Media campaign fronted by Janey Godley: FOI release

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

Information requested

With reference to the recent media campaign fronted by Janey Godley (JG), I am seeking the following information:
(1) Who initially proposed JG to front the campaign?
(2) All internal communications proposing and discussing the proposal for JG to front the campaign.
(3) All communications with the creative services agency related to JG fronting the campaign.
(4) What communication channels were used to communicate with the creative services agency with regard to the campaign (e.g. unrecorded telephone calls, email, recorded telephone calls, etc.) ?
(5) All documents signed by JG or JG's representative regarding this campaign.
(6) The review undertaken by the creative services agency of JG's social media activity - including any summary or conclusion of findings.
(7) All internal communications discussing or evaluating JG's social media activity or JG's direct style and use of profanities.


1. In response to a Ministerial Cabinet request to produce a bold new advert to increase levels of compliance, the Scottish Government Marketing Department proposed Ms Godley alongside other celebrities for consideration.
2. Internal communications proposing and discussing the proposal for Ms Godley to front the campaign are included within this response.
3. Communications with the creative services agency relating to Ms Godley fronting the campaign are included within this response.
4. The communication channels used to communicate with the creative services agency were email, Teams calls and unrecorded telephone calls.
5. Regarding your request for all documents signed by JG or JG's representative, there is no contract between the Scottish government and Ms Godley. All matters relating to casting are managed throughthe appointed creative services agency, therefore the Scottish government does not hold documents  signed by Ms Godley or her representative.
6. No summary document was produced as communication between the Scottish Government and the creative services agency was handled by telephone. The review carried out by the Scottish Government’s appointed creative services agency did not identify the historic racist content which was later brought to the Scottish Government's attention. At which time all content featuring Ms Godley was removed.
7. Attached to this response are all communications held by the Scottish Government in relation to using Ms Godley.

With reference to points 2, 3 and 7 above, whilst our aim is to provide information whenever possible, in this instance we are unable to provide some of the information you have requested because of 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.

 About FOI

The Scottish Government is committed to publishing all information released in response to Freedom of Information requests. View all FOI responses at

FOI - 202100248293 - Information released 1
FOI - 202100248293 - Information released 2


Please quote the FOI reference
Central Enquiry Unit
Phone: 0300 244 4000

The Scottish Government
St Andrews House
Regent Road

Back to top