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FOI response - TV Licensing (Read 18,034 times)
idb
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FOI response - TV Licensing
Aug 19th, 2005 at 4:46pm
 
Response from the BBC. This has been through an OCR so there may be a textual oddity or two.

<<
Thank you for your request under the Freedom of Information Act 2000 ("the Act") dated 21 July 2005. Your reference number for this request is RFxxxxxxxxxxxx.

I note that you have made a previous freedom of information request (19 April 2005, RFxxxxxxxxxxxx) that is substantially similar but as your new request involves different contracts we are treating this as a fresh request. I have quoted your six questions and provided corresponding answers below.

I would like to point out that "TV Licensing" is a trading name used by the companies contracted by the Licensing Authority (the BBC) to administer the collection of television licence fees and enforcement of the television licensing system. As you will be aware it is the BBC that is subject to the Act, not our contractors, other than for information that they hold on our behalf (as per section 3(2)(b) of the Act).

The majority of the administration of TV Licensing is contracted to Capita Business Services Ltd (Capita), with the administration of the Cash Easy Entry payment schemes contracted to Revenue Management Services Ltd, and marketing and public relations activities contracted to the AMV Consortium. Therefore our responses relate to information held by these contractors on our behalf. You will also find the responses below are substantially similar to those provided previously.

continued...
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idb
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Re: FOI response - TV Licensing
Reply #1 - Aug 19th, 2005 at 4:48pm
 
...

1 - What are the equivalent geographic numbers (i.e. overlay numbers) for all services that currently operate using 0870 numbers.

I can confirm that the BBC holds this information, however, this information is exempt under section 43(2) (commercial interests) of the Act. Under this section, information is exempt if it is likely to prejudice the commercial interests of any person.

In this case, the commercial interests of Capita and the BBC would be harmed if the geographical numbers were released which would have an impact on the BBC's revenue stream and Capita's ability to carry out their contractual obligations. The reasons for withholding the numbers are set out below.

Releasing the information would cause an operational risk; the telephone switch could be compromised. This might be by some form of lobby group attempting to circumvent the BT call plans by trying to make direct calls to the call centre. Capita uses over 131 different 0870 numbers in order to provide specific services to customers with different licensing requirements. The call plans allow 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 calls are managed according to their contract with the BBC.

Capita rely on the ability to report on traffic across non-geographic numbers to achieve service level agreement targets set by the BBC. If callers used nongeographic numbers, Capita would lose the ability to report accurately as no equivalent statistics are available. This would be to the detriment of the service provided to TV Licensing customers.

Capita's call response plans, which include networked IVR (Interactive Voice Response) require the ability to manage call traffic across their call centres as a virtual site, switching calls to any site or to various customer self serve options. This is also a requirement for contingency planning, disaster recovery and for service continuation during technical failures.

The answer to question 2 provides further information on why these numbers are important to TV Licensing's operations.

We are 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 for the reasons outlined above.

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Re: FOI response - TV Licensing
Reply #2 - Aug 19th, 2005 at 4:49pm
 
...

2 - Why did the TVL introduce 0870 numbers? Please provide any supporting information, for example meeting notes etc.

Please note that TV Licensing has used non-geographic numbers since 5 April 1995 and that there are a number of reasons why TV Licensing decided to and continues to, use 0870 numbers.

There are three important operational and technical advantages in 0870 numbers compared with geographic numbers such as 0207, 0141 etc. First, 0870 calls (and the other `intelligent numbers' as they are called ) can be routed to different places, such as our different call centres, at different times, Secondly, unexpected peaks in demand can be coped with through prioritising the different types of call, use of IVR and by pre-recorded messages. Thirdly, the BBC partners such as Capita, and their sub-contractors, deliver services according to contractual agreements. 0870 and other special numbers enable sophisticated statistical reporting, to assist both us and our contractors to manage the performance of the call centre and track the effectiveness of our marketing campaigns. These three advantages would be lost with geographic numbers.

Another benefit is equal access from all over the UK - everyone pays the rate regardless of where they are calling from (although different providers may levy slightly different charges, it is the most equitable framework in this regard).

The 0870 and 0845 tariffs are also the best way of delivering value for money for licence fee payers. It avoids the costs of an 0800 freephone number (which the company has to pay for) which is known to stimulate demand. The rebate from 0870 numbers also enabled the call automation systems to be self-financing to a degree which avoids costs to the BBC.

A preliminary search of our files has not revealed any relevant supporting information and has not enabled us to ascertain whether the information would be held in a particular archived file. Therefore I estimate that to deal with this part of your request by searching across a large number of files would take more than two and a half days; under section 12 of the Freedom of Information Act 2000 we are allowed to refuse to handle the request if it would exceed the appropriate limit. 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).

