Thank you for your request under the Freedom of Information Act 2000 ("the Act") dated 19 April 2005, seeking the following information:

[...]

To give you some background on how 0870 numbers are managed by the BBC I should explain that the BBC has contracted Capita Business Services Ltd ('Capita') to provide the BBC Information contact centre services that use 0870 numbers. Capita in turn purchases telecoms services from Cable & Wireless ('C&W') to deliver calls to the contact centres. Therefore the contract to supply is between Capita and C&W.

We are withholding the list of underlying geographic numbers to which our 0870 numbers deliver under section 43(2) (commercial interests), and I set out below our reasons for this.

Releasing the information would create an operational risk; the telephone switch would be compromised. This could be in the form of a lobby group choosing to 'attack' the switch by calling directly and thus circumventing all the protection offered by C&W's Call Plans. Capita uses over 50 different numbers, a handful are in use continually, the rest are used for brief periods in support of specific campaigns, e.g. ticket requests for the VE-day concert. The Call Plans permit Capita to balance the call volumes received across the switch depending on forecast call volumes per number or campaign. In this way Capita are able to ensure that the absolute maximum number of callers can get through across all live numbers.

Capita rely on the ability to report on traffic across non-geographic numbers to manage Service Level agreements (SLA). If callers used geographic numbers Capita could not report accurately on call volumes; no reliable statistics would be available, making it immensely difficult for Capita to manage the contract with the BBC.

Capita's Reserve Plans (that include network Interactive Voice Responses) allow them to deal with unplanned surges of telephone calls by using pre-recorded messages. This service would not be able to function for calls delivered directly to geographic numbers - again making it more difficult for Capita to manage the services within SLA.

The three reasons above mean that both Capita and the BBC would suffer commercial harm if the numbers were released; Capita would be less able to deliver to the BBC and the BBC would receive a lower quality of service for the license fee payer.

Neither the BBC nor Capita receives any money from C&W by way of revenue-share for the traffic on the BBC's 0870 numbers. Instead the BBC and Capita receive a higher quality of support from C&W. C&W also commits additional resources to support in order to provide a faster, more-responsive service that is subject to shorter times for turnaround of requests for change. In turn this means that the BBC (and Capita working on behalf of the BBC) are able to respond quickly to changes in call traffic as a result of changing national and international events. Also these are not regarded by Ofcom or telecommunications providers as 'premium rate' numbers. They are 'national rate' numbers. Premium rate numbers begin with 09.

We have not been able to identify any public interest in disclosing the underlying geographic numbers used by the BBC. I am 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.

[...]

This site is REALLY starting to work well - you can tell this from the BBC reply above - drawn up by lawyers I reckon.

There are some serious issues here - and I hope that someone with legal training on this site can get their teeth into this an mount an appeal etc... Otherwise we could find other government departments using this defense.

There are a number of factual inaccuracies to say the least:

"If callers used geographic numbers Capita could not report accurately on call volumes"

- this is rubbish as far as I'm aware.

"Also these are not regarded by Ofcom or telecommunications providers as 'premium rate' numbers. They are 'national rate' numbers"

- ho hum - that 'ol story. Point them to the BT webpage!

It might also be pointed out that the BBC watchdog site has a daft long disclaimer about the cost etc... of using their 0870 number. Why don't the BBC use this same disclaimer everywhere they list their 0870 numbers?  

They do have a bit of a point about call volumes. In the old days radio 1 was an London 071 number and calling it for competitions led to an engaged tone most of the time. Well the answer to that is for the BBC to do away with Capita and manage the calls themselves. Or do what radio 2 do and still have a third party manage the calls but use an 0800 number for all BBC numbers. This way everybody is happy. I think they know that radio 2 listeners wouldn't stand for 0870 whereas radio 1's listeners are from a rip off generation and don't give a monkeys.

wrote on May 23^rd, 2005 at 5:42pm:

We have not been able to identify any public interest in disclosing the underlying geographic numbers used by the BBC.

The mind boggles.  No public interest?

Studying this more:

"The three reasons above mean that both Capita and the BBC would suffer commercial harm if the numbers were released; Capita would be less able to deliver to the BBC and the BBC would receive a lower quality of service for the license fee payer. "

Commerical harm to the BBC? Thats rubbish. Never mind about Capita because we do not pay our licence fee to them. Perhaps we should argue that we are entitled to a free or geographical number because we have already paid enough money via the licence fee, therefore the BBC are unjustified to indirectly charge us any more to call them. It is not relevant that the BBC do not keep any call revenue, and that they spend it on Capita's management services, these costs if needed should come out of the licence free already.

"We have not been able to identify any public interest in disclosing the underlying geographic numbers used by the BBC."

But there is public interest for reasons stated above, ie cost of calling them.

"I am 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."

They are talking about our public interest in their call management services being paid for BY US as being more important to US than us calling them at local rate. This is again, total rubbish.

wrote on May 23^rd, 2005 at 8:36pm:

Never mind about Capita because we do not pay our licence fee to them.

Well, actually we do!

http://www.capita.co.uk/Group/MediaCentre/PressReleases/PressReleaseArchive/BBCsignsTVLcontract.htm

;-)

Reply from the BBC in response to a request for internal review.

>>>

Original Request: To provide a list of underlying geographic equivalent numbers for all BBC services that currently terminate on 0870 numbers

Issues on review: The application of s.43(2) of the FOI Act.

Decision
My view is that s.43(2) of the FOI Act does apply.

Reasons for decision
There are compelling reasons why the 0870 telephone service is more advantageous to licence fee payers and to the BBC and its contractors:- 1. Calls can be managed more flexibly and efficiently (especially peaks and troughs in demand) 2. The use of pre-recorded messages and Interactive Voice Responses aids better communication, and 2. Sophisticated statistical reporting allows BBC partners such as Capita and Siemens and their subcontractors to deliver services according to contractual Agreements. The BBC and its contractors would, therefore, suffer commercial harm if the geographic numbers which underpin the 0870 system were released. For this reason, we are withholding this information under s.43(2) (commercial interests). In addition, the use of 0870 numbers offers equal access to all licence fee payers wishing to use the numbers in the UK. Because the service is more efficient, it also offers the best value for money. The use of geographic numbers would deny UK audiences these advantages. It is worth restating that the BBC’s international services (BBC World Service, BBC World and BBC Prime) offer overseas audiences the use of geographic numbers

If what the BBC say is true, then people living abroad must be getting a very poor service when calling the BBC.  Think of all those calls that don't get answered etc!!

