Your Ref:
Our Ref: FOI/367550 APPEAL /
Mr Michael Stanford
Email: / 5 June 2015
Dear Mr Stanford
Freedom of Information Request 367550
I am writing in respect of your request for a review of the City Council’s response to your request for information, dated the 26 March 2015, which was handled under the Freedom of Information Act 2000. This matter has been assigned to me to investigate and review. The result of my review is contained within this letter.
The information you originally requested was as follows
- Can I have a copy of the Liverpool City Council's, and any council owned entities/subsidiaries, policies and procedures regarding marketing activities, especially any references to authorisation of payments for advertising across all media platforms.
- Who within the Liverpool City Council, and any council owned entities/subsidiaries has the power to authorise advertising and what oversight is there to such activity.
- Details of all advertising costs paid out by the council departments from all budgets, including all wholly or part owned entities/subsidiaries, over the last 12 months. Including all individual payments, to which organisations these payments have been made and for what reason.
- What due diligence is taken into confirming the circulation (not readership) of each of the publications, billboard audience, radio audience, online hits, subscribers, viewers etc. with regards to ensuring that any advertising will reach the required audience and that maximum benefit for the public money expended is undertaken prior to placing advertising. Please could you provide details of background research undertaken for each of the different companies/organisations that the council has placed advertising through for example ABC's, circulation statistics, unique monthly users, number of hits/likes/Subscribers etc.
We provided the following response and an accompanying spreadsheet –
- There is no single policy or procedure. The need to engage in marketing activities is a matter for individual teams across the council, reflecting their various needs to engage with residents, service users, customers or visitors.
- Please refer to point (1) response above.
- Please see the attached spreadsheet for the relevant information.
- Any external media used are assessed against their audience reach on a case-by-case basis. Where available, circulation/ traffic figures are assessed first in accordance with professional good practice.
For purposes of clarity, I will be conducting our internal review based onyour email to the City Council dated the26 March in which you stated –
- I find your response insufficient and severely lacking in detail. As you can read by my question I did not request a SINGLE policy or procedure document. I asked for any policies and procedures regarding marketing activity especially (but not exclusively to) those that reference advertising and procurement of such. Please could you send me copies of what each department (throughout LCC and the Mayors Office) has for policies and procedures and the guidelines they follow with regards to all marketing activity as I do not believe they just make it up as they go along. Also my question covered any and all council owned entities/subsidiaries, not just individual council departments/services, which I would have presumed you would have access to the information of, especially when the council is responsible for the oversight of such bodies.
Being the ultimate parent company/shareholder of numerous entities the council has responsibilities to provide the information of any publicly/council owned businesses so this query also includes but is not exclusive to the following –
SCHOOL IMPROVEMENT LIVERPOOL LIMITED registration number 08867114 (LCC 100% Ownership), ARENA AND CONVENTION CENTRE LIVERPOOL LIMITED registration number 05204033 (LCC 100% Ownership) including ACC LIVERPOOL HOTEL LIMITED registration number 08798224 (100% owned by ACC Liverpool)
LIVERPOOL VISION LIMITED registration number 06580889 (owned by LCC 100%) “Liverpool Vision is the arm’s length economic development company for the City of Liverpool; it is a wholly owned subsidiary of Liverpool City Council.” - Liverpool Vision Business Plan 2013
Should I provide you with a full list of companies that LCC is a shareholder of or are you able to access the information of all entities/subsidiaries of LCC? If unable to provide these details could you explain why as this should be information available to the public.
Further I cannot fathom that an entity as large as Liverpool City Council does not have any centralised policies, procedures or guidelines with regards to marketing and advertising procedure so I again request you check this and verify to me that these do not exist anywhere within Liverpool City Council or its subsidiary organisations, entities (and this does include any part owned entities). May I ask further who is responsible for setting such policies in the council and why this has not happened?
