Dear Sir or Madam,

With reference to the Metropolitan Police's advertising of the
Anti-terrorist Hotline on the Google search engine's AdWords
program, I would like you to make available without prejudice any
documents, reports, emails and minutes of meetings related to
discussions or other business relating to the initiation,
preparation, maintenance or any other activity connected to the
above matter, including but not limited to:

* Why were no other search engines besides Google used for
advertising? Was there a public tender involved?
* How were search terms decided upon?
* How was the appropriate budget level decided?
* How was the cost-effectiveness of the campaign evaluated?
* Which stakeholders were consulted in the forming of policy on
this matter?

Please focus on supplying documents related to the above questions
if it will cost too much to supply more than that.

Thank you for your help, and don't hesitate to ask me for
clarifications if something is not clear in my request.

Yours faithfully,

Guy Freeman

Dear Mr Freeman

Freedom of Information Request Reference No: 2009020007246

I write in connection with your request for information which was received
by the Metropolitan Police Service (MPS) on 26/02/2009. I note you seek
access to the following information:

With reference to the Metropolitan Police's advertising of the
Anti-terrorist Hotline on the Google search engine's AdWords program, I
would like you to make available without prejudice any documents, reports,
emails and minutes of meetings related to discussions or other business
relating to the initiation, preparation, maintenance or any other activity
connected to the above matter, including but not limited to:
* Why were no other search engines besides Google used for advertising?
Was there a public tender involved? * How were search terms decided upon?
* How was the appropriate budget level decided?
* How was the cost-effectiveness of the campaign evaluated? * Which
stakeholders were consulted in the forming of policy on this matter?

Please focus on supplying documents related to the above questions if it
will cost too much to supply more than that.

Your request will now be considered in accordance with the Freedom of
Information Act 2000 (the Act). You will receive a response within the
statutory timescale of 20 working days as defined by the Act, subject to
the information not being exempt or containing a reference to a third
party. In some circumstances the MPS may be unable to achieve this
deadline. If this is likely you will be informed and given a revised
time-scale at the earliest opportunity.

Some requests may also require either full or partial transference to
another public authority in order to answer your query in the fullest
possible way. Again, you will be informed if this is the case.

COMPLAINT RIGHTS

Your attention is drawn to the attached sheet, which details your right of
complaint.

Should you have any further enquiries concerning this matter, please write
or contact Shannon Aldridge on telephone number 020 7161 3527 quoting the
reference number above.

Yours sincerely

Shannon Aldridge
Support Officer

COMPLAINT RIGHTS

Are you unhappy with how your request has been handled or do you think the
decision is incorrect?

You have the right to require the Metropolitan Police Service (MPS) to
review their decision.

Prior to lodging a formal complaint you are welcome and encouraged to
discuss the decision with the case officer that dealt with your request.

Ask to have the decision looked at again –

The quickest and easiest way to have the decision looked at again is to
telephone the case officer that is nominated at the end of your decision
letter.

That person will be able to discuss the decision, explain any issues and
assist with any problems.

Complaint

If you are dissatisfied with the handling procedures or the decision of
the MPS made under the Freedom of Information Act 2000 (the Act) regarding
access to information you can lodge a complaint with the MPS to have the
decision reviewed.

Complaints should be made in writing and addressed to:

FOI Complaint
Public Access Office
PO Box 57192
London
SW6 1SF

In all possible circumstances the MPS will aim to respond to your
complaint within 40 working days.

The Information Commissioner

After lodging a complaint with the MPS if you are still dissatisfied with
the decision you may make application to the Information Commissioner for
a decision on whether the request for information has been dealt with in
accordance with the requirements of the Act.

For information on how to make application to the Information Commissioner
please visit their website at www.informationcommissioner.gov.uk.
Alternatively, phone or write to:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Phone: 01625 545 700

show quoted sections

Dear Mr Freeman

Freedom of Information Request Reference No: 2009020007246

I write in connection with your request for information which was received
by the Metropolitan Police Service (MPS) on 26/02/2009. I note you seek
access to the following information:

With reference to the Metropolitan Police's advertising of the
Anti-terrorist Hotline on the Google search engine's AdWords program, I
would like you to make available without prejudice any documents, reports,
emails and minutes of meetings related to discussions or other business
relating to the initiation, preparation, maintenance or any other activity
connected to the above matter, including but not limited to:
* Why were no other search engines besides Google used for advertising?
Was there a public tender involved? * How were search terms decided upon?
* How was the appropriate budget level decided?
* How was the cost-effectiveness of the campaign evaluated? * Which
stakeholders were consulted in the forming of policy on this matter?
Please focus on supplying documents related to the above questions if it
will cost too much to supply more than that.

