RFI20080896
PRODUCERS’ GUIDELINES
THE BBC’S VALUES AND STANDARDS
Our audiences rightly expect the highest editorial and ethical standards from the BBC.
These Guidelines are a public statement of those values and standards and how we
expect our programme-makers to achieve them. They detail the BBC's approach to the
most difficult editorial issues and provide guidance which programme makers at all levels
need to be aware of and to follow.
This fourth edition of the Guidelines contains, for the first time, a succinct summary of
the BBC's fundamental editorial values such as impartiality, accuracy, fairness, editorial
independence and our commitment to appropriate standards of taste and decency. As
the new world of digital media grows and fragments, the significance the BBC attaches to
these values will become even more important as we continue to set the standard for
broadcasting in all media.
This edition of the Guidelines has been substantially revised to reflect the challenges of
the digital age as well as the BBC's increasing role in international television and the
growing importance of online. It also contains new advice on ensuring the highest
standards in research, on reflecting the diversity of the United Kingdom and on natural
history programmes.
The worldwide reputation of the BBC has been established through the dedication to
public service broadcasting of generations of programme makers. The Producers'
Guidelines codify the good practice which they have helped to establish, and which we
expect today's producers and editors, whether working in radio, television or online, to
continue.
These Guidelines are a working document for programme teams to enable them to think
their way through some of the more difficult dilemmas they may face. Risk-taking is and
must remain an essential part of the creative process at the BBC. What the Guidelines
can do is to help us to make sensible calculations about those risks by leaning on the
experience of others who have been in similar situations.
Our staff, those freelancers working with us, and the independent producers we
commission - all need to be familiar with these Guidelines and to apply their underlying
principles. This is more than just a moral responsibility; it is also a contractual obligation
for everyone who makes programmes for the BBC. Where there is any doubt about the
right approach, programme makers must consult their editorial manager. The BBC's
Controller of Editorial Policy must be consulted if any departure from the Guidelines, or
their underlying principles, is contemplated.
We publish the Producers' Guidelines, firstly so that audiences can read for themselves
the editorial standards that we aspire to, and secondly so that they can judge our
performance accordingly.
Greg Dyke
Director General
1
RFI20080896
Contents Page
Director General's Introduction
1. Consultation and Referral
Values, Standards and Principles
2. Impartiality and Accuracy
3. Fairness and Straight Dealing
4. Privacy
5. Surreptitious Recording
6. Taste and Decency
7. Violence
8. Imitative and Anti Social Behaviour
9. Portrayal
10. Conflicts of Interest
11. Global Broadcasting and New Media
Issues In Programmes
12. Reporting Suffering and Distress
13. Interviewing
14. Children And Programmes
15. Crime
16. Relations with the Police
17. Confidentiality and Release of Programme Material
18. Terrorism and National Security
19. Reporting the United Kingdom
20. Recording The Natural World
21. ReUse and Reversioning of BBC Television Programmes
22. Game Shows and Competitions
23. Coverage of the National Lottery
Programme Funding and External Relationships
24. Commercial Relationships and Appropriate Programme Funding
25. Product Prominence and Use of Free or Reduced Cost Facilities
26. Material Supplied by Outside Organisations
27. On Air References to BBC Products, Services and Publications
28. Covering Outside Events
29. Advertising, Promotional Activities and the BBC Brand
30. Social Action Programming, Campaigning Groups and Charities
31. Support Services and Support Material
32. Phone Ins and Telephone Services in Programmes
Politics
33. Politics and Politicians
34. Broadcasting During Elections
35. Opinion Polls
36. Party Broadcasts
Matters of law
37. General
38. Defamation
2
RFI20080896
39. Contempt
40. Copyright and other Intellectual Property Rights
Accountability
41. Relations with the Public and the Press
42. The Programme Complaints Unit
43. The Broadcasting Standards Commission
Appendix 1: Section 5.1 of the Agreement
THE BBC’S EDITORIAL VALUES:
“We aim to be the world’s most creative and trusted broadcaster and
programme maker, seeking to satisfy all our audiences with services that
inform, educate and entertain and enrich their lives in the ways that the market
alone will not. We aim to be guided by our public purposes; to encourage the
UK’s most innovative talents; to act independently of all interests, and to aspire
to the highest ethical standards:” Impartiality…
Due impartiality lies at the heart of the BBC. All BBC programmes and services
should be open minded, fair and show a respect for truth. No significant strand of
thought should go unreflected or under represented on the BBC (see Chapter 2).
Accuracy…
We must be accurate and must be prepared to check, cross-check and seek
advice to ensure this. Wherever possible we should gather information first-hand
by being there ourselves or, where that is not possible, by talking to those who
were. But accuracy is often more than a question of getting the facts right. All
relevant information should be weighed to get at the truth of what is reported or
described (see Chapter 2).
Fairness….
BBC programmes should be based on fairness, openness and straight dealing.
Contributors should be treated honestly and with respect. They have a right to
know what a programme is about, what kind of contribution they are expected to
make, whether it will be live or recorded and whether it is to be edited (see
Chapter 3).
Giving a Full and Fair View of People and Cultures….
…. in the United Kingdom and across the world. BBC programmes and services
should reflect and draw on this diversity to reflect life as it is. By doing so we
introduce new talent, perspectives, faces and voices enriching our programmes
for our audiences.
When portraying social groups, stereotypes should be avoided (see Chapter 9)
Editorial Integrity and Independence…
Audiences must be able to trust the integrity of BBC programmes. They should be
confident that decisions are made only for good editorial reasons, not as a result
of improper pressure, be it political, commercial or special interest (see Chapter
24).
The outside activities of programme-makers must not improperly influence BBC
programmes (see Chapter 10).
Respect for Privacy….
The BBC should respect the privacy of individuals, recognising that any intrusions
have to be justified by serving a greater good. Private behaviour, correspondence
3
RFI20080896
and conversation should not be brought into the public domain unless there is a
wider public interest (see Chapter 4).
Respect for Standards of Taste and Decency….
Programme makers should be aware of and respect their audiences’ often diverse
views on what will and will not cause offence. The right to challenge audience
expectations in creative and surprising ways must be safeguarded but audiences
should not be needlessly offended by what we broadcast and publish. It is vital to
consider the expectations that audiences’ have of particular programmes, service
and time slots.
BBC television schedules must respect the 9 p.m. Watershed (see Chapter 6).
Avoiding the Imitation of Anti Social and Criminal Behaviour….
Audiences are concerned about the possibility of people imitating behaviour they
see or hear on television and radio. We should try to ensure that any life
threatening, anti-social, or criminal behaviour portrayed in BBC programmes does
not encourage copycat actions (see Chapter 8).
Safeguarding the Welfare of Children…
Programme makers must take care to safeguard the welfare of children who take
part in programmes They should consider carefully the impact of the programme
on any child involved - both in the way it is made, and any possible impact it may
have when broadcast (see Chapter 14).
Fairness to Interviewees...
BBC interviews should be well mannered and courteous. They may be searching,
sharp, sceptical, informed and to the point - but not partial, discourteous or
emotionally attached to one side of an argument. They should not be aggressive,
hectoring or rude, whatever the provocation. Interviewees should be given a fair
chance to set out their full response to the questions (see Chapter 13).
Respect for our Diverse Audiences in the U.K.…
BBC programmes and services should be relevant and appropriate for all our
audiences in all parts of the United Kingdom (see Chapter 19).
Independence from Commercial Interests…
BBC programmes must never give the impression that they are endorsing or
promoting any product, service or company. References to all products and
services should be editorially justifiable and there should be no element of
plugging (see Chapter 25).
4
RFI20080896
A
Abuse, of children, Chapter 6, Chapter 14, Chapter 37
Access agreements, Chapter 16
Access to untransmitted material, Chapter 17
Accidents and disasters, reporting, see Chapter 12
Accountability
.....Broadcasting Standards Commission, see Chapter 43
.....Programme Complaint Unit, see Chapter 42
.....relations with the public, see Chapter 41
Accuracy, Chapter 2
.....accurate language, Chapter 2
.....achieving accuracy, Chapter 2
.....checking recorded or repeated programmes, Chapter 2
.....correcting mistakes, Chapter 2
.....reconstruction, Chapter 2
.....reporting statistics, Chapter 2
.....staging and restaging events, Chapter 2
.....use of computer graphics, Chapter 2
.....use of library material, Chapter 2
Acquired programmes and violence, Chapter 6, Chapter 7
Advertising, Chapter 24
.....advertising boards, Chapter 28
.....advertisements on clothing, Chapter 28
.....advertising and promoting events, Chapter 28
.....and information services, Chapter 28
.....at events covered by the BBC, Chapter 28
.....at sports events, Chapter 28
.....for contributors, Chapter 3
.....party political, at outside events, Chapter 28
.....product placement, Chapter 25
Advice for programme makers, Chapter 1, see also Consultation and
Referral
Air crashes, reporting, Chapter 12
Animals, filming, see Chapter 20
.....captive sequences, ethical and editorial considerations, Chapter 20
.....ethical considerations, Chapter 20
.....filming named animals, Chapter 20
.....legal constraints, Chapter 20, Chapter 37
.....life cycle portrayal, Chapter 20
.....locations, Chapter 20
.....reconstruction and simulation, Chapter 20
.....violence against, Chapter 7, Chapter 20
Anonymity, Chapter 3
.....and children, Chapter 14
.....and criminals, Chapter 3
.....identification of crime victims and witnesses, Chapter 37
.....identification of children in court cases, Chapter 14, Chapter 37
.....jigsaw identification, Chapter 37
.....in pictures, making it effective, Chapter 3
.....victims of sexual offences, Chapter 37
Anti-social behaviour, imitation of, Chapter 8
Appeals, charity, Chapter 30
Appeals Advisory Committee, Chapter 30
Appeals charter, Chapter 30
Archive material, see Re-use and Reversioning of BBC Television
5
RFI20080896
Programmes, see also library material
Articles and letters by BBC personnel, Chapter 41
Artists, promotional activities undertaken by, Chapter 29
Artists rights, in re-used or reversioned material, Chapter 21
Audience feedback and confidentiality, Chapter 31
Audience Lines, Chapter 31, Chapter 32, Chapter 41
Audiences, regional differences, Chapter 19
Awards ceremonies and sponsorship, Chapter 28
B
Balance during election campaigns Chapter 34, see also Chapter 35
Balance and impartiality, see Chapter 2
BBC brand, protecting integrity of, see Chapter 29
BBC branded products, appropriate use of, see Chapter 27
BBC characters in commercials and promotions, Chapter 29
BBC commercial channels, references to, Chapter 27
BBC Commercial Policy Guidelines, Chapter 24
BBC Corporate Press Office, Chapter 41
BBC fund-raising projects, Chapter 30
BBC Information Centres, Chapter 41
BBC Information Line, Chapter 41
BBC Knowledge, Chapter 24, Chapter 31
BBC magazines: online references, Chapter 27
BBC magazines: references on radio, Chapter 27
BBC magazines: references on television, Chapter 27
BBC merchandise and local radio campaigns, Chapter 27
BBC merchandise, on-air references to, Chapter 27
BBC On Air magazine, Chapter 19, Chapter 27
BBC ONLINE, see Online services and the internet
BBC orchestras, and commercial issues, Chapter 24
BBC organised events, Chapter 28
BBC presenters, use of in commercials, Chapter 10, Chapter 29
BBC products and publications, trails of Chapter 27
BBC publications and products, promotion of, see Chapter 27
BBC publicity departments, working with, Chapter 41
"Black", use of term, Chapter 9
Blasphemy, Chapter 6
Blind people, interviewing, Chapter 9
Books, mention of on-air, Chapter 25
Books, reviewed on-air, Chapter 25
Bomb hoaxes, Chapter 18
Bomb warnings, Chapter 18
Branded products or services,
.....appropriate use of, see Chapter 25
.....and competitions, Chapter 22
Breach of confidence, Chapter 40
"British", use of term, Chapter 19
British Board of Film Classification, Chapter 6
Broadcasting Act 1996, see Chapter 43
Broadcasting During Elections, see Chapter 34
Broadcasting Standards Commission, see Chapter 43
Broadcasting Support Services, Chapter 30
BSC Code of Practice on taste and decency, see Chapter 43
"Bugging", (unattended recording devices), Chapter 5
By-elections, Chapter 34
C
Call cut offs, Chapter 32
6
RFI20080896
Campaigning groups, Chapter 30
Candidates
.....BBC people standing as, Chapter 10
.....during elections, Chapter 34
.....in European elections, Chapter 34
.....in local elections, Chapter 34
.....in overseas elections, Chapter 34
.....in Scottish and Welsh elections, Chapter 34
Cash prizes, Chapter 22
CCTV footage, use of, Chapter 4, Chapter 26
Ceefax, Chapter 25, Chapter 31, Chapter 32
.....commercial references on, guidelines, Chapter 27
Central Office of Information, Chapter 26
Charities and charity appeals, see Chapter 30
.....Appeals Advisory Committee, Chapter 30
.....Appeals Advisory Committees in the Nations, Chapter 30
.....Appeals Charter, Chapter 30
.....Charities Act (1992), Chapter 30, Chapter 32
.....Children in Need, Chapter 22, Chapter 27, Chapter 28, Chapter 30,
Chapter 31
.....and conflicts of interest, Chapter 10
.....donations and premium rate telephone calls, Chapter 30, Chapter 32
.....donations to, Chapter 30
.....emergency appeals, Chapter 30
.....fact sheets and further information, Chapter 30
.....helplines, Chapter 31
.....joint initiatives, Chapter 30
.....and Local Radio Advisory Councils, Chapter 30
.....and Local radio stations, Chapter 30
.....on-air references to, Chapter 30
.....outside fund-raising events, Chapter 30
.....premium rate telephone lines, Chapter 30, Chapter 32
.....programme credits, Chapter 30
.....programmes and items about charitable work, Chapter 30
.....regional broadcasting, Chapter 30
.....regions, Chapter 30
.....United Kingdom Disasters Emergency Committee, Chapter 30
.....unsolicited donations to charity, Chapter 30
.....World Service and Worldwide Television and fact sheets and support
materials, Chapter 30
Checking recorded or repeated programmes, Chapter 2, see also Chapter
43
Chief Political Adviser
.....mandatory referral, elections, Chapter 34
.....mandatory referral, opinion polls, Chapter 35
.....mandatory referral, party leaders, Chapter 33
Children, see Chapter 14
.....and abuse, Chapter 6, Chapter 14, Chapter 37
.....and anonymity, Chapter 14, Chapter 37
.....Children Act (1989), Chapter 14
.....Children's Panel System, Chapter 14
.....and consent, Chapter 14
.....in court, identification of, Chapter 14, Chapter 37
....."Custody", Chapter 14
.....dangerous or illegal activity among children, Chapter 8, Chapter 14
.....drama involving child performances, Chapter 14
.....and European Directive TV without Frontiers, Chapter 37
7
RFI20080896
.....i
nterests and welfare of child, Chapter 14
.....interviewing techniques, Chapter 14
.....laws affecting children, Chapter 14, Chapter 37
.....and phone-ins, Chapter 32
.....Protection of Children Act (1978), Chapter 6, Chapter 14
.....and sex, Chapter 6, Chapter 14
.....taste and decency issues, Chapter 6, Chapter 14
.....trails during children's programmes, Chapter 6
.....as victims of sexual offences, Chapter 14
.....violence against, Chapter 7
.....Youth court proceedings, Chapter 14
Children In Need, Chapter 22, Chapter 27, Chapter 28, Chapter 30, Chapter
31
Civil Trespass, Chapter 37
Close Circuit Television, use of footage from, Chapter 4, Chapter 26
Clothing, advertisements on, Chapter 28
Co-funding, Chapter 24
.....editorial control, Chapter 24
.....and independent productions, Chapter 24
Comedy, light entertainment and surreptitious recording, Chapter 5
Comedy and entertainment, taste and decency issues in, Chapter 6
Comic Relief, Chapter 27, Chapter 28, Chapter 30
Commercial Policy Guidelines, Chapter 24, Chapter 25, Chapter 27, Chapter
28, Chapter 29, Chapter 31
Commercial references on Ceefax, guidelines, Chapter 27
Commercial references Register, Chapter 24
Commercials, television and radio, using extracts from, Chapter 25
