British Broadcasting Corporation Room BC2 B6 Broadcast Centre White City Wood Lane London W12 7TP
Telephone 020 8008 2882 Email xxx@xxx.xx.xx
Information Policy & Compliance
bbc.co.uk/foi
bbc.co.uk/privacy
Martin Milan
Via email: Martin Milan
xxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxxxxx.xxx
4 October 2013
Dear Mr Milan
Request for Information – RFI20131304
Thank you for your request of 6th September 2013 under the Freedom of Information Act 2000 (‘the Act’)
seeking the following information:
I understand that TV Licensing is not a legal entity in and of itself, but rather an exercise in
branding. My understand is that you negotiate contracts for other organisations (largely Capita) to
undertake work on matters concerning the adminisration of the TV License system, and the
detection, investigation and prosecution of TV License evasion.
Since you award the work on a contractual basis, it seems reasonable for me to presume that you
would monitor the performance of the various contractors against a number of criteria, which
would require you to collect various items of data.
This gives rise to the following questions...
Question 1
==========
Are any of the metrics used in assessing the performance of TV Licensing contractors concerned
with whether the contractor's staff have been found to be dishonest in terms of fabricating
evidence?
Question 2
==========
Assuming that you do consider the honesty of your contractor's staff to be a factor when reviewing
contract performance, can you provide me with details as to level (both quantity and severity) of
dishonest incidents you consider to be unacceptable performance?
Question 3
==========
Do you require contractors to notify you of incidents of dishonesty?
Question 4
==========
Can you please provide me with a list comprising of the offence, date of conviction, geographic area
of conviction (a county level would be sufficient) and details of sentence for all incidents of you have
knowledge of people engaged on TV Licensing work receiving a conviction as a consequence of
actions undertaken in connection with that work.
Question 5
==========
Do you require contractors to notify you in circumstances where they have had to take internal
disciplinary action against an employee for matters pertaining to dishonest conduct?
Question 6
==========
Assuming the answer to question 5 to be yes, can you provide me with any data you hold
concerning such incidents.
I accept the need to anonymise data in response to questions 5 and 6.
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 Mediaedge:CIA International Limited ("MEC"). The BBC is a public authority in respect of
its television licensing functions and retains overall responsibility.
Please note that in responding to your request we have interpreted your request as referring to our
contractor Capita, as it performs the majority of TV Licensing’s activities.
I shall address each of your requests in turn below.
Question 1
==========
Are any of the metrics used in assessing the performance of TV Licensing contractors concerned with
whether the contractor's staff have been found to be dishonest in terms of fabricating evidence?
I can confirm under section 1(1) of the Act that we do hold information broadly relevant to this request in
that there are business metrics in place to measure performance of TV Licensing. However in terms of your
specific request regarding metrics concerned with whether the contractor’s staff have been found to be
dishonest in terms of fabricating evidence, I can confirm under section 1(1) of the Act that we do not have
specific metrics that relate to this. However both the BBC and Capita expect as a matter of course that all
staff are honest and Capita have the relevant audit systems and procedures in place to make the
appropriate checks and deal with any issues that did occur.
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Question 2
==========
Assuming that you do consider the honesty of your contractor's staff to be a factor when reviewing contract
performance, can you provide me with details as to level (both quantity and severity) of dishonest incidents
you consider to be unacceptable performance?
The Freedom of Information Act gives a right of access to recorded information. This request is not a
request for recorded information but rather a request for an opinion. However, as stated above, I can tell
you that we do not expect dishonest behaviour to be tolerated and our contractors have appropriate
disciplinary procedures in place to deal with such incidents, though information relating to such incidents is
held by Capita and not on our behalf.
Question 3
==========
Do you require contractors to notify you of incidents of dishonesty?
The current contract with Capita requires Capita to disclose disciplinary issues when requesting staff to be
authorised for enforcement activity which would include fraud/dishonesty.
Question 4
==========
Can you please provide me with a list comprising of the offence, date of conviction, geographic area of
conviction (a county level would be sufficient) and details of sentence for all incidents of you have
knowledge of people engaged on TV Licensing work receiving a conviction as a consequence of actions
undertaken in connection with that work.
We have previously responded to requests about criminal convictions of TV Licensing staff as a
consequence of actions undertaken in connection with that work. As such, please refer to the links below
for the information relevant to this question of your response:
RFI20131204
https://www.whatdotheyknow.com/request/87292/response/220533/attach/3/RFI20111165%20Final%20
response.pdf
RFI20111165
https://www.whatdotheyknow.com/request/87292/response/220533/attach/3/RFI20111165%20Final%20
response.pdf
RFI20110731
https://www.whatdotheyknow.com/request/173741/response/429888/attach/4/RFI20131204%20final%2
0response.pdf
RFI20110625
https://www.whatdotheyknow.com/request/73521/response/185716/attach/3/RFI20110625%20final%20r
esponse.pdf
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Question 5
==========
Do you require contractors to notify you in circumstances where they have had to take internal disciplinary
action against an employee for matters pertaining to dishonest conduct?
Please refer to our response to question 3. In addition I can tell you that, although the contractual
requirement to notify applies only where Capita is requesting staff to be authorised for enforcement
activity, we are generally notified informally of disciplinary incidents and actions taken as they arise.
However such reports are made verbally and are not recorded and therefore I can confirm under section
1(1) of the Act that we do not hold information relevant to such disciplinary proceedings.
Question 6
==========
Assuming the answer to question 5 to be yes, can you provide me with any data you hold concerning such
incidents.
I can confirm under section 1(1) of the Act that we do not hold any further information, aside from the
information regarding criminal convictions to which we have directed you in our response to question 4.
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, Cheshire, SK9 5AF,
telephone 01625 545 700 or see
http://www.ico.gov.uk/. Kind regards
Louise Wright
Senior Policy Advisor, TV Licensing Management Team
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