- Again I find your response insufficient and severely lacking in detail. I cannot believe that each department is left to pursue its own course as having worked with councils myself previously I know that authorisation has to be given by someone somewhere and I am requesting the details of who these people are within the council AND council owned subsidiaries and other entities. I understand that data protection would prevent you giving names most likely but one would presume that you could give the positions of those people who are authorised to sign-off advertising and in doing so are spending taxpayers money. Further you do not address my query with regards to oversight. One would presume that public expenditure especially in these times of austerity should be monitored closely so there should be some oversight of the decision makers. Could you please explain who is responsible for overseeing the people authorising marketing and advertising activity and that they are spending tax payers money wisely.
- I asked for the details of all advertising costs from all budgets, as I understand it each department/service has its own budget and subsequently the figures I should have received should have been separated accordingly. You have collated these figures without giving details of what departments funded them. This is even more important now that you have been lacking in your answers to my first two questions. Further you have used “Various Statutory Notices” when I asked for information on all individual payments, further information is required not least the number of notices. Also am I to believe this is all advertising (in all forms) from all Liverpool City Council departments/services, and any subsidiaries or entities of the council in the last twelve months? £136,419 seems pretty low in my estimations. Further some of the details you have provided are insufficient as I asked for information of the organisations so whereas Trinity Mirror one could presume it was advertising in the Liverpool Echo (although the information you have provided is not sufficient enough so does not confirm it) but when “SMRS” is quoted I do not find this information to be of any use whatsoever as to who this business is. “University Newspaper” which university newspaper publication/publisher? “IMP... FSD Advert” abbreviations give no information as to who or what the advertisement pertains to. Please could you provide a more detailed response.
- Again I find the response wholly insufficient in answering my question. You have negated in providing the information and details I have requested which I have highlighted for you above. One would presume that this information would be researched and collated (by those responsible in the different departments) with regards to the individual companies prior to placement of advertising and held on record (possibly in the departments) by the council so that due diligence can be proven to have taken place. So this information should be ready to hand if this research had indeed been carried out in the first place.
After liaising with the relevant departments I am now in a position to provide the following:
- While going on to respond to each of your points the City Council would like to make clear that it is not exceptional that there aren’t reams of policy documents setting out in infinite detail how and what the City Council does. While always adhering to the relevant governing legislation process can be managed via a process of precedent, common sense, and professional judgment, while anything new or exceptional is approached on a case-by-case basis.
Moving on, in terms of point 1, the City Council upholds its original response. The City Council does not undertake a lot of advertising and any that is undertaken is done so on a case by case basis in discussion with the relevant departments’ requirements. Additionally, we can confirm that the City Council is not responsible for the Echo Arena or Liverpool Vision et al so they may have their own protocols.
In response to point 2, again the City Council upholds its original response and can only reiterate what has been previously stated that this area of work is a matter for individual departments.
In response to point 3 – Please refer to the attached spreadsheet which provides all information held by the City Council relevant to this element of your request. The City Council provides this information in addition to what has previously been supplied and hopes this satisfies this element of your request. Consequently the city Council does not uphold our original response to this element of your request.
Finally, in response to point 4 – we assess on a case by case basis and obviously wouldn’t advertise in media we didn’t think were fit for purpose
This concludes my review and, as a result, the City Council acknowledges its original response could have been more detailed.
As I have now reviewed your original response, you have exhausted the Council’s appeals process for the purposes of this request.
Accordingly, should you remain dissatisfied, please contact the Information Commissioner’s Office, via the following:
Website is and the postal address and telephone numbers are:-
Information Commissioner’s Office, Wycliffe House, Water Lane
Wilmslow, Cheshire, SK9 5AF
Fax number 01625 524 510
Telephone 01625 545745
Email – (they advise that their email is not secure)
ÿÿYours sincerely
Michael Jones
Deputy Head of Democratic Services
Information Team Municipal Buildings Dale Street Liverpool L2 2DH
Telephone 0151 2330418 Fax 0151 225 2392