RFI20180995 response.pdf

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

George Robinson
xxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxxxxx.xxx

14 June 2018

Dear Mr Robinson,

Freedom of Information Act 2000 – RFI20180995

Thank you for your request under the Freedom of Information Act (‘the Act’) of 17 May, seeking:

‘Please provide a list of all IP’s and domain names for BBC services online.’

Please find attached the information you requested.  The list of domain names is separated into
two lists:

1)  A list of domain names that the BBC uses (or are archived on bbc.co.uk); and

2)  A list of domain names that are used by BBC World Service and BBC Worldwide.  Please
note that many of these sites receive commercial funding through advert sales revenue and
other commercial activities carried out by BBC Worldwide Limited, the commercial arm
of the BBC.  As a commercial subsidiary of the BBC, BBC Worldwide is legally separate
from the BBC and is not covered by the Act (Section 6(1)(b)(ii)). However, on this
occasion and in order to assist you as much as possible we have provided certain domain
names on a voluntary basis.

Please be aware that the lists we have provided are not entire lists as the information you have
requested is excluded from the Act because it is held for the purposes of ‘journalism, art or
literature’ (for example, domain names related to certain programmes which are still in the
process of being produced). The BBC is therefore not obliged to provide this information to you
and will not be doing so on this occasion.  Part VI of Schedule 1 to FOIA provides that information
held by the BBC and the other public service broadcasters is only covered by the Act if it is held
for ‘purposes other than those of journalism, art or literature”.  The BBC is not required to supply

information held for the purposes of creating the BBC’s output or information that supports and is
closely associated with these creative activities.1

The limited application of the Act to public service broadcasters was to protect freedom of
expression and the rights of the media under Article 10 European Convention on Human Rights
(“ECHR”).  The BBC, as a media organisation, is under a duty to impart information and ideas on
all matters of public interest and the importance of this function has been recognised by the
European Court of Human Rights.  Maintaining our editorial independence is a crucial factor in
enabling the media to fulfil this function.

In addition, some of the information you have requested (while in accordance with section 1(1) of
the Act we do confirm we hold further domain names), we consider that information to be
exempt from disclosure under section 43(2) of the Act as disclosure would be likely to prejudice
the commercial interests of the BBC by revealing the BBC’s domain name strategy.

Disclosure of these domain names could allow interested third parties to identify the BBC’s
domain name purchasing strategy.  This purchasing strategy allows BBC to purchase domain names
that may be attractive to cyber squatters.

As section 43 is a qualified exemption, the BBC is required by section 2(2) of the Act to consider
the public interest factors in this case. Specifically, we looked at whether in all the circumstances
of the case, the public interest in maintaining the exemption outweighs the public interest in
disclosing the information.

In favour of disclosure, we recognised that there is a public interest in the following:
  that there is transparency in the accountability of the BBC for public funds;
  that the BBC is using public money effectively, and that the BBC is getting value for money
when purchasing goods and services; and
  that business can respond better to opportunities with the BBC.

On the other hand, in considering factors that might weigh in favour of the public interest in
withholding, we took into account:

  That the BBC maintains a strong bargaining position vis-à-vis suppliers (and/or cyber
squatters) during contractual negotiations (and/or litigation) in order to ensure that the
licence fee is spent effectively.

I am therefore satisfied, in terms of section 2 of the Act, that in all the circumstances of the case,
the public interest in maintaining the exemption outweighs the public interest in disclosing the
information.


1 For more information about how the Act applies to the BBC please see the enclosure which follows this letter.
Please note that this guidance is not intended to be a comprehensive legal interpretation of how the Act applies to the
BBC.

The BBC’s live TV internet streams are served by two Content Delivery Networks (CDNs).
Currently neither the CDNs' logs, nor the BBC’s own monitoring systems, collect the IP
addresses of the servers serving these streams.

The CDNs do not allocate IP addresses to the BBC (there is not a set of address blocks from
which they are constrained to be served that has been allocated to us). I therefore confirm that
the BBC does not hold the information you have requested, and so am unable to assist you on this
occasion.

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. 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 (local rate) or 01625 545 745
(national rate) or see http://www.ico.org.uk/

Yours sincerely,

Information Rights

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