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Re: FOI response - TV Licensing
Reply #3 - Aug 19th, 2005 at 4:51pm
 
...

3 - How much revenue/rebate does NL receive from its non-geographic numbers?

The rebate received by TV Licensing from its non-geographic numbers is received by our contractor Capita. This is a commercial agreement between Capita and BT and the BBC is not a party to this agreement, however, the BBC does hold information on the amount of the rebate. This information is exempt under section 43(2) (commercial interests) of the Act. Under this section, information is exempt if it is likely to prejudice the commercial interests of any person.

Capita have confirmed that they do consider the amount of the rebate to be sensitive as it is offset against their charges within their contract with BT and is indicative of the volume of business that Capita do with BT. This information forms part of Capita's pricing arrangements and is used in contract negotiations. To disclose this information would jeopardise Capita's ability to compete in bids for further contracts.

The disclosure of this information would be likely to prejudice the commercial interests of the BBC and Capita as this relationship is in itself commercial and releasing the figures we hold would prejudice Capita's commercial interests, and thus in turn, the BBC's commercial interests.

We are 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.

While there is a public interest in knowing the amount of the rebate as it has an impact on the costing in the BBC's contract with Capita, and the rebate generated through their use allows us to keep collection costs as low as possible, this does not outweigh the public interest in not releasing this information, since disclosure would be likely to cause commercial prejudice to Capita in terms of them negotiating contract prices, which would in turn prejudice the commercial interests of the BBC.

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Re: FOI response - TV Licensing
Reply #4 - Aug 19th, 2005 at 4:53pm
 
4 - Which company supplies the non-geographic numbers?

BT provides these.

5 - Is TVL aware of the difficulties experienced by overseas callers attempting to dial non-geographic numbers and the increased costs faced by UK callers in contacting these numbers?

Our contractors, TV Licensing, are fully aware that customers, who may wish to contact them from an overseas address, may experience difficulties using nongeographic telephone numbers. They receive very few contacts from people living abroad and for this reason customers are asked to communicate either by e-mail, through the N Licensing website, www.tvlicensing.co.uk or by post to Customer Services, TV Licensing, Bristol BS98 1TL, UK.

6 - The use of 0870 numbers for public enquiries contravenes the government's own advice regarding the operation of call centres (source: COI http//www.coi.gov.uk/ccaldownload.php 'cost to citizen' update). Why is the COI's advice is being ignored in that NL, as a public-facing department, continues to operate 0870 numbers? Has the COI advice been considered and if it has, please provide meeting minutes and any other supporting information that relates to this issue.

As previously stated in correspondence to you, the COI guidance you refer to is internal guidance for relevant HM Government departments and, to our knowledge, is not HM Government policy or practice. However we believe that N Licensing's use of these types of numbers clearly meets the guidelines from the COI.

TVL offers a variety of contact mechanisms and uses different cost models for differing market segments. All calls for our cash scheme customers are on 0845 numbers which are charged at what was known as a local rate, as are the help lines for Over 75's. Customers can also choose to contact us online, or visit a Post Office to pick up literature or buy a licence both of which are either free to use or the cost is controlled by the customer. In addition to these channels there is still the post; the cost of a second class stamp is equivalent to the cost of a telephone call. In offering this mix of contact channels we more than meet the COI recommendations of ensuring that 'citizens' are not prevented from obtaining their rights through by cost barrier.

You have the right to seek an internal review of my refusal to release the information referred to above. You can either email foi@bbc.co.uk or write to BBC Freedom of Information, PO BOX 48339, London, W12 7XH, UK. If you are not satisfied with internal review you then have the right to seek a further review from the Information Commissioner. Please see www.informationcommissioner.gov.uk or contact the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, telephone 01625 545 700 for details.

Policy Advisor BBC TV Licensing Management Team

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Re: FOI response - TV Licensing
Reply #5 - Aug 19th, 2005 at 4:55pm
 
I expected nothing less of Capita.
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Re: FOI response - TV Licensing
Reply #6 - Aug 19th, 2005 at 6:37pm
 
Quote:
...This information is exempt under section 43(2) (commercial interests) of the Act. Under this section, information is exempt if it is likely to prejudice the commercial interests of any person...
I believe their reply was exactly the same as BBC's and was nothing new or surprising.

I note that their website contact us doesn't state the cost of calls to them so I'll email them with the ASA/CAP guildlines (although technically the ASA/CAP wouldn't cover their website but hope they don't realise this).
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Re: FOI response - TV Licensing
Reply #7 - Aug 20th, 2005 at 4:15pm
 
0800 551 550 checked and added to alternative numbers
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Re: FOI response - TV Licensing
Reply #8 - Oct 9th, 2005 at 7:06pm
 
Similarly, 0800 328 2020 also works.
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