Commissioning Opinion Polls, Chapter 35
Committal proceedings, reporting, Chapter 37
Competitions, and prizes, see Chapter 22
.....and BBC Worldwide Television, Chapter 22
.....and branded products or services, Chapter 22
.....cash prizes, Chapter 22
.....and co-sponsored events, Chapter 22
.....donated prizes, Chapter 22
.....entry forms, Chapter 22
.....ITC restrictions, Chapter 22
.....legal considerations, Chapter 22
.....organisation of competitions, Chapter 22
.....and premium rate telephone calls, Chapter 22, Chapter 32
.....prizes in jointly organised competitions, Chapter 22
.....run in association with BBC magazines, Chapter 22
.....run by others, Chapter 22
Complaints, dealing with, Chapter 41
Complaints to the BSC, see Chapter 43
Complaints to the Programme Complaints Unit, see Chapter 42
Composers, payment of, Chapter 40
Computer Credits in sports coverage, Chapter 26
Computer graphics, Chapter 2
Confidentiality, Chapter 17, Chapter 37, Chapter 40
.....Confidential sources, Chapter 17
.....need for referral, Chapter 1
Conflicts of interest, see Chapter 10
.....business and financial Interests, Chapter 10
.....campaigning bodies, Chapter 10
.....charitable work, Chapter 10
.....in consumer and lifestyle programmes, Chapter 10
8
RFI20080896
.....di
rectorships, and consultancy work, Chapter 10
.....experts and specialists, and promotional activities, Chapter 10
.....factual programme presenters in drama, Chapter 10
.....in financial journalism, Chapter 10
.....and free facilities, Chapter 10, Chapter 25
.....and free products, Chapter 25
.....involvement in music production, Chapter 10
.....and media training, Chapter 10
.....in News, Current Affairs, and Topical Programmes, Chapter 10
.....people affected by, Chapter 10
.....personal benefits, Chapter 10
.....and political activities, Chapter 10
.....presenters and personal view programmes, Chapter 2, Chapter 10
.....promotional activities, Chapter 10
.....public appearances and performances, Chapter 10
.....rival organisations, work for, Chapter 10
.....seeking approval, Chapter 10
.....and standing for election, Chapter 10
Consent, and children, Chapter 14
Consent form for candidates in elections, Chapter 34
Consultation and referral, see Chapter 1
.....and independent productions, Chapter 1
.....legal referral, Chapter 1
.....mandatory referrals, Chapter 1
Consumer programmes
.....conflicts of interests in, Chapter 10
.....and use of free or reduced cost facilities, Chapter 25
Consumer tests, see test products
Contempt, see Chapter 39
.....'active' proceedings, Chapter 39
.....broadcasting an interview with a witness, Chapter 39
.....defences against, Chapter 39
.....risks of committing, Chapter 39
.....talking to a juror, Chapter 39
Continuity announcements, Chapter 6
Contracts with independent producers, Chapter 1, Chapter 24
Contributors
.....advertising for, Chapter 3
.....anonymity, Chapter 3
.....dealing with, Chapter 3
.....fairness to, see Chapter 3
.....names and addresses, Chapter 17
Controller Editorial Policy, referral to
.....confidentiality, Chapter 17
.....contact with escaped prisoners, Chapter 15
.....DA notices, Chapter 18
.....doorstepping, Chapter 4
.....interviewing criminals, Chapter 15
.....interviewing paedophiles, Chapter 15
.....interviewing prisoners, Chapter 15
.....interviewing terrorists, Chapter 15, Chapter 18
.....interviewing witnesses, Chapter 15
.....mandatory referrals, Chapter 1
.....Northern Ireland, Chapter 19
.....payment of criminals, Chapter 15
.....publishing details of sex offenders, Chapter 15
.....payment to witnesses, Chapter 15
9
RFI20080896
.....recordi
ng telephone calls with prisoners, Chapter 15
.....staged events by terrorist groups, Chapter 18, Chapter 19
.....surreptitious recording, Chapter 5
.....untransmitted material, Chapter 17
Controller Northern Ireland, referral to, Chapter 19
.....longer term programme proposals, Chapter 19
.....mandatory referrals, Chapter 1
Controversial issues, in programmes
.....dealing with in relation to the press, Chapter 41
.....referral about, Chapter 1
Copyright, see Chapter 40
.....advice about, Chapter 40
.....music, Chapter 40
.....use without permission, Chapter 40
.....video and film, Chapter 40
Corporate Press Office, Chapter 41
Correcting mistakes, Chapter 2
Correspondence from viewers and listeners, dealing with, Chapter 41
Co-sponsorship of BBC events, Chapter 28
.....approval for, Chapter 28
.....co-sponsored events and BBC premises, Chapter 28
.....co-sponsored events run as competitions, Chapter 22
.....co-sponsorship with commercial organisations, Chapter 28
.....co-sponsorship guidelines, Chapter 28
.....debates and forums, Chapter 28
Councils, local, assistance from, Chapter 24
Councils, local elections to, see local authority elections
Court reporting, contempt, see Chapter 39
Courtesy in interviews, Chapter 13
Covering Outside Events, see Chapter 28
Credits, references to charities in, Chapter 30
Credits for co-funding, Chapter 24
Credits for co-production partners, Chapter 24
Credits for outside information, Chapter 25, Chapter 26
Credits for sponsors of events, Chapter 28
Credits for sports events, Chapter 28
Crime, reporting of, see Chapter 15
.....contact with escaped prisoners or people wanted by the police, Chapter
15
.....general principles, Chapter 15
.....guidance for news programmes, Chapter 15
.....guilt by association, Chapter 15
.....library material of, Chapter 15
.....paedophiles and sexual crime, Chapter 15
.....Prevention of Terrorism Act, Chapter 15
.....prisons and prisoners, Chapter 15
.....putting crime in context, Chapter 15
.....re-use of material, Chapter 21
.....running stories, Chapter 15
.....use of statistics, Chapter 15
.....use of surreptitious recording, Chapter 5
.....victims of, Chapter 15
.....witnesses of, Chapter 1, Chapter 15, Chapter 37
.....witnessing of by programme makers, Chapter 15
Crime reconstruction in current affairs programmes, Chapter 15
.....camera angles and point-of-view shots, Chapter 15
.....reconstructing detail (including dialogue), Chapter 15
10
RFI20080896
.....reconstructi
ng wounds, Chapter 15
.....use of incidental music or irrelevant sound effects, Chapter 15
Crime reconstruction in news programmes, Chapter 15
Crime and vandalism, imitation of, Chapter 8
Crime victims, Chapter 15
Crime victims and witnesses, identification of, Chapter 37
Criminal Trespass, Chapter 37
Criminals, dealing with, Chapter 15
.....families of, Chapter 15
.....interviews with, Chapter 15
.....overseas, definition of, Chapter 15
.....payments to, Chapter 15
"Custody", and children, Chapter 14
D
DA Notices (formerly D Notices), Chapter 18
Data Protection Act, Chapter 37
Dead, injured or missing, concern for next of kin, Chapter 12
Dead, reporting the, Chapter 12
Deafness, terminology of, Chapter 9
Dealing with Contributors, Chapter 3
Decency and taste, see Chapter 6
Deception in factual programmes, Chapter 3
Defamation see Chapter 38
.....and the BSC see Chapter 43
.....defences to libel, Chapter 38
.....libel, Chapter 38
.....Negative Checks, Chapter 38
.....pictorial, Chapter 38
.....registered trade marks, Chapter 38
Defence advisory notices (formerly D Notices), Chapter 18
Defences against contempt, Chapter 39
Demonstrations, coverage of, Chapter 16
"Dial and listen" information lines, Chapter 31
Digital text services, Chapter 25, Chapter 32
"Disturbance fee", Chapter 33
Disabilities, portrayal of, Chapter 9
Disability Discrimination Act, Chapter 9
Disasters, accidents, and tragic events reporting of, see Chapter 12
Disguising identities, Chapter 5
Donated prizes, Chapter 22
Donations to charity, Chapter 32
Donations, to charity, unsolicited, Chapter 30
Doorstepping, Chapter 4
.....recording telephone calls, Chapter 5
Drama, Chapter 2
.....drama-documentaries, Chapter 2
.....drama involving children, Chapter 14
.....history in drama, Chapter 2
.....portrayal of real people in, Chapter 2
.....portraying contemporary situations, Chapter 2
Drama, Arts, Music and Entertainment Programmes, Impartiality in, Chapter
2
Drugs, Chapter 8
Due impartiality, Chapter 2
Due impartiality within a factual programme, Chapter 2
.....and the series provision, Chapter 2
11
RFI20080896
.....i
n social action programming, Chapter 30
E
Editing recorded interviews, Chapter 13
Editorial Policy Unit, Chapter 1
Elections, broadcasting during, see Chapter 34
Election campaigns, fairness in programmes during, Chapter 34
Elections
.....European Parliament, Chapter 34
.....local authority, Chapter 34
.....overseas, Chapter 34
.....Scottish Parliament and Welsh Assembly, Chapter 34
E-mails from viewers and listeners, Chapter 41
Embargoes, Chapter 3
Emergency appeals, Chapter 30
Emergency services, use of video from, Chapter 26
"English", use of term, Chapter 19
Entertainment, and surreptitious recording, Chapter 5
Entertainment, taste and decency issues in, Chapter 6
Entry forms, Chapter 22
Emergency announcements, Chapter 26
Emergency appeals, Chapter 30
Epilepsy, susceptibility to, Chapter 37
Escaped prisoners or people wanted by the police, contact with, Chapter 15
Ethnic minorities, portrayal of, Chapter 9
European Directive: Television without Frontiers, Chapter 6, Chapter 37
European Parliament, coverage of, Chapter 33
European Parliament election campaigns, Chapter 34
Evasion in interviews, dealing with, Chapter 13
Even handedness in Interviews, Chapter 13
Event information phone lines, Chapter 32
Events organised or sponsored by BBC magazines, Chapter 27, Chapter 28
Excerpts, re-use of, Chapter 21
Exhibitions, BBC organised, Chapter 28
Exit polls, Chapter 35
Explicit lyrics in songs, Chapter 6
F
Fact and fiction, mixing of, Chapter 2
Facts, accuracy of, Chapter 2
Factsheets and booklets, Chapter 30, Chapter 31
Fairness
.....and advertising for contributors, Chapter 3
.....and BSC, see Chapter 43
.....to Contributors, see Chapter 3
.....and editing interviews, Chapter 13
.....and independence, Chapter 3
.....to interviewees, Chapter 13
.....to people asked for help or advice in the preparation of programmes,
Chapter 3
.....in programmes during Election Campaigns, Chapter 34
.....and research, Chapter 3
.....and refusals to take part, Chapter 3
.....and working abroad, Chapter 3
Fees, see payments
Films, taste and decency considerations, Chapter 6
Financial journalism and conflicts of interest, Chapter 10
"Fishing expeditions", Chapter 5
12
RFI20080896
Fl
ashing and flickering images, dangers of, Chapter 37
Focus groups, Chapter 35
Four letter, words, use of, Chapter 1, Chapter 6
Free or reduced cost facilities and products, Chapter 25
.....and consumer programmes, Chapter 25
.....and credits, Chapter 25
.....and editorial independence, Chapter 25
.....holiday and travel programmes, see Chapter 25
.....and media facility trips, Chapter 25
Funding
.....appropriate programme, see Chapter 24
.....for support services, Chapter 31
Fundraising events
.....BBC, Chapter 30
.....joint initiatives, Chapter 30
.....Outside, Chapter 30
Funerals, Chapter 12
G
Gambling, Chapter 22, Chapter 32
Game shows and people shows Chapter 6, see also Chapter 22
.....co-sponsored events, Chapter 22
.....fair treatment of contestants, Chapter 22
.....ITC restrictions, Chapter 22
.....prizes, Chapter 22
.....prizes in jointly organised competitions, Chapter 22
.....safety, Chapter 22
.....selecting contestants, Chapter 22
Gays and lesbians, stereotyping, of, Chapter 9
Global broadcasting, Chapter 11
Government information, Chapter 26
Governors' Complaints Appeals Committee, see Chapter 42
Grief and distress, reporting of, Chapter 5, see also Chapter 12
Grief and distress, surreptitious recording of, Chapter 5
Guilt by association, Chapter 15
Guns, see weapons
H
Hanging scenes, Chapter 8
Harassment, see media scrums
Health and safety, Chapter 37
Helplines, Chapter 31
.....and premium rate lines, Chapter 31, Chapter 32
Hidden microphones and cameras, see surreptitious filming
Hi-jacking, kidnapping, hostage taking and sieges, Chapter 16
History in drama, Chapter 2
Hoaxing, ("serial guests"), Chapter 3
Holiday and travel programmes, Chapter 25
Homosexuality, portrayal of, Chapter 6, Chapter 9
.....terminology, Chapter 9
Honesty, in dealing with contributors, Chapter 3
Hostage taking, Chapter 16
Hosted programmes, Chapter 24
Hypnotism, Chapter 8
I
Identification of children in court, Chapter 14, Chapter 37
Identification of Crime Victims and Witnesses, Chapter 37
13
RFI20080896
.....courts si
tting in private, Chapter 37
.....identifying victims of sexual offences, Chapter 37
....."jigsaw" Identification, Chapter 37
Illegal activity, witnessing of by programme makers, Chapter 15
Imitative and Anti-Social Behaviour, see Chapter 8
.....and children, Chapter 8
.....crime and vandalism, Chapter 8
.....drugs, Chapter 8
.....hanging scenes, Chapter 8
.....hypnotism, Chapter 8
.....methods of inflicting pain and injury, Chapter 7, Chapter 8
.....religious sensitivities about smoking and drinking, Chapter 8
.....seat belts, Chapter 8
.....smoking and drinking in children's programmes, Chapter 8
.....social and anti-social behaviour, Chapter 8
.....suicide, Chapter 8
Impartiality, see Chapter 2
.....in drama, arts, music and entertainment programmes, Chapter 2
.....in drama portraying contemporary situations and drama-documentaries,
Chapter 2
.....due impartiality, Chapter 2
.....due impartiality within a factual programme, Chapter 2
.....in election coverage, see Chapter 34
.....fact, fiction and labelling, Chapter 2
.....in factual programmes, Chapter 2
.....in factual programmes not dealing with matters of political or industrial
controversy, Chapter 2
.....history in drama, Chapter 2
....."major matters", Chapter 2
.....in news programmes, Chapter 2
.....in party political, party election, and ministerial broadcast, Chapter 2
.....in personal view programmes, Chapter 2
.....portrayal of real people in drama, Chapter 2
.....reporting in times of national emergency and military action, Chapter 2
.....right of reply, Chapter 2
.....sensitivity to offence, Chapter 2
.....in series provision, Chapter 2
.....in social action programming, Chapter 30
Impartiality and Accuracy Code, see Chapter 2
Indemnities, Chapter 16
Independent productions,
.....and commercial referral, Chapter 24
.....consultation and referral, Chapter 1
.....premium rate telephone lines, Chapter 32
.....taste and decency, Chapter 6
.....violence, Chapter 7
Information from outside sources, Chapter 26
Information lines, Chapter 31, Chapter 32
Information lines provided by event organisers, Chapter 32
Injunctions and Interdicts, Chapter 37
Innuendo, sexual, Chapter 6
Intellectual Property, see Chapter 40
Intellectual Property Department, Chapter 37, Chapter 40
Interactive voting, Chapter 35
Interdicts, Chapter 37
International Audience Correspondence Unit, Chapter 41
International services, Chapter 11
14
RFI20080896
Internet, Chapter 6, Chapter 31
Interviewing, see Chapter 13
....."as live", Chapter 13
.....BBC Correspondents, Chapter 13
.....blind people, Chapter 9
.....children, Chapter 14
.....courtesy in, Chapter 13
.....criminals, Chapter 15
.....dealing with interviewees, Chapter 13
.....editing a recorded interview, Chapter 13
.....evasion in, Chapter 13
.....even handedness in, Chapter 13
.....fairness to interviewees, Chapter 13
.....ordinary people, Chapter 13
.....people injured or grieving, Chapter 12
.....political, Chapter 33
.....preparation for, Chapter 13
.....purpose of, Chapter 13
.....tailoring to time, Chapter 13
.....tone and tactics, Chapter 13
.....unreasonable demands by interviewees, Chapter 13
.....witnesses, Chapter 15
.....witnesses, dangers of contempt, Chapter 39
Inventions, Chapter 40
ITC Code of Advertising Standards and Practice, Chapter 24
ITC Code of Programme Sponsorship, Chapter 22, Chapter 24
ITC Programme Code, Chapter 22, Chapter 24
ITC Regulation, Chapter 24, Chapter 31
ITC restrictions, on competitions, games shows and prizes, Chapter 22
ITC Rules on Advertising Breaks, Chapter 24
J
"Jigsaw" Identification, Chapter 37
Joint editorial initiatives, Chapter 24
Joint initiatives in support material, Chapter 31
Jurors, speaking to, Chapter 39
K
Keeping programmes, Chapter 41
Kidnaps, reporting of, Chapter 16
Knives, Chapter 8
L
Labelling
.....in programmes that mix fact and fiction, Chapter 2
.....reconstructions, Chapter 2
.....video and audio news releases, Chapter 26
Language
.....accurate, Chapter 2
.....disability, Chapter 9
.....non sexist, use of, Chapter 9
.....in portrayal of ethnic minorities, Chapter 9
.....in portrayal of women, Chapter 9
.....phone-ins, Chapter 6
.....in relation to Regions, Chapter 19
.....religious sensitivities, Chapter 9
.....sexual orientation, Chapter 9
.....strong, Chapter 6
15
RFI20080896
.....strong l
anguage, referral for, Chapter 1, Chapter 6
.....and taste and decency issues, Chapter 6
.....terrorism, Chapter 18
.....violence, Chapter 7
Law
.....animals, Chapter 20, Chapter 37
.....breach of confidence, Chapter 37
.....children, Chapter 14, Chapter 37
.....and confidential sources, Chapter 17
.....contempt, see Chapter 39
.....copyright, see Chapter 40
.....courts sitting in private, Chapter 14, Chapter 37
.....defamation, see Chapter 38
.....health and safety, Chapter 37
.....identification of witnesses, Chapter 37
.....injunctions/interdicts, Chapter 37
.....intellectual property, see Chapter 40
.....jigsaw identification, Chapter 37
.....legal referral, Chapter 1, Chapter 37
