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
Michael John
xxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxxxxx.xxx 10 September 2020
Dear Mr John
Request for Information – RFI20201217
Thank you for your request to the BBC of 12th August 2020 under the Freedom of Information
Act 2000 (‘the Act’) seeking the following information.
“Under the freedom of information act i require a list of all private Tv Licence Enforcement
companies/ Agents the BBC are Employing.
Under the freedom of information act i require the information held in relation to where and when
consent has been given or asked for pursuant to the GDPR for the BBC to pass private personal
Data to private 3rd parties ( i.e Enforcement Agents ).
Under the freedom of information act i require the information held in relation to the protocols
that are in place or a code of conduct for TV Licensing Agents, i.e are they allowed to cause alarm
, distress , harassment to vulnerable people i.e the over 75s ??”
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. Target Group (‘Target’) is the
supplier for the Simple Payment Plan. Marketing and printing services are contracted to Proximity
London Ltd. Media services are contracted to Havas Media Limited. The BBC is a public authority
in respect of its television licensing functions and retains overall responsibility.
Please be advised the Act gives a general right of access to al types of recorded information held
by public authorities; and that we are not required to create new information to respond to a
request, or give a judgement or opinion that is not already recorded.
Part 1
As explained on the TV Licensing website at
http://www.tvlicensing.co.uk/about/foi-administering-
the-licence-fee-AB20 (under the heading “Who employs enquiry officers?”), TV Licensing visiting
officers are engaged by Capita.
Part 2
The manner in which, and the purposes for which, the BBC (including its contractors) process
personal data are set out in TV Licensing’s privacy policy, which can be found here:
https://www.tvlicensing.co.uk/privacy-security-policies By way of explanation, and as the policy states, the BBC has a legal duty to operate the TV licence
fee system, so for the purposes of the GDPR the principal lawful basis for TV Licensing’s
processing is that such processing is necessary for the performance of a task carried out in the
public interest and in the exercise of official authority. When we share data for that purpose,
consent is not required by the GDPR. This includes sharing data with our contractors for that
purpose.
Part 3
Information on the rules for the conduct for TV Licensing visiting officers is publicly available and
can be found here:
https://www.tvlicensing.co.uk/visit TV Licensing will not be visiting households who previously held a free TV licence, while the new
over 75s scheme is being implemented. For those outside of this group, our visiting officers are
required to conduct themselves professionally and courteously at all times.
As visiting officers are engaged by Capita, please be advised that details of any training they receive
are not held by Capita on the behalf of the BBC.
The Act gives rights of public access to information held by public authorities (as defined in section
3 of the Act). Section 3(2)(a) of the Act says that, for the purposes of the Act, information is held
by a public authority if it is held by the public authority themselves or if it is held by another
person on behalf of the authority. Capita is not a public authority as defined by the Act therefore
information it holds but which is not held on behalf of the BBC is not subject to the Act.
Appeal Rights If you are not satisfied that we have 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 and including your reference
number. A request for an internal review must be made within 40 working days of receiving the
BBC’s response to your original request.
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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, Tel: 0303 123 1113 or see
https://ico.org.uk/. Yours sincerely
Rupinder Panesar
Freedom of Information Advisor, TV Licensing Management Team
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