After all, as they state, offering a service on a geographical number leads to such a bad deterioration in service, it could cause harm to the BBC!!

How about doing a survey with people who call the BBC from abroad using geographic numbers, and ask them whether they get a good service on the phone.  If it's no different to the 0870 service UK customers call, then maybe they should think about giving licence fee payers better value for money and allow us to use our cheap landlines call packages to call them.

The point no one seems to have raised yet is that if as it is claimed neither the BBC nor Capita receive the premiums, who gets them?

My guess is that some of this revenue flows back to both Capita and the BBC as some sort of "fee", and that is what they really mean by "commercial interests". It sure would harm their "commercial interests". They would loose this revenue!!!

As for the claim that these numbers are "National Rate" numbers and that they are not premium numbers, well the lies and the smoke and mirror attempts just continue and multiply like Pinnochio's nose!

wrote on Jul 5^th, 2005 at 4:40pm:

My guess is that some of this revenue flows back to both Capita and the BBC as some sort of "fee", and that is what they really mean by "commercial interests". It sure would harm their "commercial interests". They would loose this revenue!!!

That would be the same 'revenue' which NHS surgeries do not receive, which goes towards paying NEG and other 'providers' for their 'service'. See Department of Health (DH) FOI Response.

ok threaten to take this to the Information Comissioner now.

I recon theyll release the info before the IC decides.

Just had an internal review refused again.

Looks like im off to the Info Comissioner under section 50.
-I put in another request for all information relating to the tender of the 0870 numbers.
I today recived a 2.8MB email back full of PDF's, as I cannot highlight the text on them (crafty BBC) I will upload them to my website and let people view them, themselves.

The interesting thing I noted, was capita was invited back in 1998 when john birt was DG to do the 0870's.
Even Capitas own 'bid' claims that the 0870 are charged at one 'national' rate!!!

I asked the BBC to supply ALL geo numbers relating to 0870 and the response follows:


BritishBroadcastingCorporationMC301.MediaCentre.MediaVillage.201 Wood Lane. London. W 12 7TQ
Telephone 020 8008 2883 Fax 020 8008 2398 Email foi@bbc.co.uk
Information Policy and Compliance
bbc.co.uk/fol
Mr D

2 August 2006
Dear Mr
Freedom of information request - RF12006******
Thank you for your request under the Freedom of Information Act 2000 ("the Act")
dated 31 July 2006. BBC Information forwarded your email to me as I deal with
freedom of information requests received by the BBC.
You have asked a number of questions about the BBC's use of 0870 numbers that I
have provided responses to below. I also enclose an explanatory note that is
available on the BBC's Publication Scheme about the BBC's use of 0870, 0845,
0800, premium rate numbers and text messages. I hope that this document will
provide some answers to your questions and some additional information on the
subject.
You may also be aware that Ofcom have decided that in future 0870 calls must cost
the same as national calls to 01 and 02 numbers which will reduce the cost from
around 8p per minute to around 3p per minute. This price reduction is likely to come
in by the end of 2007.
1. Why do you use 0870 numbers?
Please see the attached explanatory note.
2. What is the equivalent geographical number of ALL your 0870 numbers
By way of background information, the BBC has contracted Capita Business
Services Ltd ('Capita') to provide the 'BBC Information' contact centre services that
use 0870 numbers. Capita in turn purchases telecoms services from Cable &
Wireless ('C&W) to deliver calls to the contact centres.
We are withholding the list of underlying geographic numbers to which our 0870
numbers deliver under section 43(2) (commercial interests) of the Act. I set out below
our reasons for this.
Releasing the information would create an operational risk; the telephone
switch would be compromised. This could be in the form of a lobby group choosing to
•attack' the switch by calling directly and thus circumventing all the protection offered
by C&W's Call Plans. Capita uses over 50 different numbers, a handful are in use
continually the rest are used for brief periods in support of specific campaigns, e.g.
ticket requests for concerts. The Call Plans permit Capita to balance the call
volumes received across the switch depending on forecast call volumes per number
or campaign. In this way Capita are able to ensure that the absolute maximum
number of callers can get through across all live numbers.
Capita rely on the ability to report on traffic across non-geographic numbers to
manage Service Level Agreements (SLA). If callers used geographic numbers
Capita could not report accurately on call volumes; no reliable statistics would be
available, making it immensely difficult for Capita to manage the contract with the
BBC.
Capita's Reserve Plans (that include network Interactive Voice Responses)
allow them to deal with unplanned surges of telephone calls by using pre-recorded
messages This service would not be able to function for calls delivered directly to
geographic numbers - again making it more difficult for Capita to manage the
services within SLA.
The three reasons above mean that both Capita and the BBC would suffer
commercial harm if the numbers were released; Capita would be less able to deliver
to the BBC and the BBC would receive a lower quality of service for the licence fee
payer.
Under section 2 of the Act I am required to weigh the public interest factors for and
against disclosure. There is no public interest in disclosing the underlying
geographical telephone numbers. Conversely, there is a public interest in Capita
managing call volumes efficiently on behalf of the BBC; therefore there is a public
interest in maintaining the exemption in this case.

3. What revenue do you receive per minute and in total from the use of 0870
numbers?
Neither the BBC nor Capita receives any money from C&W by way of revenue-share
for the traffic on the BBC's 0870 numbers. Instead the BBC and Capita receive a
higher quality of support from C&W. C&W commits additional resources to support in
order to provide a faster, more-responsive service that is subject to shorter times for
turnaround of requests for change. In turn this means that the BBC (and Capita
working on behalf of the BBC) are able to respond quickly to changes in call traffic as
a result of changing national and international events.
4. Are you aware of the revenue collected by your telecom provider, from your
callers?
0870 costs vary according to the telco provider and time of day and of course length
of call BT costs are up to 8p per minute during the day, 5p in the evening and 3p in
the weekend. However for 4 out of 5 callers to the BBC calls cost no more than 14p
and for 9 out of 10 less than 21 p.
5. Have you considered the revised COI guidelines? If so, what conclusions did you
come to?
Yes The COI guidance was prepared for central government departments and do
not apply to the BBC. The BBC is interested in what COI recommends and takes
their views into account.
6. Do you realise that all calls (local/national) cost the same?
We are aware of the cost of calls and indeed the fact that the costs are the same
from anywhere in the UK was seen as a benefit - namely the numbers provide equal
access from all over the UK.

contd......

