Mr M Meaney
[FOI #46154 email]
29th September 2010
Dear Mr M Meaney
Freedom of Information Act 2000 – RFI20101186
Thank you for your request under the Freedom of Information Act (‘the Act’) of 2nd September
2010 asking:
I would like to know how much money the BBC has spent on Internet marketing from
2009-2010.
1) Which Internet marketing methods do the BBC currently use? (e.g SEO, PPC, etc)
2) How much has been spent on each of these methods between 2009 - 2010?
To maximise the value delivered to licence payers, the BBC needs to build awareness of the new
content we produce and distribute. Alongside on-air trails, we use a variety of web-based
marketing techniques where appropriate, to support both our digital and traditional content.
Most of the BBC's digital marketing activity is delivered at little or no direct cost. Examples of this
include:
• Twitter feeds
• Reflecting Search Engine Optimisation (SEO) principles in the design of our web pages
• Marketing messages on our own site which assist user navigation
Occasionally, we use paid-for digital marketing inventory where it is especially able to reach
particular discrete groups - eg youth audiences, or children. The two principal forms of paid-for
marketing we use in the digital space are paid search marketing, and digital display advertising (ie,
banners, buttons, Media Placement Units). In 2009/10, the BBC's Marketing department spent:
• c. £1.4m on digital display advertising
• c. £220k on paid search marketing
There may be small amounts of digital marketing spend across the BBC which are funded by the
individual production areas. However, if any activity does take place, the information about these
would be excluded from the Act because such information is held for the purposes of ‘journalism,
art or literature’. The BBC would therefore not be obliged to provide this information to you.
Part VI of Schedule I to FOIA provides that information held by the BBC and the other public
service broadcasters is only covered by the Act if it is held for ‘purposes
other than those of
journalism, art or literature’. The BBC is not required to supply information held for the purposes
of creating the BBC’s output or information that supports and is closely associated with these
creative activities, including their promotion.
However, even if it was determined that the information fell within the scope of the Act the BBC
is of the view that, due to the need to contact every individual team throughout the BBC to
identify if they had spent any money on marketing that fits the description of your request and
then to collate any information, would take a significant amount of time and section 12 of the Act
would apply. As you may be aware, we are allowed to refuse to handle the request if it would
exceed the appropriate limit. The appropriate limit has been set by the Regulations (SI 2004/3244)
as being £450 (equivalent to two and a half days work, at an hourly rate of £25).
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 above, 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/
Yours sincerely,
Colin Sellers
Chief Advisor, BBC Marketing, Communications and Audiences
Freedom of Information
From January 2005 the Freedom of Information (FOI) Act 2000 gives a general right of access to all
types of recorded information held by public authorities. The Act also sets out exemptions from that
right and places a number of obligations on public authorities. The term “public authority” is defined in
the Act; it includes all public bodies and government departments in the UK. The BBC, Channel 4 and
S4C are the only broadcasters covered by the Act.
Application to the BBC
The BBC has a long tradition of making information available and accessible. It seeks to be open and
accountable and already provides the public with a great deal of information about its activities. BBC
Information operates 24 hours a day, seven days a week handling telephone and written comments
and queries, and the BBC’s website bbc.co.uk provides an extensive online information resource.
It is important to bear this in mind when considering the Freedom of Information Act and how it
applies to the BBC. The Act does not apply to the BBC in the way it does to most public authorities in
one significant respect. It recognises the different position of the BBC (as well as Channel 4 and S4C)
by saying that it covers information “held for purposes other than those of journalism, art or
literature”. This means the Act does not apply to information held for the purposes of creating the
BBC’s output (TV, radio, online etc), or information that supports and is closely associated with these
creative activities.
A great deal of information within this category is currently available from the BBC and will continue
to be so. If this is the type of information you are looking for, you can check whether it is available on
the BBC’s website bbc.co.uk or contact BBC Information.
The Act does apply to all of the other information we hold about the management and running of the
BBC.
The BBC
The BBC's aim is to enrich people's lives with great programmes and services that inform, educate and
entertain. It broadcasts radio and television programmes on analogue and digital services in the UK. It
delivers interactive services across the web, television and mobile devices. The BBC's online service is
Europe's most widely visited content site. Across the world, the BBC broadcasts radio programmes in
32 languages on the BBC World Service and the 24 hour television service, BBC World News.
The BBC's remit as a public service broadcaster is defined in the BBC Charter and Agreement. It is
the responsibility of the BBC Trust (the sovereign body within the BBC) to ensure that the
organisation delivers against this remit by setting key objectives, approving strategy and policy, and
monitoring and assessing performance. The Trustees also safeguard the BBC's independence and
ensure the Corporation is accountable to its audiences and to Parliament.
Day-to-day operations are run by the Director-General and his senior management team, the
Executive Board. All BBC output in the UK is funded by an annual Licence Fee. This is determined and
regularly reviewed by Parliament. Each year, the BBC publishes an Annual Report & Accounts, and
reports to Parliament on how it has delivered against its public service remit.