.....Northern Ireland, Chapter 19
.....Obscene Publications Act, Chapter 37
.....Official Secrets Act, Chapter 18
.....racial discrimination, Chapter 37
.....reference books for, Chapter 37
.....repeated programmes, Chapter 37
.....reporting of committal proceedings, Chapter 37
.....victims of sexual offences, Chapter 37
Laws affecting children, Chapter 14, Chapter 37
Laws in other parts of the world, respecting, Chapter 3
Laws of privacy in other parts of the world, Chapter 4
Leaders of political parties, interviews with, Chapter 33
Learning difficulties, portrayal of people with, Chapter 9
Legal Adviser's Division, Chapter 37
Letters and articles for publication, by BBC personnel, Chapter 41
Letters from viewers and listeners, Chapter 41
Lesbians, portrayal of, Chapter 9
Libel, Chapter 38
Library material
.....accurate use of, Chapter 2
.....of crime, Chapter 15
.....outside, crediting, Chapter 26
.....re-use and reversioning of, see Chapter 21
Library use of scenes of suffering, and violence, Chapter 7, Chapter 12
Light entertainment and surreptitious recording, Chapter 5
Litigation Department, Chapter 37
Local authority elections, Chapter 34
Local councils, Chapter 24
Local council elections, see local authority elections
Local law, observing, Chapter 3
Local Radio Advisory Councils and charities, Chapter 30
Local Radio Campaigns and BBC Merchandise, Chapter 27
Local Radio and commercial issues, Chapter 24
Local radio stations and charities, Chapter 30
Long lenses, use of, Chapter 5
Lotteries and Amusements Act, 1976, Chapter 22, Chapter 32
Lottery, National, see National Lottery
Lyrics, explicit, Chapter 6
16
RFI20080896
M
Magazines, BBC, Chapter 27
.....and competitions, Chapter 27
.....references to, online, Chapter 27
.....references to, on radio, Chapter 27
.....references to, on television, Chapter 27
.....and sponsorship, Chapter 28
Mandatory referrals, Chapter 1
Media facility trips, Chapter 25
Media scrums, Chapter 4
Media training, Chapter 10
Members of Parliament, payment of, Chapter 33
Methods of inflicting pain and injury, imitation of, Chapter 7, Chapter 8
Military action, reporting in times of, Chapter 2
Ministerial Broadcasts, see Chapter 36
Missing People, rights of privacy, Chapter 4
Mistakes, correcting, Chapter 2
Mobile phones, Chapter 8
Moral rights, in copyright, Chapter 40
Music Copyright, Chapter 40
Music Copyright section, Chapter 40
Music production, Chapter 10
N
Names and addresses of contributors, Chapter 17
"National", use of word, Chapter 19
National Lottery, see Chapter 23
.....coverage a service not a promotion, Chapter 23
.....lottery tickets, Chapter 23
.....trails for, Chapter 23
.....use of library pictures of the lottery programme, Chapter 23
National Security, see Chapter 18
.....DA Notices, Chapter 18
.....mandatory referral, Chapter 1, Chapter 18
.....Official Secrets Act, Chapter 18
.....reporting in times of national emergency and military action, Chapter 2
Natural history filming, see Chapter 20
.....captive sequences, ethical and editorial considerations, Chapter 20
.....ethical considerations, Chapter 20
.....filming named animals, Chapter 20
.....legal constraints, Chapter 20
.....life cycle portrayal, Chapter 20
.....locations, Chapter 20
.....reconstruction and simulation, Chapter 20
Negative checks, Chapter 38
New Media, Chapter 11
News black-out, requests for, Chapter 16
News coverage of sponsored sports events, Chapter 28
News presenters, conflict of interests of, Chapter 10
News presenters, in drama, Chapter 10
News programmes, impartiality in, Chapter 2
Non-BBC events, promotion of, Chapter 28
Non-sexist language, use of, Chapter 9
News releases by outside bodies, use of, Chapter 26
News reports of disasters and accidents, Chapter 12
Northern Ireland, Chapter 19
.....mandatory referrals, Chapter 1
17
RFI20080896
.....Northern Irel
and Assembly, reporting, Chapter 33, Chapter 34
.....Northern Ireland (Emergency Provisions) Acts, Chapter 19
.....prevention of terrorism legislation, Chapter 19
.....reflecting reality, Chapter 19
.....special legal considerations, Chapter 19
.....staged events, Chapter 19
O
Obscene Publications Act, Chapter 37
Offence
.....interviewing people whose views might offend, Chapter 2
.....phone-ins, Chapter 6
.....taste and decency, see Chapter 6
.....sensitivity to offence and outrage, Chapter 2
Offensive language, Chapter 6
Off-air promotions with publications, Chapter 24
Official Secrets Act, Chapter 18
Older people, portrayal of, Chapter 9
On-air promotions, Chapter 24
On-air publicity for outside events, Chapter 28
On-air references to charities, Chapter 30
On-air references to products, services and publications, see Chapter 25
.....BBC characters in commercials and promotions, Chapter 29
.....BBC magazines: references on radio, Chapter 27
.....BBC magazines: references on television, Chapter 27
.....BBC presenters, use of in commercials Chapter 10, Chapter 29
.....BBC Publications and products, see Chapter 27
.....BBC Publications and products, promotion of, see Chapter 29
.....Books and other publications, Chapter 25, see also Chapter 27
.....Branded products and services, appropriate use of, see Chapter 27
.....Commercial recordings, Chapter 25
.....Competitions run in association with BBC magazines, Chapter 27
.....Credits for sponsors of events, Chapter 28
.....Events sponsored by BBC magazines, Chapter 28
.....On-air references to other BBC merchandise, Chapter 27
.....Presenters, use of in commercials, Chapter 10, Chapter 29
.....Product placement, Chapter 25
.....Products used as props, Chapter 25
.....Reviews of products or services, Chapter 25
.....Television and radio commercials, Chapter 25
.....Testing products, Chapter 25
.....Trails for BBC products or publications, Chapter 27
ONLINE Guidelines, Chapter 1, Chapter 6, Chapter 11, Chapter 25, Chapter
27, Chapter 31
Online services and the Internet, Chapter 11
.....commercially funded sites, Chapter 27
.....and overseas elections, Chapter 34
.....hot links, Chapter 25
.....interactive voting, Chapter 35
.....and Northern Ireland, Chapter 19
.....and overseas elections, Chapter 34
.....and product prominence, Chapter 25
.....references to BBC merchandise, Chapter 27
.....support services on, Chapter 31
.....taste and decency issues in, Chapter 1, Chapter 6
.....trailing products and services on, Chapter 27
Opinion Polls, see Chapter 35
18
RFI20080896
.....commi
ssioning opinion polls, Chapter 35
.....in election results programmes, Chapter 35
.....at election times, Chapter 35
.....exit polls, Chapter 35
.....online and interactive voting, Chapter 35
.....panels or focus groups, Chapter 35
.....phone-in polls, Chapter 32, Chapter 35
.....referral to Chief Political Adviser, Chapter 1, Chapter 35
.....sceptical approach to, Chapter 35
.....studio audiences, polling of, Chapter 35
.....and surveys, Chapter 35
.....validity of opinion poll methods, Chapter 35
.....voting intention polls, rules for reporting, Chapter 35
Orchestras, BBC and commercial issues, Chapter 24
Outside bodies, programmes provided by, Chapter 24
Outside events, covering, see covering outside events
Outside information, using, Chapter 26
.....varying sources, Chapter 26
Ownership of copyright, see Chapter 25
P
Paedophiles and sexual crime, Chapter 15
Panels or focus groups, Chapter 35
Parliament, broadcasting the proceedings of, Chapter 33
Parliament, conditions of use of pictures and sound from, Chapter 33
.....European, Chapter 33
.....National Assembly for Wales, Chapter 33
.....Northern Ireland Assembly, Chapter 33
.....Scottish Parliament, Chapter 33
.....Westminster, Chapter 33
Parliament, statements made in, Chapter 33
Parliamentary broadcasting, legal aspects, Chapter 33
Parliamentary Broadcasting Unit, Chapter 33
Parliamentary committees, broadcasting of, Chapter 33
Parliamentary material, use of, Chapter 33
Parliamentary privilege, Chapter 33
Party broadcasts, see Chapter 36
Party Election Broadcasts, see Chapter 36
Party Political Broadcasts, see Chapter 36
Party Political, Party Election and ministerial broadcasts, impartiality in,
Chapter 2
"Passing off", Chapter 40
Patents, Chapter 40
Payment of composers/writers, Chapter 40
Payment of criminals, Chapter 15
Payment of criminals or former criminals mandatory referral, Chapter 1
Payment of MPs, Chapter 33
Payment of witnesses, Chapter 15
People shows and game shows, see game shows and people shows
Performers' Rights, Chapter 40
Performing Animals (Regulation) Act, 1925, Chapter 37
Personal view programmes, Chapter 2
Personal view programmes and BBC presenters Chapter 2
Phone-in polls, Chapter 32, Chapter 35
Phone-in polls, and premium rate telephone lines, Chapter 32
Phone-in polls, reporting the results of, Chapter 35
Phone-ins, Chapter 6, Chapter 32
19
RFI20080896
Phonographic Performance Ltd, Chapter 40
Pictorial defamation, Chapter 38
Pixilation, Chapter 3
Placard carrying the names of sponsors, Chapter 28
Plugging products and services, Chapter 25, see also Chapter 26 and
Chapter 27
Police, relations with, see Chapter 16
.....coverage of public demonstrations, Chapter 16
.....making arrangements for programmes, Chapter 16
.....procedures during hi-jacking, hostage taking and sieges, Chapter 16
.....requests for untransmitted material see, Chapter 17
Police "facilities", Chapter 16
Police indemnities, Chapter 16
Police messages and information, Chapter 16, Chapter 26
Police raids, going on, Chapter 16
Political activities and conflicts of interest, Chapter 10
Political involvement of BBC staff, Chapter 10
.....levels of, Chapter 10
.....Political Research Unit, Chapter 33
.....standing for election, Chapter 10
Politicians, refusals to take part in programmes by, Chapter 33
Politicians appearing in News, Current Affairs and factual Programmes,
Chapter 33
Politics and politicians, see Chapter 33 and Chapter 34
Portrayal, see Chapter 9
.....of disabilities, Chapter 9
.....of ethnic minorities, Chapter 9
.....hurtful or inaccurate stereotypes, Chapter 9
.....of older people, Chapter 9
.....of religious groups, Chapter 9
.....of sexual orientation, Chapter 9
.....under-representation on-air, Chapter 9
.....use of non-sexist language, Chapter 9
.....of women, Chapter 9
Portrayal of real people in drama, Chapter 2
Premium rate telephone services, Chapter 32
.....call cut offs, Chapter 32
.....and charities, Chapter 30, Chapter 32
.....children's services, Chapter 32
.....and competitions, Chapter 32
.....and donations to charity and charity appeals, Chapter 30, Chapter 32
.....duration of calls, Chapter 32
.....financial arrangements, for, Chapter 32
.....guidelines concerning, Chapter 31, Chapter 32
.....and independent productions, Chapter 32
.....and non-BBC services, Chapter 32
.....paying for support material via, Chapter 31
.....and phone-in polls, Chapter 32
.....price message, Chapter 32
.....voting by, Chapter 32
Preparation for interviews, Chapter 13
Presentations of awards and sponsorship, Chapter 28
Presenters
.....conflicts of interest, see conflicts of interest
.....and personal view programmes, Chapter 2, Chapter 10
.....and promotional activities, Chapter 10
.....use of in commercials, Chapter 10, Chapter 29
20
RFI20080896
Press, rel
ations with, Chapter 41
Prevention of Terrorism Act, Chapter 15
Price messages and call cut offs, Chapter 32
Prisoners and prisons, Chapter 15
Privacy and the gathering of information, see Chapter 4 and Chapter 5
.....CCTV Footage, Chapter 4
.....comedy, light entertainment, Chapter 5
.....dead, injured and missing, Chapter 12
.....depicting trauma, Chapter 12
.....doorstepping, Chapter 4
....."fishing expeditions", Chapter 5
.....funerals, Chapter 12
.....grief and distress,surreptitious recording of, Chapter 5
.....interviews with those injured or grieving, Chapter 12
.....laws of privacy in other parts of the world, Chapter 4
.....library use of scenes of suffering, Chapter 12
.....long lenses, use of, Chapter 5
.....media scrums, Chapter 4
.....and missing people, Chapter 4
.....open recording in public when the subject is on private property,
Chapter 4
.....private property, operating on, Chapter 4
.....protecting by-standers, Chapter 5
.....public figures, Chapter 4
.....recording telephone calls, Chapter 5
.....reporting accidents and disasters, Chapter 12
.....re-visiting past events, Chapter 12
.....secret recordings made by others, Chapter 5
.....social research, Chapter 5
.....surreptitious recording, see Chapter 5
.....unwarranted infringement of privacy and BSC, see Chapter 43
Prizes, Chapter 22
.....cash, Chapter 22
.....donated, Chapter 22
.....in jointly organised competitions, Chapter 22
.....substantial, Chapter 22
Product placement, Chapter 25
Product prominence, Chapter 25
Products used as props, Chapter 25
Programme Complaints Unit, see Chapter 42
Programme Legal Advice Department, Chapter 37
Programme material, from outside sources, see Chapter 26
Programme material, requests for, Chapter 17
Programmes related events, Chapter 28
Promotion of events, Chapter 28
Promotional activities and conflicts of interest, Chapter 10
Promotions, joint, Chapter 24
Pronunciation of place names, Chapter 19
Props
.....supply of, Chapter 25
.....use of products as, Chapter 25
Protection of Children Act, Chapter 6, Chapter 14
Public, relations with, Chapter 41
Public appearances and conflicts of interest, Chapter 10
Publications, mentions of on-air, Chapter 25
Publications reviewed on-air, Chapter 25
Publicity Departments, BBC, Chapter 41
21
RFI20080896
P ublicity departments, working with, Chapter 41
Q
Qualified privilege, of parliamentary proceedings, Chapter 33
Quoting viewers and listeners letters on-air, Chapter 41
Quiz shows, Chapter 6, and see Chapter 22
.....co-sponsored events, Chapter 22
.....fair treatment of contestants, Chapter 22
.....ITC restrictions, Chapter 22
.....legal considerations, Chapter 22
.....prizes, Chapter 22
.....prizes in jointly organised competitions, Chapter 22
.....safety, Chapter 22
.....selecting contestants, Chapter 22
R
Race, see ethnic minorities
Race Relations Act, 1976, Chapter 37
Racial Discrimination, Chapter 37
Racist abuse, terms of, Chapter 6
Radio credits and sponsored sports events, Chapter 28
Radio and taste and decency issues, Chapter 6
Radio Times, Chapter 6, Chapter 19
Raids, police, Chapter 16
Reconstruction, Chapter 2
Reconstructions, of crime, Chapter 15
Record companies, copyright, Chapter 40
Record companies, work for, see music production
Recording telephone calls, Chapter 5
Red Nose Appeal, Chapter 30
Refusals to take part in programmes, Chapter 3
Refusals to take part in programmes, by politicians, Chapter 33
Referendums, Chapter 34
Referral and consultation, see Chapter 1
Referral
.....anonymity, granting, Chapter 1
.....animals, filming of, Chapter 20
.....attending a crime, Chapter 1
.....co-funding, Chapter 24
.....commercial referrals, Chapter 1
.....confidential sources, Chapter 1, Chapter 17
.....conflicts of interest, Chapter 10
.....co-productions, Chapter 24
.....co-sponsored competitions, Chapter 22
.....coverage of illegal activity, Chapter 15
.....credits for sponsors of events, Chapter 28
.....DA Notices, Chapter 18
.....defamation, Chapter 38
.....doorstepping, Chapter 1, Chapter 4
.....election coverage, Chapter 34
.....emergency appeals, Chapter 30
.....events sponsored by BBC magazines, Chapter 28
.....featuring real persons in drama without consent, Chapter 1
.....interviewing children, Chapter 14
.....interviews with criminals, Chapter 1, Chapter 15
.....interviews with party leaders Chapter 1, Chapter 33
.....interviews in prison, Chapter 1, Chapter 15
.....interviews with terrorists, Chapter 1, Chapter 15, Chapter 18
22
RFI20080896
.....i
nterviews with witnesses Chapter 1, Chapter 15
.....legal referral, Chapter 37
.....library material of scenes of suffering, Chapter 12
.....mandatory referrals, Chapter 1
.....national security Chapter 1, Chapter 18
.....Northern Ireland, Chapter 1, and see also Chapter 19
.....Official Secrets Act, Chapter 18
.....opinion polls, Chapter 1, Chapter 35
.....payment to criminals, Chapter 1, Chapter 15
.....presenters involved in promotional activities, Chapter 10
.....promotion of BBC merchandise, Chapter 27
.....publishing the name of a sex offender, Chapter 1, Chapter 15
.....recording a crime, Chapter 1, Chapter 5
.....recording telephone calls, Chapter 5
.....releasing untransmitted material, Chapter 1, Chapter 17
.....re-used and reversioned material, Chapter 21
.....staged events by terrorist groups, Chapter 18
.....strong language, Chapter 1, Chapter 6
.....surreptitious recording, Chapter 1, Chapter 5
.....untransmitted material, Chapter 17
.....violence in fiction, Chapter 7
Refusal to take part in programmes, Chapter 3, Chapter 33
Regional variations across the United Kingdom, Chapter 19
.....general, Chapter 19
.....language and style, Chapter 19
Registered trade marks, Chapter 38, Chapter 40
Relations with the Police, see Chapter 16
Relations with the Press, Chapter 41
Relations with the Public, Chapter 41
Religion and comedy, Chapter 6
Religion and taste and decency issues, Chapter 6
Religious groups, portrayal of, Chapter 9
Religious sensibilities and language, Chapter 6
Religious sensitivities about smoking and drinking, Chapter 8
Repeated programmes
.....checking for accuracy, Chapter 2
.....legal issues in, Chapter 37
.....re-use and reversioning of, see Chapter 21
Reporters, promotions undertaken by, Chapter 29
Reporting
.....bomb warnings, Chapter 18
