13th July 2015
In my e-mail I asked six questions about Defra's voluntary agreement with the junk mail industry and the Door Drop Preference Service. The questions are reasonable enough. Is it not fair, for instance, to ask why Defra and the Direct Marketing Association don't take minutes at meetings? Or, is it not a concern that the data on which policy is made is unverifiable and comes from a biases source? And shouldn't the British public be entitled to ask what on Earth the Environment Secretary was talking about when she told every media outlet in the country that the Government was
throwing down the gauntlet on companies that don't respect 'No Junk Mail' signs?
From: Stop Junk Mail
To: Clive Lewis MP
Subject: Questions for Defra
Date: Mon, 13 Jul 2015 20:01:59 +0100
Dear Mr Lewis,
I run a junk mail advice service / anti-junk mail campaign (stopjunkmail.org.uk) and have recently been in contact with Defra about an opt-out scheme for unsolicited, unaddressed mail. Unfortunately, I'm finding that the department is extremely reluctant to talk with me. As I feel the issue is in the public interest I'd like to ask you to help me establish a line of communication with the department.
The opt-out scheme is the so-called 'Door-Drop Preference Service'. The scheme is part of a 'voluntary producer responsibility deal' between Defra and the junk mail industry and was first announced in November 2011. The opt-out service was supposed to be up and running by April 2012 - but it has never been launched. In July 2012 I found that the reason for the delay was that Defra and the Direct Marketing Association disagreed about what they had agreed – an issue that was at the time covered by BBC News.
I've since submitted a number of freedom of information requests aimed at finding out how the impasse was being resolved. My requests for information to Defra are routinely rejected but on 20th March this year Defra did sent me a statement in response to a request I had submitted in November 2014. In the statement Defra confirmed that the opt-out scheme would not go ahead because of concerns raised by the junk mail industry. The scheme's failure has subsequently been reported by, among others, The Times, Daily Mail and You and Yours (BBC Radio 4).
Interestingly, both the Direct Marketing Association and the Royal Mail have since repeatedly told journalists that they are unaware that the opt-out scheme has been abandoned and that Defra has confirmed to them that the scheme is still very much alive. To clarify the situation I contacted Defra on 2nd July. At around the same time a journalist from Marketing Week and the producer of You and Yours also contacted Defra. The latter two received a general statement that talked about how committed Defra is to helping householders reduce unwanted junk mail – but not an answer to the question they had asked (they also refused to discuss the issue with me on You and Yours). As I'm merely a member of the public I didn't get the honour of receiving a response.
Although I appreciate that it's a little embarrassing for Defra to talk about its failure to deliver the opt-out scheme I feel it's important for a government department to be open and transparent when things go wrong. This scheme was part of the government's ambition to work towards a zero waste, low carbon economy – there's a clear public interest in establishing the facts. Unfortunately, Defra's reluctance to talk with me seems to grow by the day. On 11th June 2015 I asked for a review of a freedom of information request I had submitted on 2nd April 2015. I've since twice asked Defra's head of information standards, Mike Kaye, to acknowledge receipt of my e-mail (on 18th and 26th June). To date, he has refused to do so. Defra's helpline, which I copied in to my last e-mail, has also failed to respond.
Having followed this story for years there are a number of questions I would like to ask Defra. I've got no hope of receiving a response to questions that might be seen as 'critical' and hope you'll be willing to forward this letter to Defra – it might just encourage them not to ignore a member of the public (and tax payer) yet again.
My questions are the following:
- In early 2011 I had a meeting with Simon Dawes, who at the time talked with the junk mail industry on behalf of Defra. Mr Dawes was interested in two suggestions I made. The first was to start taking minutes at meetings. It may sound bizarre but whenever Defra meets with the junk mail industry no minutes are taken. I believe the idea behind this is that it makes it difficult for journalists and members of the public to find out what has been discussed and I'd like to ask Defra if it agrees that a) not taking minutes at meetings creates an air of secrecy that flies in the face of open and transparent government; and b) having minutes might have made it easier resolve the disagreement that became apparent on 3rd May 2012.
- The second suggestion Mr Dawes was interested in was replacing the two existing opt-out schemes for unaddressed mail with a sticker scheme. At the time I did some work on this for Mr Dawes – I got him an English translation of the Dutch junk mail industry's code of practice, which talks extensively about how the Dutch sticker scheme works, and gave him the contact details of various Dutch organisations involved in making sure that the scheme in the Netherlands is the remarkable success it is. I'm aware a stickers scheme was discussed with the junk mail industry in 2011 but – of course – there's no record of why Defra and the industry preferred the Door-Drop Preference Service. Now that the opt-out scheme has been scrapped I'd like to ask Defra if it's willing to have an informed and open discussion about the pros and cons of a sticker scheme.
- On the subject of sticker schemes, Defra's press release announcing the opt-out scheme quoted the environment secretary as saying: “This also throws down the gauntlet to those companies hand-delivering brochures and fast-food menus to respect ‘no junk mail’ signs and only deliver what people want.” Does this statement imply that Defra had agreed to ensure that all unaddressed advertising mail would be covered by the scheme, rather than just items distributed by the Royal Mail and members of the Direct Marketing Association?
- And on the subject of press releases, on 20th March I asked Defra why it had not issued a press release / media statement when it decided not to take forward the work it was doing on implementing the opt-out scheme. When the scheme was first announced Defra contacted every media outlet in the country and got an enormous amount of positive publicity. Given that the scheme was so important to the department I genuinely don't understand why it never told the media that the scheme wouldn't go ahead after all. As I didn't receive a response to my question I'd like to ask it again.
- It's my understanding that the responsibility deal is underpinned by statistics about junk mail volumes, waste caused by junk mail and the contribution of junk mail to the UK economy. It's also my understanding that all these statistics come from the junk mail industry. I'd like to ask if Defra has any concerns about how scientifically sounds these statistics are. My concern is that the industry's research is paid for by the industry and that they've got a clear interest in its findings. This makes it conceivable that the research is biased and it's therefore important that the data can be scrutinised and verified - yet the industry never publishes the raw data of its research. Does Defra have access to the raw data and does the department properly scrutinise the validity of the industry's research?
- And finally, I'd like to ask why no consumer representative is part of the responsibility deal. The (ongoing) agreement is supposed to benefit consumers and it seems to me that it would be appropriate to make sure that consumers – the recipients of junk mail – are properly represented. Would Defra consider inviting an organisation such as Which? to be part of the discussions?
Thank you for attention to this matter. I hope you'll be able to help and look forward to hearing from you.