Summary of the letter
Date: 16 November 2017
To: Mr Dave Skelton, UK Public Policy, Google
Email address: firstname.lastname@example.org
From: Louise Edwards, Head of Regulation
Format: Sent by email
Dear Mr Skelton
Political campaign finance transparency
I write further to our email exchange proposing a meeting with Google to discuss the important issues arising from digital political campaigning.
The Electoral Commission is responsible for regulating and enforcing the rules - set out in the Political Parties, Elections and Referendums Act 2000 (PPERA) - that govern political campaign finance in the UK. These rules cover the funding of and spending on campaign activity, and include provisions and offences about acting as an agent for donations, and arrangements to evade the rules on donations.
You will be aware of concerns that individuals or organisations from outside the UK, and notably from or on behalf of Russia, may have been campaigning via social media platforms in the June 2016 referendum on the UK’s membership of the EU. Further, concerns have been raised that the individuals and funds behind such campaigning, if it occurred, were hidden from those viewing the campaign material.
EU referendum campaign activity
Campaign activity in the context of the EU Referendum included activities that were intended to, or were otherwise in connection with, promoting or bringing about a particular outcome in the referendum. This included campaign broadcasts, advertising of any kind, unsolicited material sent to voters and market research or other methods of finding out how people intended to vote. Further clarification on what constituted campaign activity was given in our guidance on referendum spending.
The referendum was preceded by a regulated period, which ran from 15 April to 23June 2016. During this period the rules stated campaign activities carried out by referendum campaigners – any individual or entity engaged in campaign activity, whether registered with the Commission or not – could only be financed from permissible donations. This excluded individuals not on the UK or Gibraltar electoral roll and companies not carrying out a business in the UK or Gibraltar.
Request for information
The Commission’s legal duties include taking all reasonable steps to secure compliance with the campaign finance rules (see section 145 of PPERA). In furtherance of this duty, please provide us with the following information:
Any evidence you hold of campaign activity conducted via Google during the regulated period for the June 2016 EU Referendum (15 April to 23 June 2016) that was funded from Russia.
Please provide any such evidence to us by 8 December 2017. In anticipation of this, thank you for your prompt assistance on this important matter.
June 2017 UK parliamentary general election
Our work in respect of the June general election is ongoing. We may, as part of our assurance work in respect of the election spending returns, wish to contact you at a later date regarding campaign activity on your platform during the general election
Please contact me if you have any questions regarding this request.