.....Committal Proceedings, Chapter 37
.....confidential sources, Chapter 17
.....crime, see Chapter 15
.....the dead, Chapter 12
.....dead injured or missing, naming of, Chapter 12
.....demonstrations, Chapter 16
.....disasters, tragic events and grief Chapter 4, and see Chapter 12
.....illegal activities, Chapter 15
.....in times of national emergency and military action, Chapter 2
.....naming individuals who are reported dead, injured or missing, Chapter
12
.....Northern Ireland, see Chapter 18
.....opinion polls, Chapter 35
.....quality of, objectivity, impartiality, Chapter 2
.....suffering and distress, Chapter 5
.....terrorism, see Chapter 18
23
RFI20080896
.....the Uni
ted Kingdom, see Chapter 19
.....violence, Chapter 7
Representation of the People Act, Chapter 34
Requests for Programme material, see Chapter 17
.....transmitted, Chapter 17
.....untransmitted, Chapter 17
Research, fairness and accuracy of, Chapter 3
Reuse and reversioning, see Chapter 21
.....accuracy, checking, Chapter 21
.....clearance for reuse, Chapter 21
.....of criminal activity, Chapter 21
.....legal considerations, Chapter 21
.....logging concerns, Chapter 21
.....rescheduling considerations, Chapter 21
.....responsibilities for, Chapter 21
.....sensitive material, Chapter 21
.....of surreptitious recording, Chapter 21
Reviews of products or services, Chapter 25
Right of reply, Chapter 2
Rights, Chapter 40
Rights, artists', Chapter 21, Chapter 40
Rights Group, Chapter 40
Risks to participants in game and people shows, Chapter 22
Royal Family, interviews with, or exclusive appearances by, members of
the, Chapter 1
Royal Liaison Officer, Chapter 1
Royalties, Chapter 40
R.P.A. (Representation of the People Act), Chapter 34
S
Safety, Chapter 22, Chapter 37
Scheduling
.....of re-used material, Chapter 21
.....taste and decency issues in, Chapter 6, Chapter 7 (see also the
Watershed)
.....on Worldwide Television, Chapter 6, Chapter 7
School holidays, differences in, Chapter 6, Chapter 19
School hours, filming during, Chapter 14
Schools stories, national considerations, Chapter 19
Scotland
.....laws of trespass in, Chapter 37
.....political parties in, Chapter 33
.....referral on Scottish law, Chapter 37
.....reporting of, see Chapter 19
.....Scottish Parliament, reporting, Chapter 33, Chapter 34
.....Scottish parliamentary elections, Chapter 34
.....style and language, differences in, Chapter 19
Seat belts, Chapter 8
Secret recording, see surreptitious recording
Sensationalism, avoiding, Chapter 6
Sensitivity to offence and outrage, Chapter 2
Series provision, the, Chapter 2
Sex
.....and children, Chapter 6
.....in drama, Chapter 6
.....in factual programmes, Chapter 6
.....portrayal of, Chapter 6
24
RFI20080896
.....on tel
evision, Chapter 6
.....sexual innuendo, Chapter 6
.....simulated, Chapter 6
Sex offenders, naming, Chapter 1, Chapter 15
Sexual crime, reporting, Chapter 15
Sexual innuendo, Chapter 6
Sexual orientation, portrayal of, Chapter 9
Sexuality, acknowledging, Chapter 6, Chapter 9
Shareholdings, Chapter 10
Sieges, Chapter 16
Signposts, Chapter 6
Slander, see defamation
Smoking and drinking portrayal of, Chapter 8
.....in children's programmes, Chapter 8
.....religious sensitivities about, Chapter 8
Social action programming, see Chapter 30
.....campaigning groups, Chapter 30
.....impartiality, Chapter 30
.....and support services and material, see Chapter 31
Social and anti-social behaviour, imitation of, Chapter 8
Social research and surreptitious recording, Chapter 5
Song lyrics, explicit, Chapter 6
SOS messages, Chapter 26
Sources
.....achieving accuracy, Chapter 2
.....reporting statistics, Chapter 2
.....reporting accidents and disasters, Chapter 12
Sources, confidential, Chapter 17
Sponsored events, Chapter 24, and see Chapter 28
Sponsored events, titles of, Chapter 28
Sponsored programmes, Chapter 24
Sponsored sports events, news coverage of, Chapter 28
Sponsored sports events, television coverage of, Chapter 28
Sponsorship
.....of BBC events, Chapter 24, Chapter 28
.....by BBC magazines, Chapter 28
.....on BBC's international television channels, guidelines, Chapter 24
.....of presentations and awards, Chapter 28
.....of telephone support lines, Chapter 31
Sports coverage, computer credits in, Chapter 26
Staged events by terrorist groups, Chapter 18, Chapter 19
Staging and restaging events, Chapter 2
Statements made in Parliament, legal protection around reporting, Chapter
33
Statistics, accurate use of, Chapter 2
Statistics, use of in crime stories, Chapter 15
Stereotypes, Chapter 6
Stereotypes, hurtful or inaccurate, Chapter 9
Stereotypes, regional, Chapter 19
Stereotypes in Comedy, Chapter 6
Stereotyping, of gays and lesbians, Chapter 9
Still photographs, for reporting trauma, Chapter 12
Stills of tobacco sponsored sport, Chapter 28
Strobing, risks of, Chapter 37
Strong language, Chapter 6
Strong language referral procedure, Chapter 1
Studio polls, Chapter 35
25
RFI20080896
Su
bliminal images, Chapter 37
Suffering and distress, Chapter 5, and see Chapter 12
.....reusing material, Chapter 21
Suicide, Chapter 7, Chapter 8
Support services, see Chapter 31
.....audience feedback, measuring, Chapter 31
.....and CD-Roms, Chapter 31
.....and Ceefax, Chapter 31
.....and Commercial Policy Guidelines, Chapter 31
.....Credits for, Chapter 31
....."Dial and listen" Information lines, Chapter 31
.....Distribution of support material, Chapter 31
.....factsheets and booklets, Chapter 31
.....funding for support services, Chapter 31
.....helplines, Chapter 31
.....joint initiatives, Chapter 31
.....online services and the Internet, Chapter 31
.....paying for via premium rate number, Chapter 31
.....social action programmes, Chapter 30
.....social action programmes and support services and material, Chapter
30
.....support material, distribution of, Chapter 31
.....telephone helplines, Chapter 31
.....trails, Chapter 31
Surreptitious recording, Chapter 4, and see Chapter 5
.....approval of, Chapter 5
.....comedy and entertainment, Chapter 5
.....disguising identities, Chapter 5
....."fishing expeditions", Chapter 5
.....general principles of, Chapter 5
.....of grief and distress, Chapter 5
.....investigating crime, Chapter 5
.....long lenses, use of, Chapter 5
.....made by others, Chapter 5
.....mandatory referral, Chapter 1
.....of people in private, Chapter 5
.....in public places, Chapter 5
.....recording telephone calls, Chapter 5
.....re-use of, Chapter 21
.....social research, Chapter 5
.....unattended recording devices ("bugging"), Chapter 5
....."unwarranted infringement of privacy", Chapter 43
.....video cameras, use of, Chapter 5, (see also secret recording)
Surveys, see opinion polls
T
Tag along raids, Chapter 16
Tailoring to time, in interviews, Chapter 13
Taste and decency, see Chapter 6
.....acquired programmes, Chapter 6
.....blasphemy, Chapter 6
.....and the BSC, see Chapter 43
.....children, Chapter 6
.....comedy and entertainment, Chapter 6
.....films, Chapter 6
.....four letter words, use of, Chapter 6
.....four letter words, referral procedure for, Chapter 1, Chapter 6
26
RFI20080896
.....game and peopl
e shows, Chapter 6
.....and international broadcasting, Chapter 6
.....language, Chapter 6
.....online material, Chapter 6
.....phone-ins, Chapter 6
.....programme billings and signposting, Chapter 6 and Chapter 7
.....Protection of Children Act, 1978, Chapter 6
.....racist abuse, Chapter 6
.....radio and taste and decency issues, Chapter 6
.....religion and comedy, Chapter 6
.....religious sensibilities and language, Chapter 6
.....re-used material, Chapter 21
.....scheduling, Chapter 6, Chapter 7 (see also the Watershed)
.....scheduling considerations on radio, Chapter 6
.....sex, Chapter 6
.....sexual innuendo, Chapter 6
.....signposts, Chapter 6
.....songs which feature strong language or explicit content, Chapter 6
.....stereotypes in comedy, Chapter 6
.....strong language, Chapter 6
.....television: the Watershed, Chapter 6
.....tragic events Chapter 6, and see Chapter 12
.....trails on television and radio, Chapter 6
.....the Watershed, Chapter 6
.....the Watershed and Worldwide television, Chapter 6
.....World Service, scheduling considerations on, Chapter 6
Telephone calls
....."dial and listen", Chapter 31
.....phone-in polls, Chapter 32, Chapter 35
.....phone-ins, Chapter 6, Chapter 32
.....premium rate, and charity, welfare etc, subjects, Chapter 30, Chapter
32
.....and premium rate telephone lines, Chapter 32
.....to and from prison, Chapter 15
.....recording, Chapter 5
.....reporting the results of, Chapter 35
.....from viewers and listeners, dealing with, Chapter 41
Telephone "doorstep", Chapter 5
Telephone helplines, Chapter 31, Chapter 32
Telephone voting, Chapter 32
Television coverage of sponsored sports events, Chapter 28
Television Credit Guidelines, Chapter 24
Television Programme Acquisition Department, Chapter 40
Television Without Frontiers, European Directive, Chapter 6, Chapter 37
Terrorism, see Chapter 18
.....bomb warnings, Chapter 18
.....individuals at risk, Chapter 18
.....language and terminology, Chapter 18
.....staged events, Chapter 18, Chapter 19
Terrorists, interviews with, Chapter 18
.....referral procedure for, Chapter 1, Chapter 18
Tickets, Chapter 22, Chapter 23, Chapter 32
Titles of sponsored events, Chapter 28
Tobacco sponsored events, stills of, Chapter 28
Tobacco sponsored non sporting events, Chapter 28
Tobacco sponsorship, Chapter 28
.....voluntary code for coverage of, Chapter 28
27
RFI20080896
T one and Tactics, in interviews, Chapter 13
Trade Marks, see Chapter 38, Chapter 40
Tragic events, dealing with on Radio and Television, Chapter 6
Tragic events and non factual programmes, Chapter 12
Trails
.....during children's programmes, Chapter 6
.....and commercial channels, Chapter 27
.....and commercial products, Chapter 24
.....and support services, Chapter 31
.....and the Watershed, Chapter 6
.....and violence, Chapter 7
.....for BBC Products or Publications, Chapter 27
.....for the National Lottery, Chapter 23
Transmitted Material, requests for, Chapter 17
Trauma, depicting, Chapter 12
.....in re-used material, Chapter 21
Trespass, Chapter 5, Chapter 37
.....civil trespass, Chapter 37
.....criminal trespass, Chapter 37
.....in Scotland, Chapter 37
U
Unattended recording devices ("bugging"), Chapter 5
Undue prominence of branded products and services in programmes,
Chapter 25
Unjust or unfair treatment in a programme, see Chapter 43
United Kingdom Disasters Emergency Committee, Chapter 30
Unreasonable demands by interviewees, Chapter 13
Unsolicited donations, to charity, Chapter 30
Untransmitted material, requests for, Chapter 17
.....access to, Chapter 17
.....mandatory referral, Chapter 1
.....and police raids, Chapter 16
.....viewing of, Chapter 17
"Unwarranted infringement of privacy" and the BSC, Chapter 43
V
Vandalism, portrayal of, Chapter 8
Verbal aggression, Chapter 7
Victims of crime, Chapter 15
Victims of crime, identification of, Chapter 37
Victims of sexual offences, identification of, Chapter 37
Video cameras use of, Chapter 5
Video and film copyright, Chapter 40
Video recording from outside sources, use of, Chapter 26
Viewer and listener competitions, see Chapter 22
Viewers and listeners correspondence, Chapter 41
Violence, see Chapter 7
.....and acquired programmes, Chapter 7
.....and adult drama, Chapter 7
.....involving animals, Chapter 7
.....and the BSC, see Chapter 43
.....against children, Chapter 7
.....in factual programmes, Chapter 7
.....in fiction, Chapter 7
.....in the news, Chapter 7
.....in programmes for children, Chapter 7, Chapter 8
.....real life violence, Chapter 7
28
RFI20080896
.....schedul
ing, warnings and the Watershed, Chapter 7
.....verbal aggression, Chapter 7
.....and the Watershed, Chapter 7
.....against women, Chapter 7
Voice-overs, using, Chapter 3
Voluntary code for coverage of tobacco sponsorship, Chapter 28
Voting intention polls, Chapter 35
Voting, interactive, Chapter 35
Voting by phone, Chapter 32
Vox pop interviews, Chapter 35
W
Wales
.....National Assembly for, reporting, Chapter 33, Chapter 34
.....reporting of, see Chapter 19
.....style and language, differences in, Chapter 19
.....Welsh Assembly elections, Chapter 34
War, reporting in times of, Chapter 2
Watershed, the, Chapter 6
.....and language, Chapter 6
.....and radio, Chapter 6
.....and scheduling, Chapter 6
.....and sex, Chapter 6
.....and trails, Chapter 6
.....and violence, Chapter 7
.....and Worldwide Television, Chapter 6, Chapter 7
Weapons, Chapter 8
.....close ups of, in reconstructions of crime, Chapter 15
Wheelchairs, people using, Chapter 9
Wildlife filming, see animal filming
Witnesses, dealing with, Chapter 15
.....identification of, Chapter 37
.....interviews with, Chapter 15
.....mandatory referral, Chapter 1, Chapter 15
.....payment of, Chapter 15
Witnessing of illegal activity by programme makers, Chapter 15
Women, portrayal of, Chapter 9
Women, violence against, Chapter 7
Working abroad, Chapter 3
World Service and fact sheets and support materials, Chapter 30
World Service and overseas elections, Chapter 34
World Service, complaints about, see Chapter 42
World Service, scheduling considerations on, Chapter 6
Worldwide Legal Department, Chapter 37
Worldwide Television and competitions, prizes and games shows, Chapter
22
Worldwide Television and fact sheets and support materials, Chapter 30
Worldwide Television and the Watershed, Chapter 6, Chapter 7
XYZ
Youth court proceedings, Chapter 14
29
RFI20080896
CHAPTER 1
CONSULTATION AND REFERRAL
1 GENERAL
2 INDEPENDENT PRODUCTIONS
3 WHEN TO REFER
4 WHERE TO REFER
5 MANDATORY REFERRALS
6 THE LAW
7 CONFIDENTIALITY
8 EDITORIAL POLICY UNIT
1
GENERAL
The Producers’ Guidelines apply to all the BBC’s broadcasting, programmes and services for
both domestic and international audiences, whether they are television, radio or online, and
whether made by a BBC department or by an independent company for the BBC.
The Guidelines help programme makers navigate their way through difficult editorial issues
so that distinctive and sometimes controversial programmes can be made which maintain the
highest ethical and editorial standards. The consultation and referral system is designed to
help BBC people make, and share, decisions about especially difficult editorial issues.
Any proposal to step outside these guidelines needs to be discussed with someone at a senior
level and should be referred to Controller, Editorial Policy.
2
INDEPENDENT PRODUCTIONS
Independent productions made for the BBC must observe the same standards as in-house
productions and must conform to BBC programme-making policy. Ultimate responsibility for
the methods and content of any material commissioned by the BBC rests with the BBC.
Independent producers are expected to observe the Producers' Guidelines and any difficult
areas should be identified and discussed at the time of commissioning whenever possible.
All contracts with an independent programme maker or re-broadcaster must include
their obligation to observe all relevant sections of the Producers’ Guidelines. On certain
independent commissions it may also be necessary to include an amendment to the standard
contract so that the BBC has an influence in the recruitment of researchers as well as other
key editorial staff.
The appropriate point of referral for Independent Producers is the relevant BBC
Commissioning Executive.
3
WHEN TO REFER
The earlier a contentious programme can be referred the better. An early discussion can often
enable a way to be found round tricky issues and enable a programme to be made without last
minute debate and changes. Late referral benefits no one. If in doubt, refer early.
4
WHERE TO REFER
Programme departments carry the main responsibility in the referral system, so programme
makers should refer first to their manager or editor. All producers, managers and editors
should have a working knowledge of the in the Producers’ Guidelines, particularly where they
30
RFI20080896
affect their specific program
me areas. Individual departments should be able to deal with, and
take responsibility for, most queries in the first instance.
The more important and contentious the issue, the higher up it should be referred. This may
lead to the relevant Head Of Department, or Commissioning Executive. The first point of
referral is always the Editor or Commissioning Executive. If Editorial Policy needs to be
consulted the Editor or Executive should make the call.
Editorial Policy should
always be consulted in the following cases:
•
mandatory referrals to Controller, Editorial Policy and Chief Political Adviser, and Chief
Adviser (see Section 5 below).
•
queries over how to interpret the Producers’ Guidelines
•
any proposal to step outside the Producers’ Guidelines
5
MANDATORY REFERRALS
The following controversial matters
must be referred:
All of the following must be referred to Controller, Editorial Policy. All should be
referred to Heads of Department or Commissioning Executives first:
•
any proposal to interview those directly associated with terrorist acts in the United
Kingdom. See Chapter 18
•
national security matters, including anything that is the subject of a Defence Advisory
Notice. See Chapter 18
• interviews with serious criminals and people sought by the police. See Chapter 16
•
payment to criminals or former criminals. See Chapter 15
•
any proposal to pay for an interview with a witness in a current or pending criminal trial.