Under the Freedom of Information Act 2000 (the Act), we have 20 working
days to respond to a request for information unless we are considering
whether the information requested is covered by one of the 'qualified
exemptions' (exemptions which must be tested against the public interest
before deciding whether they apply to the information in question).

Where we are considering the public interest test against the application
of relevant qualified exemptions, Section 17(2)(b) provides that we can
extend the 20 day deadline.

Section 17(2) provides:

2) Where-
a) in relation to any request for information, a public authority is, as
respects any information, relying on a claim-
i) that any provision of Part II which relates to the duty to confirm or
deny and is not specified in section 2(3) is relevant to the request, or
ii) that the information is exempt information only by virtue of a
provision not specified in section 2(3), and
b) at the time when the notice under subsection (1) is given to the
applicant, the public authority (or, in a case falling within section
66(3) or (4), the responsible authority) has not yet reached a decision as
to the application of subsection (1)(b) or (2)(b) of section 2,
the notice under subsection (1) must indicate that no decision as to the
application of that provision has yet been reached and must contain an
estimate of the date by which the authority expects that such a decision
will have been reached.

I am sorry to inform you that we have not been able to complete our
response to your request by the date originally stated, as we are
currently considering whether 'qualified exemptions' apply to the
information you have requested. As a result we will not be able to respond
within 20 working days.

For your information we are considering the following exemption(s):

Section 31(1) (a)
Section 43 (2)

I can now advise you that the amended date for a response is 16 April
2009.

May I apologise for any inconvenience caused.

COMPLAINT RIGHTS

If you are dissatisfied with this response please read the attached paper
entitled Complaint Rights which explains how to make a complaint.

Should you have any further enquiries concerning this matter, please
contact me on 0207 230 2401 or at the address at the top of this letter,
quoting the reference number above.

Yours sincerely

Gill Brown
Information Manager

COMPLAINT RIGHTS

Are you unhappy with how your request has been handled or do you think the
decision is incorrect?

You have the right to require the Metropolitan Police Service (MPS) to
review their decision.

Prior to lodging a formal complaint you are welcome and encouraged to
discuss the decision with the case officer that dealt with your request.

Ask to have the decision looked at again -

The quickest and easiest way to have the decision looked at again is to
telephone the case officer that is nominated at the end of your decision
letter.

That person will be able to discuss the decision, explain any issues and
assist with any problems.

Complaint

If you are dissatisfied with the handling procedures or the decision of
the MPS made under the Freedom of Information Act 2000 (the Act) regarding
access to information you can lodge a complaint with the MPS to have the
decision reviewed.

Complaints should be made in writing and addressed to:

FOI Complaint
Public Access Office
PO Box 57192
London
SW6 1SF

In all possible circumstances the MPS will aim to respond to your
complaint within 40 working days.

The Information Commissioner

After lodging a complaint with the MPS if you are still dissatisfied with
the decision you may make application to the Information Commissioner for
a decision on whether the request for information has been dealt with in
accordance with the requirements of the Act.

For information on how to make application to the Information Commissioner
please visit their website at www.informationcommissioner.gov.uk.
Alternatively, phone or write to:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Phone: 01625 545 700

show quoted sections

Dear Gill,

Thank you for keeping my updated.

Yours sincerely,

Guy Freeman

Dear Mr Freeman

Freedom of Information Request Reference No: 2009020007246

I write in connection with your request for information which was
received by the Metropolitan Police Service (MPS) on 26/02/2009. I
note you seek access to the following information:

With reference to the Metropolitan Police's advertising of the
Anti-terrorist Hotline on the Google search engine's AdWords program, I
would like you to make available without prejudice any documents,
reports, emails and minutes of meetings related to discussions or other
business relating to the initiation, preparation, maintenance or any
other activity connected to the above matter, including but not limited
to:

· Why were no other search engines besides Google used for
advertising?
· Was there a public tender involved?
· How were search terms decided upon?
· How was the appropriate budget level decided?
· How was the cost-effectiveness of the campaign evaluated?
· Which stakeholders were consulted in the forming of policy on
this matter?

Please focus on supplying documents related to the above questions if
it will cost too much to supply more than that.

Please accept this letter as an acknowledgement of receipt of your
request which has been considered under the Freedom of Information Act
2000 (FOIA).

