(I hope that regular readers will enjoy another “epic”. On this occasion I consider it to be unusually suitable to discuss general campaign tactics in public.)
Well done
confirmordeny
.
The exchange shows admirable courteous persistence against responses which, although polite and sometimes helpful, were essentially resisting the request.
The issue of these “
international numbers” is interesting. Previous adventures have shown that calls from the UK may not be accepted by agents answering these numbers.
The locater information clearly states “
If you're calling from abroad please telephone: ”, whereas these numbers are said in the correspondence from HMCR to represent, both on the website and in the re-formatted list that has been provided, “
the information requested”.
The request clearly asked for “
geographic alternatives” not for the numbers used for some different purpose in the same office. The importance of the relationship of equivalence between the two was made very clear.
If the geo number is only for a specific service, i.e. access for overseas callers, then it is not truly an “alternative”. If the situation remains as previously understood then this information is not what is requested and the response
may need to be challenged (see below).
I am not a lawyer, so my beliefs cannot be taken as having any authority, however I would understand that a response to a FOI request does not place HMRC under any direct and legally enforceable obligation to ensure that the information provided is made to be accurate. One cannot demand that the tail wags the dog. FOI requests are only about information that is held, not about how a public body behaves. Indeed, a major purpose of FOI requests is to drag out information that is held so as to show it to be false.
If I am correct, then as things stand, any caller using one of these so called “alternatives” from the UK who is asked to call again on the 0845 number cannot cite the FOI response as providing authority for anything more than them having made an innocent mistake.
That is not however to say that this great achievement is meaningless - far from it. FOI requests can help in raising issues that lead to changes of policy. The dog can, as it were, be led by the tail.
The information has been provided without any qualification about the use for overseas callers (other than the reference to it also existing on the web site). Given this, I see every good reason to encourage callers to use the alternatives (except where the 0845 number would be cheaper or the same cost). It is likely that the media may be interested to run this story.
This could provide help with efforts to press HMRC to consider and adopt relevant policy changes, such as those listed below:
1. Withdraw the privilege of a dedicated line offered to overseas callers, given that this truly exists, by offering the alternative to all. (This simple measure could be implemented on a temporary basis, perhaps forced by wide publication of a misleading response to a FOI request, pending more radical changes.)
2. Provide and publish genuine alternatives to the non-geographic numbers. (This would be a natural continuation of the process of the FOI request. It is however likely to be somewhat fraught.)
3. Replace ALL 0845 numbers with 0345 (or 0300), assuming that there is some genuine benefit in use of non-geographic numbers. Perhaps offer 0845, and other, alternatives for those who may benefit from lower rates from some telephone companies, if such promotion of particular telephone companies is considered proper or necessary. Provide alternative numbers and services for overseas callers, confident in the knowledge that these would not need to be abused. (I see this as the only solution to be applied across HMRC and all other public sector bodies. This may have to wait until more general reviews of telephone access that are currently underway have been completed.)
I would be happy to extend my own engagement with officials and media on these matters, with reference to this specific issue, if invited to do so (please email or PM me if this could be helpful).