Parliamentary Questions for the Minister for Communications and Information

Opportunity to Correct Inaccurate Information Before Issuing Correction Direction under POFMA

13 November 2024

Ms Hazel Poa asked the Minister for Digital Development and Information (a) why it is the established practice for the Government to approach mainstream media outlets to correct inaccurate information instead of issuing a correction direction under the Protection from Online Falsehood and Manipulation Act 2019 (POFMA); and (b) why does the Government not provide non-mainstream media outlets or other persons with the opportunity to correct inaccurate information before issuing a correction direction under POFMA.

Mrs Josephine Teo: The Protection from Online Falsehoods and Manipulation Act 2019 (POFMA) allows the Government to address online falsehoods expeditiously, by requiring the correct facts to be put up alongside the falsehood. This establishes an honest and factual basis for public discourse on issues of public interest.

Accredited media outlets have long established practices to publish editor’s notes or corrections if there are inaccuracies in their reports. Such processes allow the Government to work with accredited media to quickly clarify any factual errors in a timely manner. Non-accredited media outlets as well as individuals do not have such established processes for clarifications and corrections to be made.

Impact of Singtel’s Outage on Emergency Calls

11 November 2024

Ms Hazel Poa asked the Minister for Digital Development and Information (a) what is the estimated number of calls to 995 and 999 that have been impacted by the Singtel landline outage on 8 October 2024; and (b) what penalties, if any, have been imposed by IMDA on Singtel for this outage.

Ms Hazel Poa asked the Minister for Digital Development and Information (a) what is the outcome of the investigation into the disruption of calls to emergency services hotlines that occurred on 8 October 2024; and (b) what actions will be taken to prevent such disruptions from happening again.

The Senior Minister of State for Digital Development and Information (Dr Janil Puthucheary) (for the Minister for Digital Development and Information): Mr Speaker, Sir, may I have your permission to answer Question Nos 11 to 16 on today’s Order Paper, as well as written Question No 23 on today’s Order Paper filed by Ms See Jinli Jean together, as they relate to the same incident.

Mr Speaker: Please proceed.

Dr Janil Puthucheary: Sir, on 8 October 2024, Singtel’s fixed line voice service faced intermittent service disruption. This affected some residential and corporate users, including Government emergency phone lines such as the Singapore Civil Defence Force’s (SCDF’s) 995 and the Singapore Police Force’s (SPF’s) 999 lines, and customer service lines for some Government agencies, healthcare organisations and companies. The Ministry of Home Affairs (MHA) and Ministry of Health (MOH) will be responding to queries on the service impact on their respective sectors arising from the incident.

During the disruption, it is estimated that half of the calls could still be connected. All services were progressively restored over a four-hour time period from the start of the incident.

The Infocomm Media Development Authority (IMDA) takes a serious view of this incident and is investigating the cause of this disruption and whether Singtel’s incident response was adequate. Preliminary findings suggest that there was a technical issue which affected the proper functioning of a network component in one of the two systems supporting Singtel’s fixed line voice service. The two systems, located in separate telephone exchanges, are designed to immediately take over the full load of the other system when one system malfunctions. However, in this instance, the failover did not happen seamlessly, which caused the intermittent service disruption. There is no evidence to suggest that the incident was related to a sabotage or cyber-attack. IMDA is continuing its investigations.

The telecommunication network in Singapore is a key infrastructure that supports our nation’s connectivity needs and requirements. IMDA holds key service providers, like Singtel, to high service standards and requires them to conduct regular audits on their network and infrastructure. This includes ensuring the security of network design, redundancy measures and business continuity plans. Service providers must also ensure that their networks are resilient against disruptions.

IMDA will not hesitate to take strong action under the Telecommunication Act, including imposing financial penalties, should any lapses be identified. IMDA is working with MHA, SCDF and SPF to conduct a comprehensive review on the availability of our emergency hotlines when disruptions occurred.

Ms Hazel Poa (Non-Constituency Member): I have a supplementary question for Minister of State Sun. How many people use the alternative SMS numbers 70999 and 70995 to contact the emergency services? And are there any plans to raise awareness of these alternatives?

Ms Sun Xueling: I thank the Member for the question. I do not have the specific numbers that she requested for as the Parliamentary Question (PQ) was originally directed at the Ministry of Digital Development and Information. I will come back to her if the Member were to file a separate PQ on this.