7. Are you aware of the cost implications to your callers, when using 0870 numbers?
Yes as noted above in question 4.


Appeal rights
If you are not satisfied with this response you have the right to an internal review by a
BBC senior manager. 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, Wydiffe House, Water Lane.
Wilmslow, Cheshire, SK9 5AF. telephone 01625 545 700 or see
[url=www. informationcommissioner.gov.uk]www. informationcommissioner.gov.uk[/url]
Yours sincerely.
^CCAJ<A(L
Liz Waite
Information Policy & Compliance
E


I have another pdf file that came as well, and I will try and get it onto the site.

THE USE OF 0870, 0845, 0800 & PREMIUM RATE TELEPHONE NUMBERS BY THE BBC
EXPLANATORY NOTE
BACKGROUND
John (later Lord) Reith said in 1924 that “Personally, I think it is worthwhile to deal carefully with programme correspondence … It all tends towards the establishment of some degree of confidence and intimacy between the broadcasting organisation and the public: and we know this to be of the highest importance”. Since then the BBC has welcomed contact with the audience, at first by letter, then telephone and later email and text messages and also face-to-face through tours, live shows and events.
The telephone is the most convenient for most of our audience who last year made around 2.6 million calls to the BBC on a variety of tariffs, mainly on 0870 but also on freephone 0800, 0845 and other numbers including some geographic numbers such as the Belfast, Cardiff and Glasgow and London switchboards. In addition around 19 million calls were made last year to premium rate 090 numbers, set up by BBC Worldwide’s Audiocall, to take part in votelines or competitions which often raise money for good causes.
WHY THE VARIETY OF TELEPHONE NUMBERS AND CHARGES?
Programme and Audience needs vary and using one number and tariff is not practicable so there are different systems, numbers and tariffs for four different kinds of services:
1. Mass access telephone response systems such as Strictly Come Dancing, generally use a premium rate 090 number which pays for the set-up, running costs and technology that ensures that the audience has an equal chance of getting through. Often premium rate systems are the only practical way to ensure that there is a robust system which can cope with millions of calls, fairly and accurately. Votes and competitions cost 15p or 25p per call. The BBC’s own editorial guidelines and the independent regulator ICSTIS have strict controls over the use of premium rate telephone numbers. The BBC’s guidelines prohibit it from aiming to make a profit from telephony – the BBC is unique amongst broadcasters in this. Therefore the BBC always seeks the lowest price for callers (the lowest tariff was recently raised by BT from 10p to 15p a call). The BBC only sets a higher tariff if the aim is specifically to raise money for charity and then seeks to return the biggest slice of the revenue to good causes. Half of every 25p charged for votes for Strictly Come Dancing went to Children in Need. This has proved an increasingly popular method of audience donation to good causes.
2. Normal business, where the BBC answers enquiries about programmes or services including booking tickets, or handles audience comments and complaints, The charging policy set by the BBC in1998 when approving the investment proposal in the Capita-run BBC Information service, was that a move from a geographic London number to a ‘national rate’ 0870 numbers would help contain demand and
1
help deter trivial calls. Paying the full cost of the call also meant that the caller was the same situation as a letter writer who has to pay for a stamp. Last year Cable and Wireless reported that 4 out of 5 callers to BBC paid 15p or less and 9 out of 10 less than 21p for their call, cheaper than a stamp. The other advantage of an 0870 number, rather than a geographical number, was that it did not imply the BBC was solely based in London, or any other one location. The BBC does not make any money for itself from audience phone calls or text messages.
3. Text messages e.g. to Radio 1 or 5Live.The BBC does not generate any revenue from text messages to the national radio networks. Messages are charged at network operator rates of 10 or 12p, which is the minimum we are able to charge on a short code, such at 81199. The majority of this goes to the network operator. A small amount (under 1p per message) goes to the third party commercial company responsible for aggregating the messages and supplying the infrastructure enabling
the BBC to receive them. In some cases, premium rate text services may be run in conjunction with charity based competitions e.g. Comic Relief. No money comes back to the BBC, and again we seek to ensure that a majority of the call cost goes to charity. In some cases the mobile operators also donate part of their profits to the charity.
4. Freephone Helplines providing further information or support following a programme that raises difficult or distressing issues such as the Hitting Home series or the organ DoNation project where over 60,000 viewers called and many of whom registered as organ donors. Because the BBC pays the cost, using a freephone 0800 number ensures that the call is confidential and does not appear on the caller’s phone bill. Freephone lines are also provided where the caller is helping other people, such as giving to approved charities on the Radio 4 Appeal or the Lifeline programme.
WHAT DOES THE AUDIENCE THINK OF THESE TELEPHONE CHARGES?
The BBC has used ‘special telephone numbers’ such as 0870, 0845 and 0800 for about a decade without any significant comment or criticism from the audience. However in the last year there has been a growing lobby against 0870 numbers. Many programmes including You and Yours, Watchdog, Money Box, Face the Facts, Newswatch and also BBC Information, Freedom of Information team and the Press Office have spent time dealing with five broad complaints.
contd.............

