Copies of policies

The request was partially successful.

Dear Channel Four Television Corporation,

Please provide me with copies of all Channel Four policies that are currently in force and readily accessible to 90% or more of Channel Four employees via an intranet or similar. The scope of this request is limited to written documents which apply organisation wide and which are described as policies internally.

Thank you,

Mr Cross

# FOI Admin, Channel Four Television Corporation

39 Attachments

Our Ref: FOI/2023/87

 

Dear Mr Cross,

 

Thank you for your request for information made under the Freedom of
Information Act 2000 (“the Act”), which we received on 13^th October 2023.
Your request was set out as follows:

 

“Please provide me with copies of all Channel Four policies that are
currently in force and readily accessible to 90% or more of Channel Four
employees via an intranet or similar. The scope of this request is limited
to written documents which apply organisation wide and which are described
as policies internally.”

 

We have attached the documents that are listed as a “policy” on the
internal Channel 4 intranet. Please note there are other documents on the
intranet that will be considered “policies”, but are not marked as such
and these have not been provided. We make further comments below about how
the search was conducted within the search limit.

 

We have excluded policies which are already in the public domain and are
readily available on our website at the following links:

 1. [1]https://www.channel4.com/corporate/about...
 2. [2]https://www.channel4.com/corporate/about...
 3. [3]https://www.channel4.com/corporate/about...
 4. [4]https://www.channel4.com/corporate/about...

 

Please note, whilst the Act applies to the information held by public
authorities rather than documents, however, on this occasion for ease of
processing your request we have provided whole policy documents.

 

We have applied redactions to these policy documents in respect of
information which is exempt from disclosure pursuant to the following
exemptions within the Act:

 

Section 40(2) Data Protection

Any personal data within these internal policies such as contact
information for Channel 4 staff has been redacted in line with Channel 4’s
obligations under the Data Protection Act 2018, this information is exempt
from disclosure pursuant to section 40(2) of the Act (personal
information). 

 

Section 38(1) Health and Safety

We have redacted details relating to staff travel arrangements as we
consider this information to be exempt from disclosure pursuant to section
38(1) of the Act (Health and Safety). In applying section 38(1) we are
required to consider the public interest test. Accordingly, we do not
consider it to be in the public interest to disclose logistical
information that, if accessed by someone with malicious intentions, could
likely be utilised to endanger the health and safety of Channel 4 staff.  

 

Section 31(a) Law Enforcement

We have also redacted information which relates to Channel 4’s internal
security measures, systems and processes, as we consider such information
to be exempt from disclosure pursuant to section 31(1)(a) of the Act (law
enforcement). 

In engaging section 31, Channel 4 is required to consider the public
interest test. Accordingly, we do not consider it to be in the public
interest for Channel 4 to publish information under the Act that could
prejudice the prevention and detection of crime, or which if accessed by
someone with malicious intentions, could likely be utilised to launch an
attack on Channel 4’s staff, premises or computer systems.

 

Section 43(2) – Commercial interests

Information within these internal policies which indicate the funds that
Channel 4 makes available for expenses such as travel and accommodation
has also been redacted. This information is commercially sensitive and
therefore exempt from disclosure pursuant to section 43(2) of the Act
(commercial interests).

 

In applying section 43(2), we are required to consider the public interest
test. Accordingly, we can confirm that it would not be in the public
interest to prejudice Channel 4’s commercial interests by disclosing the
amount of money available for such expenses, as this would indicate to
suppliers the total funds available for specific services and could then
be used by suppliers as a bargaining tool when negotiating future rates.
Accordingly, we are unable to provide further information in this regard.

 

Derogation

As you might be aware, the Act gives the public a right of access to
certain types of recorded information held by public authorities. However,
it also sets out various exemptions from that right where, for example,
the information is commercially sensitive or confidential. Further, the
Act does not apply to Channel 4 in the same way as most other public
authorities because Channel 4 is not required to make available
information held for purposes of journalism, art or literature (known as
the “designation”). This means that the Act does not apply to information
concerning, relating to, or closely associated with Channel 4’s output
(e.g. TV, film, online etc). We have therefore not provided you with any
internal policies held in relation to our output.

 

For more information about how the Act applies to Channel 4, you may find
it helpful to visit our Freedom of Information website at
[5]http://www.channel4.com/info/corporate/l....

 

Finally, we are minded that The Freedom of Information and Data Protection
(Appropriate Limit and Fees) Regulations 2004 set out an ‘appropriate
limit’ in respect of the costs to public authorities of responding to
requests made under the Act. Please note that the costs threshold
appropriate to Channel Four Television Corporation is £450, with staff
costs calculated at a rate of £25 per hour (i.e. a total of 18 hours). We
have therefore provided information which we could locate, retrieve, and
extract within the applicable 18-hour time limit. 

 

Please note that if you are unhappy with the decisions made in relation to
your request you may ask for an internal review. In accordance with the
Code of Practice issued by the Cabinet Office under section 45 of the Act,
please be advised that requests for an internal review should be made
within 40 working days of this email. If you wish to do this then please
email the FOI Admin Team.

 

Following this, if you have any further issues regarding Channel 4’s
handling of this matter under the Act, we would invite you to take this up
directly with the Information Commissioner who can be contacted at:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF.

 

Thank you for your interest in Channel 4.

 

Yours sincerely,

 

FOI Admin Team

 

Channel 4

[6][Channel 4 request email]

 

[7]www.channel4.com

 

References

Visible links
1. https://www.channel4.com/corporate/about...
2. https://www.channel4.com/corporate/about...
3. https://www.channel4.com/corporate/about...
4. https://www.channel4.com/corporate/about...
5. http://www.channel4.com/info/corporate/l...
6. mailto:[Channel 4 request email]
7. http://www.channel4.com/