Information on Social media management

Freedom of information request reference no: 01.FOI.24.039108

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. What is your annual spend on a Social media management tool?
4. What dates does your contract with your current supplier end ( month & year) ?
5. Do you use a social listening / media monitoring platform?
6. If so, what tools do you use?
7. What is your annual spend on a social listening / media monitoring tool?
8. What dates does your contract with your current supplier end ( month & year)
9. Who is the senior person responsible for managing these contracts?

Decision

I have today decided to disclose some of the requested information. 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 40(2)&(3) - Personal Information

Reason for decision

Section 40(2)(a)(b) of the Act provides that any information to which a request for information relates, is exempt information if the first condition of Section 40(3A)(a) is satisfied. The first condition of Section 40(3A)(a) states that personal information is exempt if its disclosure would contravene any of the data protection principles. If the disclosure of the requested personal data would not contravene the data protection principles, the disclosure must also not contravene Sections 3A(b) and 3B of the Act.

There are six principles that are set out in Article 5(1)(a) of the General Data Protection Regulations (GDPR) that dictate when the processing of personal data is lawful. The first principle requires that any processing of personal data must be lawful, fair and transparent. Under Article 6(1)(f) of the GDPR, the disclosure of personal data is considered to be lawful if:

a. There is a legitimate interest in the disclosure of that personal data.
b. The disclosure of the personal data is necessary to meet that legitimate interest.
c. The disclosure would not cause unwarranted harm to the data subject.

Having considered the release of information relating to MPS staff I have found, having considered the legitimate interest test, that:

a. The disclosure of this information would not satisfy an identifiable legitimate interest.

b. As there is no legitimate interest identified at point a I do not find there is a need for disclosure.

c. Publication of the name of this staff member would be likely to lead to unwanted and unsolicited intrusion as they all do not have public facing roles nor are they of a grade that warrants their personal information to be released. In this regard, I believe that disclosure of this personal data would be likely to cause unwarranted harm.

The provision to refuse access to information under Section 40(2)(a)(b) and (3A)(a) of the Act is both absolute and class based. When this exemption is claimed, it is accepted that harm would result from disclosure. There is accordingly no requirement to demonstrate what that harm may be in refusing access to information.

Disclosure

Q1 - Do you use a social media management platform?

Yes.

Q2 - If so, what tools do you use?

Sprinklr.

Q3 - What is your annual spend on a Social media management tool?

£50k

Q4 - What dates does your contract with your current supplier end (month & year)?

July 2026.

Q5 - Do you use a social listening / media monitoring platform?

Yes we use a media monitoring platform.

Q6 - If so, what tools do you use?

The MPS uses Cision.

Q7 - What is your annual spend on a social listening / media monitoring tool?
Q8 - What dates does your contract with your current supplier end ( month & year)

The MPS does not hold information in relation to questions 7 and 8. This is because the MPS are not the contract holder for Cision - we are a user of a service procured by TFL on behalf the GLA group.

Q9 - Who is the senior person responsible for managing these contracts?

Having located and considered the relevant information, I am not required by statute to release the information requested. The exemption I have applied is s.40(2) of the Freedom of Information Act, governing Personal Information.