The most common criticism is that 0870 numbers have become unjustifiably relatively expensive for callers, as BT and other telephone networks have introduced packages that allow cheap ‘long distance’ calls for as little as 1p/minute and include ‘free minutes’. These packages are taken up by increasing numbers of people but they exclude special numbers such as 0870 and 0845 which have therefore become relatively expensive at up to almost 8p/minute peak time.
A second criticism very strongly expressed by some individuals and lobby groups is that revenue sharing is wrong in principle because it is a kind of ‘premium rate’ service where companies using 0870 can receive a payment from the telephone network of about 1p/minute and this can reward companies who keep callers hanging on thus earning more revenue.
2
A general criticism of 0870 and other special numbers is the lack of transparency – although most people understand that 0800 means a ‘free call’ most consumers do not understand the difference between the various special numbers and premium rate services or what they cost. Unlike premium rate numbers there is no obligation to state the cost of calling 0870 and 0845 numbers.
Another, though less common criticism is that international access can be difficult for our overseas audience because some overseas telephone networks cannot connect to a UK 0870 number because of commercial or technical reasons.
Some have criticised BBC consumer programmes for being hypocritical in apparently publicising heavily the ‘say no to 0870’ campaign to encourage government departments, public and commercial organisations to drop 0870 in favour of geographic numbers such as those beginning 0207 (London) 0141 (Glasgow) etc or at least to give people a choice and to publish information on call costs.
However, more important than the relatively low cost of calling the BBC is whether the BBC is providing value to its audience. There are very few complaints about the mass access telephone systems or the freephone helplines and for normal business, BBC Information achieves very high rates of customer satisfaction independently measured by MORI with 87% rating the service 8 or more out of 10.
FUTURE CHANGES
In 2004 Ofcom launched a review of 0870 and 0845 and BBC has welcomed Ofcom’s proposals to reduce prices and improve price information. Ofcom’s own research indicated that most people thought that 0870 costs were higher than they actually are and confuse them with 090 premium rate numbers. Ofcom have now published their decision that ‘revenue share’ will end and that the link between 0870 and ‘geographic numbers’ restored. This is expected to reduce the cost of calling 0870 numbers from a maximum of 8p per minute to around 3p per minute. This may take until 2008 to implement.
The BBC has already changed the way it describes the cost of 0870 calls. In print and on the ‘contact us’ and other websites we say “calls from a BT line cost up to 8p per minute (some operators and mobiles vary) and may be recorded for training”
QUESTIONS AND ANSWERS
3
1. If the BBC does not make any money from 0870 does it get any other benefits?
Yes. 0870 numbers bring some technology and operational benefits for the BBC and callers and also in return for waiving the ‘revenue share’ from 0870 calls the telephone networks supply the BBC with a higher level of service which would otherwise cost the licence fee payer more to provide. The value of these saved costs is significantly more that the value of the revenue share foregone.
2. If the BBC wants to be accountable and open to the audience why not use 0800 numbers for everything so callers could call for free like sending emails?
The problem with 0800 numbers is that they attract a lot of nuisance or trivial calls. Extending the 0800 numbers beyond the existing use for helplines would waste licence fee money, increase the staff frustration in dealing with time-wasting calls particularly at night and probably produce an overall reduction in quality of service as genuine callers found it more difficult to get through.
3. Why not replace 0870 with geographic numbers like 0141 or 0207 etc so callers could ring for free or very cheaply under call discount plans?
We decided against that in 1998 when the Governors approved the use of 0870 numbers because they are fairer – everyone pays the same regardless of where they live. The 0870 numbers also bring some technology and operational advantages such as being able to redirect calls. The BBC has welcomed Ofcom’s proposals to cut the cost of 0870 calls and improve information so we expect it will become cheaper to call the BBC.
4. If the BBC is not making money from callers why does the BBC spend licence fee money on subsidising and answering calls rather than moving completely to online services?
The audience should have the choice of whether to call, write or click on-line. The BBC is however increasingly using simple-to-use technology to allow self service when ordering tickets or booklets e.g. when over 300,000 viewers requested a Springwatch pack and their requests were handled online and through automated 0870 telephone services. The new BBC complaints service does include a special on-line system for people to send in email complaints if they prefer to write rather than call.
Michael Stock
Business and Partnerships Manager
Marketing, Communications & Audiences
March 2006
4

Obviously I will ask for an internal review, which will be turned down,I will then forward it to the IC who If they ever get round to it will probably refuse anyway.

Just thought I would bump this up as it has been buried on page 3??

Received the follwing e-mail:-

Dear

We have received your request for an internal review relating to our decision to withhold the underlying geographic numbers to which our 0870 numbers deliver under the Freedom of Information Act 2000. Your request for an internal review was received on 3 August 2006.  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 IR20060*****.  

Yours sincerely

Fern Kersey

Information Policy and Compliance
BBC Freedom of Information
PO Box 48339
London W12 7XH, UK  

Website: www.bbc.co.uk/foi/
Email: mailto:foi@bbc.co.uk
Tel: 020 8008 2883
Fax: 020 8008 2398



6 weeks to do an internal review?? and I bet I know the outcome ;D

OK, I have received the response to my request for an internal review, and guess what? the upheld the decision to not release the geo numbers. their reasons follow in the next post.

With a view to the last paragraph,(in red), do you think this means that the BBC will continue to use these numbers when there is no revenue share on them? ;D ;D ;D

Looks like I will have to now put it in the hands of the ICO, for what use they are?!

Freedom of Information Internal Review Decision
Internal Reviewer: Mike Lewis, Senior Rights Negotiator
Reference: IR200600**** (RFI200600****)
Date: 7 September 2006
Original Request:
The requester Mr *  ****** asked a series of questions about the BBC’s use of 0870 numbers.
Issues on Review:
Whether the BBC was correct in refusing to release a list of the underlying geographic telephone numbers associated with its 0870 services on the grounds that would result in commercial harm to both the BBC and Capita, who have the contract to provide the “BBC Information” contact centre services that use 0870 numbers. The information was withheld under s.43(2).
Decision:
I have read all of the correspondence on file and have been in contact with both the BBC’s Marketing, Communications and Audiences Division (MC&A), who are in charge of this area and Capita.
The BBC’s decision to withhold the underlying geographic numbers was made under section 43(2) of the Freedom of Information Act (commercial interests), for three reasons:
     • that releasing the information would create an operational risk with the telephone switch being potentially compromised by lobby groups choosing to “attack” the switch by calling directly thus circumventing all the protection offered by C&W’s Call Plans, which permit Capita to balance the call volumes received across the switch depending on forecast call volumes per number or campaign. The BBC contends that in this way Capita are able to ensure that the maximum number of callers can get through across all live numbers
     • that Capita rely on the ability to report on traffic across non-geographic numbers to manage Service Level Agreements (SLA’s) with the BBC
     • that Capita’s Reserve Plans allow them to deal with unplanned surges of telephone calls by using pre-recorded messages and that this service would not be able to function for calls delivered directly to geographic numbers, again making it more difficult for them to manage SLA’s.


