PACE compliance of TVL interviews

Roedd y cais yn rhannol lwyddiannus.

Dear British Broadcasting Corporation,

I bring to your attention a page produced by HSE instructing investigating officers on conducting PACE compliant interviews.

The contrast between this document produced by an organisation that takes its legal obligations seriously and the TVL Visiting Procedures produced by an organisation that has no problem acting ultra vires is plain for anyone to see so I won't go into details here. But I would note that whilst HSE has no issue publishing it's procedures on the internet, TVL has been incredibly secretive about its own procedures, releasing them only in response to FOIA requests and even now the visiting procedures remain heavily redacted. I raise the question about whether the reason for the redactions is to prevent ultra vires policies and actions from being subject to public scrutiny

Section 67(9) of PACE states that persons other than Police Officers charged with the duty of investigating offences shall in discharge of that duty have regard to any relevant provision of such a Code and TVL has confirmed it's statutory obligation to ensure that its procedures comply with PACE here in which you state “The Courts have held that persons such as TV Enquiry Officers are …
persons charged with the duty of investigating offences.”

In light of the above I would like you to send me any and all documentation concerning the rationale behind the decision to produce procedures without regard to the PACE codes.

I would like you to send me detailed information concerning the design of the TVL178.

Was independent legal advice taken on this? What were the qualifications of the person providing the advice? What date was legal advice last sought? Was the legal advice applied in full? If not, explain why not.

Kindly demonstrate how the form complies with PACE requirements to maintain a verbatim record of an interview (there is no space for verbatim answers to be entered and the interviewer is encouraged to simply draw circles around printed choices) and how the form complies with 3.5 of CIPA (the pre-prepared questions assume guilt and do not allow the possibility of exploring explanations pointing towards the suspects innocence)

Yours faithfully,

Louisa Woodward

FOI Enquiries, Y Gorfforaeth Ddarlledu Brydeinig

1 Atodiad


Dear Louisa Woodward


Thank you for your request for information under the Freedom of
Information Act 2000, as detailed in your email. Your request was received
on 10/03/2018.  We will deal with your request as promptly as possible,
and at the latest within 20 working days. If you have any queries about
your request, please contact us at the address below.


The reference number for your request is RFI20180452.


Kind regards,



Information Rights


BBC Freedom of Information

BC2 A4, Broadcast Centre

201 Wood Lane

London W12 7TP



Email: [2][BBC request email]


Tel: 020 8008 2882





dangos adrannau a ddyfynnir

FOI Enquiries, Y Gorfforaeth Ddarlledu Brydeinig

2 Atodiad

Dear Louisa Woodward


Please find attached the response to your request for information,
reference RFI20180452.


Yours sincerely


BBC Information Policy and Compliance

Room BC2 A4

Broadcast Centre

White City


W12 7TS



Website: [1]

Email: [2]mailto:[BBC request email]


[3]Description: Description: \\BBCFS2025\UserData$\myrien01\Documents\My



Visible links
1. file:///tmp/
2. mailto:[BBC request email]

Gadawodd RP Hodges anodiad ()

Care should be taken when reviewing the BBC response in that they make reference to “ These are not requests for recorded information. However, I can tell you outside the scope of the Act”, which implies that the Author is not requesting information in line with the FOI Act.

Having read the questions, these are clearly requests for information from the BBC. Whether the BBC hold or do not hold this information is not clear in their response, but their response “I can tell you outside the scope of the Act” suggests that they do hold the information.