But specifically, on her comment as to the publicity around the SMS numbers, the numbers are not new. The numbers have been around for some time. There have been marketing efforts. Every time when we go out and we tell members of the public in times of emergency you can call the hotlines, we also append the SMS numbers. But I think, arising from this incident, we will be even more enthusiastic about putting out the numbers when it comes to the SMS numbers.

Criteria for Issuing Correction Directions under POFMA

15 October 2024

Ms Hazel Poa asked the Minister for Digital Development and Information what criteria are used by the Government to determine whether or not to issue correction directions under Protection from Online Falsehoods and Manipulation Act when factual errors are published.

Mrs Josephine Teo: Ministers are empowered to issue Correction Directions under the Protection from Online Falsehoods and Manipulation Act 2019 (POFMA). Two conditions must be satisfied before a Correction Direction can be issued; first, a false statement of fact must be communicated in Singapore, and second, the Minister in question is of the opinion that it is in the public interest to issue the Correction Direction.

Whether a Correction Direction should be issued for a false statement of fact is a fact-specific assessment made by the Minister within whose domain the falsehood falls. The relevant Minister, supported by his or her staff with the requisite domain expertise, will carefully evaluate each case. This includes the nature of the falsehood, its context and the harm to the public, before deciding whether a Correction Direction should be issued.

Mobile Guardian App’s Hacking Incident

10 September 2024

Ms Hazel Poa asked the Minister for Digital Development and Information (a) whether the Cyber Security Agency (CSA) is assisting the Ministry in investigating the Mobile Guardian hacking incident in August 2024; (b) what is CSA’s role in assisting other agencies in investigating security vulnerabilities in IT systems owned, operated, or otherwise used by the Government; and (c) whether the task force set up to bolster Singapore’s tech resilience following the CrowdStrike outage will also be assessing the Mobile Guardian incident in August 2024.

Mrs Josephine Teo: The Cyber Security Agency (CSA) focuses on the higher risk systems that could affect our national security and delivery of essential services because of the widespread or systemic impact if disrupted. These are designated as Critical Information Infrastructure (CII) under the Cybersecurity Act and held to high standards of cybersecurity and resilience. CSA also requires CII owners to conduct regular audits and testing on their CIIs so that vulnerabilities can be quickly identified and remediated. If they encounter cyber-attacks, CSA’s incident response teams will support CII owners to investigate, contain and remediate the attack.

But not all Government information technology (IT) systems are designated as CIIs, nor should they be. Disruptions to non-CII IT systems cause varying degrees of impact. It is therefore only practical to take a risk-based approach in managing their cybersecurity and resilience. Their disruption may cause inconvenience and loss which should certainly be avoided. But the consequences are generally localised or do not pose widespread or systemic disruptions compared to disruption to a CII. The owners of these non-CII systems are in the best position to decide the resources to be put in to protect such systems against disruption, which should in general, be proportionate to their risks and impact. All systems must, however, maintain a baseline of cybersecurity and resilience measures that are appropriately stepped up according to their risk assessments. Defensive measures must also be complemented by business continuity plans that mitigate the impact of disruptions when they occur. Agencies that own IT systems are responsible for their cybersecurity and resilience. They can draw on the expertise of CSA and the Government Technology Agency (GovTech), if needed, to investigate vulnerabilities and compromises that have been discovered.

A device management solution such as that provided by Mobile Guardian is not a CII. While the Ministry of Education has overall responsibility for its cybersecurity and resilience, CSA and GovTech provided various types of support such as forensic investigations when incidents happened. The Minister of Education has already covered the details in his earlier reply.

My Ministry has set up a task force to draw lessons from the CrowdStrike incident as the incident had the potential to cause disruptions to a wider set of systems. This is part of the effort to strengthen the overall security and resilience of our digital infrastructure.

Censorship Review Committee

3 April 2024

Ms Hazel Poa asked the Minister for Communications and Information (a) why has the Censorship Review Committee (CRC) that is to be formed once every decade not been convened since 2009; (b) whether the Government intends to reconvene the CRC in view of rapid changes in Singapore’s media and social landscape; and (c) if so, when.