In summary the BBC contends that both it and Capita would suffer commercial harm if the numbers were released with Capita less able to deliver to the BBC and the BBC therefore receiving a lower quality service for the licence fee payer. From this follows the BBC view that there is no public interest in disclosing the underlying geographic numbers but there is a public interest in Capita managing call volumes efficiently on behalf of the BBC and therefore the exemption should be maintained.
My view is that the use of 0870 numbers is of significant benefit to licence fee payers as a whole and that the BBC and Capita would suffer commercial harm if the geographic numbers were released. I therefore believe the exemption under section 43(2) of the Act does apply in this case and I am upholding the original decision.
It is the case however that the Office of Communications (Ofcom) has recently announced its policy decision on this subject following a review and it has said that revenue sharing between telcos and companies using 0870 numbers should cease and that the price should come down from next year from the 8ppm maximum to 3ppm, which is equivalent to the national geographic rate. Hopefully this will prevent further complaints about the use of 0870 numbers
Mike Lewis

From the e-mail, the above post was the attachment.

Dear Mr ******,

Please find attached the internal review decision note that relates to your FOI request (reference RFI20****). You will see that the original decision has been upheld in this case. If you wish to appeal to the Information Commissioner full details are available on their website: http://www.informationcommissioner.gov.uk/

<<IR20060***** - IR decision note.pdf>>

Yours sincerely,

James Leaton Gray
Head of Information Policy & Compliance
BBC Freedom of Information
MC3D1, Media Centre,
201 Wood Lane,
London W12 7TQ, UK

Website: www.bbc.co.uk/foi/
Email: mailto:foi@bbc.co.uk
Tel: 0208 008 2883
Fax: 0208 008 2398

derrick wrote on Sep 12^th, 2006 at 1:36pm:

With a view to the last paragraph,(in red), do you think this means that the BBC will continue to use these numbers when there is no revenue share on them?

I'd say it's a fairly safe bet they'll change to 5p/minute 0844 or, more likely, 10p/minute 0871 numbers well before then.

Heinz wrote on Sep 12^th, 2006 at 3:14pm:

derrick wrote on Sep 12th, 2006 at 1:36pm: With a view to the last paragraph,(in red), do you think this means that the BBC will continue to use these numbers when there is no revenue share on them? I'd say it's a fairly safe bet they'll change to 5p/minute 0844 or, more likely, 10p/minute 0871 numbers well before then.

Ye, that is what I thought, hence why I put the cheesy grins after the ?

My view, for what it's worth, is that the real winners in the equation are the companies that bid for the '0870 management contract' or whatever they choose to call it.  Because these companies are basically justifying their jobs, and no doubt the variety of excuses you hear are provided at the first by them.  After all, they have a lot to lose, it's a big contract, and somebody's got to pay for it - that'll be you.  

The statements that imply that 'nobody makes any money by doing this' are preposterous.  Somebody's making money out of it by definition; we are all paying 8p per minute for the priviledge.  Do we naively believe that it's just BT who are making profit here?  No of course, Capita are making profit.  Simply put, they wouldn't be in business if they weren't.  

I have no doubt it IS easier for the BBC if another company is managing the calls, and outsourcing is commonplace in industry.  It does sometimes result in an overall reduction in cost, but my question is this.  Who is paying it?  And do we agree with the methods through which we are paying for it?  Should this not be included in the licence fee?  

What annoys me more than anything else is this "concern for the unfairness" excuse relating to someone across the country having to pay for a National Rate when those living closer get a Local Rate.  This used to be the case before the telecoms industry was opened up and do the BBC really believe the population they serve have so little idea?  There's been a mobile revolution folks!  

Everybody knows about the free calls packages because BT aggressively market them every time they send out post. We all know we can get free calls across the country therefore making a "national rate" a FREE Rate or VERY CHEAP rate.  And I'm sure if they had a box on the license fee slip that said "do you want calls starting 01.... or 0870 which would you prefer?"  You'd get 98% of people preferring the 01... number.  It very much is in the public interest, if not in the public consciousness, and they're hoping we won't notice.

Just received the following e-mail:-


20th September 2006

Case Reference Number FS501*****


Dear Mr ******


Your information request to the BBC.

Thank you for your correspondence dated 14th September 2006 in which you make a complaint about the BBC's decision not to release the information you requested.  


Your case has been allocated to one of our case resolution teams who will contact you as soon as possible to explain how your case will be progressed. Due to the volume of complaints we are receiving at present it may be several months before you hear from us.


If you need to contact us about any aspect of your complaint about the BBC please contact our Freedom of Information Helpline on 01625 545745 being sure to quote the reference number at the top of this letter.  


Yours sincerely,


Sent on behalf of

Mr Paul Arnold

Head of Customer Service

FoI Case Reception Unit

The Information Commissioner's Office



So no answer anytime soon then??

Derrick,

I personally don't think you'll get anywhere but anyhow you could try including a link to Ofcom's press-release about 0870 numbers and 0870 use by public bodies:-

Quote:

Ofcom continues to recommend that public bodies should not use NTS numbers exclusively (ie: without giving equal prominence to a geographic alternative) especially when dealing with people on low incomes or other vulnerable groups.

This is because the IC, in their public interest test, will need to be aware that these costs are extensive and upto 40p/min from a mobile and some gov departments actually make money from the calls, and that Ofcom does not recommend public bodies use NTS numbers without a geographical number.

Obviously by using 0870 numbers BBC are making themselves in some cases unreachable due to the excessive cost of these calls and not everyone has internet access to email them.

bbb_uk wrote on Sep 20^th, 2006 at 5:34pm:

Derrick, I personally don't think you'll get anywhere but anyhow you could try including a link to Ofcom's press-release about 0870 numbers and 0870 use by public bodies:- Quote: Ofcom continues to recommend that public bodies should not use NTS numbers exclusively (ie: without giving equal prominence to a geographic alternative) especially when dealing with people on low incomes or other vulnerable groups. This is because the IC, in their public interest test, will need to be aware that these costs are extensive and upto 40p/min from a mobile and some gov departments actually make money from the calls, and that Ofcom does not recommend public bodies use NTS numbers without a geographical number. Obviously by using 0870 numbers BBC are making themselves in some cases unreachable due to the excessive cost of these calls and not everyone has internet access to email them.

That has already been mentioned in  e-mail correspondence with the BBC and all e-mail correspondence has been forwarded to the ICO, as has the cost of calling from mobiles and payphones.


