TV licences for road vehicles

A Willmore made this Freedom of Information request to British Broadcasting Corporation

This request has been closed to new correspondence. Contact us if you think it should be reopened.

The request was partially successful.

Dear British Broadcasting Corporation,

As part of the response to RFI20131619 it was stated in the answer to Question 3: "a vehicle registration could be used as a licensable address".

Under the transparency afforded to me by the Freedom of Information Act I would like to know, please:

1) The number of TV licences that have a vehicle registration as a licensable address as at 1st October 2013.

2) All of the procedures that have been put in place to prevent TV licence letters and documents from erroneously being sent by post to road vehicles.

3) All of the procedures used by TV Licensing to send paper communications to the holders of licences registered to road vehicles who do not have a "poste restante" address.

4) The number of visits made by TV Licensing staff in 2012 to permanent residents of road vehicles who were believed to be without a TV licence.

5) The number of licences subsequently sold as a result of the visits described in question 4.

6) The number of prosecutions made as a result of the visits described in question 4.

Yours faithfully,

Mr A Willmore

Watchkeeper left an annotation ()

Love it!

FOI Enquiries, British Broadcasting Corporation

Dear Mr Willmore,

Thank you for your request for information under the Freedom of Information Act 2000, as detailed in your email below. Your request was received on 2 December 2013. 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 RFI20131804

Kind regards

The Information Policy & Compliance Team

BBC Freedom of Information
BC2B6, Broadcast Centre
201 Wood Lane
London W12 7TP

www.bbc.co.uk/foi
Email: [BBC request email]

Tel: 020 8008 2882
Fax: 020 8008 2398

show quoted sections

FOI Enquiries, British Broadcasting Corporation

1 Attachment

Dear Mr Willmore

 

Please find attached the response to your request for information,
reference RFI20131804. We apologise for the delay in issuing this response
to you and we accept that we have failed to meet the statutory 20-day
deadline on this occasion; we would also like to apologise for any
inconvenience caused by the delay.

 

 

Yours sincerely,

The Information Policy and Complaince Team

 

BBC Information Policy and Compliance

BC2B6, Broadcast Centre

201 Wood Lane

London W12 7TP, UK

 

Website: [1]www.bbc.co.uk/foi

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

Tel: 020 8008 2882

Fax: 020 8008 2398

 

 

 

 

show quoted sections

References

Visible links
1. http://www.bbc.co.uk/foi
2. mailto:[BBC request email]
3. http://www.bbc.co.uk/

Dear British Broadcasting Corporation,

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

I am writing to request an internal review of British Broadcasting Corporation's handling of my FOI request 'TV licences for road vehicles'.

As part of the response to RFI20131619 it was stated in the answer to Question 3: "a vehicle registration could be used as a licensable address". There are many people in the UK who have mobile homes and caravans (and boats too) as their primary accommodation, i.e. not as a second home. Because they can, many of these people will choose to move around the country and will not be in a position to have an address that can be reached by normal postal services, or be in a position to take advantage of the Post Office services available. Many will not have internet access either.

I find it hard to believe that these people are outside of TV Licensing's jurisdiction so I feel that there MUST be some kind of procedure in place that allows people such as those I have described above to (a) comply with the law and own a TV licence, and (b) receive the necessary paperwork involved with such ownership.

I note that the TV Licensing web site does not allow entry of anything other than a recognised street address with post code when applying for a licence.

I accept that a manual check of 31 million addresses is unreasonable, but I ask that a review is undertaken of the other information (questions 2 to 6) that I have requested and whether more meaningful answers can be provided, even if only in the most general of terms.

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

Yours faithfully,

A Willmore

Watchkeeper left an annotation ()

For the BBC to say "we would need to manually examine each individual address on our database to find the information you have requested" is, quite frankly, ridiculous. This is what computers are for! It would be a simply matter to construct a suitable query or series of queries which would distinguish a vehicle registration number from any other type of address. For example, a first step would be to eliminate all records carrying a postcode and this would take seconds. Subsequent operations would depend on the fields available in the records. As Sir Winston Churchill very nearly said - "Give me the tools and I will finish the job."