Before I explain the reasons for the decisions I have made in relation
to your request, I thought that it might assist you if I outline the
parameters set out by the Freedom of Information Act 2000 (the Act)
within which a request for information can be answered.

The Freedom of Information Act 2000 creates a statutory right of access
to information held by public authorities. A public authority in
receipt of a request must, if permitted, confirm if that public
authority holds the requested information and, if so, then communicate
that information to the applicant.

The right of access to information is not without exception and is
subject to a number of exemptions, which are designed to enable public
authorities to withhold information that is not suitable for release.
Importantly, the Act is designed to place information into the public
domain, that is, once access to information is granted to one person
under the Act, it is then considered public information and must be
communicated to any one.

REASONS FOR DECISION

Section 17 of the Act provides:

(1) A public authority which, in relation to any request for
information, is to any extent relying on a claim that any provision in
part II relating to the duty to confirm or deny is relevant to the
request or on a claim that information is exempt information must,
within the time for complying with section 1(1), give the applicant a
notice which-

(a) states the fact,
(b) specifies the exemption in question, and
(c) states (if that would not otherwise be apparent) why the exemption
applies.

In this case I am relying on the following exemptions:

31 Law enforcement

(1) Information which is not exempt information by virtue of section 30
is exempt information if its disclosure under this Act would, or would
be likely to, prejudice—

(a) the prevention or detection of crime,
(b) the apprehension or prosecution of offenders,

This is a prejudice based qualified exemption that requires that I
provide an assessment of the harm and a public interest test.

40 Personal information

(2) Any information to which a request for information relates is also
exempt information if—
(a) it constitutes personal data which do not fall within subsection
(1), and
(b) either the first or the second condition below is satisfied.
(3) The first condition is—
(a) in a case where the information falls within any of paragraphs (a)
to (d) of the definition of “data” in section 1(1) of the [1998 c. 29.]
Data Protection Act 1998, that the disclosure of the information to a
member of the public otherwise than under this Act would contravene—

(i) any of the data protection principles,

Under principle one of the Data Protection Act 1998, personal data must
be processed by an organisation fairly and lawfully. Therefore to
release the personal data of third party individuals, which would be
included within the information you have requested, would breach the
agreed use of that information and would infringe the Data Protection
principles.

The first data protection principle states:
1. Personal data shall be processed fairly and lawfully an, in
particular, shall not be processed unless-
(a) at least one of the conditions in schedule 2 is met.

Some of the information requested, which has not been disclosed, is
classed as personal data in Section 1 of the Data Protection Act.

Section 40 in an absolute exemption.

43 Commercial interests
(1) Information is exempt information if it constitutes a trade secret.
(2) Information is exempt information if its disclosure under this Act
would, or would be likely to, prejudice the commercial interests of any
person (including the public authority holding it).

Section 43 is a class based qualified exemption that requires that a
public interest test is completed.

Evidence of Harm

In considering whether or not this information should be disclosed, I
have considered the potential harm that could be caused by disclosure.
This might include the release of the details of the budget set aside
as this might lead those involved in bidding or preparing work to
increase their prices. This could lead to a less than effective use of
public resources.

Information held about the process of identifying the search terms etc
is commercially sensitive and cannot be widely shared without creating
an unfair situation for those organizations working with us at
present. To publish this information would give others an unfair
advantage in any future bidding processes as the companies currently
managing the process have created this information as part of their
contracted service. The MPS have paid for this commercial expertise
and it would not be sound business practice to release this
information, developed by one organisation as part of the current
successful bid, to all potential competitors for future campaigns.

Public Interest Test

Public interest considerations favouring disclosure

Public Participation
The circulation of all of the material will enable the public to be
aware of all of the efforts being made by the Counter Terrorism Command
to engage with all communities in the effort to promote awareness of
the potential terrorist threat and to encourage the sharing of
information that might be of assistance on preventing acts of
terrorism.

Use of public funds/resources
This would enable the wider public to be aware that the funds available
to the Counter Terrorism Command are being used to the best effect in
developing publicity campaigns to raise awareness and promote
information sharing.

Public interest considerations favouring non-disclosure

Timing of request
To reveal all of the information about budgets during times when there
are other publicity campaigns in the future will enable those bidding
to have clarity about the funds available and may therefore enable them
to increase their bids. This could have a detrimental effect on the
use of public funds.

Efficient and effective conduct of the service.
The MPS Counter Terrorism Command is developing methods to facilitate
the flow of information to police from all parts of the community
employing as many types of media as possible. This campaign was part
of that activity and the release of the details requested may impact of
the ability to run such campaigns in the future if sensitive cost
information is released.