See Chapter 15
•
any proposal to grant anonymity to anyone trying to evade the law in the United
Kingdom. See Chapter 15
•
any proposal to record or attend a specific crime. See Chapter 15
•
any proposal to enter a prison to conduct an interview with a prisoner for broadcast
without the permission from the prison authorities. See Chapter 15
• any proposal to publish the name of a released sex offender who has served their
sentence, when that name has not been made public by the Police. See Chapter 15
• using an unattended recording device on private property. See Chapter 5
• broadcasting any surreptitious recording originally made for legal or note taking purposes
see Chapter 5
31
RFI20080896
•
any proposal to show or feature people in a live broadcast for entertainment purposes
using a hidden camera or microphone. See Chapter 5
•
broadcasting a recording made secretly by anyone outside the BBC. See Chapter 5
•
"doorstepping without prior approach"- confronting an interviewee whilst recording,
when there has been no prior approach for an interview, and the interviewee has no
expectation of being approached. See Chapter 4
• requests from outside the BBC to see or obtain untransmitted recorded materials. See
Chapter 17
•
any proposal to feature a real person in a drama where their permission, or the permission
of their surviving relatives has not been secured. See Chapter 2
If any of the above have a connection with Northern Ireland they must also be referred to
Controller Northern Ireland or in the case of News programmes
Head of News and
Current Affairs Northern Ireland.
Both of the following must be referred to the Chief Political Advisor, Editorial Policy:
•
commissioning of opinion polls on any political issue or issue of public policy. See
Chapter 35
•
interviews with the leaders of any UK political party (short news interviews need not be
referred). See Chapter 33
Other important issues listed below must also be referred:
•
any long term programme intentions about
Northern Ireland, whether factual or
otherwise, should be discussed with Controller Northern Ireland or nominee.
Proposals
should be discussed at an early stage. Repeated consultations may be necessary with the
BBC in Belfast during the making of the programme. See Chapter 19
•
Strong language - the use of the most offensive four letter words must be approved by
the relevant Channel Controller, in the case of the World Service language sections, the
Head of Region, and for online services the Director of BBC ONLINE. See Chapter 6
•
Surreptitious recording – all proposals must be referred to the head of programme
department, National Controller, Commissioning Executive or in the World Service, the
Head of Region with further reference to Controller Editorial Policy if necessary. See
Chapter 5
•
any request from programmes outside BBC News for interviews with, or exclusive
appearances by, members of the Royal Family must be discussed with the BBC’s Royal
Liaison Officer
•
any proposal to use a tourist visa to enter a country when the intention is to work for the
BBC must be referred to the relevant Head of Department. See Chapter 3
32
RFI20080896
•
any proposed advertisement to recruit contributors for factual programmes must be
referred via Department Heads, Commissioning Executives or their equivalent to the
relevant Directorate representative. See Chapter 3
The Controller of the relevant Nation (Scotland, Wales, Northern Ireland) must be
informed in advance in writing of:
•
plans by producers outside the nation to produce programme material which significantly
deals with national issues or themes, or which is based in the relevant nation.
•
in the case of Ireland, Controller Northern Ireland should also be alerted to all significant
projects involving the Republic of Ireland as well as those about Northern Ireland.
Chief Adviser Editorial Policy (Multimedia and Commercial) must be consulted in
advance about:
•
Any proposal for outside sponsorship of a BBC event. See Chapter 28
•
Any proposal for a BBC magazine to sponsor an established outside event mounted by a
non-BBC organisation. See Chapter 28
•
Any coverage of a BBC event mounted by BBC Worldwide in conjunction with BBC
magazines. See Chapter 28
•
Any proposal to mount coverage of a non Sports event sponsored by a tobacco related
brand. See Chapter 28
6 THE LAW
Broadcasting is fraught with legal risks, such as defamation or contempt, which can affect any
area of programming. Legal problems may arise not just with what we broadcast but with how
we make programmes. The BBC has its own team of programme lawyers and they need to be
consulted at the earliest possible stage about programmes which may run legal risks.
While lawyers can offer legal advice, the final decision remains an editorial one. If
programme makers wish to continue with a programme despite legal advice they must refer
upwards to Head of Department, National Controller, or Commissioning Executive (see also
Matters Of Law, chapters 37-40 of these guidelines).
7 CONFIDENTIALITY
The protection of confidential sources is a serious matter for any journalist or programme
maker and has potential consequences for the Corporation as a whole. In circumstances where
legal action might be taken to try and discover a source it will normally be appropriate to refer
to a high level before agreeing to maintain confidentiality (see also Chapter 17:
Confidentiality and Release of Programme Material).
8 EDITORIAL POLICY UNIT
The Editorial Policy Unit offers advice on specific problems and issues that programme
makers may have and how the BBC’s editorial policies apply. Heads of Department and
33
RFI20080896
Com
missioning Executives who need advice about difficult editorial issues can consult the
Unit, which offers a 24 hour service.
The Unit draws up and reviews the Producers’ Guidelines, and other editorial policy, and can
offer advice on interpreting the Guidelines.
The Producers’ Guidelines are also available on the Editorial Policy website on the BBC’s
Gateway intranet. The site also contains other relevant guidelines (e.g. BBC ONLINE
Guidelines), and urgent advice on specific editorial policy issues.
CHAPTER 2
IMPARTIALITY & ACCURACY
CHAPTER 2:
IMPARTIALITY & ACCURACY
PART ONE:
1 OUR JOURNALISTIC VALUES
2 IMPARTIALITY IN GENERAL
3 FACTUAL PROGRAMMES
4 NON-FACTUAL & ARTS PROGRAMMES
5 PARTY POLITICAL, PARTY ELECTION, AND MINISTERIAL BROADCASTS
PART TWO:
1 ACHIEVING ACCURACY
2 CORRECTING MISTAKES
3 ACCURATE LANGUAGE
4 REPORTING STATISTICS
5 RECONSTRUCTION
6 STAGING AND RE-STAGING EVENTS
7 USE OF COMPUTER GRAPHICS
8 USE OF LIBRARY FOOTAGE
9 CHECKING RECORDED OR REPEATED PROGRAMMES
PART ONE
1 OUR JOURNALISTIC VALUES
Accurate, robust, independent, and impartial, journalism is the DNA of the BBC. Audiences
should always feel they can trust our words and our deeds. If we live in a more diverse and
fragmented society, the BBC must continue to stand out as a place where people feel they are
being told openly and honestly about what is happening in the world; where they can rely on
34
RFI20080896
unbiased and im
partial reporting and analysis to help them make sense of events; and where a
debate can take place in which relevant and significant voices are heard, including those who
have uncomfortable questions to ask.
The BBC’s journalistic promise is rooted in five basic editorial values set out in the Neil
Report (June 2004) on which there can be no compromise. They are:
• Truth and Accuracy
• Serving the Public Interest
• Impartiality and Diversity of Opinion
• Independence
• Accountability
Truth and Accuracy
We will always strive to establish the truth of what has happened as best we can.
We aim for the highest possible levels of accuracy and precision of language. Our journalism
will be well sourced, based on sound evidence, and thoroughly tested. It will rely on fact
rather than opinion, and be set in context. We will be honest and open about what we don’t
know and avoid unfounded speculation.
Serving the Public Interest We seek to report stories of significance, striving to make them interesting and relevant to all
our audiences. We will be vigorous in trying to drive to the heart of the story, and well
informed when explaining it. Our specialist expertise will bring authority and understanding
to the complex world in which we live. We will be robust, but fair and open-minded, in
asking searching questions of those who hold public office and in reporting that which it is in
the public interest to reveal. Our news and current affairs journalism will never campaign, but
pursue journalistically valid issues and stories, without giving undue prominence to any one
agenda. We will provide a comprehensive forum for public debate at all levels.
Impartiality and Diversity of Opinion
We report the facts first. Understand and explain their context. Provide professional
judgements where appropriate, but never promote our own personal opinions. Openness and
independence of mind is at the heart of practising accuracy and impartiality. We will strive to
be fair and open minded by reflecting all significant strands of opinion, and by exploring the
range and conflict of views. Testing a wide range of views with the evidence is essential if we
are to give our audiences the greatest possible opportunity to decide for themselves on the
issues of the day.
Independence The BBC is independent of both state and partisan interest and will strive to be an
independent monitor of powerful institutions and individuals. We will make our journalistic
judgments for sound editorial reasons, not as the result of improper political or commercial
pressure, or personal prejudice. We will always resist undue pressure from all vested interests,
35
RFI20080896
and will jealously protect the independence of our editorial judgm
ents on behalf of our
audiences. Whatever groups or individuals may wish us to say or do, we will make all
decisions based on the BBC’s editorial values.
Accountability
Our first loyalty is to the BBC’s audiences to whom we are accountable. Their continuing
trust in the BBC’s journalism is a crucial part of our contract with them as licence payers. We
will act in good faith at all times, by dealing fairly and openly with the audience and
contributors to our output. We will be open in admitting mistakes when they are made,
unambiguous about apologising for them, and encourage a culture of willingness to learn
from them.
These values are the code of conduct for every person who practises journalism in the BBC at
whatever level. But editors have a special responsibility as the day-to-day custodians of BBC
values. Senior commissioning and programme editors must take an important role of
leadership in ensuring that all BBC presenters and journalists embrace these values. The scale
of BBC journalism carries risk. An important leadership role of any editor is to realise at what
point it is necessary to take senior editorial or legal advice.
2 IMPARTIALITY IN GENERAL
Due impartiality lies at the heart of the BBC. It is a core value and no area of programming is
exempt from it. All BBC programmes and services should show open-mindedness, fairness
and a respect for truth.
The BBC is committed to providing programmes of great diversity which reflect the full
range of audiences’ interests, beliefs and perspectives. Representing the whole spectrum is a
requirement on all programme genres from arts to news & current affairs, from sport to
drama, from comedy to documentaries, from entertainment to education and religion. No
significant strand of thought should go unreflected or under represented on the BBC.
In order to achieve that range, the BBC is free to make programmes about any subject it
chooses, and to make programmes which explore, or are presented from, a particular point of
view.
The BBC applies due impartiality to all its broadcasting and services, both to domestic and
international audiences.
In achieving due impartiality the term "due" is to be interpreted as meaning adequate or
appropriate to the nature of the subject and the type of programme. There are generally more
than two sides to any issue and impartiality in factual programmes may not be achieved
simply by mathematical balance in which each view is complemented by an equal and
opposing one.
The Agreement accompanying the BBC’s Charter specifies that the Corporation should treat
controversial subjects with due accuracy and impartiality both in news programmes and other
programmes that deal with matters of public policy or of political or industrial controversy. It
states that due impartiality does not require absolute neutrality on every issue or detachment
from fundamental democratic principles. The BBC is explicitly forbidden from broadcasting
its own opinions on current affairs or matters of public policy, except broadcasting issues.
36
RFI20080896
Special considerations, both legal and editorial, m
ay apply during the campaign periods for
elections (see Chapter 34: Broadcasting During Elections).
• This Chapter of the Producers’ Guidelines constitutes the BBC’s code as required by
section 5.3 of the Agreement associated with the BBC’s Charter, and gives guidance as to the
rules to be observed under section 5.1 (c) of the Agreement. The relevant sections of the
Agreement appear as an appendix to these Guidelines.
3 FACTUAL PROGRAMMES
3.1 Due impartiality within a programme
A factual programme dealing with controversial public policy or matters of political or
industrial controversy will meet its commitment to due impartiality if it is fair, accurate and
maintains a proper respect for truth. A programme may choose to explore any subject, at any
point on the spectrum of debate, as long as there are good editorial reasons for doing so. It
may choose to test or report one side of a particular argument. However, it must do so with
fairness and integrity. It should ensure that opposing views are not misrepresented.
There will be times where a wide range of views is appropriate, and times when a narrow
range is acceptable. The key is for programme makers to be fair to their subject matter, and to
ensure that right of reply obligations are met (see below).
Sometimes it will be necessary to ensure that all main viewpoints are reflected in a
programme or in linked programmes, for example, when the issues involved are highly
controversial and a defining or decisive moment in the controversy is imminent.
3.2 News programmes
The Agreement specifies that news should be presented with due accuracy and impartiality.
Reporting should be dispassionate, wide-ranging and well-informed. In reporting matters of
industrial or political controversy the main differing views should be given due weight in the
period during which the controversy is active. News judgements will take account of events
as well as arguments, and editorial discretion must determine whether it is appropriate for a
range of views to be included within a single programme or item.
News programmes should offer viewers and listeners an intelligent and informed account of
issues that enables them to form their own views. A reporter may express a professional,
journalistic judgement but not a personal opinion. Judgement must be recognised as
perceptive and fair. Audiences should not be able to gauge from BBC programmes the
personal views of presenters and reporters on controversial issues of public policy.
3.3 Presenters
Presenters are the public face and voice of the BBC’s journalism. The tone and approach that
they take to stories has a significant impact on the perceptions of the BBC’s impartiality.
Their presentation needs at all time to embody the core editorial values of the BBC.
3.4 Where a BBC programme or the BBC is the story
On occasions when a programme broadcast by the BBC, or the BBC itself, becomes the story,
we need to ensure that we do not put ourselves in a position where our impartiality is put into
question or presenters or reporters are placed in a potential conflict of interest. Our reporting
37
RFI20080896
m
ust remain accurate, impartial and fair even where the BBC is the story. It will be
inappropriate to refer to either the BBC or the programme as “we”. There should also be
clear editorial separation between those reporting the story and those responsible for
presenting the BBC’s case.
If the programme itself, or an interview by the programme’s presenter or presenters is the
centre of controversy, consideration should be given by senior editorial figures to whether any
follow up interviews on that programme should be undertaken by different presenters.
Editorial Policy advice should be sought.
3.5 The series provision
The Agreement provides that in observing due impartiality a series of programmes may be
considered as a whole. For this purpose there are two types of series:
•
a number of programmes where each programme is clearly linked to the other(s) and
which deal with the same or related issues.
Programmes may achieve impartiality over an entire series, or over a number of
programmes within a series. The intention to achieve impartiality across a number of
programmes should be planned in advance and normally made clear to audiences.
•
a number of programmes broadcast under the same title, where widely disparate issues
are tackled from one edition to the next.
In this type of series due impartiality should normally be exercised within each individual
programme.
Special considerations apply to "personal view" and "authored" programmes (see below).
Sometimes it may be appropriate, in order to achieve due impartiality, to link a programme or
a series with a follow-up discussion programme which looks at the issues raised and allows
other views to be put. Audiences should normally be informed of the follow-up programme
when the first programme is broadcast. The follow-up programme should closely follow the
original programme or be within a reasonable period of time after it having regard to the
length of the series.
3.6 Personal view programmes
The BBC has a long tradition of series which allow open access to the airwaves for a wide
range of individuals or groups to offer a personal view or advance a contentious argument.
These can add significantly to public understanding, especially when they bring forward
unusual and rarely heard perspectives on topics that are well-known from orthodox
viewpoints. They have a valuable position in the schedules. However, personal view
programmes which deal with matters of public policy, or of political or industrial controversy
entail special obligations:
• The nature of a personal view programme should be signalled clearly to audiences in
advance
38
RFI20080896
•
Editors should ensure that these programmes do not seriously misrepresent opposing
viewpoints. There should be proper respect for factual accuracy.
• It may be appropriate to provide an opportunity to respond to a programme, for example
in a right to reply programme or in a pre-arranged discussion programme.
• It is not appropriate for BBC staff, or for regular BBC presenters or reporters normally
associated with news or public policy related programmes, to present personal view
programmes on controversial matters.
While a series of personal view programmes which is a long-running fixture in the schedules
has no need to give equal time to every relevant point of view on each subject covered, there
must be a sufficiently broad range of views from a wide variety of perspectives within a
series.
For an occasional series of personal view programmes dealing with different aspects of the
same subject matter it will normally be necessary to achieve impartiality within the series.
3.7 Series that present a particular perspective
When a series is "authored" by an individual or a group representing a body of thought, it
should maintain a proper respect for facts and truth and should not ignore opposing points of
view. Special care is needed if a series takes a particular approach to a controversial issue.
This might reflect an original body of thought or research which may not be readily balanced,
or the analysis of a respected specialist in a particular field.
In the case of such “authored” series that take a particular approach to matters of political or
industrial controversy, care should be taken to ensure that during the year preceding or the
year following the series a sufficiently broad range of views and perspectives has been
included in a similar type of series or in programming of similar weight.
3.8 "Major matters"
Due impartiality is required in relation to all matters of public policy or industrial
controversy. But due impartiality is of special importance in relation to what paragraph 5.4 of
the Agreement refers to as "major matters". For networks these would be issues of
significance for the whole of the United Kingdom, such as a UK-wide public sector strike, or
highly contentious new legislation on the eve of a crucial Commons vote. In the nations and
regions , major matters would be issues of comparative importance having considerable
impact on the nation or region.
In dealing with major matters of controversy editors should ensure that a full range of
significant views and perspectives are heard during the period in which the controversy is
active.
3.9 Right of reply
Where a programme reveals evidence of iniquity or incompetence, or where a strong,
damaging critique of an individual or institution is laid out, there is a presumption that those
criticised be given a fair opportunity to respond. There may be occasions when this is
39
RFI20080896
inappropriate (usually for legal or overriding ethical reasons) in which case the Head of
Department should be consulted. It may then be appropriate to consider whether an
alternative opportunity should be offered for reply at a subsequent date.
3.10 Reporting in times of National Emergency and Military Action
In times of emergency or when a military action is under way, journalism may be constrained
by questions of national security. Such times are particularly testing for journalists, as for
others. Matters involving risk to, and loss of, life need handling with the utmost sensitivity to
national mood and feeling.
The public has, at the same time, a particular need for fast, trustworthy news and measured
assessment. Good journalism will be based on all available facts. The concept of impartiality
still applies. All views should be reflected in due proportion to mirror the depth and spread of
opinion in the United Kingdom.