A Willmore left an annotation ()

You know that, I know that, but apparently they do not. I have visions of TVL sending out reminders to "Motor Home ABC123X, Somewhere in the UK". The TVL web site is strangely silent about setting up a primary abode in anything other than a house on a street with a post code so I have asked them to clarify their procedures used when that is not the case.

Dear FOI Enquiries,

Further to my request for an internal review, I would also like you to consider the following:

I have just spoken to TV Licensing's help line and I asked how I would go about purchasing and renewing a TV licence should I choose to:

- Move in to a mobile home
- Make this my primary home
- Travel the country at will
- Not have internet access
- Have a paper-free bank account (accessible at any branch)
- Continue to watch television lawfully

I was told explicitly that a TV licence registration requires a static street address with a post code, and that a "care-of address" of some kind would be needed.

It was confirmed to me twice that there was no provision for the TV Licencing database to record a vehicle registration number as a licensed address, which is contrary to your response given to RFI20131619, and that all communications would have to be to a static address with post code.

I look forward to reading your explanation of this discrepancy.

Yours sincerely,

Mr A Willmore

FOI Enquiries, British Broadcasting Corporation

Dear Mr Willmore,

We have received your request for an internal review relating to RFI20131804. The information you requested related to TV Licensing. Your request for an internal review was received 4 January 2014. We shall deal with the review as promptly as possible and, at the latest, within 30 working days. If you have any queries please contact us at the address below.

The reference number for your internal review is IR2014001

BBC Information Policy and Compliance
BC2B6, Broadcast Centre
201 Wood Lane,
London, W12 7TP

Website: www.bbc.co.uk/foi/
Email: [BBC request email]
Tel: 020 8008 2883
Fax: 020 8008 2398

show quoted sections

Dear FOI Enquiries,

I spoke to the TV Licensing help line again this morning. During the conversation we discussed what would happen should I choose to live permanently on a canal boat as a "continuous cruiser".

I was told that anybody who does not have a fixed abode, a mooring address or care-of address and who does not power their television by mains electricity does not need to purchase a television licence.

This statement seems to fly in the face of the advice given at http://www.tvlicensing.co.uk/check-if-yo...

This page states: "As long as the address where you live is licensed, you’re also covered to watch TV outside your home using any device powered solely by its own internal batteries. This includes your mobile phone, laptop and tablet."

TVL have told me that there is no need to purchase a licence, but most on-board TVs are of a type that is powered by the boat's own power supply, and so not by internal batteries.

Again, definitive clarification on this issue would be appreciated.

Yours sincerely,

A Willmore

Dear FOI Enquiries,

Your message sent to me on 7th January with reference to an internal review states "We shall deal with the review as promptly as possible and, at the latest, within 30 working days".

By my reckoning, today (18th February) is 32 working days since 6th January - the first working day after my request was received (4th January).

I would be grateful for an indication of when the results of the review will be made known to me.

Yours sincerely,

Mr A Willmore

Dear British Broadcasting Corporation,

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

I am writing to request an internal review of British Broadcasting Corporation's handling of my internal review relating to my FOI request 'TV licences for road vehicles'.

On 4th January 2014 I requested an internal review concerning this request.

On 7th January 2014 I received an acknowledgement of my request which included the text "We shall deal with the review as promptly as possible and, at the latest, within 30 working days."

On 18th February 2014 - 32 working days after my internal review was requested - I asked for an indication of when the review results would be made available to me.

I have not received ANY communication from the BBC regarding this FOI request since 7th January.

I note today (5th March 2014) is 43 working days since I requested an internal review.

I would now like to request another internal review concerning the handling of the internal review I requested on 7th January and the non-existent response to same.

