection costs.
3. The fact that the BBC is required to satisfy the National Audit Office ('NAO') as to the value for
money of the collection and enforcement arrangements and is accountable for the economy,
efficiency and effectiveness of such arrangements. (NAO's most recent audit, dating from 18
January 2007, is published online at www.nao.org.uk/publications).
4. The fact that the BBC has reduced the cost of collection from 6.2% of the total licence fee
collected in 1991/2 (when it took over responsibility from the Home Office), to 3.6% for the
financial year 07/08. This demonstrates that the TV Licensing system is being efficiently run. This
and further related information is available in the BBC’s annual report (see www.bbc.co.uk) and the
TV Licensing Annual Review (see www.tvlicensing.co.uk/aboutus).
In this instance, the public interest is served by maintaining an effective deterrent to licence fee evasion and
thus in turn protecting the BBC’s revenue stream.
There is hence a greater public interest in ensuring the effective collection of the licence fee than in
disclosing the information you have sought. I am therefore satisfied, in terms of section 2 of the Act, that in
all the circumstances of the case, the public interest in maintaining the exemption outweighs the public
interest (outlined above) in disclosing the information.
Your appeal rights
This enquiry has been dealt with under the terms of the Freedom of Information Act. 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
