British Broadcasting Corporation Room BC2 A4 Broadcast Centre White City Wood Lane London W12 7TP
Telephone 020 8008 2882 Email xxx@xxx.xx.xx
Information Rights
bbc.co.uk/foi
bbc.co.uk/privacy
Mr Scott
Via email:
xxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxxxxx.xxx
25 October 2017
Dear Mr Scott
Request for Information – RFI20171458
Thank you for your request of 4th October 2017 under the Freedom of Information Act 2000 (‘the Act’)
seeking the following information:
“1) What is the current cost per letter sent to unlicensed properties?
2) How many letters are sent per month to unlicensed properties?
3) How much does it cost TVL to use the Royal Mail second class stamp reproduction? Please round
to the nearest 1,000 pounds.
4) How many mass mailings from TVL are Returned to Sender per month?
5) How many letters are sent to a property before an officer is assigned to visit?
6) What percentage of mass mailings are made of recycled paper?”
Please note that “TV Licensing” is a trade mark 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 (‘Capita’). Over-the-counter
services are provided by PayPoint plc (‘PayPoint’) in the UK, and by the Post Office in the Isle of Man and
Channel Islands. Marketing and printing services are contracted to Proximity London Ltd. Media services
are contracted to Media Planning Limited trading as Havas Media UK. The BBC is a public authority in
respect of its television licensing functions and retains overall responsibility.
TV Licensing has a statutory duty to ensure people are covered by a TV Licence to watch or record
television programmes as they are being shown on TV or live on an online TV service, and to download or
watch BBC programmes on demand, including catch up TV, on BBC iPlayer. It has a comprehensive
database of more than 30 million addresses across the UK and there are over 25 million TV Licences in
force. TV Licensing minimises paper communications wherever possible and uses letters only where it does
not have an email address or customer consent to use an email address. All TV Licensing’s mailings have a
positive return on investment (ROI) and sending letters is the most cost effective means of enforcing the
law regarding TV Licensing.
I shall address your requests in turn below. As you have not specified a time period to which your request
relates, all information provided pertains to the 2016/17 financial year.
Requests 1 and 3
The cost of sending TV Licensing mailings comprises print and fulfilment, which is carried out by Proximity
(who sub-contract to Communisis Group (Communisis)); and postal services, which are contracted to
Communisis. I can confirm that we do hold information that we consider relevant to your request, namely
costs information in respect of the constituent elements of printing and fulfilment and postage. However, I
am withholding this information under section 43(2) of the Act because the release of such pricing
information would be likely to prejudice the commercial interests of Proximity, Communisis and the BBC.
The release of the information would reveal valuable information about our contractors’ and sub-
contractors’ pricing to their competitors, while they would not be in possession of the same information
regarding their competitors. The release of the requested information would therefore be likely to assist
such competitors in future negotiations.
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 exemptions outweighs the public interest in disclosing the information. I have provided
further explanation of my consideration of the public interest test in the section ‘Why information has been
withheld’ below.
In line with the duty to provide you with reasonable advice and assistance under section 16 of the Act, I can
confirm the average postage cost for a standard TV Licensing letter during the 2016/17 financial year was
£0.22 (please note that this information has previously been released).
Request 2
Please see below the approximate figure for the number of mailings sent by TV Licensing to unlicensed
addresses, where we have not been informed by the occupier that a licence is not required (this
information has previously been released):
2016/17 financial year: 28,592,877
Please note that this numbers refers to letters sent, not to the number of addresses mailed, as unlicensed
addresses will receive several letters before being visited.
Request 4
We keep a record of the number of undelivered mailings that have been returned to TV Licensing; however,
we do not track the specific reasons for these being returned. I can confirm that 1,852,580 mailings were
returned in the 2016/17 financial year.
Request 5
As part of TV Licencing’s overarching enforcement strategy we will send various unlicensed mailings to
various addresses in various combinations. An enquiry officer visit is assigned depending on the individual
circumstances and therefore it isn’t possible to provide you with a definitive response to this part of your
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request. Please note that we consider more detailed information about our enforcement strategy to be
exempt under section 31 of the Act which relates to law enforcement.
Request 6
All white outer envelopes, manila outer envelopes and reply envelopes are produced from recycled stock.
Letterhead and inserts are produced from virgin pulp stock. In all cases, regardless of paper types, all stocks
are sourced from either FSC or PEFC accredited sources. Please note that we encourage customers to
communicate with us via email wherever possible.
Why information has been withheld
As section 43 is a qualified exemption, I am required by section 2(2) of the Act to assess whether the
public interest in maintaining the exemption outweighs the public interest in disclosing the information.
The following factors are in favour of disclosure:
1.
that the BBC is using public money effectively; and
2.
that the BBC is getting value for money in respect of its use of the licence fee when purchasing
goods and services.
However, it is the BBC’s contention that given its commercial sensitivity, these objectives wil be prejudiced
if the information requested is disclosed.
I consider that the above public interest factors in favour of disclosure are served by the fol owing:
1.
The fact that the BBC is subject to a broad range of internal mechanisms, including oversight by the
BBC Board which is responsible for ensuring the effective and efficient management of BBC
finances and operations in accordance with the principles of regularity, propriety, value for money
and feasibility (Articles 16 and 20(7)(a) of the Charter).
2.
The BBC is required to comply with Ofcom regulations, the fair trading regime and competition law
in general.
3.
In the interests of transparency and accountability, certain limited information on expenditure is
already provided in the BBC’s Annual Report and Accounts and the TV Licensing Annual Review.
In addition, the following factors are in favour of withholding the information:
1.
That the BBC maintains a strong bargaining position vis-à-vis suppliers during contractual
negotiations in order to ensure that the licence fee is spent effectively.
2.
That the competitive position of companies in their particular market is not disadvantaged by doing
business with the BBC. It would not be in the public interest to disclose sensitive information about
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the commercial arrangements between particular companies if that information would be likely to
be used by competitors to gain a competitive advantage.
3.
Releasing the cost of commercial transactions would be likely to adversely affect the BBC’s
negotiating position in future contractual negotiations with suppliers of this type of service. This
would compromise the BBC’s ability to achieve value for money for licence fee payers.
In this instance, I consider that the public interest is served by ensuring that the pricing details of the BBC’s
commercial arrangements are protected. I am therefore satisfied, in terms of section2(2) of the Act, that in
al the circumstances of the case, the public interest in withholding the information outweighs the public
interest (outlined above) in disclosing the information.
Appeal Rights
If you are not satisfied that the BBC has 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 under the Act 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 SK9 5AF. Tel: 0303 123
1113 or see
http://ico.org.uk
Kind regards
Rupinder Panesar
Freedom of Information Advisor, TV Licensing Management Team
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