Dear Office of Communications,

Please could you supply me with a copy of all internal documentation related to your list of accredited price comparison sites, as listed on this page:

http://consumers.ofcom.org.uk/price-comp...

I would like to know what, precisely, forms the basis of the "independent audit" of these sites, and what criteria are used to judge a site's eligibility for accreditation.

If these sites are required to submit documentation to Ofcom as part of their application for accreditation, I would also like a copy of all supplied documents by all currently accredited sites.

Finally, please could you also let me know if Ofcom has received any complaints about any of these sites, and, if so, the nature of the complaint(s) and the outcome of Ofcom's investigation.

Yours faithfully,

Mark Goodge

Dear Office of Communications,

I have yet to receive any response to my FOI request sent on 6th March. While I appreciate that you are not obliged to respond earlier than is practically possible, I am somewhat concerned that I have not even had an acknowledgement.

Given that your deadline for providing me with the information is only ten days away, and that includes two bank holidays, it would be helpful if you could confirm that you have received the request and will be able to meet the legal deadline for a full response.

Yours faithfully,

Mark Goodge

Dear Office of Communications,

Please pass this on to the person who conducts Freedom of Information reviews.

I am writing to request an internal review of Office of Communications's handling of my FOI request 'Accredited comparison sites'.

You have refused to provide me with some of the information I requested on the grounds that Section 44 of the FOIA prevents disclosure of information which is forbidden under another Act. You then cite Section 393 of the Communications Act as being the relevant legislation.

However, this does not appear to apply in this case. Section 393 of the Communications Act only addresses information obtained by Ofcom relating to powers conferred by that Act (or its predecessors) or in the management of the radio spectrum. The accreditation of a price comparison site is not a power conferred by the Communications Act, nor is it related to the management of the radio spectrum.

The only way that accreditation of a price comparison site could be considered a power coffered by the Communications Act is if it were covered by Section 1(3), which gives Ofcom a general power to do anything related to its duties. However, if this is interpreted as a function of Ofcom in the sense intended by Section 393, then that would imply that all of Ofcom's activities fall within this exemption, thus effectively exempting Ofcom completely from the FOIA.

That is clearly an absurd conlusion, and therefore the only sensible interpretation of Section 393 is that it only applies to activities of Ofcom which fall within its primary remit as a regulator. As this does not include regulating price comparison sites, there is no justification for refusing to provide the requested information in this case.

For avoidance of doubt, I am not asking for an internal review of your decision to refuse the first part of my request on grounds of excess cost. I will address that separately by means of a more limited request which will, I hope, fall within the cost limit.

A full history of my FOI request and all correspondence is available on the Internet at this address:
http://www.whatdotheyknow.com/request/ac...

Yours faithfully,

Mark Goodge