FOI16652 – Request for information
Thank you for your email of 7 March 2016 requesting the following information in accordance with the Freedom of Information Act 2000 (FOIA):
- In the last 12 months all projects given funding under the same marketing budget and the proposed and actual returns generated. I don’t need details of the actual marketing activities if that is confidential.
- All correspondence internally with regard to Streetwise Maps Ltd in the last six months including but not limited to correspondence about the allocation of budget for promoting VML.
In your email of 4 April, you clarified that:
- It is my understanding that the name of the business receiving funding would be anonymised so I would receive by each project what funding was received, what return was proposed and what was the actual return to OS.
- All correspondence relates to only correspondence related to the allocation of budget for promoting VML. An example of this would be emails between XXXXXXX XXXXX and those involved in allocating budget.
We confirm that we hold this information. Whilst we are able to release the information described below (attachment available on request), note that some of the information has been redacted as it falls under the “Personal information” exemption in section 40(2) of the FOIA; see below for details.
In addition, certain information has been redacted on the basis of section 43(2) (commercial interests), as its disclosure would be likely to prejudice the commercial interests of OS. Further details on these exemptions are provided below.
(Note that we have not included correspondence between OS and Streetwise Maps Ltd, as we assume that you will have seen this already).
- Table showing funding provided under the MDF scheme in the last 12 months, together with revenue forecast and, where available, revenue achieved. For those projects where funding has been provided, the table also shows total funding approved; where the funding provided is less than that approved, this will be because either certain elements of the proposed activities are no longer going ahead, or because certain activities have yet to commence.
- Email chain ending with email of 16/9/15 at 14:18.
- Email chain ending with email of 25/09/15 at 13:04 (note that we have redacted certain information on the basis of section 43(2) (in addition, the redacted information is not relevant to your request, and is potentially exempt under section 41) – see below for details).
- Email chain ending with email of 10/11/15 at 17:45.
- Email chain ending with email of 29/2/16 at 08:29.
- Email chain ending with email of 1/3/16 at 08:57.
- Email of 2/3/16 at 15:09 attaching note of meeting of MDF panel review (note that certain information has been redacted on the basis of section 43(2) (commercial interests) of the FOIA, as its disclosure would be likely to prejudice the commercial interests of OS – see below for details).
Note that in all of the emails and the meeting note released pursuant to this FOI request, we have redacted the names of specific individuals and their contact details, where we consider this information to be exempt under section 40(2) ‘Personal Information’.
Section 40(2)(a) and (b), together with the condition under section 40(3)(a)(i) and (b) of the FOIA, provides an absolute exemption, where the disclosure of information would contravene any of the data protection principles under the Data Protection Act (DPA) 1998. In this case, we have exempted information constituting the personal data of living individuals, the release of which would be in breach of the Data Protection Principles.
In applying this exemption, we have considered whether disclosure of the personal data in question would be 'fair' (as described in Schedule 1 of the Data Protection Act). We have given particular consideration to the likely expectations of the data subjects regarding the disclosure of their personal information, whether they are already publicly referenced through their position and if they would expect to be publicly referenced in this manner, in reaching our decision to withhold this information.
Where information has been redacted on the basis of section 43(2), this is because it is considered that disclosure would be likely to prejudice the commercial interests of OS. In relation to the ROI ratio, the ratio proposed in each MDF application is, as you would expect, one of the key factors considered in reaching decisions on such applications. OS considers that if OS’s target ROI for MDF applications were to be published, licensed partners making an MDF application might be incentivised to make a proposal that just meets the ROI ratio, rather than making the best proposal that they can.
This is a qualified exemption and we are required to consider the public interest.
OS is a wholly owned Government company; like other companies, it is required to generate revenue from its commercial activities in order to fund its operations (including, in OS’s case, its public task).
Whilst we recognise the requirement for transparency, this has to be balanced against the public interest in allowing OS to protect its commercial interests (so that it is not disadvantaged in comparison to organisations which are not subject to the FOIA) such that it can continue to fulfil its public task and deliver its obligation to HM Government to operate on a commercial, self-financing basis.
Having considered the above, we are satisfied that the public interest is best served by withholding the information under this exemption.
Under our duty to provide advice and assistance under section 16 of the FOIA, we would note that, in addition to the projects which received funding as set out in the attached table, applications for five other projects were rejected.
Your enquiry has been processed according to the Freedom of Information Act (FOIA) 2000. If you are unhappy with our response, you may request an internal review with our FOI Internal Review Officer, by contacting them as follows:
FOI Internal Review Officer
Customer Service Centre
Please include the reference number above. You may request an internal review where you believe Ordnance Survey has:
- Failed to respond to your request within the time limits (normally 20 working days)
- Failed to tell you whether or not we hold the information
- Failed to provide the information you have requested
- Failed to explain the reasons for refusing a request
- Failed to correctly apply an exemption or exception
The FOI Internal Review Officer will not have been involved in the original decision. They will conduct an independent internal review and will inform you of the outcome of the review normally within 20 working days, but exceptionally within 40 working days, in line with the Information Commissioner’s guidance.
The FOI Internal Review Officer will either: uphold the original decision, provide an additional explanation of the exemption/s applied or release further information, if it is considered appropriate to do so.
Appeal to Information Commissioner's Office (ICO)
If, following the outcome of the internal review you remain unhappy with our response, you may raise an appeal with the Information Commissioner’s Office at:
The Case Reception Unit
Customer Service Team
The Information Commissioner’s Office
Telephone helpline: 0303 123 1113 or 01625 545745 for advice, Monday to Friday.
Thank you for your enquiry.