Social Media Management and Listening
Freedom of information request reference no: 01.FOI.23.032611
I note you seek access to the following information:
1) Do you use a social media management platform?
2) If so, what tools do you use?
3) How much do you spend annually on a Social media management tool?
4) Which month & year does your contract with your supplier end?
5)Do you use a social listening / media monitoring platform?
6) If so, what tools do you use?
7) How much do you spend annually on a social listening / media monitoring tool?
8) Which month & year does your contract with your supplier end?
9) Who is the senior officer in charge of these contracts?
Decision
I will disclose some of the requested information in two separate responses. Firstly, from a MetCC perspective and secondly, from a Communication and Engagement department perspective. These answers will be detailed under the section titled Disclosure. However, I will not disclose the answers to Q3, Q6 and Q7 in relation to the Communication and Engagement department, and I will not disclose the answer to Q3 in relation to MetCC.
Some data has been withheld as it is exempt from disclosure and therefore this response serves as a Refusal Notice under Section 17 of the Freedom of Information Act 2000 (the Act) by virtue of the following exemptions:
Section 24(1) – National Security
Section 31(1) - Law Enforcement
Section 43(2) - Commercial Interests
Reason for decision
Section 24(1) – National Security & Section 31(1) - Law Enforcement - Any disclosure under FOI is a release to the public at large. Whilst not questioning the motivation behind this specific request, disclosing details of the provider of social media monitoring tools used by the force would cause operational harm and affect the ability to fulfil the core function of law enforcement in the future. Providing details of such providers would allow members of the public to identify the resources and tactics used in the gathering of intelligence for operational law enforcement purposes. It would enable individuals and organisations that are intent on causing disruption to identify strengths and weaknesses at force level, and more so nationally, which could be exploited causing harm to members of the public. This would be to the detriment of providing an efficient policing service and a failure in providing a duty of care to all members of the public. Providing details about the particular software used by the MPS to gather information, including intelligence, from social media would allow those with malicious intent to target cyber-attacks on those producers, causing disruption or service denial to the MPS and thereby preventing intelligence acquisition and undermining law enforcement.
The threat from terrorism cannot be ignored. It is generally recognised that the international security landscape is increasingly complex and unpredictable. Since 2006, the UK Government has published the threat level based upon current intelligence, and that threat is currently judged as “SUBSTANTIAL”, meaning that an attack on the UK is likely. It is well established that police forces use tactics and technology to gain intelligence in order to counteract criminal behaviour, and it has been previously documented in the media that many terrorist incidents have been thwarted due to intelligence gained by these means.
Providing details of social media monitoring/intelligence gathering tools or platforms used by the MPS would limit operational capabilities as criminals/terrorists would gain a greater understanding of the MPS’s capabilities, enabling offenders to take steps to counter them. It may also suggest the limitations of MPS capabilities in this area, which may further encourage criminal/terrorist activity by exposing potential vulnerabilities.
This detrimental effect is increased if the request is made to several different law enforcement bodies. In addition to the local criminal fraternity now being better informed, those intent on disrupting policing functions throughout the UK will be able to ‘map’ where the use of certain products are and are not deployed. This can be useful information to those committing (or those intent on committing or planning) crime.
Any information identifying the focus of policing activity could be used to the advantage of terrorists or criminal organisations. Information that undermines the operational integrity of these activities will adversely affect public safety and have a negative impact on both National Security and Law Enforcement.
Providing the information would render policing and security measures less effective. This would lead to the compromise of ongoing or future operations to protect the security or infra-structure of the UK and increase the risk of harm to the public.
Providing details of the social media monitoring tools used would have the effect of compromising law enforcement tactics. It has been recorded that FOIA releases are monitored by criminals and terrorists and so to provide specific information concerning intelligence gathering tools would lead to law enforcement being undermined. The MPS is reliant upon all manner of tools and techniques and the public release of details about these tools would prejudice the ability of the MPS to perform the functions it exists to provide.
Disclosure of specific tools and software would compromise the forces’ ability to protect the public. Disclosing the MPS’ capabilities would provide persons intent on disrupting their work, with information that would assist them to do so. The safety of the public is of paramount importance to policing purposes, and any increase in crime would place the public at risk of harm
The security of the country is of paramount importance and the MPS will not divulge details of specific tools and software if to do so would place the safety of an individual at risk, undermine National Security or compromise law enforcement.