3.11 Factual Programmes Not Dealing with Matters of Political or Industrial
Controversy
Documentaries, magazine and feature programmes of various kinds often properly
concentrate on a narrow area or give an opportunity, for example in an interview, for a single
view to be expressed.
Overall, such output seeks to represent reality. There remains an obligation to ensure that a
proper range of views and perspectives is aired over a reasonable time. This calls for
systematic review and continuing discussion so that the output builds into a complete mosaic.
3.12 Sensitivity to Offence and Outrage
In aiming to record all pertinent opinions programmes will sometimes need to report on or
interview people whose views will cause serious offence to many. In such cases programme
editors must be convinced, after referral where necessary, that there is a material public
interest to be served which outweighs the offence.
Questioning should not be hectoring, but when we interview people whose behaviour or
views cause real outrage we need to be sensitive to the opinions of the audience. Questioning
must be unmistakably firm, and answers should be challenged robustly and repeatedly if
necessary. It would be inappropriate for an interviewer to express personal offence or
indignation, but the questioning should recognise the public mood.
On occasion, particular events will greatly raise the level of emotion and it will be harder for
an audience to accept an impartial programme. Programme makers should not shy away from
tackling difficult issues in such circumstances, but careful consideration should be given to
the timing and the tone of the programme.
4. NON FACTUAL AND ARTS PROGRAMMES 4.1 Drama, Arts, Music and Entertainment Programmes
All these areas need to offer artists, writers and entertainers generous scope for individual
expression.
40
RFI20080896
Program
me executives in drama, arts and entertainment have a responsibility to ensure that
the BBC reflects the widest possible range of talent and perspective internationally, nationally
and regionally. This is a matter for regular review in the programme areas.
4.2 Drama Portraying Contemporary Situations & Drama-Documentaries
When drama realistically portrays living people or contemporary situations in a controversial
fashion, it has an obligation to be accurate - to do justice to the main facts. If the drama strives
for a fair, impartial and rounded view of events, no problem arises. If it is an accurate but,
nonetheless, partisan and partial portrayal of a controversial issue, the commissioning
executive should proceed only if convinced that the insight and excellence of the work justify
the platform offered; and that it will be judged honest, thoughtful and stimulating.
A clear distinction should be drawn between plays based broadly on fact or real characters
and dramatised documentaries which seek to reconstruct actual events. Audiences should be
clear as to whether they are watching fact or fiction.
Any dramatised reconstruction of a controversial current event should observe the standards
of fairness which apply to factual programmes dealing with such issues. It is inevitable that
the creative realisation of some elements, such as characterisation, dialogue and atmosphere,
will introduce a fictional dimension, but this should not be allowed to distort the known facts.
(see also section 7: Reconstruction in Part Two of this chapter).
4.3 Portrayal of Real People in Drama
Whenever appropriate, persons portrayed in a drama or their surviving near relatives should
be notified in advance and, where possible, their co-operation secured. Where their co-
operation or approval is withheld on reasonable grounds the portrayal should not proceed.
However, there may be occasions where the BBC will decide to proceed with such a portrayal
without the approval of the individual, where it can be shown that the programme serves a
substantial public interest and that the portrayal is fair. In deciding whether such a portrayal
should proceed, it will be necessary to take into account the extent to which the portrayal can
be shown to be based on a substantial and verifiable body of evidence.
In such instances where it is being proposed that the portrayal should proceed without the
approval of the individual portrayed,
or their surviving near relatives
the matter must be
referred to Controller Editorial Policy for approval before a commitment is made to the
production (see also Chapter 38, Matters of Law: Defamation).
4.4 History in Drama
Questions of accuracy, impartiality and fairness also arise in historical drama. Drama should
normally aim to give a fair account of historical events. But there are differing views about
history and producers should be aware of the likely critical reaction when they diverge from
received opinion. Portrayals of recent history may be particularly sensitive and controversy
often arises when drama questions the British role in an historical event.
If a drama of artistic merit is written from an obviously partial standpoint, the producer must
consider how to label and publicise it in order to make its nature clear. When a powerful
drama of this kind is likely to prove particularly controversial, the BBC will need to consider
whether to offer an alternative viewpoint in other types of programmes.
41
RFI20080896
Problem
s can arise when drama combines fictional characters with historical figures.
Producers should be certain that they are clearly aware of what is established fact and what is
fiction and that the public is not confused by the mixture.
4.5 Fact, Fiction and Labelling Great care must be taken in continuity announcements, trails and promotional material to
ensure that the audience is aware of the nature of the drama. Where fact and fiction are mixed
the public should be made aware of this. It must be made clear that the drama is only an
interpretation of a current or historical situation.
5 PARTY POLITICAL, PARTY ELECTION, and MINISTERIAL BROADCASTS
The content of party political broadcasts, party election broadcasts, and Ministerial broadcasts
(together with Opposition replies) is primarily a matter for the originating party or the
government and therefore is not required to achieve impartiality. The BBC remains
responsible for the broadcasts as publisher, however, and requires the parties to observe
proper standards of legality, taste and decency.
All such broadcasts must be clearly labelled, and audiences must be in no doubt that they are
hearing the views of a particular party.
The BBC seeks to achieve impartiality in the allocation of such broadcasts (see Chapter 36:
Party Broadcasts).
PART TWO: ACCURACY
1 ACHIEVING ACCURACY
The BBC must be accurate. Research for all programmes must be thorough. We must be
prepared to check, cross-check and seek advice, to ensure this. Wherever possible we should
gather information first-hand by being there ourselves or, where that is not possible, by
talking to those who were. Accuracy can be difficult to achieve. It is important to distinguish
between first and second-hand sources. An error in one report is often recycled in another.
Material already broadcast and newspaper cuttings can get out-of-date quickly or simply be
wrong.
Note taking: Accurate and reliable note taking is essential. Failure to take good notes, and
keep them safe, can lead to inaccuracy and expensive and lost law suits. Wherever
practicable, interviews with sources should be recorded on tape. In circumstances where
recording might inhibit the source, full shorthand or longhand notes are the best alternative.
Journalists should not rely on memory but refer back to their notes or tape. Writing up a fuller
version of an interview from memory afterwards is less reliable than “live” notes. Any key
points not found in the notes should be explicitly checked with the source before use.
With serious and major allegations, a full and accurate note of conversations is an essential
element in the BBC being confident about the broadcast. If notes give rise to any doubts
whatsoever about what was said, then the journalist must check their accuracy with the source
before broadcast. In any event, the editor as publisher should be satisfied as to the fullness
and accuracy of the note.
42
RFI20080896
Sources
: Programmes should be reluctant to rely on a single source. Where an unnamed
single source is relied upon, the story itself should be of significant public interest, and the
source of proven credibility and reliability, as well as in a position to have sufficient
knowledge of the events featured in the story. Granting anonymity to a source should never
be done casually or automatically. When the BBC uses an unnamed source we are asking our
audiences to trust us even more with the information we are broadcasting. A named on the
record source is always to be preferred.
Anonymous sources: However, the BBC will continue to report stories based on a single
source where the story is one of significant public interest and the correct procedures have
been followed. With an anonymous source, especially a source making serious allegations,
the audience should be told why the source is anonymous and, in the BBC’s view, credible. If
the source of an allegation has to remain anonymous, we must give the audience as much
accurate information as is compatible with protecting the identity of the source. We should
explain why the source is anonymous, why the programme is confident about using this
person as the source, and why we believe that source to be credible.
We should never mislead the audience about the nature of an anonymous source; it is better to
explain that we cannot give any information rather than offer speculation. Protection of
confidential sources is a fundamental principle of journalism.
We must never exaggerate the importance of an anonymous single source. The credibility of
an anonymous single source must be evaluated by the programme editor as the publisher.
They must be in a position to establish in detail the pedigree and provenance of the source.
Fair dealing requires that when a source of information demands to remain anonymous as a
condition of giving the information, the BBC must agree precisely with that source the way
he or she is to be described on air. There is a need to balance a source’s desire for
confidentiality with the need to ensure that editors are able to reach informed judgements
about whether a story should be broadcast.
As a general principle, whenever a story involves an anonymous source, the relevant editor
has the right to be told the name of that source. However the editor has the discretion not to
exercise that right. The seniority and track record of the correspondent is a relevant
consideration. In extreme cases involving serious allegations, the head of the division should
also have the right to know the name of a source. Some sources may insist that a reporter
does not reveal their identity to any other BBC person. We should resist this. If this happens,
the reporter should make clear that information so obtained may not be broadcast
The story itself should be discussed thoroughly within the editorial chain before broadcast.
Anonymous sources and allegations: Where it is proposed to broadcast serious allegations
made by an anonymous source or sources about an individual or an organisation, it should be
referred first to the relevant editor and then on to his or her output Head. The referral is to
establish whether the story meets a public interest test; to probe, as far as is practicable, its
accuracy, the credibility of the source, their possible motivation or level of knowledge, and
their reliability; what legal issues may arise, and whether the allegations have yet been put to
the subject of the story. (See later Fairness section.) Accuracy is more important than speed.
Scripting and two-ways: The report will need to be carefully scripted to flag the nature of
the allegation that is being made and be followed carefully. It will normally be appropriate to
attribute clearly when the allegation comes from an anonymous source, indicate whether there
43
RFI20080896
has been independent corroboration, and m
ake it clear that the allegation is being made by the
source not the BBC.
Live, unscripted two-way exchanges should normally not be used to report allegations of
serious wrong doing. The editor must decide whether a live two-way is the appropriate and
safest way to break the story. The seniority and track record of the correspondent is a relevant
consideration.
When later programmes follow up on the original story, the editors should ensure that they
understand the terms in which the allegations are to be reported.
Agency reports: The reliability of news agency reports, especially from overseas, varies
according to the agency, the bureau and the reporter. It is good practice not to run a story
from one agency unless it can be substantiated by a BBC correspondent or another agency.
The World Service newsroom and language services can often advise on agency and bureau
reliability, as well as providing context for foreign news stories and advice on pronunciation
and geography.
Weighing the facts: Accuracy is often more than a question of getting the facts right. All the
relevant facts and information should be weighed to get at the truth of what is reported or
described. If an issue is controversial, relevant opinions as well as facts may need to be
considered. If an item is legally contentious, its accuracy must be capable of withstanding
scrutiny in a court of law.
2 CORRECTING MISTAKES
When a serious factual error does occur it is important to admit it clearly and frankly. Saying
what was wrong as well as putting it right can be an important element in making an effective
correction.
Inaccuracy may lead to a complaint of unfairness. Where an error is acknowledged, a timely
correction may dissuade the aggrieved party from complaining.
Where we may have broadcast a defamatory inaccuracy BBC lawyers should be consulted
about the wording of a correction. An appropriate correction may help in our defence of a
court action: an inappropriate one could exacerbate the defamation.
3 ACCURATE LANGUAGE
It is not sufficient that we get our facts right. We must use language fairly. That means
avoiding exaggeration. We must not use language inadvertently so as to suggest value
judgements, commitment or lack of objectivity.
4 REPORTING STATISTICS
Statistics should be used or reported carefully and in context. It is extremely difficult to
convey the context of statistical evidence in a few words, so programmes may need to find
time to explain perspectives. With regularly published sets of statistics this may mean giving
the trend of the figures over a relevant period. Even then statistical evidence should not be
accorded more weight than could stand scrutiny. Sources should always be indicated so the
audience can form a judgement about the status of the evidence.
5 RECONSTRUCTION
44
RFI20080896
The reconstruction or re-staging of events in factual program
mes can be a great help in
explaining an issue. It must always be done truthfully with an awareness of what is reliably
known. Nothing significant which is not known should be invented without
acknowledgement. Reconstructions should not over dramatise events in a misleading or
sensationalistic way.
Reconstructions should be identified clearly so that no-one is misled. Repeated labelling may
be necessary to achieve this.
When a programme invents a realistic scene based on real cases but without reconstructing
any one case this needs to be made clear.
News programmes should not normally stage reconstructions of current events. The risk of
confusing the viewer is too high. But reconstructions staged by others (perhaps by the police
investigating a crime) may of course be reported in the usual way.
6 STAGING AND RE-STAGING EVENTS
Factual programmes should always present a fair and accurate picture of the situations they
portray. Audiences should never be misled by what they see or hear in a programme.
However, there are few factual films which do not involve some intervention from the
director, even those which are commonly described as "fly on the wall" or observational
documentaries.
The use of reconstruction, (see Section 7: Reconstruction), where all events are quite
explicitly re-staged for the camera or microphone and where the programme team was never
present when the events first happened, is a separate technique and must be labelled as such.
However production methods, especially in television with single camera location shooting,
sometimes mean that it is impossible to record all events exactly as they happen. Many of the
techniques that are used to overcome this have long been part of the accepted grammar of
programme-making. The conventional skills employed to edit sound and picture together are
widely understood and accepted by audiences.
Such techniques may sometimes involve a departure from the strict chronology of events.
Additional bridging shots known as cut-aways may be edited in to shorten a sequence.
Directors may wish to capture a variety of shots from a variety of angles to cover a sequence
imaginatively. So long as editing, changes in shot order and, indeed, new juxtapositions of
shots do not distort the story told and so mislead viewers, this is part of the normal grammar
of film production.
Factual programme-makers may sometimes legitimately ask contributors to do things for the
camera twice or to repeat routine things, which they do regularly, but on this particular
occasion are doing for the camera. (e.g. the set-up shot for an interview). But all such
interventions require carefully balanced judgements. We should never be so embarrassed by
the techniques that we use that we cannot share them with our audience.
Commentary must always respect the truth and should never be used to give the audience a
dishonest impression of events.
Some types of documentary film are deliberately stylised and the set-up is totally clear to the
viewer. For example, in a stylised documentary about front gardens, it would not be
45
RFI20080896
m
isleading to the audience to ask the owners to stand in front of their garden and stare fixedly
at the camera lens.
In judging what is acceptable and unacceptable practice in factual programmes, programme-
makers must ensure that:
• programmes truthfully and fairly depict what has happened
• programmes never do anything to mislead audiences
• while it may, on occasions, be legitimate to re-shoot something that is a routine and
insignificant action, it is not legitimate to stage or re-stage action which is
significant to
the development of the action or narrative, without clearly signalling this to the audience
• contributors should
not be asked to re-enact
significant events, without this being made
clear in the film. (This does not preclude programme-makers arranging to record
sequences at a particular time to fit in with the timetable of a shoot)
• if significant events have been arranged for the cameras (including the recruitment of
contributors) that would not have taken place
at all without the intervention of the
programme-makers, then this must be made clear to the audience
• shots and sequences should never be inter-cut to suggest that they were happening at the
same time if the resulting juxtaposition of material leads to a distorted and misleading
impression of events
7 USE OF COMPUTER GRAPHICS
Computerised graphics give programmes great scope for the creation of arresting and
informative images to aid story-telling, but there are ethical dangers. Viewers must not be
misled into believing that they are seeing something which is a "real" document, event or
subject when in fact it is a creation of a graphic artist.
Programmes must not lay themselves open to a charge of deception. When composite images
are created it should be clear that the graphic is not a simple photographic image. On occasion
it may be appropriate to signal, verbally or visually, that what is being depicted is an
illustration.
8 USE OF LIBRARY MATERIAL
Library material used to illustrate a current issue or event must be clearly labelled if there is
any danger of confusion. Audiences must never be misled about what they are seeing or
hearing. It is important not to use library material of one event to illustrate another in such a
way as to suggest the audience is witnessing something it is not.
Beware of causing pain or offence through use of inappropriate or outdated material. Try to
avoid identifiable shots of people who are incidental to the subject: they may have died since
the pictures were taken. Avoid repeated use of the same incident to illustrate a general theme:
the same driver being breathalysed repeatedly is unfair and may be defamatory.
Avoid needless repetition of traumatic library material, especially if it features identifiable
people. Use of material depicting pain, suffering, violence, grief or death becomes less
46
RFI20080896
defensible as the original event passes into history. It should not be used as wallpaper or to
illustrate a general theme and should not normally be used in headline sequences. Library
pictures of identifiable grieving or distressed people must be used only after referral to a
senior level in the programme department.
Avoid inadvertently perpetuating racial, sexual or other stereotypes by careless use of library
pictures.
When non-news programmes want to use news material they should always check with the
relevant news library to make sure there are no special considerations.
9 CHECKING RECORDED OR REPEATED PROGRAMMES
Programmes recorded some time before transmission or being repeated must be checked to
make sure they have not been overtaken by events, for example the death of a contributor or
the charging of an offender. In some cases, a preceding announcement may be appropriate. In
others, the alteration or removal of some material may be required. Programme makers know
their own material best and are most likely to be sensitive to an event with implications for a
programme they have been involved with. It is important for them to inform Heads of
Department and not rely on others to make the connection (see also Chapter 21: Re-Use and
Reversioning of Television Programmes)
CHAPTER 3:
FAIRNESS AND STRAIGHT DEALING
1 GENERAL
2 FAIR DEALING
3 RESEARCH
4 ADVERTISING FOR CONTRIBUTORS
5 REFUSALS TO TAKE PART
6 FAIRNESS AND INDEPENDENCE
7 EMBARGOES
8 ANONYMITY
9 OBSERVING LOCAL LAW
1 GENERAL
The BBC’s commitment to robust, original journalism means that there are times when the
BBC will make allegations as a result of conducting its own investigations. But it is a guiding
principle of BBC journalism that we are fair to all – fair to those against whom allegations are
being made, fair to the audience, and fair to contributors.
The principles outlined in these guidelines should be observed regardless of location.
Wherever in the world the BBC operates contributors should be treated with fairness and
respect. Producers and reporters working overseas should bear in mind that items they prepare
47
RFI20080896
for broadcast in Britain m
ay be broadcast back to the country concerned as well.
