New licence payment plans and data protection

Response to this request is long overdue. By law, under all circumstances, British Broadcasting Corporation should have responded by now (details). You can complain by requesting an internal review.

Dear British Broadcasting Corporation,

This request is regarding the announcement of payment plans for TV licences as described here

The article states

"The trial plan will only be available to certain groups of customers:

1. people who have sought debt advice from certain charities
2. those who have previously held a licence which was recently cancelled because of missed payments
3. people who have been questioned under caution for TV licence fee evasion"

Two charities named "Christians Against Poverty" and "Money Advice Trust" indicate that they will be working with TVL with regard to the new scheme.

With regard to 1. -

Please provide under the FOIA a full and unredacted list of all the charities or debt organisations who have been approached about working with TVL under this scheme.

Please provide a full and unredacted list of all those who have formally agreed to do so.

Please provide information about how data will be shared under such agreements especially with regard to obtaining the informed consent of individuals whose data will be shared, the security of such data in transit and storage and specifically what information about the individuals will be shared with TVL, how it will be used and how long it will be retained.

Please state whether the charities or organisations concerned will be instructed to advise the individuals concerned of the legal alternative of simply not watching live broadcast Tv or iPlayer and therefore not requiring a TV licence?

With regard to 3. -

My question concerns specifically those who are legally unlicensed because they do not watch broadcast television or BBC iPlayer. Such individuals may have been interviewed under caution but there is no evidence or any REASONABLE grounds to suspect TV licence evasion. (The simple fact of not having a TV licence is not reasonable grounds to suspect evasion in view of the multiplicity of alternative choices such as Netflix that are now available and do not require a TV licence).

Does TVL process private data about such individuals?
What data is retained, for how long and for what purpose?

Since such individuals are not customers of TVL/BBC and are not licence evaders please explain specifically how the processing of data about such individuals, and the use of such data for what is essentially the marketing of a new payment scheme for licenseable entertainment content, is compliant with the General Data Protection Regulation (GDPR).

I would remind you that, unlike the old condition for processing data for functions of a public nature in Schedule 2 of the Data Protection Act 1998, The public task basis in Article 6(1)(e) of the GDPR says that the relevant task or function must have a clear basis in law. There is no basis in law or statute for TVL to have any non-consensual relationship whatsoever with the legally licence free.

Yours faithfully,

Louisa Woodward

FOI Enquiries, British Broadcasting Corporation

1 Attachment


Dear Louisa Woodward


Thank you for your request for information under the Freedom of
Information Act 2000, as detailed in your email. Your request was received
on 10/03/2018.  We will deal with your request as promptly as possible,
and at the latest within 20 working days. If you have any queries about
your request, please contact us at the address below.


The reference number for your request is RFI20180451.


Kind regards,



Information Rights


BBC Freedom of Information

BC2 A4, Broadcast Centre

201 Wood Lane

London W12 7TP



Email: [2][BBC request email]


Tel: 020 8008 2882




show quoted sections

FOI Enquiries, British Broadcasting Corporation

2 Attachments

Dear Louisa Woodward


Please find attached the response to your request for information,
reference RFI20180451.


Yours sincerely


BBC Information Policy and Compliance

Room BC2 A4

Broadcast Centre

White City


W12 7TS



Website: [1]

Email: [2]mailto:[BBC request email]


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