The reply below was sent to me in an e-mail to me dated 2nd August 2006, that was in reply to my e-mail to them dated 24th July 2006.

5. Have you considered the revised COI guidelines? If so what conclusions did you come to?

Yes. The COI guidance was prepared for central government departments and do not apply to the BBC. The BBC is interested in what COI recommends and takes their views into account.

Despite cleverly avoiding the use of Ofcom's phrase, that reply indicates that the BBC considers itself not to be a 'public body'.

But, as BBC wages are paid for from the licence fees the public is required to pay, it follows that the BBC is a public body.

They're going to continue to hide behind semantics (they've had ten years of training from the experts in that - their political masters).

Heinz wrote on Sep 21^st, 2006 at 9:37am:

Despite cleverly avoiding the use of Ofcom's phrase, that reply indicates that the BBC considers itself not to be a 'public body'. But, as BBC wages are paid for from the licence fees the public is required to pay, it follows that the BBC is a public body. They're going to continue to hide behind semantics (they've had ten years of training from the experts in that - their political masters).

A point I have made to them

The BBC appears to be above reproach and therefore thinks itself as not a accountable to anyone/anything.

The thing is it is allowed to get away with stuff and is exempt from some things whereas other government departments aren't.

Another example is adverts on BBC do not come under the remit of ASA so the BBC is in itself accountable to itself for adverts.  How is that being independant?

derrick wrote on Sep 12^th, 2006 at 1:38pm:

The BBC’s decision to withhold the underlying geographic numbers was made under section 43(2) of the Freedom of Information Act (commercial interests), for three reasons: • that releasing the information would create an operational risk with the telephone switch being potentially compromised by lobby groups choosing to “attack” the switch by calling directly thus circumventing all the protection offered by C&W’s Call Plans

Now if this is all true then why is the BBC able to use normal geographical numbers for BBC Watchdog?

I have just received some correspondence from the ICOs office re my request,  boy don't they take some time? and it is by no way near a decision, the 0870 will have stopped revenue sharing before a decision is taken on this, and if not, and it goes my way, the BBC will appeal it, so I don't think we will get a result before revenue sharing ends!

Have you also noticed they are now supplying an 0845 number for telephone contact on the bottom of letters!



12th September 2007  
     
Case Reference Number FS5013****

Dear Mr
I am writing to inform you that your case has now been allocated to me to investigate your complaint against the British Broadcasting Company ("BBC").
In order to reach a decision as to whether the Freedom of Information Act ("the act") has been correctly applied, I will need to carry out a thorough investigation. This may take me some time as I will need to ensure that I am aware of all the relevant facts and that I carefully consider the application of the law to those facts.
Where possible the Information Commissioner prefers complaints to be resolved by informal means. If this does not prove to be possible, he will usually issue a Decision Notice to you and the public authority once an investigation has been completed. This will inform you of his decision and the reasons for it.
Where the Commissioner decides that a request has not been handled properly he may specify what steps he believes are necessary to remedy the situation. This can include requiring a public authority to release information which has previously been withheld. A copy of the Decision Notice will be placed on our website (with your details omitted). If you disagree with the decision that has been reached you have a legal right of appeal to the Information Tribunal.
Your request
From the information which you have provided to us, I understand that you made a request to the BBC by e-mail on 31 July 2006 for the geographic telephone numbers behind the 0870 numbers.


The BBC provided a response to you on 2 August 2006 in which it refused to disclose the information you requested on the basis of the exemption contained in section 43(2) of the act.
You requested an internal review of the public authority's decision on the 3 August 2006. On 7 August 2007 the public authority wrote to you with the details of the result of the internal review it had carried out. The outcome of the review was to uphold the original decision.
The scope of the case
The focus of my investigation will be to determine whether or not the BBC has acted in accordance with the act.
Please contact me as soon as possible if there are matters other than these that you believe should be addressed. This will help avoid any unnecessary delay in investigating your complaint. If I do not hear from you, my investigation will focus only upon the matters identified above.
As I have indicated, the process of reaching a decision may take some time but I will update you on the progress of the investigation as appropriate but at least every 6-8 weeks. However, if you have any queries at any time you are welcome to write to me at the above address, or at
Richard.Lawanson@ico.gsi.gov.uk (please ensure that you quote the above case reference) or by telephoning me on 016125 524 5386.
It may not be possible for me to respond to enquiries immediately due to other work commitments but I will endeavour to provide a response as promptly as possible and will ensure that a response is provided within 14 working days of the receipt of any enquiry.
Yours sincerely


Richard Lawanson


Senior ComplaintsOfficer

Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF t:0845 630 6060 f:01625 524510 e:mail@ico.gsi.gov.uk w:ico.gov.uk
           

derrick wrote on Sep 13^th, 2007 at 4:09pm:

telephoning me on 016125 524 5386

Also notice how he misquoted his telephone number so any "not in the know" person would have to ring the 0845 number to get hold of him...

jgxenite wrote on Sep 14^th, 2007 at 12:56pm:

derrick wrote on Sep 13th, 2007 at 4:09pm: telephoning me on 016125 524 5386 Also notice how he misquoted his telephone number so any "not in the know" person would have to ring the 0845 number to get hold of him...

I hadn't picked up on that, I just thought it was a number in Manchester, they could have an office there!

Any way I have just rung the number as it is written and it seems to connect to a fax machine, at least it makes noises that I have heard before when I connect to a fax machine!

0161 is Manchester, 01625 is Wilmslow/Macclesfield and is only spitting distance away (it was/is within the local call area for Manchester residents) so I'd assume it was just a typo as a local would be used to using both codes a lot.

The point wasn't that the area codes are geographically close - the point was the number with the extra 1 in wouldn't connect. Obviously he didn't proof read the letter before he sent it lol  ::)

I have posted this elsewhere, but as this is the original thread, I thought I would put it here as well.

Received the following from th ICO,( I originally contacted this waste of space in September 2006 about this),

17 March 2008

Case Reference Number FS50******

Dear Mr ,

Thank you for your most recent email.

Unfortunately I am unable to provide you with a definitive date as to when the formal decision will be reached. Similarly, at present, I am not in a position to provide you with an indication as to my recommendations to the Commissioner. I would however appreciate your comments on some of the assertions (outlined below) made by the BBC.