Mrs Josephine Teo: There is no set time frame to convene a content review committee. The Government takes into consideration Singapore’s prevailing media and social landscape in deciding when to convene content regulatory reviews and the appropriate format for such reviews. For example, in the lead up to the Online Safety (Miscellaneous Amendments) Bill of 2022, the Ministry of Communications and Information (MCI) conducted extensive engagements, including a public consultation with a wide range of stakeholders, to gather their feedback and suggestions on the proposed measures to enhance online safety.

More recently, to develop the Code of Practice for Online Safety which applies to designated Social Media Services (SMSes), the Infocomm Media Development Authority also consulted various stakeholders, including the designated SMSes, to gather feedback before finalising the Code.

On specific content, policies and standards, we also continue to consult a range of advisory committees. These varied approaches provide more flexibility in responding to shifts in the media landscape, community sentiments and societal norms.

SPH Media Trust

7 February 2023

Ms Hazel Poa asked the Minister for Communications and Information whether an external investigation on the fraud involving SPH Media Trust’s circulation figures will be conducted and the report made public.

Ms Hazel Poa asked the Minister for Communications and Information whether the Ministry will share with the public SPH Media Trust’s review of the overstated circulation data, including accounts provided by the executives involved in the case.

Ms Hazel Poa asked the Minister for Communications and Information whether the Ministry has been informed of the reasons for SPH Media Trust not breaking the news on the overstated circulation numbers of their own accord but through media queries.

Mrs Josephine Teo: These questions have been addressed in my reply to Question Nos 2 to 18 for oral answer on the Order Paper for 6 February 2023 and to subsequent clarifications sought by Members. [Please refer to “Government’s Response to SPH Media Trust’s Inflated Circulation Numbers”, Official Report, 6 February 2023, Vol 95, Issue 81, Oral Answers to Questions section.]

In essence, the findings of circulation discrepancy for the period of SPH Media Trust (SMT)’s internal review from September 2020 to March 2022 have not resulted in the loss of public funds. There is no change to the Government’s decision to provide funding to support SMT’s capability development. There is also no change to the amount of funding as it is targeted towards technology development, talent development and the strengthening of newsrooms, particularly vernacular newsrooms.

I had also explained that certain questions would be better addressed by SMT after its Audit and Risk Committee has completed its further investigations and shared its findings. If there is evidence of fraud or other wrongdoing, SMT is obliged to do the right and lawful thing to refer to a relevant agency for follow-up.

SMT’s approach to communications both within and outside the organisation, is a matter for its board and management to consider. Even so, MCI has made clear its expectations that SMT has a responsibility to uphold public trust. It must rectify what needs to be rectified, and be transparent with the public on how it intends to proceed.

7 February 2023

Ms Hazel Poa asked the Minister for Communications and Information whether there are reasons to be concerned about the corporate culture within SPH Media Trust given that it will be Government-funded and that integrity and credibility is of utmost importance to a news media.

Mrs Josephine Teo: This question has been addressed in my reply to Question Nos 2 to 18 for oral answer on the Order Paper for 6 February 2023. [Please refer to “Government’s Response to SPH Media Trust’s Inflated Circulation Numbers”, Official Report, 6 February 2023, Vol 95, Issue 81, Oral Answers to Questions section.]

3 April 2024

Ms Hazel Poa asked the Minister for Communications and Information whether SPH Media Trust has raised funding from sources other than the Government and, if so, how much.

Mrs Josephine Teo: Government funding provided to SPH Media Trust (SMT) is intended to support its talent, technology and vernacular capabilities. Outside of this, SMT may independently raise funding from other sources, based on its business decisions and operating needs. Information on SMT’s finances can be obtained from ACRA.

Livestreams of Parliamentary Sittings

2 April 2024

Ms Hazel Poa asked the Minister for Communications and Information (a) for how long will the livestreams of parliamentary sittings be retained on MCI’s YouTube channel; and (b) whether MCI will consider permanently retaining all livestreams of parliamentary sittings on its YouTube channel and, if not, where will they be archived.

Mrs Josephine Teo: As mentioned in the Ministry of Communications and Information’s (MCI’s) reply to a similar Parliamentary Question in January 2021, the full video of each Parliamentary Sitting livestream will remain on MCI’s YouTube channel for six months after the end of the Sitting. [Please refer to “Livestream of Parliamentary Proceedings”, Official Report, 4 January 2021, Vol 95, Issue 14, Written Answers to Questions section.]