To be clear, I require from you:
- A response to my FOI request.
- The results of the internal review concerning the inadequate response provided to me on 3rd January 2014.
- The results of the second internal review concerning the poor handling of the internal review you acknowledged on 7th January.

I shall be interested to see who reviews the reviewers!

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

Yours faithfully,

Mr A Willmore

FOI Enquiries, British Broadcasting Corporation

Dear Mr Willmore,

Thank you for your email, I would like to take this opportunity to apologise for the dealy in responding to you and the inconvience caused. The BBC does not offer internal reviews into the handling of internal reviews. I would however like to take this oportunity to update you on the progress of your internal review reference IR2014001. Unfortunately the response to your request for an internal review is not yet ready. We have therefore failed to meet our 30-working-day deadline, for which we apologise.

We are working on your review and will send you a response as soon as possible.

Yours sincerely

Information Policy and Compliance

BBC Information Policy and Compliance
BC2B6, Broadcast Centre
201 Wood Lane
London W12 7TP, UK

Website: www.bbc.co.uk/foi
Email: mailto:[BBC request email]
Tel: 020 8008 2883
Fax: 020 8008 2398

show quoted sections

Dear FOI Enquiries,

Many thanks for your communication.

I note that 50 working days have now passed.

Yours sincerely,

A Willmore

Dear FOI Enquiries,

Details of this information request and its subsequent handling have been passed to the Information Commissioner's Office today.

Yours sincerely,

Mr A Willmore

Peter Jones left an annotation ()

An internal review of an internal review... sounding a bit like a Monty Python sketch!

Dear FOI Enquiries,

I note that 57 working days have now passed since you told me that "We shall deal with the review as promptly as possible and, at the latest, within 30 working days".

How hard can it be to provide the information I have requested?

The BBC's blatant disregard for the law of the land is abhorrent.

Yours sincerely,

Mr A Willmore

FOI Enquiries, British Broadcasting Corporation

1 Attachment

Dear Mr Willmore

Please find a copy of our internal review attached.

We apologise again for the delay in completing this review.

Yours sincerely

BBC Information Policy and Compliance
Room BC2 B6, Broadcast Centre
201 Wood Lane
London W12 7TP, UK

Website: www.bbc.co.uk/foi
Email: [BBC request email]
Tel: 020 8008 2882
Fax: 020 8008 2398

show quoted sections

A Willmore left an annotation ()

Hmmm... but I'm not finished with this yet.

Dear FOI Enquiries,

As suggested in the internal review ("If the applicant seeks further guidance or clarification about TV Licensing, I suggest that he contacts TV Licensing directly: https://www.tvlicensing.co.uk/contact-us...), I wrote the following to TV Licensing directly:

******
The BBC's Information Policy and Compliance department
suggested that I contact you. In response to a FOI request concerning the holding of TV licences by people who live permanently in a mobile home (RFI20131619) the BBC has stated "a vehicle registration could be used as a licensable address". I queried this with yourselves some time ago and I was told that this is not possible and that a "bricks and mortar" street address with post code is needed to register a TV licence. I would be grateful if you would answer the following questions for me assuming that these apply to somebody who wishes to watch live TV lawfully:

1) Can a vehicle registration be used as a licensable address?

2) If somebody lives permanently in a road vehicle and has no access to mains electricity, do they need a TV licence?

3) If somebody lives permanently on a on a canal boat and has no access to mains electricity, do they need a TV licence?

4) How can a licence be registered to a vehicle or boat owner if they cannot or do not supply a street address with post code?

5) What procedures do TV Licensing have in place to prevent TV licence letters and documents from erroneously being sent by post to road vehicles?

6) What procedures are used by TV Licensing to send paper communications to the holders of licences registered to road vehicles and "continuous cruiser" boat owners who do not have a "poste restante" address?
******

Rather than replying themselves, TV Licensing have chosen to not acknowledge my communication and have instead raised another FOI request (RFI20140523) on my behalf. I consider the actions of TV Licensing in this instance to be a waste of my time, and yours.