2 FAIR DEALING Programmes should be based on fairness, openness and straight dealing. This is important to
everyone involved. It reflects concern for the interests of the programme, the interests of the
people who appear in it and the interests of the audience. All these interests are important,
although none of them is automatically more important than the others.
From the start, programme makers should be as clear as they can be about the nature of the
programme and its purpose. Unless there are special and legitimate considerations of
confidentiality they should be open about their plans, and honest with anyone taking part in a
programme.
Fairness to contributors: Contributors may be unfamiliar with broadcasting. Processes and
assumptions that a professional may regard as obvious may not be shared by a layperson.
Whether they are public figures or ordinary citizens contributors ought to be able to assume
that they will be dealt with in a fair way. They should not feel misled, deceived or
misrepresented before, during or after the programme, unless there is a clear public interest,
when dealing with criminal or anti social activity. Contributors have a right to know:
• what a programme is about
• what kind of contribution they are expected to make - an interview or a part in a
discussion, for example. If invited to take part in a debate or a discussion they should be
told in advance about the range of views being represented, and wherever possible, who
the other participants will be
• whether their contribution will be live or recorded and whether it will be edited. They
should not be given a guarantee that their contribution will be broadcast, but nor should
we normally record a substantial contribution unless we expect to use it.
The need for fairness applies equally to people asked for help or advice in the preparation of
programmes. They should be told why they were contacted and what the programme is about.
In news and factual programmes, there may be very rare occasions when it is acceptable
for programme makers not to reveal the full purpose of the programme to a contributor
where there is an overriding public interest such as exposing crime or significant anti
social behaviour, exposing misleading claims which could impact on the health, safety,
well-being or security of others, revealing incompetence in office, or exposing corruption
or injustice.
The deception should be the minimum necessary in proportion to the subject matter. In such
rare cases, referral to the departmental head and Controller Editorial Policy is mandatory.
Fairness to those accused: Where serious allegations of wrong doing are to be made, those
allegations should normally be put to the persons or organisations concerned by the
programme (See also 3.9 Right of Reply under Impartiality) in time for a considered response
before transmission. Where a number of individuals, or different organisations, or parts of an
organisation are involved, care should be taken to ensure that all key parties have been
contacted. The approach should be honest, clear and specific about what is being alleged and
open-minded as to the response. It is the responsibility of whoever makes the approach to
48
RFI20080896
m
ake and keep a clear record of the contact, logging the time, the name of the person spoken
to and the key elements of the exchange.
Legally and ethically, it is essential that the Editor ensures that the nature of the allegation is
described in sufficient detail to enable a response and that the approach is properly noted or
logged. The weight and strength of any response should be taken into account in deciding
how to report the story. It should be broadcast as part of the first transmission of the story.
However, when the BBC wishes to broadcast an allegation in the public interest which it
believes to be true, it may be permissible not to make the approach in order to get the report
into the public domain. In these very rare cases, referral to the departmental head and the
Controller Editorial Policy is mandatory.
Fairness to the audience: We should give audiences as much information as possible to
enable them to form their own view of a story. We should never mislead but explain when we
cannot give information rather than offer speculation. Openness and honesty are of the
essence.
Contributors to both factual and entertainment programmes should not be patronised or
exploited, nor should we be seen to humiliate them (see also Chapter 22: Game Shows and
Competitions).
There are separate guidelines covering issues of deception in comedy and light entertainment
programmes (see section 9 of Chapter 5: Surreptitious Recording).
Contributors should feel they have been treated decently by the BBC in all our dealings with
them, throughout the production process. In programmes that deal with personal trauma or
distress continuing contact with contributors may be appropriate to offer them help and
reassurance up to the point of transmission and beyond.
Some contributors may ask to see a copy of the finished programme before it is broadcast.
The BBC does not usually agree to this, for legal reasons and to maintain editorial
independence. However, there may be circumstances under which it is appropriate to allow
previews without surrendering editorial control. When we agree to give previews it should be
made clear on what terms such a preview will be offered. It is best to do this in writing in
advance. Editorial Policy can advise on individual cases. (see also Chapter 17:
Confidentiality and Release of Programme Material).
In return for dealing with contributors in a fair way we should expect them to be honest and
truthful with the BBC. Our own research should be rigorous and accurate enough to screen
out contributors who may be less than honest (see also Section 3 Research). It may also be
appropriate to remind contributors of the importance of straightforward and truthful
contributions, both verbally, through studio announcements, and in any contractual
arrangements. But a contractual commitment cannot be a substitute for thorough research.
3 RESEARCH
Research for all programmes must be thorough and accurate. Facts must be checked and
crosschecked. Particularly when dealing with members of the public, contributors’ credentials
may need to be checked and corroborated several times. Documentary evidence may be
49
RFI20080896
needed to validate both stories and contributors identities. It will usually be appropriate to
seek corroboration from sources other than those suggested by the contributor.
It is helpful if clear and contemporaneous notes are made of all conversations and other
relevant details. Members of the public who make a significant contribution should usually be
spoken to, and checked, by more than one member of the programme team before their
participation.
Researchers should not rely on outside bodies to do programme research about contributors.
When finding contributors news agencies and other specialist agencies can sometimes be a
useful source. But any information or contact supplied must be carefully crosschecked and
verified. Agencies who deal with actors and performers should not be used to find people to
talk about experiences outside their specific profession. When agencies are used to recruit
specialist contributors all appropriate checks should still be made.
4 ADVERTISING FOR CONTRIBUTORS
On occasion, advertising for contributors to factual programmes can be an appropriate way of
finding contributors or information that cannot be obtained in any other way. But adverts
must be used sparingly, and very much as a last resort.
Any advertising for contributors must be based on solid prior research. It should come at the
end of the research process not at the beginning. Any social trends or developments which the
programme highlights must be based on prior research not just on the fact that sufficient
participants have answered an advert.
We should be aware of the dangers of recruiting contributors through advertisements and on
air appeals. These can encourage exaggeration and “serial guests”. Anyone recruited through
an advert should be checked extremely thoroughly.
The wording of any advert must be carefully phrased. Any advert must not bring the BBC
into disrepute.
It may be appropriate for entertainment programmes to advertise for contestants and
audiences. Even then all appropriate checks should be made to screen out unsuitable or
untruthful contributors.
All proposed advertisements and their wording should be referred via Department
Heads, Commissioning Executives or their equivalent to the relevant Directorate
representative. In Broadcast these are the Controllers of Scotland, Wales, Northern
Ireland and the English Regions, and the Head of the Independent Commissioning
Group, in Production the Head of Editorial Compliance, in News, the Deputy Chief
Executive, in the World Service the Director of English Programmes, and in Worldwide
the Head of Programming, International Networks.
5 REFUSALS TO TAKE PART
The refusal of an organisation or an individual to take part in a programme should not be
allowed to act as a veto. It may have that effect in a few cases i.e. candidates during election
periods (see Chapter 34: Broadcasting During Elections), but there are usually ways of
overcoming it (see Chapter 33: Politics, and Politicians).
50
RFI20080896
Anyone has a right to refuse, but when the audience m
ight otherwise wonder why a
contributor or organisation is missing the reasons for their absence should be explained. This
should be done in terms that are fair to the absentee. The programme editor should consider
whether it is possible to give a good idea of the views of the missing contributor based on
what is already known. It is rarely acceptable to exclude the missing view altogether.
6 FAIRNESS AND INDEPENDENCE
Some interviewees, often public figures, may try to intimidate programme- makers before or
after making a contribution. Programme makers who have been fair are justified in giving a
tough response - and they will be supported by the BBC. No one who has willingly taken part
in a programme or recording has the right to prevent the contribution being used, but we
should always listen carefully to anyone who raises reasonable objections.
7 EMBARGOES
When programmes accept material under embargo, BBC policy is to observe it. Sometimes it
may be possible to persuade an organisation to lift or vary its embargo. If embargoes are
broken by other media or by the originator of the embargo the BBC may be justified in doing
so as well. This will depend on the extent of the breach: the more widespread the breach, the
more unreasonable it is for the BBC to be bound by the original embargo.
8 ANONYMITY
There is no absolute obligation to name all programme contributors, though in most cases
both contributors and audiences would expect it, if their contribution is significant. However,
a deliberate decision to withhold or disguise the identity of a significant contributor raises
difficult issues.
The authority of programmes can be undermined by the use of anonymous contributors whose
status the audience cannot judge. But there are times when anonymity is appropriate, for
example:
• for reasons of safety
• to avoid undue embarrassment
• for legal reasons
Anonymity should not normally be granted to anyone trying to evade the law in the United
Kingdom. There may be some exceptional cases, but Controller Editorial Policy must be
consulted, in advance.
Where contributors make anonymity a condition of taking part in a programme, it is important
to establish the degree of anonymity sought. It may be sufficient simply to ensure that
contributors are not readily recognisable to the general public, or it may be necessary to
ensure that they cannot be identified even by friends or family. Such matters should be
resolved in advance.
Where anonymity is necessary producers must make it effective. Both picture and voice may
need to be disguised. A "voice-over "by another person is usually better than technically
induced distortion which can be reversed. In such cases, audiences must be told what they are
hearing.
51
RFI20080896
Great care needs to be taken over pictures. Blurring rather than "pixilation "(which can be
reversed) is the best way of ensuring anonymity in pictures. If absolute anonymity is
essential, programme makers must ensure there is no evidence of the contributors’ identity
even on the original recording or in any documentation. Editorial Policy can offer advice on
this.
Our international services often rebroadcast material originally recorded for the BBC’s
domestic services. If this material might compromise the safety of contributors when it is
rebroadcast, it may be appropriate to disguise the identity of those concerned.
Producers should check with the contributor when anonymity is being discussed whether
there are any additional factors that need to be taken into account with international
transmission.
For guidance on confidentiality see section 1 of Chapter 17: Confidentiality and Release of
Programme Material.
9 OBSERVING LOCAL LAW
When working abroad local laws should be observed. If an aspect of local law appears
inimical to fundamental freedoms or democratic principles or represents a serious impediment
to responsible programme-making, the relevant Head of Department or Commissioning
Executive must be consulted about the appropriate way to proceed. Heads of Department or
Commissioning Executives should consult Controller, Editorial Policy, if necessary.
If there is any proposal to act in a way which is contrary to local law it will always be
necessary to consider the possible impact on individuals - including BBC people not involved
in the programme concerned - and on the BBC’s wider reputation.
When entering countries to work for the BBC people should normally be open about their
purposes.
Any proposal to use a tourist visa in a way which would avoid visa restrictions,
when the intention is to carry out work for the BBC should be referred to Heads of
Department or Commissioning Executive who may also consult Controller, Editorial
Policy. When such a proposal is approved, the News Editor in Newsgathering should also be
informed.
Where our coverage has been distorted or censored by local laws, this must be made clear to
audiences.
CHAPTER 4
PRIVACY
1 BASIC PRINCIPLES
2 PRIVATE LIVES AND PUBLIC ISSUES
3 OPERATING ON PRIVATE PROPERTY
4 DOORSTEPPING
5 MEDIA SCRUMS
6 CCTV FOOTAGE
7 MISSING PEOPLE
1 BASIC PRINCIPLES
52
RFI20080896
The BBC should respect the privacy of individuals,
recognising that any intrusions have to be
justified by serving a greater good. The right to privacy is qualified by:
•
The Public Interest
People are less entitled to privacy when protection of privacy means concealing matters
which are against the public interest
•
Behaviour
People are less entitled to privacy where their behaviour is criminal or seriously anti
social.
•
Location
The right to privacy is clearly much greater in a place such as a private home than it is in
public places
Private behaviour, correspondence and conversation should not be brought into the public
domain unless there is a clear public interest. It is essential that we operate within a
framework which respects people's right to privacy, treats them fairly, yet allows us to
investigate and establish matters which it is in the public interest to know about.
We should respect people’s privacy wherever in the world we are operating. While there is no
law of privacy as such in the United Kingdom, the Government has enacted the European
Convention on Human Rights which includes the right to privacy as well as the right to
freedom of expression. Privacy laws do exist in other parts of the world including continental
Europe and should be respected. In countries where exposing corruption, injustice or other
matters of public concern may bring the BBC into conflict with local laws, we should not
proceed without consultation with heads of department, lawyers and, if necessary, Controller,
Editorial Policy.
The BBC’s guidelines on use of hidden microphones and cameras are contained in Chapter
5: Surreptitious Recording.
2 PRIVATE LIVES AND PUBLIC ISSUES
Public figures are in a special position, but they retain their rights to a private life. The public
should be given the facts that bear upon the ability or the suitability of public figures to attain
or hold office or to perform their duties, but there is no general entitlement to know about
their private behaviour provided that it is legal and does not raise important wider issues.
As a general principle, BBC programmes should not report the private legal behaviour of
public figures unless broader public issues are raised either by the behaviour itself or by the
consequences of its becoming widely known. The mere fact that other parts of the media have
reported private behaviour, and that in that sense it is "in the public domain" (i.e. that
someone else has reported it), is not of itself sufficient to justify the BBC reporting it too. As
a result, where there are no broader public interest issues and the behaviour itself is within the
law, there may be occasions where the BBC does not report stories which are being covered
by the rest of the media
Even when the personal affairs of public figures become the proper subject of enquiry they do
not forfeit all rights to privacy. BBC programmes should confine themselves to relevant facts
and avoid gossip. The information we broadcast should be important as well as true. It is not
53
RFI20080896
enough to say that it is interesting. Having established the relevant facts, program
mes should
concentrate on any publicly important issues arising. If a person's private life is the proper
subject of a running story we should report it when there are significant developments and
ignore it when there are not.
3
OPERATING ON PRIVATE PROPERTY
On most occasions programme makers will seek permission before operating on private
property. But there will be instances when it is acceptable for programme makers to operate
on private property without seeking permission. For example it may be acceptable to film or
record in a public shopping precinct or a railway station, places where the public has general
access. Or it may be acceptable in more restricted places where serious criminal or antisocial
activity is being exposed.
Sometimes going onto private land without authority can constitute a civil offence (in which
the police have no jurisdiction). Sometimes, however, there is a risk of committing criminal
trespass. It is important for programme makers to understand the laws of trespass in detail
(see section 5 of Chapter 37: Matters of Law: General) and to seek advice if they are in
doubt about how to proceed
When we are on private property and are asked by the legal occupier to leave, we should
normally do so promptly.
4
DOORSTEPPING
This is the term used in broadcasting to mean occasions on which a reporter confronts and
records a potential interviewee without prior arrangement, either in public or sometimes on
private property.
People who are currently in the news must expect to be questioned and recorded by the
media. Questions asked by reporters as public figures come and go from buildings are usually
part of legitimate newsgathering, even if the questions are sometimes unwelcome, and the
rules on doorstepping are not intended to prevent this.
In all other cases doorstepping should generally be a last resort.
It needs to be approved in
advance by the Head of Department who should do so only if:
•
the investigation involves crime or serious anti-social behaviour, and
•
the subject of the doorstep has failed to respond to a repeated request to be
interviewed, refused an interview on unreasonable grounds, or if they have a history
of such failure or refusal
Doorstepping should not be used merely to add drama to a factual report.
Controller, Editorial Policy must approve in advance any proposal to doorstep where
there has been no prior approach to the interviewee. CEP will usually grant permission
only if there is clear evidence of crime or significant wrong-doing, and if there is reason
to suspect that a prior approach will result in the individual evading questioning
altogether.
5
MEDIA SCRUMS
54
RFI20080896
W
hen a person suddenly features in a news event it may be proper for representatives of many
media organisations to go to a private home to try to secure pictures or interviews. This can
result in large numbers of media people gathered in the street outside.
In such cases, it is important that the combined effect of legitimate newsgathering by a
number of organisations does not become intimidating or unreasonably intrusive. We must
not harass people unfairly with repeated telephone calls, or repeated knocks at the door, or by
obstructing them as they come and go (this could amount to a criminal offence of aggravated
trespass if it takes place on private property). It may be possible or appropriate for pooling
arrangements to be reached, or for the BBC to withdraw altogether if it is clear that the
subject does not intend to appear. BBC teams on the spot who are asked by the subject to
leave should refer to editors for guidance. The appropriate decision will depend upon the
precise circumstances, but considerations to bear in mind are:
•
is the subject a private citizen or a public figure?
•
is the subject victim, villain, or merely interested party?
•
has the subject expressed a clear intention or wish not to appear or give interviews?
There will be cases when the BBC judges it proper to withdraw and we therefore miss
material which other organisations gather and publish.
Prominent public figures must expect media attention when they become the subject of news
stories, but the open use of cameras or other equipment on public property aimed at recording
them on private property must be appropriate to the importance of the story. Any use of such
equipment must respect the rights of public figures to a proper level of privacy.
6
CCTV FOOTAGE
When dealing with Close Circuit Television (CCTV) video or recordings provided by the
emergency services or other bodies or individuals, special care must be taken over issues such
as privacy, anonymity and defamation. Our ignorance of the circumstances surrounding the
recording increases the risk in using it, and we must apply the same ethical, editorial
considerations we would to material we record ourselves. The principles in this chapter and
Chapter 5: Surreptitious Recording should apply. If illegal or anti-social activity is shown
there may be real risks of defamation or contempt. If in doubt seek legal advice.
7 MISSING PEOPLE
BBC programmes sometimes broadcast details of missing people sent in by relatives and
friends. While helping to trace people may be a useful public service, care must be exercised
when deciding what details to broadcast for fear of causing embarrassment or distress to the
person who is the subject of the message. Programme makers should bear in mind the fact
that not all missing people wish to be traced and should exercise caution in accepting
everything the family or friends say at face value. Before broadcasting, programme makers
should consider whether to hold back information the missing person might regard as being
personal and private and which they might wish to keep secret.