The key purpose of livestreaming the Parliamentary proceedings is to allow members of the public to view the Parliamentary proceedings real-time, without the need to be physically present in Parliament. Thereafter, the full records of Parliamentary proceedings are documented through the Hansard and accessible to all online.

Disruption of Digital Services

9 May 2023

Ms Hazel Poa asked the Minister for Communications and Information (a) whether public and private organisations are liable for losses suffered by consumers and businesses as a result of disruptions to their digital services; and (b) if not, whether the Government will consider taking steps to protect consumers and businesses from losses due to such disruptions to digital services or impose minimum service standards on service providers.

Mrs Josephine Teo: As with many types of services, liability for losses incurred due to disruptions of a digital service would be governed under (a) the terms of use for the service and/or (b) the contractual agreement between buyer and seller.

Where services have significant impact to our economy and society, regulatory agencies have also imposed minimum service standards. For example, the Infocomm Media Development Authority requires telecom operators and Internet service providers to comply with Quality of Service standards and audit requirements for network resilience. The Monetary Authority of Singapore has strict requirements for banks with regard to the resilience of their critical services, which include digital banking. These were detailed during the 21 April 2023 Parliament Sitting. [Please refer to “Banking Disruptions That Have Lasted More Than An Hour in Last Five Years”, Official Report, 21 April 2023, Vol 95, Issue 101, Written Answers to Questions for Oral Answer not Answered by End of Question Time section.]

SPH Media Trust’s Inflated Circulation Numbers

6 February 2023

The Minister for Communications and Information (Mrs Josephine Teo): Mr Speaker, may I seek your permission to address Question Nos 2 to 18 in today’s Order Paper, as well as related written Question Nos 33 and 34 together?

Mr Speaker: Please proceed.

Mrs Josephine Teo: I will also address the related matters raised in the questions by Mr Darryl David,¹ Mr Gerald Giam,² Ms Hazel Poa and Dr Wan Rizal,³ which are scheduled for a subsequent Sitting. I invite Members to seek clarifications, if need be, at this Sitting.

Members have asked about the internal review of circulation numbers by SPH Media Trust (SMT). The following is what we have been told by SMT, all of which is on public record.

After the transfer of the media business from Singapore Press Holdings Limited (SPHL) to SMT in December 2021, SMT started a review to assess the data that it had taken over. This included circulation data.

SPHL’s previous annual reports set out circulation data. These were stated to be in accordance with rules established by the Audit Bureau of Media Consumption Singapore (ABC).

Over time, quantifying print circulation became less relevant and ABC ceased operations in Singapore in 2019.

As many other publishers have done, SMT decided to reassess the methodology for reporting circulation data so as to establish a new measurement framework and baseline. The circulation data they reviewed covered the period September 2020 to March 2022.

In its review, SMT found that circulation numbers in some months during the period under review were overstated by up to 90,000 average daily copies.

Sir, these events took place before SMT was formed, when the media business was under SPHL, a private listed company. However, this discrepancy has impacted SMT, including the newsrooms and journalists. SMT’s Board and management have decided to investigate the matter fully. They will have to rectify what needs to be rectified and be transparent about how they proceed.

From the Government’s perspective, we have three core interests in this matter: first, the usage of public funds; second, whether SMT’s findings on circulation affect the Government’s assessment of the need to provide funding support to SMT; and third, if we continue to assess that funding support is needed, whether the amount of funding should be revised.

Mr Speaker, I will discuss these three core interests in turn.

Parliament was informed in May 2021 that the Government supported the restructuring of SPHL’s media business into SMT. Subsequently, in February 2022, Parliament was informed of the funding that the Government was prepared to commit to support SMT’s capability development for five financial years, from FY2022.

Up to now, we have not disbursed any funds. Moreover, the Government did not have a funding relationship with SMT before FY2022. Therefore, the findings of SMT’s internal review of circulation data from September 2020 to March 2022 have no bearing on public funds.

Second, do the findings of SMT’s internal review affect the Government’s assessment of the need to provide funding support? This is what MCI’s own review sought to answer – and what Ms Jessica Tan, Mr Darryl David, Mr Don Wee, Mr Gerald Giam and others have asked about.

MCI’s review started after SMT shared its internal report with the Government on 9 January 2023. We re-examined our analysis of the media landscape in early 2021, when the decision was taken to support the restructuring of SPHL’s media business into SMT. We also reviewed our reasons for committing public funds to support SMT’s capability development.

