Response: The Counter Disinformation Data Project
Published 28 June 2024
© Crown copyright 2024
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| Reference number | FOI2024-18509 |
|---|---|
| Date of request | 25 August 2023 |
| Date of response | 25 September 2024 |
| Outcome | Information partially withheld |
Request for information
The Department for Science, Innovation and Technology (the department) received the following request for information which we responded to under the Freedom of Information Act 2000 (FOIA):
A copy of any documents outlining the scope of the Counter Disinformation Data Platform, the brief for its establishment and building, and any external contracts related to it.
Our response
We can confirm that the Department for Science, Innovation & Technology does hold some information within scope of your request:
| Document | Document name | Status |
|---|---|---|
| 1 | Shared Outcomes Fund | Partially disclosed |
| 2 | Discovery Report | Withheld |
| 3 | Product Operating Model | Withheld |
| 4 | Tender for an expert evaluator | Disclosed |
| 5 | Schedule setting out contract pricing details | Disclosed |
| 6 | Evaluation and Monitoring Contract between DCMS and Oliver Wyman | Partially disclosed |
| 7 | Contract Variation between DSIT and Faculty | Disclosed |
| 8 | Contract between DCMS and Faculty | Partially disclosed |
| 9 | Contract Variation between DCMS and Faculty | Partially disclosed |
| 10 | Contract Variation between DCMS and Faculty | Partially disclosed |
| 11 | Contract Variation between DCMS and Faculty | Disclosed |
| 12 | Contract between DCMS and NewsWhip Media Limited | Partially disclosed |
| 13 | Contract between DCMS and Faculty | Partially disclosed |
The documents in scope are subject to the exemptions detailed below.
Section 40
We are withholding selected parts of documents 1, 6, 8, 9, 10, 12, and 13 under section 40(2) as these documents contain personal data that may identify a third-party individual. Section 40(2) is engaged because of the condition at section 40(3A), which relates to the personal data of third parties. This exempts personal data from release if disclosure would contravene any of the data protection principles in Article 5(1) of the UK General Data Protection Regulation and section 34(1) of the Data Protection Act 2018. Release would breach the first data protection principle since it would be unlawful and unfair to disclose the information. As section 40 is an absolute exemption, the department is not required to carry out a public interest test.
Section 43
Where the documents contain commercially sensitive information, this information is exempt under section 43(2) of the Act. This exemption has been applied to document 13. Section 43 is a qualified exemption, and it has therefore been necessary to consider the public interest test.
Public interest test
In favour of releasing the information, we recognise the general interest in government transparency and that the public has an interest in the contractual relationships which government enters into and how public money is spent. This ensures that government is more accountable to the public, which in turn increases trust. Therefore, we have tried to provide as much detail as possible and limit the redactions where the information falls within this exemption.
In favour of withholding the information, we consider that there is a public interest in not disclosing some information where this could harm the government’s position in future procurement exercises. For example, disclosing commercially sensitive information could result in the loss of business confidence with our commercial stakeholders. Additionally, disclosing this information could harm the department’s negotiating position in future commercial activities and could prejudice its ability to access a wide range of providers within the market. Further, where the content describes commercially sensitive information, the content may be subject to intellectual property protection.
Having considered the merits of both arguments, we have concluded that the public interest is weighed in favour of not disclosing that confidential information.
Section 35
Where the documents contain information which relates to the formulation and development of government policy, that information has been redacted under section 35(1)(a) of the Act. This exemption has been applied to document 1. As section 35 is a qualified exemption, again we have applied the public interest test.
Public interest test
In favour of releasing the information we recognise there is a general interest in government transparency, and that the information contained in these documents would provide an insight into the department’s operational processes and approach to tackling mis and disinformation. We recognise that greater transparency makes the government more accountable to the public and increases trust in it. We have made endeavours to provide as much detail as possible and limit redactions on this basis, extensively reviewing each document to provide as much context as possible.
However, in favour of withholding the information there is strong public interest in ensuring officials are able to consider and discuss policy options fully and frankly. Officials are required to think through all the implications of different options and to undertake rigorous and candid assessments of the risks to particular programmes and projects, and the space in which such discussions take place requires some protection. If this information were made public, we believe the nature of such consideration on key issues would be inhibited and the department would be prevented from taking decisions based on the fullest understanding of the issues involved. This must also be considered in terms of future discussions, which take place between the department and third parties, for example with external experts or stakeholders, who may become reluctant to provide advice due to the likelihood of this advice being disclosed.
Having considered these arguments, we have concluded that the arguments in favour of withholding the information outweigh those in favour of its release.
Section 23
Where the documents contain information which relates to bodies which deal with security matters, section 23(1) has been applied to that information. This exemption is an absolute exemption and therefore the public interest test does not apply.
The department neither confirms nor denies that it holds any additional information falling within the description specified in your request. The duty in Section 1(1)(a) of the Act does not apply, by virtue of section 23(5) – Security Bodies. Section 23(5) is also an absolute exemption and therefore does not require a public interest test. Section 24 The Department neither confirms nor denies that it holds any additional information falling within the description specified in your request. The duty in Section 1(1)(a) of the Act does not apply, by virtue of section 24(2). The exemption in section 24(2) is a qualified exemption and we have considered the public interest arguments in confirming or denying whether the department holds the requested information.
We acknowledge that confirming or denying that information is held would provide reassurance that the department is transparent, which in turn increases public trust in government. However, confirming or denying may itself disclose sensitive information which would be of use to malign actors and hostile states and could compromise measures to protect the UK. This could cause a national security incident or significant harm to the UK, its citizens or its institutions.
We have determined that in all the circumstances of the case, the public interest in maintaining the exclusion of the duty to confirm or deny outweighs the public interest in confirming whether the information is held. This should not be taken as an indication that the information you requested is or is not held by the department.
Section 36
Some of the information within the documents has also been redacted under section 36(2)(c) because its release would be prejudicial to the effective conduct of public affairs. The information outlines the capabilities of the Counter Disinformation Data Project (CDDP), key operational details of how the CDDP works and its potential vulnerabilities. It also provides sensitive details of how the CDDP fits into the government’s overall response to harmful mis and disinformation which is targeted at the UK’s institutions and population.
This exemption has been applied to every document except document 5. We have sought the opinion of the qualified person as required by section 36, who has concluded that the exemption is engaged in these circumstances. As section 36 is a qualified exemption, we have then considered the public interest test and whether it would be in the public interest to release the information.
Public interest test
In favour of releasing the information we recognise there is a general interest in government transparency, and that the information contained in these documents would provide an insight into the department’s operational processes and approach to tackling mis and disinformation. We recognise that this greater transparency makes the government more accountable to the public and increases trust.
In relation to the arguments in favour of withholding the information, the release of this information would provide critical detail concerning the extent of the CDDP’s capabilities, along with key operational details, which could be used by hostile actors to refine and hone the techniques used to target UK audiences with mis and disinformation. This in turn would be likely to prejudice the effective conduct of public affairs.
Having considered both arguments, we have reached the conclusion that the arguments in favour of withholding the information outweigh those in favour of its release.
Where possible we have attempted to provide as much detail as is reasonable and limit the amount of information which has been redacted using this exemption. However, due to the sensitivity of the information contained, Documents 2 and 3 have been redacted in full because the majority of the information within those documents falls within the exemptions contained in sections 24 and 36(2)(c) of the Act and it would not be in the public interest to release that information on the grounds set out above. The removal of this information renders the remainder of the documents illegible, and it is therefore appropriate to withhold these documents in their entirety.