I have written to TV Licensing again today asking them to either answer my questions or to explain exactly why they have chosen not to and why they bizarrely felt a new FOI request was the best course of action.

Yours sincerely,

Mr A Willmore

FOI Enquiries, British Broadcasting Corporation

Dear Mr Willmore,

 

Freedom of Information request – RFI20140382

 

Thank you for your request under the Freedom of Information Act 2000 (“the
Act”) dated 5^th March 2014.

 

I apologise but we are currently not in a position to respond to your
request.

 

I sincerely apologise for this delay and for any inconvenience this may
cause you.  I would like to take this opportunity to assure you that your
request is a priority as it is late.

 

Kind regards,

 

The Information Policy & Compliance Team

 

 

 

 

 

show quoted sections

References

Visible links
1. http://www.bbc.co.uk/

A Willmore left an annotation ()

They refused my request.

Then they refused my request again following an internal review.

Then they apologise for being late with their reply.

Me neither.

Watchkeeper left an annotation ()

Stick with it, brother. This is not a frivolous FoI request. In December 1997 I sold my house and began a nomadic life in a motorcaravan, which was my sole place of residence. This lasted until August 2000. Was I TV licensed? No - how could I be? Was I watching or recording TV programme service? The BBC will never know, as it does not know whether I'm doing so today.

The situation is real, and the BBC ought to tell the public what the licensing requirements are under these circumstances. If ignorance of the law is no defence, the public has a right to know what the law is. The BBC, as the TV Licensing Authority, should tell us.

A Willmore left an annotation ()

Finally, a response from TVL:

******
I can confirm that it's possible to use the registration of a vehicle as a licensable address.

If somebody lives permanently on a canal boat or in a road vehicle, and they're watching live broadcasts on any device, they would require a TV Licence regardless of whether or not they're using mains electricity. If, however, they had a permanent residence which had a licence and they were using only the battery power of a laptop to watch live television, for example, whilst on their boat or in their vehicle, they would be covered the licence at their home address.

If a permanent address can't be supplied it's possible, if it's a road vehicle, to use the registration as the licensed address. Furthermore, as my colleague has stated in a previous email, it's possible to use TV Licensing's details as a holding address. If it's a licence for a canal boat and a permanent address can't be supplied we ask for the name of the boat, and the address and postcode of the mooring that it's registered to.

The licence holder can sign up to receive correspondence electronically. If, however, the customer would prefer to receive paper copies of their licence and renewal reminders and doesn't have a poste restante, all I can advise is that a forwarding address is provided, and we can redirect all correspondence to that address.
******

A Willmore left an annotation ()

I have received another reply directly from BBC FOI:

Request for Information – RFI20140523 and RFI20140538

I write further to your email to TV Licensing Customer Relations on 27 March 2014. We have interpreted your query as a request under the Freedom of Information Act 2000 (‘the Act’) seeking the following information:

RFI20140523

“The BBC's Information Policy and Compliance department suggested that I contact you. In response to a FOI request concerning the holding of TV licences by people who live permanently in a mobile home (RFI20131619) the BBC has stated "a vehicle registration could be used as a licensable address". I queried this with yourselves some time ago and I was told that this is not possible and that a "bricks and mortar" street address with post code is needed to register a TV licence. I would be grateful if you would answer the following questions for me assuming that these apply to somebody who wishes to watch live TV lawfully:

1) Can a vehicle registration be used as a licensable address?

2) If somebody lives permanently in a road vehicle and has no access to mains electricity, do they need a TV licence?

3) If somebody lives permanently on a on a canal boat and has no access to mains electricity, do they need a TV licence?

4) How can a licence be registered to a vehicle or boat owner if they cannot or do not supply a street address with post code?

5) What procedures do TV Licensing have in place to prevent TV licence letters and documents from erroneously being sent by post to road vehicles.