The BBC has a general telecommunications technology contract with Siemens who order non-geographic numbers from their preferred communications supplier for BBC services - Cable & Wireless (C&W).There are two ways that the BBC receives 0870 numbers from C&W those supported with a call plan and those that are not.

0870 numbers with call plans attached have functionalities such as:

•      Time of the day routing - which provides a mechanism for callers to be
diverted to different routing numbers dependent on the time of the day and the
day of the week.

•      Queue Managers - which can be applied to any call centre where in-bound
peaks in call traffic exceed the resources available to answer calls. Calls are
automatically answered by the queue manager system and held in the
network.

•      Call Forwarding - provides for call diversion to another number when lines
are busy or if there is no answer.


• IVR (Interactive Voice Responses) - provides for calls to be answered by an auto attendant service (currently C&W sub-contract their IVR services to Telecom Express).

The majority of the BBC's 0870 numbers with call plans are used by Capita to provide services to the BBC. While some calls may be forwarded to BBC geographic telephone numbers at a later stage, all the initial calls are routed through geographic telephone numbers owned and managed by Capita. Capita needing to have their own set of geographic numbers as a technical requirement for providing telecommunication services such as premium rate lines. As such the geographic telephone numbers are held by Capita not the BBC; nor are they held on the BBC's behalf by Capita.

If you wish me to consider your views on the BBC's assertions above (or indeed any views you have not previously expressed) please deliver them to me within twenty working days from the date of this letter.

■ Your sincerely

  Richard Lawanson

Senior Complaints Officer



Any comments to assist in  a response  will be appreciated, as the last paragraph appears to give some scope for further questions/points

Please go to the new thread I have just started regarding a crucial meeting of the BBC Executive Board on Monday April 21st to decide whether or not to switch to geographic call rate 03 numbers for all of the BBC's normal contact telephone numbers for all its programs and all its radio and tv stations.  
 
Your help in emailing members of the BBC Executive Board and BBC Trust to indicate your personal backing for a switch by the BBC to all 03 numbers would be very helpful in persuading the BBC to take the right decision as we do not know whether the BBC Board Members have been advised to choose the 03 option or to choose some other more undesirable alternative such as switching to all 0845 or all 0844 5p per minute phone numbers.  
 
See my new thread on this topic at www.saynoto0870.com/cgi-bin/forum/YaBB.cgi?num=1208458341/0

;D
I've only joined this marvellous site in the last 14 days.Although, my own experiences with numerous govt depts have been - let me be polite - rather confrontational I reckon that if i had experienced some of the problems over such a time i might have invested my money in a few pick axe handles! A few well aimed strikes at their status symbol- the car would have given me a great deal of satisfaction.The latest answer you have recd is either the work of a man who is very clever and is deliberately obfuscating(good word ) the issues and is actually deriving sadistic pleasure from being patronising and imperious or he really has not been able to grasp the notion of why 0870/45 are unjust, not necessary and invariably hit hardest those who can least afford it.I do sympathise sometimes with the poorly trained, badly paid bods who are virtually put up as sacrificial lambs when trying desperately search for the bit of paper with the party line they are supposed to quote - whatever the query.Over the last 18 months I have earned myself a bit of a reputation.Whether it is a letter to a utility company or an email to my "mates" at the loacal job centre for a problem of my own or now increasingly someone else's I do derive comfort from slaying goliath.Armed with the right info (I can recommend the Handbook on welfare benefits by the child poverty action group) taking on these orgs can be quite amusing - absurd comedy - mayme hence my smiley.I can now see myself taking forward in a small way this websites work.Together we can change things.Respect to you all - regards nogard  

I recently requested from the BBC all of their geo numbers for the 0845/0844/0871 numbers that they use, on Wednesday I received a list of numbers,(without locations),  today, Saturday, I called all of the numbers supplied and list them as follows; -


    TRIED NUMBERS BELOW ON  SATURDAY MORNING 14th FEBRUARY BETWEEN 9-10

0845               Geographical  Number  equivalent

08453000097               02380710229    Number not answered
08453000190               02087527828    BBC person you are calling is not available
08453001086               02920322739    Message centre, please leave a message
08453002872               02074650264    Busy for at least 2 hours!!!
0845300319                 01386421129    Number not recognised
08453033008               01628407777    Support rep will answer your call shortly!
08453007557               01604737652     Joanne cannot be reached, leave a message.
08453050961               02380374374     Solam guide? Only manned Fridays 8-4
08453043008               01628407777     Duplicate number.
08453053008               01628407777                “         “
08453055852               01604737652                “          “
08453063027               01619570019     BBC Northwest tonight
08453660090               02890338136     This number is not currently in use
08459001630               01159350098     Number not recognised!
08459005200               02476630809     BBC Coventry Radio
08459005200               02476630809            “           “     Duplicate number
08459006949               01179804346     Bristol Radio
08459007949               01179467467     Number not answered
08459123600               02089141603     Short change phone line! “show now off air” !!
08459200104               02890550080     Number not recognised
08459200105               02890550081     Number not recognised
08459311444               01865480995     Number not answered
08459311555               01865889089     Fax machine
08459311666               01865480991     BBC Jam line, traffic & travel for the South East, but will send                                                               out to other local stations
08459409644               01634821032     This goes to a Peugeot dealer in Rochester who assure
                                                          me  that their  number is 01634 842231
08459456700              01132247009       Dead number!
08459555678              02890555678       Radio Ulster
08459568811              02074470045       Fax machine
08459600701              02072242000       BBC Radio London
08459643120              02087429513       Private house
08459770775              01162537453       Number not answered.
08459818000              02087439552       Number not answered.


The following is the text that accompanied the numbers; -


Dear Mr ******

Freedom of Information request – RFI20****

Thank you for your request under the Freedom of Information Act 2000 (“the Act”) dated 10
February 2009.  The reference number for your request is RFI20090301.

You requested a copy of the following information:

“Please supply to me…all of the underlying geographical telephone numbers for all of your revenue
sharing telephone numbers beginning 0845, 0844, and 0871 these should include the telephone
numbers that are used to access BBC local radio stations, TV phone in shows and TV licensing,
these type of numbers are confirmed by Ofcom as being “revenue sharing”, i.e.
http://www.ofcom.org.uk/consumeradvice/landline/costofcalls/08faq/
”

It is noted that your request is being made in context of your previous request for information
RFI2006000462 and the resulting Information Commissioner Decision (reference number
FS50133140), in regards to underlying geographical numbers for the BBC’s 0870 revenue sharing
numbers.