SMT’s internal review of circulation numbers reinforced our assessment that the media landscape had become highly unfavourable for news organisations, even if they had substantial reach and were trusted by the public. In particular, demand for print and digital subscriptions had weakened because news had become freely available. This is why circulation had come under pressure.

I emphasise: this does not make it right for anyone to overstate circulation numbers. But it reaffirms the need for restructuring.

On the reasons to commit Government funds to support SMT, Members will recall that the Government had set these out on two occasions in Parliament. The first was through a Ministerial Statement in May 2021 by Minister Iswaran who was then Minister for Communications and Information. The second was in February 2022 when I responded to several Parliamentary Questions.

It is useful to remind ourselves of the key reasons laid out on both occasions.

The first reason is that our local news media is at a watershed. Structural changes, technological advances and the Internet have severely disrupted the media industry which traditionally relied on print advertising revenue.

But moving to digital poses its own set of challenges. Our local news media face intense competition for eyeballs online. Moreover, the cost of running professional newsrooms often outstrips the revenue from an online model. Although digital advertising revenue has increased, a large share of it goes to Big Tech companies like Google and Meta.

The second reason is that preserving local news media serves a larger, longer-term public interest. They give voice to the Singapore identity and Singaporean perspectives. They report world news for Singaporeans by Singaporeans. This is important given that the Internet has made it exceedingly easy for foreign news and content producers to reach and influence our domestic audiences.

In addition, there are the local vernacular news outlets, which are critical in preserving the voices of our multiracial communities. We must support them even though vernacular products are difficult to sustain financially, given their inherently smaller readership or viewership.

The third reason is that in a crowded information space where anyone and everyone can be a publisher, citizens must have sources which they can trust to be accurate and objective. We saw how important this was during the COVID-19 pandemic. Our mainstream media including SMT played crucial roles conveying accurate information in a timely fashion.

Based on an MCI survey, more than 70% of respondents accessed SMT’s digital content at least a few times a week in 2021, a jump of almost 30% since 2018. The Reuters Institute Digital News Report indicated that 77% of respondents expressed trust in The Straits Times in 2021, up from 70% in 2018.

The public has continued to choose and trust SMT’s products. We need to keep these products as viable propositions so our people can continue to benefit from the public good of quality journalism.

But staying in this game – and hopefully, getting ahead – requires deep investment in tech, infrastructure and capabilities. For example, The New York Times and German publishing giant Axel Springer have all run up hundreds of millions in investments to go digital. With the steep global decline of print media, the Government support to accelerate SMT’s transformation will give it a fighting chance in a highly competitive digital space.

Mr Speaker, these reasons for supporting SMT remain valid today. And this brings us to the third question: whether the findings of SMT’s review of the circulation numbers should affect the amount of funding committed.

Mr Speaker, in February 2022, I informed Parliament that the Government had assessed that it would provide up to $180 million of public funds annually to support SMT’s transformation for five years, starting from FY2022.

The funds would be used for technology development – for example, product development for the digital space, newsroom tools like content management resources and data analytics as well as IT infrastructure.

They would also be used for talent development – training journalists for the new operating environment, including equipping them with digital skills and multimedia capabilities.

The funds would be used also for the preservation of vernacular media – sustaining the vernacular newsrooms and developing new content formats like videos and podcasts to reach younger audiences.

I had also informed Parliament that in its initial years, we expect SMT to spend approximately 40% of the funding on tech investments and digital talent. The remainder will be spent on newsroom capability building and training, in particular, of the vernacular newsrooms.

As Members can see, in assessing the funding required for SMT’s transformation, circulation numbers were not a key consideration. The level of funding previously assessed for the purposes of investing in technology and capability development remain valid.

Let me now talk about ensuring accountability.

When Government funding is given, SMT will be held to account. Our focus is on readership and reach, which measure how many people consume the content; and not circulation, which is how many print and digital copies are sold or distributed.

Readership and reach are measured through surveys done by third parties. SPHL had previously commissioned surveys conducted by third-party research agencies such as GfK. MCI had also independently verified readership and reach using data sources outside of SPHL and SMT, including data collected by the Reuters Institute of Oxford University and our own News Consumption Surveys. We also have in place conditions and safeguards to ensure that public funding is used in an accountable and responsible manner.

