Local authorities are required by UK law to obtain public consent for certain projects. Many employ a company called Commonplace to assist them in carrying out their consultations. Commonplace provides local authorities with websites on which they give information about their proposals. The websites also record people’s responses. But the company can do much more than this. According to its CEO Mike Saunders, by making the existence of a consultation known to those who will benefit from a proposal, the company is able to overwhelm opposition to whatever’s being proposed. (1)

This is done by targeting social media ads at groups who will support the local authority’s proposal. (2) (3) (4) Sometimes the ads are placed by Commonplace, sometimes they’re placed by the local authority, and sometimes no ads are placed. When ads are placed, who places them depends on the type of contract that was signed (there are three types). (5)

At the end of each consultation, people are asked by Commonplace if they want to know about other “Commonplaces” in their “area.” (6) People who say “Yes” have their email addresses added to a database of at least 200,000 people nationwide, known by Commonplace as its “Community Panel.” (7)

In Leeds, the council’s definition of “area” applies to a large part of the city. So when a Commonplace was launched at the end of January 2023, the council issued 19,000 emails to people across Leeds asking them to “Have Your Say,” even though its proposal affected only a relatively small section of road. (8) The council didn’t even ask for the postcodes of respondents. (9) It didn’t seem to care that the responses were from local people. And people hadn’t signed up to “Have Your Say.” They’d just signed up for information.

Asking people what they think, who will be unaffected by a scheme is, according to Commonplace, more likely to produce a positive response than asking people who will be affected. (10) It was probably by using a combination of the Community Panel and targeted social media ads, that helped Leeds City Council achieve a 63.3% positive response in its January 2023 consultation. (11)

Local authorities get access to the Community Panel when they sign a contract with Commonplace. Because the email addresses “belong” to Commonplace, the only way that local authorities can retain access to them, is by repeatedly renewing their contracts with Commonplace. (12) (13)

Commonplace states that its consultations get a 65% positive response “where previously there was vocal opposition.” (14) The company says much the same thing in numerous of its web pages. (15) (16) (17) (18) (19)

Local authorities which use Commonplace, and Commonplace itself, have committed several breaches of the Data Protection Act 2018. So far, nothing has been done about this.

References

(1) Extract from a speech given by Commonplace CEO Mike Saunders.
(2) A Commonplace webpage on targeted social media ads.
(3) Another Commonplace webpage on targeted social media ads.
(4) A further Commonplace webpage on targeted social media ads.
(5) Commonplace Contract Types
(6) Commonplace Preferences
(7) Commonplace’s Community Panel
(8) A660 Consultation Report Analysis
(9) Leeds City Council A660 Online Consultation January 2023
(10) Low Traffic Neighbourhoods Report
(11) LCC Deputation response 2 May 2023
(12) Commonplace Technical Overview
(13) Gary Bartlett’s email dated 28 April 2023
(14) Commonplace Statement to Parliament
(15) A Commonplace webpage stating it gets a 66% positive response rate
(16) A Commonplace webpage stating it gets a 66% positive response rate.
(17) A Commonplace webpage stating it gets a 65% positive response rate.
(18) A Commonplace webpage stating it gets a 70% positive response rate.
(19) A Commonplace web page stating it gets a 72% positive response rate.