As you will be aware, the ICO took the view that the BBC does not hold the information you
previously sought as regards non-geographic numbers accompanied by a call-plan, as numbers
accompanied by a call-plan “may be directed to an interactive voice response system or to a BBC
geographic number.  Accordingly, there is not an equivalent geographical number held by the BBC for
its non-geographical numbers with a call plan”.  However, the ICO required the BBC to disclose the
equivalent geographic number of the BBC’s non-geographical numbers not accompanied by a call
plan, and this was provided to you on 30 January 2009.

Further to my post above, I received the following today after asking the BBC to confirm the numbers and to where they direct to; -



0845 number     Geographic Equivalent     Service

08453001086      02920322739                 BBCWales
08453050961      02380374374                 RadioSolent
08453055852      01604737652                 RadioNorthampton
08453063027      01619570019                 NorthWestTonight
08459005200      02476630809                 BBCCoventry&Warks
08459006949      01179804346                 RadioBristol
08459311444      01865480995                 BBCOxford
08459311555      01865889089                 BBCOxford
08459311666      01865480991                 BBCOxford
08459456700      01132247009                 RadioLeeds
08459555678      02890555678                 RadioUlster
08459600701      02072242000                 BBCLondon
08459770775      01162537453                AsianNetwork

I can't guarantee them being correct, as I have not had chance to ring them.



The following is the text that accompanied them; -

20 April 2009


Dear Mr ******

Freedom of Information request – RFI*****

Thank you for your further request under the Freedom of Information Act 2000 (“the Act”) dated 15
March.  The reference number for your request is RFI********.  I apologise for the delay in our
response.

You requested a copy of the following information:

“I therefore request that you inform me of the terminating location for the list of numbers that you
have supplied, i.e which radio stations or offices that they relate to, this should be made under your
same reference RF**********.

If you chose not to use the same reference, then please treat this as a separate request under the
Freedom of Information Act 2000, and respond as my above request.
…
I require, as per my original request that you supply the geographical numbers for TV Licensing, this
company is employed by the BBC to collect the licence fee, (the way the BBC is funded), and
should not have a revenue sharing number to covertly extract more money from the licence fee payers.

0871 numbers, (as ALL 084/087), numbers DO have geographical numbers, that is how they work,
so please supply those numbers.

It is noted that your request is being made in context of your previous request for information
RFI2*****.

As you are aware, the Information Commissioner recently took the view that there is not an
equivalent geographical number held by the BBC when a non-geographical number is accompanied by
a call plan.  However, where a non-geographical number is not accompanied by a call plan the BBC
was required to disclose the equivalent geographical number, as a result of Decision Notice
FS5********.

With reference to the above finding by the Information Commissioner, we have previously disclosed
to you all TV Licensing numbers that are not associated with a call plan, and these numbers and their
geographical equivalents were provided to you in our letter of 11 March 2009.

Furthermore, as advised in our previous correspondence, the BBC does use a limited number of non-
geographical 0871 numbers; however these numbers do not have a geographical equivalent.  To
clarify, while the BBC does use a limited number of non-geographical 0871 numbers, these numbers
are accompanied by a call plan and therefore an equivalent geographical number is not held by the
BBC as supported by the above ICO Decision.  

With regard to the 0845 numbers supplied to you in our letter of 11 March, the 0845 numbers are
predominately attached to local radio stations and there is no central record of the numbers and the
location where they terminate. I can confirm that the list provided to you in our response to
RFI******** came directly from the BBC’s 0845 number supplier, Cable & Wireless. We have
contacted the local radio stations and those with 0845 numbers currently in use are provided in the
amended table below. To clarify: the numbers omitted from this list are either not currently in use or
are not customer facing.

It is worth noting that we are currently reviewing our existing 0845 numbers as part of our
examination of a potential move to 0345. Some numbers which are rarely used - for example
because audience contact has generally switched to email or live calls to radio stations as opposed to
answerphone comment lines - will be discontinued as this process continues.

After requesting again that they supply me with the geo number for TV Licensing I received the following response; -

"Dear Mr ******

I write in response to your further query of 21 April 2009.

As we advised in our previous responses to your requests for information under the Freedom of Information Act 2000 (reference numbers RFI20090301 and RFI20090445) TV Licensing only has three numbers that are not associated with a call plan, which are the minicom numbers.  In our response of 11 March 2009, you were provided with the TVL numbers not associated with a call plan and their geographical equivalents.

You will note in our previous responses that we have made reference to the Information Commissioner Decision (FS50133140) where the ICO took the position that the BBC does not hold an equivalent geographical number where a non-geographical number is associated with a call plan.  In the above case the ICO took the view that numbers accompanied by a call plan "may be directed to an interactive voice response system or to a BBC geographic number.  Accordingly, there is not an equivalent geographical number held by the BBC for its non-geographical numbers with a call plan".

I trust the above is of assistance.

Yours sincerely
Charlotte Gibson

BBC Information Policy and Compliance
Room 2252, 2nd Floor, White City
201 Wood Lane
London W12 7TS, UK

Website: www.bbc.co.uk/foi
Email: mailto:foi@bbc.co.uk
Tel: 020 8008 2883
Fax: 020 8008 2398"




So they are hiding behind the ICO's decision re the previous case and will not release that, (highly profitable),number!

Random thought - what do you think they'd say if you submitted a new request asking for details of the calls plans...?

irrelevant wrote on May 1^st, 2009 at 7:14am:

Random thought - what do you think they'd say if you submitted a new request asking for details of the calls plans...?

As the IC has already agreed with the BBC, that they do not hold these numbers, (which I doubt), then it would be a fruitless exercise.

Well there's always the option of asking for a list of all the landlines & DDI ranges that they rent ....  I imagine that it would be a very long list to go through, though ..

Hi,

Please see below the BBC's response to my Freedom of Information request which I made on Saturday 17th Ocober 09, the BBC responsed on Friday 13th November 09

http://www.whatdotheyknow.com/request/21300/response/55549/attach/3/RFI20091436%20final%20response.pdf