I informed Parliament last year about the Key Performance Indicators (KPIs) we would be applying, including (a) total reach and engagement of SMT’s products, with a focus on their digital platforms; and (b) specific reach indicators for vernacular groups and youths.

The achievement of the KPIs will determine the amount of funding SMT receives. SMT’s KPI performance and financial statements must be audited by independent external auditors before submission to the Government. The Government can also conduct its own audits of SMT.

I further shared that SMT would be required to provide progress updates to MCI on a half-yearly basis. Specifically, funding will only be disbursed if SMT provides satisfactory regular updates on where and how funding has been utilised, and future business plans. The Government will also review the funding quantum during the mid-term and adjust KPIs and funding where necessary.

Mr Speaker, I have explained the Government’s key concerns with respect to SMT’s findings from its review of circulation data. Specifically, no public monies have been lost; there is no change to the decision to provide funding support to SMT; and there is no change to the amount of funding for SMT.

Let me now turn to other questions Members have raised.

Mr Leong Mun Wai asked if the Government had independently audited the financial statements and other data provided by SPHL as part of its due diligence process before making the decision to grant it public funding. The answer is yes. Our focus was on reach and readership, as I explained earlier.

Mr Gerald Giam and Mr Leong asked about the circulation figures cited by Minister Iswaran in May 2021. As the figures cited were for 2017 to 2020, a time outside the period of SMT’s review, we cannot conclude that they were inaccurate.

There were other questions about the details of SMT’s review, including (a) the duration and financial implications of the overstated circulation numbers; (b) the manner, timing and extent to which SMT discloses details of its review; and (c) police investigations.

The Members’ concerns are valid and these questions should be addressed to SMT. This includes the corporate culture Ms Hazel Poa asked about as well as SMT’s position with advertisers, as noted by Ms Mariam Jaafar.

SMT has its own corporate governance and executive team. Their CEO is accountable to their Board, which is in turn accountable to the members of the CLG. The Government cannot speak on behalf of SMT and it is premature for us to say more at this juncture. This is especially as the Board has tasked its Audit and Risk Committee to conduct further investigations into the circulation discrepancy.

The Government welcomes the Board’s resolve to examine the findings of its internal review and to put SMT on the right footing. MCI expects SMT to share the findings of its Audit and Risk Committee’s investigation with us.

SMT’s Board and management must also be mindful of their public duties, their responsibility to maintain the public’s trust in their newsrooms and journalists, and the need to discharge these responsibilities in a diligent and timely manner.

Ms Hazel Poa (Non-Constituency Member): One of the roles of a news media is to expose wrongdoing. In this case, we have SMT discovering its own wrongdoing but not breaking the news themselves. Did the Minister seek an explanation from SMT why they did not break the news themselves but instead waited for an online news media platform to break it; and then responded?

Mrs Josephine Teo: Mr Speaker, on a day-to-day basis, many things happen in an organisation and it is up to the management to decide if and how each particular event or incident ought to be communicated, both within the organisation and outside the organisation. Keep in mind that this review was initiated by SMT and they were still in process. In fact, they have decided that they need to investigate more fully and that is why they have asked their own Audit and Risk Committee to take on this work on an extended basis. Should the manner in which they had communicated been approached differently? I think that is a matter that SMT, the management and the Board, will have to consider.

Note(s) to Question No(s) 2-18:

¹ To ask the Minister for Communications and Information (a) whether the Government can provide some insight from the internal report received from SPH Media Trust (SMT) regarding the alleged inconsistencies in the circulation data of their publications; and (b) how will these inconsistencies impact the Government’s commitment to fund SMT.

² To ask the Minister for Communications and Information (a) what is the total number of newspaper copies that were printed, counted and destroyed by SPH Media Trust or its predecessor company for the entire duration of the scheme to inflate circulation numbers; (b) what is the estimated total weight of paper used; and (c) what is the environmental impact of these actions.

³ To ask the Minister for Communications and Information (a) whether the Ministry can provide insights from the internal report received from SPH Media Trust (SMT) regarding the alleged inconsistencies in its circulation data; and (b) whether the Ministry can provide an update on its review on whether the inconsistencies in SMT’s circulation data would have affected the decision to fund SMT and the amount of funding committed by the Government.