6) What procedures are used by TV Licensing to send paper communications to the holders of licences registered to road vehicles and "continuous cruiser" boat owners who do not have a "poste restante" address?

I also note that you subsequently contacted the BBC directly on 3rd April 2014 with the following related request:

RFI20140538

“This FOI request has, presumably, been raised on my behalf by TV Licensing. Your email yesterday came as something of a surprise to me as I was expecting and hoping that TVL would answer my questions themselves as a previous FOI request (RFI20131804) had failed to provide the information I am seeking.

I would like to know, please, the name of the person at TV Licensing who raised this FOI request on my behalf.”

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. Marketing and printing services are contracted to Proximity London Ltd. Media services are contracted to Mediaedge:CIA International Limited ("MEC"). The BBC is a public authority in respect of its television licensing functions and retains overall responsibility.

Firstly, in response to your request RFI20140538, I note that the Internal Review Decision IR2014001 (in respect of your earlier request RFI20131804) suggested that you should contact TV Licensing directly for further guidance or clarification about TV Licensing. Please note that the web contact details provided directs individuals to TV Licensing Customer Relations which deals with general queries and/or complaints.

Please be advised that the Act gives a general right of access to all types of recorded information held by public authorities. As TV Licensing Customer Relations is managed by Capita, all requests for recorded information received by this department are automatically passed to the BBC to respond to. This is because Capita is not a public authority as defined in the Act. In retrospect, this could have been made clearer in the Internal Review Decision and I apologise for any inconvenience this may have caused.

Turning to your request RFI20140523, I shall address your questions in turn below.

1) Can a vehicle registration be used as a licensable address?

As explained in my response to RFI20141619 (on which your request RFI20131804 was predicated), anyone who watches or records television programmes at the same time as they are shown on TV will need a TV Licence. Motor vehicles do not require a separate licence provided a licence is held at the user's primary address. However, if a motor vehicle is the primary place of residence and you watch or record television programmes at the same time as they are shown on TV, you will need a TV Licence. In the latter case, the vehicle will constitute a licensable address.

Where a vehicle is the primary place of residence and that vehicle is static, such as a caravan situated in a caravan park; or has a semi-permanent location, such as a boat with a mooring address, TV Licensing will use that fixed site address to communicate with the licence holder. If the vehicle is mobile with no fixed correspondence address, TV Licensing will seek a forwarding address from the licence holder for the purpose of communicating with them. If the licence holder is unable to provide a forwarding address, TV Licensing will set up an e-licence until such time as one could be supplied.

2) If somebody lives permanently in a road vehicle and has no access to mains electricity, do they need a TV licence?

3) If somebody lives permanently on a on a canal boat and has no access to mains electricity, do they need a TV licence?

Please be advised that the Act gives a general right of access to all types of recorded information held by public authorities. As these are hypothetical questions they fall outside the scope of the Act. However, under our duty to advise and assist you under section 16 of the Act, I can tell you that a TV Licence is required in both scenarios if you watch or record television programmes at the same time as they are shown on TV.

4) How can a licence be registered to a vehicle or boat owner if they cannot or do not supply a street address with post code?

5) What procedures do TV Licensing have in place to prevent TV licence letters and documents from erroneously being sent by post to road vehicles.

6) What procedures are used by TV Licensing to send paper communications to the holders of licences

registered to road vehicles and "continuous cruiser" boat owners who do not have a "poste restante" address?

Please see my response to question 1 above.

Appeal Rights

If you are not satisfied that the BBC has 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 under the Act 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 SK9 5AF. Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate) or see http://www.ico.gov.uk/.

Kind regards

Rupinder Panesar

Freedom of Information Advisor, TV Licensing Management Team

J. Jones left an annotation ()

You vill pay come what may, ve have vays of sending out speedboats, that vill be a lot faster than your barge - you haf seen james bond, on your unlicenced TV? Ves, Ve have a vaster one ;)

Merry Xmas 2014 to all in this sparring contest!