RFI20151087 Response.pdf

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Information Policy & Compliance
bbc.co.uk/foi
bbc.co.uk/privacy

Peter Jones
Via email: xxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxxxxx.xxx

29th July 2015

Dear Mr Jones

Request for Information – RFI20151087

Thank you for your request of 5th July 2015 under the Freedom of Information Act 2000 (‘the Act’) seeking
the following information:

“I am making this request for information under the terms of the Freedom of Information Act 2000.

I am interested in TV Licensing employees that have committed criminal offences in the course of
their duties with TV Licensing. By TV Licensing employees I mean any person employed by the BBC
or any of the TV Licensing contracted companies acting on the BBC's behalf as the statutory
Television Licensing Authority.

Background information:
I have previously made two similar requests, RFI20110731 & RFI20111165, but given passage of
time it is likely that more recent relevant information is held by the BBC.

My request:
Please provide me with the following information:
1. The number of TV Licensing employees that have been convicted of criminal offences committed
during the course of their TV Licensing duties since the date of my previous request (24 September
2011).

2. In relation to those convictions disclosed in response to question 1: Also provide details of the
offences they were convicted of, their dates of employment with TV Licensing and the geographic
location (county, town or city) they were based.

3. The number of TV Licensing employees that have received a formal police caution for criminal
offences committed during the couse [sic] of their TV Licensing duties since the date of my previous
request (24 September 2011).

4. In relation to those formal police cautions disclosed in response to question 3: Also provide details
of the offences they were cautioned for, their dates of employment with TV Licensing and the
geographic location (county, town or city) they were based.”

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, may I remind you that following your requests RFI20110731 and RFI20111165 you submitted a
similar request (RFI20131204) on 18th August 2013, which the BBC responded to on 16th September 2013.
Question 3 of RFI20141204 sought the following information:

“3. The total number of TV Licensing staff that have been convicted of criminal offences committed
during the course of their TV Licensing duties since the year 2000. Please provide this information as
a yearly breakdown, which also shows the nature of offences committed and the geographic
location (county, town or city) the staff were based.”

The BBC’s response is published on the What Do They Know website at
https://www.whatdotheyknow.com/request/tv_licensing_staff_discipline_an#incoming-429888 but for
ease of reference I would like to summarise the specific response to question 3 above:

  The request was considered to be satisfied for the period 2000 to 24th September 2011 via the
BBC’s responses to your requests RFI20110625, RFI20110731 and RFI20111165.

  For the period 25th September 2011 to 18th August 2013 (the date RFI20131204 was received), we
confirmed that to the best of our knowledge, that there had been no convictions relating to
offences committed in the course of their TV Licensing duties by any person employed by the BBC
or any of the TV Licensing contracted companies (acting on the BBC's behalf).

I am therefore responding to questions 1 and 2 of your current request in respect of the period 19th August
2013 to 5th July 2015 (the date of your current request). Following searches conducted in line with our
previous responses on this subject matter, I can confirm that  that there have been no convictions relating
to offences committed in the course of their TV Licensing duties by any person employed by the BBC or any
of the TV Licensing contracted companies (acting on the BBC's behalf) in this period.

With regard to questions 3 and 4, we have undertaken searches in respect of the period 25th September
2011 to 5th July 2015. I can confirm that to the best of our knowledge we are not aware of any person
employed by the BBC, or any of the TV Licensing contracted companies (acting on the BBC's behalf), that
has received a police caution relating to offences committed in the course of their TV Licensing duties
during this period.

However, I estimate that to conduct a fully comprehensive search in order to confirm this conclusively
would take more than two and a half days; under section 12 of the Act, we are allowed to refuse to handle
the request if it would exceed the 'appropriate limit'. This is because in order to find the information we
would need to examine every retained personnel file for every individual who has worked for any of our
service providers or their subcontractors in the period in question. This would number several thousand
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files. The appropriate limit has been set by the Regulations (SI 2004/3244) as being £450 (equivalent to two
and a half days work, at an hourly rate of £25).

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

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