Whilst there is a public interest in the transparency of policing technologies and providing assurance that the MPS are appropriately and effectively managing the threat posed by various groups or individuals, there is a very strong public interest in safeguarding the integrity of MPS systems and all areas of operations carried out by police forces throughout the UK.
As much as there is public interest in knowing that policing activity is appropriate and balanced this will only be overridden in exceptional circumstances. The use of technology can be a sensitive issue that would reveal MPS tactics and therefore it is our opinion that for these issues the balancing test for providing information is not made out.
Section 43(2) – Commercial Interests - allows public authorities to withhold information if it is likely to or would prejudice the commercial interests of the public authority. A commercial interest relates to a public authorities ability to participate competitively in a commercial activity.
Negotiating position - There is a public interest in ensuring that companies are able to compete fairly. However, the data requested has been used as part of commercial competition and discussions, making this data commercially sensitive. To release this into the public domain would prejudice and thus damage the MPS’ bargaining and negotiating power with suppliers in relation to future competition for this contract. The ICO states that ‘revealing information such as a pricing mechanism can be detrimental to your negotiations on other contracts and procurements’. It is therefore relevant to consider that if an individual or organisation knows how much the MPS pay for an item or service they could use the winning suppliers bid and pricing to their advantage. You may ask how so?
In reality this could result in prospective suppliers using this figure as a benchmark, which could then be used to compare their proposed bid to. In addition to this, if the exact cost of a service is made public that company may then be expected to provide the same product/s at similar costs to other companies. Ultimately, the release of the requested data could harm relationships with existing suppliers. The National Police Chiefs Council argues that ‘companies compete by offering something different from their rivals. The difference will often be reflected in their price and may also relate to the quality or specification of the product or service they offer’. The release of the requested data would indeed have a negative impact on the competitive nature of the tendering process by supplying the specific cost of the service offered, and thus provide an unfair advantage to one company over another.
Evaluation - It is worth noting that information that is made available under the Freedom of Information Act 2000 is published by the MPS via the publication scheme, making it readily available to the public, and not just the individual making the request. This is significant, as even if there is a public interest that would be satisfied by the release of the requested data this must be balanced against any identified risk. I have identified that the release of the requested data would illuminate two areas, firstly it provides a better understanding of the decision making process and secondly, it provides a better understanding of how public funds are spent. These are two important factors favouring disclosure.
Conversely, I have found that the release of the requested data would damage the MPS’ negotiating power with suppliers in future. One of the strong public interest arguments against disclosure is to ensure a competitive process with no commercial bias. Ultimately, the MPS would not want to provide data that would have a negative impact upon the MPS’s ability to achieve best value in future procurement processes in this area. I find this to be the significant factor in refusing to disclose this part of your request.
Disclosure
Communication and Engagement department perspective
Q1 - Do you use a social media management platform?
Yes
Q2 - If so, what tools do you use?
Brandwatch
Q3 - How much do you spend annually on a Social media management tool?
The annual spend has been withheld by virtue of Section 43(2) – Commercial Interest.
Q4 - Which month & year does your contract with your supplier end?
July 2024
Q5 - Do you use a social listening / media monitoring platform?
Yes
Q6 - If so, what tools do you use?
The data has been withheld by virtue of Section 24(1) – National Security & Section 31(1) - Law Enforcement.
Q7 - How much do you spend annually on a social listening / media monitoring tool?
The annual spend has been withheld by virtue of Section 43(2) – Commercial Interest.
Q8 - Which month & year does your contract with your supplier end?
July 2026
Q9 - Who is the senior officer in charge of these contracts?
Contracts: Director of Commercial Services. Senior Responsible Officer for the service: Deputy Director for Communications & Engagement.
MetCC perspective
Q1 - Do you use a social media management platform?
Yes
Q2 - If so, what tools do you use?
Sprinklr.
Q3 - How much do you spend annually on a Social media management tool?
The annual spend has been withheld by virtue of Section 43(2) – Commercial Interest.
Q4 - Which month & year does your contract with your supplier end?
July 2025
Q5 - Do you use a social listening / media monitoring platform?
NO
Q6 - If so, what tools do you use?
N/A due to the answer given in question 5
Q7 - How much do you spend annually on a social listening / media monitoring tool?
N/A due to the answer given in question 5
Q8 - Which month & year does your contract with your supplier end?
N/A due to the answer given in question 5
Q9 - Who is the senior officer in charge
Contracts: Director of Commercial Services. Senior Responsible Officer for the service: OCU Commander for MO12 Met Command & Control.