NHS Scotland Covid-19 advertisement campaign: FOI release

Information request and response under the Freedom of Information (Scotland) Act 2002

Information requested

Minutes of meetings and discussions, and relevant emails, which concern the process for procuring the services of Ms Godley. Specifically, please provide documentation, or appropriate commentary, to cover:

1. How Ms Godley was selected - what process was used, and over what timeframe.

2. Whether other options, e.g. other comedians, were considered, and why they were discounted.

3. What the approval process was, and who approved the decision to procure Ms Godley's services. (Name and appointment, if a politician or political appointee, or just appointment if a civil servant).

4. How it was determined whether Ms Godley's fee represented value for money.

5. Whether Ms Godley was contracted as a private individual, or through a service company, agency or other company.


Please find attached documentation relating to the development of the campaign featuring Ms Godley.

While our aim is to provide information whenever possible, in this instance we are unable to provide some of the information you have requested because an exemption under section S.30(b)(ii) – formulation or development of government policy of FOISA applies to that information. The reasons why that exemption applies are explained below.

Reasons for not providing information

An exemption under section 30(b)(ii) of FOISA (free and frank exchange of views) applies to some of the information requested.

This exemption applies because disclosure would, or would be likely to, inhibit substantially the free and frank exchange of views for the purposes of deliberation. This exemption recognises the need for officials to have a private space within which to discuss issues and options before the Scottish Government reaches a settled public view. Disclosing the content of these discussions will substantially inhibit such discussions in the future, because there will be a reluctance to provide views fully and frankly if those views are likely to be made public, particularly while these discussions are still ongoing and decisions have not been taken.

This exemption is subject to the ‘public interest test’. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exemption. We have found that, on balance, the public interest lies in favour of upholding the exemption. We recognise that there is a public interest in disclosing information as part of open, transparent and accountable government, and to inform public debate. However, there is a greater public interest in allowing Ministers and officials a private space within which to communicate. Premature disclosure is likely to undermine the full and frank discussion of issues, which in turn will undermine the quality of the decision making process, which would not be in the public interest.

On the specific points raised:

1. This campaign was developed over a period of seven days as a result of the increase in COVID-19 cases and increasing levels of hospitalisation. Qualitative research highlighted that a different approach was needed to advertising activity to that which had been used to date in order to reach the most resistant audiences and influence their behaviour. Ms Godley was included as she is a well-known celebrity who has posted her own social media content relating to the pandemic. Ms Godley was available to take part in the campaign within the timescales available. All direct discussions with Ms Godley or her agent were undertaken by the appointed creative services agency or their appointed production company.

2. Other celebrities were considered alongside Ms Godley but were unavailable within the timescale required to be part of the first phase of campaign activity.

3. All Scottish Government marketing campaigns are submitted to the relevant Ministers at various stages during the campaign development process. This campaign was submitted for approval to the First Minister, Deputy First Minister and Cabinet Secretary for COVID Recovery, and the Cabinet Secretary for Health and Social Care.

4. The payment is in-line with the industry standard for such a high-profile campaign.

5. This is not information held by the Scottish Government as there is no contract between the Scottish Government and Ms Godley. All matters relating to casting are managed through the Scottish Government’s appointed creative services agency and their appointed production company.

About FOI

The Scottish Government is committed to publishing all information released in response to Freedom of Information requests. View all FOI responses at http://www.gov.scot/foi-responses.

FOI - 202100238627 - Information Released - Annex A
FOI - 202100238627 - Information Released - Annex B


Please quote the FOI reference
Central Enquiry Unit
Email: ceu@gov.scot
Phone: 0300 244 4000

The Scottish Government
St Andrews House
Regent Road

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