Balancing Test
After weighing up the competing interests I have determined that the
disclosure of the information covered by the exemptions quoted above
would not be in the public interest. I consider that the benefit that
would result from the information being disclosed does not outweigh
disclosing information relating to the compilation of the search terms
and budgetary information.

However in respect of your remaining questions the following answers
have been compiled.

· Why were no other search engines besides Google used for
advertising?

Other search engines were considered for this project however Google is
the most widely used search provider and therefore most effective.
Google has an 85% market share in the UK making it by someway the
biggest volume driver, which means we are confident of delivering
forecasted volume, which is not necessarily the case with others such
as Yahoo and MSN. In addition to this, we tend to see better response
rates in terms of click-to-interaction on Google. So by putting the
entire budget into Google this results in less click-wastage for people
coming through search than we would see if we introduced Yahoo and MSN
too.

· Was there a public tender involved?

There was no public tender for this specific project as this work was
carried out by our contracted media planning and buying agency. Our
media planning and buying agency was selected by OJEU process.

· How were search terms decided upon?

This information is considered to be commercially sensitive and has
been subjected to the Public Interest and Harm assessment details
above.

· How was the appropriate budget level decided?

The budget for this activity was based on overall campaign budget
availability and advice from our contracted media planning and buying
agency who's role is to advise on the best way of getting messages
across to the public. The principle purpose of the campaign activity is
to raise awareness and educate people of the preparatory activities
associated with terror attacks.

In terms of individual bids for search terms, all bids are set low
because they are either brand terms (i.e. Metropolitan Police) or very
specifically related to terrorism (i.e. specific chemicals) which means
that there are no other advertisers bidding on those terms.

We also have a daily cap of search spend in place to ensure that the
budget gets spread across the entire year. The existence of the cap is
reviewed when there are any high-interest terrorism related news
stories in the media, in order to ensure that anybody interested in the
subject matter can reach us.

· How was the cost-effectiveness of the campaign evaluated?

The campaign is based on number of people searching for the word and
click through rates to the MPS pages.

· Which stakeholders were consulted in the forming of policy on
this matter?

The MPS was originally responsible for funding and setting up of Google
search activity, more specifically the Directorate of Public Affairs
and Specialist Operations. ACPO TAM later invested in this project.

Please find attached your copies of the information that we are
prepared to release redacted using the exemptions referred to in the
above explanation.

COMPLAINT RIGHTS

If you are dissatisfied with this response please read the attached
paper entitled Complaint Rights which explains how to make a
complaint.

Should you have any further enquiries concerning this matter, please
contact me on 0207 230 2401 or at the address at the top of this
letter, quoting the reference number above.

Yours sincerely

Gill Brown
Information Manager

In complying with their statutory duty under sections 1 and 11 of the
Freedom of Information Act 2000 to release the enclosed information,
the Metropolitan Police Service will not breach the Copyright, Designs
and Patents Act 1988. However, the rights of the copyright owner of the
enclosed information will continue to be protected by law.
Applications for the copyright owner's written permission to reproduce
any part of the attached information should be addressed to MPS
Directorate of Legal Services, 1st Floor (Victoria Block), New Scotland
Yard, Victoria, London, SW1H 0BG.

COMPLAINT RIGHTS

Are you unhappy with how your request has been handled or do you think
the decision is incorrect?

You have the right to require the Metropolitan Police Service (MPS) to
review their decision.

Prior to lodging a formal complaint you are welcome and encouraged to
discuss the decision with the case officer that dealt with your
request.

Ask to have the decision looked at again –

The quickest and easiest way to have the decision looked at again is to
telephone the case officer that is nominated at the end of your
decision letter.

That person will be able to discuss the decision, explain any issues
and assist with any problems.

Complaint

If you are dissatisfied with the handling procedures or the decision of
the MPS made under the Freedom of Information Act 2000 (the Act)
regarding access to information you can lodge a complaint with the MPS
to have the decision reviewed.

Complaints should be made in writing and addressed to:

FOI Complaint

Public Access Office

PO Box 57192

London

SW6 1SF

In all possible circumstances the MPS will aim to respond to your
complaint within 40 working days.

The Information Commissioner

After lodging a complaint with the MPS if you are still dissatisfied
with the decision you may make application to the Information
Commissioner for a decision on whether the request for information has
been dealt with in accordance with the requirements of the Act.

For information on how to make application to the Information
Commissioner please visit their website at
www.informationcommissioner.gov.uk. Alternatively, phone or write to:

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Phone: 01625 545 700

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