S. Damian
[FOI #3909 email]
18 November 2008
Dear Mr Damian,
Freedom of information request – RFI 2008 1182
Thank you for your request dated 2 November 2008 seeking further information about TV
Licensing. Your request is being dealt with under the Freedom of Information Act 2000 (“the
Act”).
Please note that “TV Licensing” is a trading name used by companies contracted by the BBC to
administer the collection of television licence fees and enforcement of the television licensing
system. The majority of the administration of TV Licensing is contracted to Capita Business
Services Ltd (which undertakes the majority of the administration of the TV Licensing system),
with the administration of our cash related payment schemes contracted to Revenues
Management Services Ltd (RMS). PayPoint Network Ltd and PayPoint Collections Ltd are
contracted to provide over-the-counter services. The marketing and public relations activities are
contracted to the AMV Consortium. The consortium is made up of the following four companies:
Abbott Mead Vickers BBDO Ltd, Fishburn Hedges Boys Williams Limited, PHD Media Limited and
Proximity London Ltd. The BBC is a public authority in respect of its television licensing functions
and retains overall responsibility.
In your request you asked the following:
For each of the last five financial years how much has been spent by the BBC on all marketing
expenses associated with encouraging people to pay their licence fee? Specifically please state how
much of that total is made up by the production of films/adverts warning people of the dangers of not
paying their licence?
The broad answer to your question is contained in the attached document
TV Licensing Costs of
Collection which you will see contains general information on communications costs, including
reminders and information campaigns.
I can confirm that we hold the more specific information that you have requested on “marketing
expenses” and the cost of advertising. However, I am withholding this information under s43 of
the Act. Section 43 states that information will be exempt under the Act if its disclosure under
the Act would, or would be likely to, prejudice the commercial interests of any person (including
the public authority holding it).
As stated above, “TV Licensing” is a trading name used by companies contracted by the Licensing
Authority (the BBC) to administer the collection of television licence fees and enforcement of the
television licensing system. Details of specific information regarding advertising costs correlates
closely with the total amount paid to the AMV Consortium. Releasing this would therefore be
likely to prejudice the commercial interests of the BBC and the AMV Consortium as this
relationship is in itself commercial and releasing the figures we hold would prejudice the AMV
Consortium’s commercial interests, and thus in turn, the BBC’s commercial interests.
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 on why information has been withheld
below.
Why information has been withheld
I am required under s 2(2) of the Act to assess whether the public interest in maintaining the
exemptions outweigh the public interest in disclosing the information.
The following factors are in favour of disclosure:
1. ensuring that public funds are being appropriately applied, that is:
a. ensuring that the TV Licensing system is being efficiently run; and
b. ensuring that value for money is being obtained.
2. ensuring a high standard of debate around the licence fee collection, currently being
generated in response to the BBC Trust’s open consultation (available at
http://www.bbc.co.uk/bbctrust/consult/open_consultations/tv_licence.html), by placing as
much information as possible into the public domain.
I consider that the above public interest factors in favour of disclosure are served by the following:
1. The attached document
BBC TV Licensing Costs of Collection
2. The fact that 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.
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
is published at http://www.nao.org.uk/publications/nao_reports/06-07/0607183.pdf.
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 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), the TV Licensing Annual Review and the
About TV Licensing document (see
http://www.tvlicensing.co.uk/aboutus/index.jsp). A key part of this success has been the
use of detection as a significant deterrent element.
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 exemptions
outweighs the public interest (outlined above) in disclosing the information.
Appeal rights
If you are not satisfied with this response you have the right to an internal review by a BBC senior
manager or legal adviser. Please contact us at the address provided, explaining what you would like
us to review and including your reference number.
If you are not satisfied with the internal review,
you can appeal to the Information Commissioner. The contact details are: Information
Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, telephone
01625 545 700 or see http://www.ico.gov.uk/
I hope this response is helpful.
Yours sincerely,
Natalie Saunderson
Policy Adviser
BBC TV Licensing Management Team