CHAPTER 5
SURREPTITIOUS RECORDING
55
RFI20080896
1 GENERAL PRINCIPLES
2 APPROVAL OF SURREPTITIOUS RECORDING
3 SURREPTITIOUS RECORDING IN PUBLIC PLACES
4 GRIEF AND DISTRESS
5 INVESTIGATING CRIME AND ANTI SOCIAL ACTIVITY
5.1 “Fishing expeditions” and “bugging”
5.2 Disguising identities
6 SOCIAL RESEARCH
7 RECORDING TELEPHONE CALLS
8 SECRET RECORDINGS MADE BY OTHERS
9 COMEDY AND ENTERTAINMENT
1 GENERAL PRINCIPLES
The BBC’s use of hidden cameras and microphones are governed by the principles set out in
Chapter 4: Privacy. We should operate within a framework which respects people's right to
privacy, treats them fairly, yet allows us to investigate and establish matters which it is in the
public interest to know about.
Surreptitious recording should not be used as a routine production tool, nor should it be used
simply to add drama to a report.
The BBC will normally only allow the use of surreptitious recording for broadcasting for one
of the following purposes;
•
As an investigative tool to explore matters which raise issues of serious anti social or
criminal behaviour, where there is reasonable prior evidence of such behaviour (see
Section 5 below)
•
To gather material, which could not be gathered openly, in countries where the local law
appears inimical to fundamental freedoms or democratic principles or represents a serious
impediment to responsible programme-making (see section 9, Observing Local Law, in
Chapter 3 Fairness and Straight Dealing)
•
As a method of social research where no other methods could reasonably capture the
behaviour under scrutiny. In such cases it will be usual practice to disguise the identities
of the individuals concerned (see Section 6 below)
•
For purely entertainment purposes where the secret recording and any deception involved
are an intrinsic part of the entertainment. In these cases it will always be necessary to
obtain the consent of the individual recorded afterwards (see Section 9 below)
The use of long lenses can be a legitimate technique which may sometimes have the effect of
recording people who do not know the camera is present. The deliberate use of such lenses, or
of small video cameras, to conceal the camera from targeted individuals being photographed
counts as surreptitious recording and is subject to these guidelines.
Many ordinary people now carry video cameras (or DVCs). Where the BBC uses people or
equipment, including DVCs, to give the impression of recording for purposes other than
broadcasting, that recording is regarded as being carried out surreptitiously, and is subject to
these guidelines.
56
RFI20080896
Occasionally recording for broadcasting can be
performed openly but without declaring its
end purpose. This may be preferable to recording which is entirely concealed. This qualifies
as surreptitious recording and is subject to these guidelines.
2
APPROVAL OF SURREPTITIOUS RECORDING
Whenever surreptitious recording is carried out by BBC programme makers it must be
approved in advance by the relevant Head of Department, National or Commissioning
Executive or in the World Service, head of Region. Where necessary Controller,
Editorial Policy should be consulted.
On each occasion secret recording is carried out, whatever the purpose, the department
concerned must keep a full record of how the recording satisfied the requirements of this
Chapter, who authorised it, and brief details of who and what was recorded. This record must
be made regardless of whether the material gathered is broadcast. Each directorate is
responsible for maintaining these records to enable the BBC to monitor and review the use of
such techniques throughout its output.
Wherever approval is required from Head of Department or from CEP for surreptitious
recording of any sort, it may be decided to consider the proposal in two separate stages,
first for recording and subsequently for transmission.
The diagram below illustrates some of the questions which should be considered by
programme makers when they propose to use surreptitious recording.
57
RFI20080896
58
RFI20080896
3 SURREPTITIOUS RECORDING IN PUBLIC PLACES
People in a public place cannot expect the same degree of privacy as in their own homes.
They can be seen by anyone, and that means they may be spotted by cameras or recorded by
microphones. In general, we should operate openly in public where we can see and be seen.
But sometimes it will be necessary for the safety of our staff or for the style or content of the
programme that we record surreptitiously in public places.
Programmes intending to do so must get approval in advance from the relevant Head of
Department, National Controller, or Commissioning Executive, who can refer particularly
sensitive situations to Controller Editorial Policy.
Although we cannot guarantee that the broadcasting of recordings made in public will not
cause individuals embarrassment, we should not intend this unless they are engaged in clearly
anti-social activity.
Some "public" places like railways stations, public transport or shops are actually private
property to which the public has ready access. When considering secret recording in such
places programme makers should be aware of the laws regarding trespass (see also section 3
“Operating on Private Property” in Chapter 4: Privacy, and section 5 “Trespass” in Chapter
37: Matters of Law: General).
4
GRIEF AND DISTRESS
Surreptitious recording of identifiable people in grief or under extremes of stress (for instance
in hospitals) requires further special consideration. Use of such material will usually be
justified only if permission has been granted by the individuals concerned or by someone
acting on their behalf. Heads of Department must be consulted. (see also Chapter 12:
Reporting Suffering and Distress).
5
INVESTIGATING CRIME AND ANTI SOCIAL ACTIVITY
In investigating the above, the BBC will generally use hidden cameras or microphones on
private property only where
•
prime facie evidence exists of crime or of significant anti-social behaviour by those to be
recorded
•
the programme maker can show why an open approach would be unlikely to succeed
If the recording is to take place in a private place, where the public do not have access, the
justification for any surreptitious recording will have to be greater.
Programme makers will need to show why the material is necessary in programme terms and
the public interest in showing such material. Each case must be approved in advance by
Heads of Department or equivalent who may refer to Controller Editorial Policy as necessary.
There may be occasions where there is prime facie evidence against a group of people but not
necessarily against known individuals in that group - for instance, the overcharging of
foreigners by some people in tourist service industries, or the exploitation of old people by
some home repair workers, where surreptitious recording may be justified. Where
surreptitious recording is carried out in this way the results should be represented fairly so as
not to give a distorted picture of the incidence of certain activity.
59
RFI20080896
Deciding to record and to transmit are two separate stages. Once the material has been
obtained the Heads of Department or equivalent must be satisfied it still meets the criteria for
secret recording before transmission.
5.1 “Fishing expeditions” and “bugging”
BBC journalists and programme makers will not go on what are known as "fishing
expeditions". That is, we will not record secretly on private property in search of crime or anti
social behaviour by identifiable individuals or group if there is no prime facie evidence
against them. This also applies when secret recording takes place on public property but is
directed towards subjects who are on private property.
The BBC will never plant an unattended recording device on private property (otherwise
known as “bugging”)without permission of the owner, occupier, or their agent
unless for the
purpose of gaining evidence of serious crime.
Controller Editorial Policy must always
agree in advance and will require clear evidence that the crime has been committed by
those who are to be the subject of the recording.
5.2 Disguising identities
There will be circumstances where a programme may legitimately secretly record anti social
or criminal behaviour but decide the individuals are not sufficiently culpable or responsible
for their actions to be individually identified. In such cases where we are seeking to expose
the practice but not the individuals to disguise the identity of the individuals. In all cases
where innocent but clearly recognisable bystanders are caught on camera, whether in a public
or private place, they should be disguised.
6
SOCIAL RESEARCH
There may be a legitimate case for the use of surreptitious recording in a narrow range of
cases where there is no prime facie evidence of wrong-doing by the people concerned. Such
cases are limited to social research items where it is in the essence of the programme to
capture attitudes or behaviour which would not be captured naturally if the subject were
aware of their being recorded - for instance how people react when passing a beggar in the
street. As in all instances of surreptitious recording, there needs to be a public interest in
showing such behaviour.
Programme proposals in this category must be approved in advance by Heads of Department.
If approved, any individual who is clearly identifiable in the recording - unless merely
incidental to it - must give permission for use of the material, and if permission is denied the
individual’s identity must be effectively obscured. Any proposal for an exception should be
referred by Heads of Department to Controller Editorial Policy.
Where surreptitious recording is carried out in this way the results should be represented
fairly so as not to give a distorted picture of the incidence of certain activity.
7
RECORDING TELEPHONE CALLS
60
RFI20080896
The BBC never records telephone conversations for broadcasting purposes without the
permission of at least one of the parties involved in the call. This is illegal in the United
Kingdom.
If BBC people wish to record a telephone call they make or receive for possible broadcasting,
they should normally seek the permission of the other party in advance
. If they wish to
record a telephone call without doing so they must consult their Head of Department
who should consult Controller, Editorial Policy. Recording will be authorised only if:
•
there is prime facie evidence of crime or serious wrong doing
•
the programme maker can show why an open approach would be unlikely to
succeed
If, during a phone call, programme makers take someone by surprise by saying, without
warning, that they are recording a call for broadcasting purposes, or broadcasting the call live
this is the equivalent of “doorstepping". Heads of department must approve this approach in
advance and may do so only if:
•
the investigation involves crime or serious anti-social behaviour, and
•
the subject has failed to respond to a repeated request to be interviewed, has refused an
interview on unreasonable grounds, or has a history of such failure or refusal
Controller, Editorial Policy must approve in advance any proposal to conduct a
telephone "doorstep" where there has been no prior approach to the interviewee.
It is permissible without prior referral for programme makers to record their own telephone
conversations for note-taking purposes, or to gather evidence to defend the BBC against
possible legal action
. Such recordings should not be broadcast. Only Controller Editorial
Policy can give retrospective permission to broadcast material recorded in this way, and
permission will be given only in exceptional circumstances.
Note that different rules apply when programmes intend to make and record phone calls for
the purposes of light entertainment or comedy. In such cases the permission of the individual
must be obtained before broadcast. See also section 9 of this chapter.
8
SECRET RECORDINGS MADE BY OTHERS
When the BBC is offered material secretly recorded by others the test is whether, under
similar circumstances, the BBC would have felt it appropriate to conduct the recording.
If the material appears to have been obtained in a way which was not consistent with BBC
guidelines, it will normally be appropriate to reject it, or to report the content of the material
without actually broadcasting the material itself.
If there is a strong public interest in
broadcasting the material irrespective of how it was obtained, programmes should refer
to the relevant Head of Department who should consult Controller, Editorial Policy.
For guidance on use of Close Circuit Television material see Section 6 of Chapter 4: Privacy.
9
COMEDY AND ENTERTAINMENT
61
RFI20080896
The specific guidelines prohibiting the planting of unattended recording devices and the
illegal recording of telephone conversations, also apply to comedy and light entertainment
programmes. However the other guidelines on secret recording are not intended to prevent
recording for purposes of comedy or light-entertainment. Here, different principles apply:
•
People who feature prominently in the recordings should be asked to give their
permission before the material is broadcast
•
The purpose should not be to expose people to hurtful ridicule or to exploit them
•
We should respect the wishes of individuals who become aware of the recording and ask
for it to stop
•
We should give assurances about the destruction of any material recorded if asked for
them
•
If permission has been obtained we must disguise any other recognisable bystanders
caught on camera whose permission has not been obtained, and if the broadcasting of the
recording might cause embarrassment
Any proposal to show or feature people live without them being aware they are being
broadcast for entertainment purposes must be referred via Head of Department to
Controller Editorial Policy.
CHAPTER 6
TASTE AND DECENCY
1 GENERAL
2 TELEVISION: The Watershed
3 RADIO
4 SIGNPOSTS
4.1 Trails on television and radio
5 INTERNATIONAL AUDIENCES
6 ONLINE
7 DEALING WITH TRAGIC EVENTS
8 LANGUAGE
9 RELIGIOUS SENSIBILITIES
10 SEX
10.1 Sexual innuendo
10.2 Children
11 COMEDY AND ENTERTAINMENT
11.1 Stereotypes
11.2 Religion
11.3 Light Entertainment and Game shows,
12 ACQUIRED PROGRAMMES
1
GENERAL
The BBC is required in the Agreement associated with its Charter not to broadcast
programmes which "include anything which offends against good taste or decency or is likely
to encourage or incite to crime or lead to disorder, or be offensive to public feeling". The
BBC seeks to apply this requirement to all its broadcasting, programmes and services,
whether for domestic or international audiences.
62
RFI20080896
The BBC’s responsibility is to remain in touch with the views of its diverse audiences. These
views will differ both domestically and internationally. People of different ages, convictions
and cultures may have sharply differing expectations.
The right to challenge audience expectations in surprising and innovative ways, when
circumstances justify, must also be safeguarded. Comedy, drama, and the arts will sometimes
seek to question existing assumptions about taste. Programmes which question these
assumptions should seek to tell the truth about the human experience, including its darker
side, but should not set out to demean, brutalise or celebrate cruelty.
The same principles of taste and decency apply to the BBC’s international broadcasting. As
domestically, the key test will always be avoiding needless offence to the audience.
Programme makers should not offend thoughtlessly or through ignorance, the different
sensibilities that operate in different parts of the world.
But avoiding offence to audiences in different parts of the world should not be confused with
compromising or altering other key BBC values, such as impartiality, accuracy and respect
for the truth, which the BBC will seek to apply equally to all parts of the world (see Section 5
International Audiences and Section 9 Religious Sensibilities).
In the United Kingdom, research suggests that while people have become more relaxed in
recent years about the portrayal of sex and sexual humour they remain concerned about the
depiction of violence (see Chapter 7: Violence). The use of strong language also divides
audiences and can be a particular source of offence on the internet.
Parents with children in the home are likely to be particularly concerned about what appears
on television. This applies especially when families are watching before the Watershed. Most
people expect to be given clear signals about what they will see and hear, especially when
new series or formats appear.
An item which might be interpreted by some viewers or listeners as being in bad taste should
only be broadcast after careful consideration, not carelessly or by mistake. It must be justified
by its purpose, and by the overall quality of the programme.
Context is everything: scheduling can be vital to audiences accepting difficult material. It is
vital to consider the expectations that audiences have of particular programmes and timeslots.
The widespread availability of material in other media, or on other broadcasters is not reason
enough to judge it acceptable. What is commonplace in cinema, video, computer programs or
on the Internet will not necessarily be appropriate for BBC television, radio, or online
services.
Programme makers should remember they are a minority, but one with considerable
influence; they should be aware of and respect their audiences’ diverse views on what causes
offence
2
TELEVISION: The Watershed
The BBC has a well-established policy of making 9pm the pivotal point of the evening's
television, a Watershed before which, except in exceptional circumstances, all programmes on
63
RFI20080896
our dom
estic channels should be suitable for a general audience including children. The
earlier in the evening a programme is placed, the more suitable it is likely to be for children to
watch on their own.
However, the BBC expects parents to share the responsibility for assessing whether or not
individual programmes should be seen by younger viewers.
The Watershed reminds broadcasters that particular care should be taken over inclusion of
explicit scenes of sex and violence, and the use of strong language.
However, seventy per cent of homes do not contain children and many viewers expect a full
range of subject matter throughout the day. On the other hand, many children may still be
watching after 9pm, particularly at holiday times or weekends or if a programme of special
appeal to young people has been scheduled. This is particularly true at Christmas, when
family audiences may be watching after the Watershed. Producers should be aware that dates
of school holidays differ across the United Kingdom.
Particular care should be taken in the period immediately after the Watershed. There should
be a gradual transition towards more adult material and sudden changes in tone should be
avoided but, where unavoidable, they must be clearly signposted. Adult material should never
be positioned close to the Watershed simply to attract audiences in a sensationalist way.
Material which is particularly adult in tone should be scheduled at an appropriate time, where
necessary sometime after the Watershed. The post Watershed period runs from 9.00pm until
5.30am the following morning.
The Watershed is a commonly held convention in British television, and all BBC public
service and commercial television services aimed primarily at the United Kingdom should
observe it. Although the Watershed is a British convention it is an important element in the
BBC’s approach to services aimed at international audiences. International television services
broadcasting to specific regions of the world should aim to apply a Watershed policy as fully
as possible but these services may serve many different time zones and so a flexible
interpretation of the Watershed may be needed. All international television services should
observe Guidelines on the use of distressing, violent or sexual images and schedule
appropriately. We should not cause offence by using images gratuitously or casually, or
through ignorance of the sensitivities of different audiences (see also Chapter 21: Re-Use
and Reversioning of Television Programmes).
Scheduling can be vital to public acceptance of challenging material. Whether or not scenes
of violence, sex, great distress or strong language cause offence to an audience can depend
not just on editorial or dramatic context, but on sensitive scheduling decisions. A good rule of
thumb is to avoid taking the audience by surprise. Announcements and warnings can play an
important part in this.
Material within programmes has to be judged in relation to its place in the schedule and the
likely expectation of the audience at that time of day or night. Producers who feel that a
programme is wrongly placed or labelled should consult their Head of Department. Trails are
subject to the same judgements.
At the point of commissioning programme makers should be informed by commissioning
executives whether their programme will be scheduled before or after the Watershed, so that
64
RFI20080896
judgem
ents can be made about the appropriateness of content.
3
RADIO
Radio is used differently from television. Children listen, and sometimes in considerable
numbers, to Radio 1 and sport on Radio 5 Live. But they are less in evidence elsewhere in
radio and therefore a general Watershed is inappropriate.
However, scheduling considerations do apply as do considerations of taste and decency.
These should be relevant to the expectations of each network’s audience. As with television,
warnings and announcements before programmes can help to prevent audiences being taken
by surprise.
All BBC Radio output is characterised by the broadcasting of a large number of “live”
programmes and producers must be aware of the possibility of contributors, phone-in guests
and sometimes presenters themselves causing offence in matters of taste, decency or language
or even breaking the law. To minimise the risk producers should anticipate any potential
problems and brief participants before they go on air. Presenters of live programmes should
be aware of how best to deal with a difficult situation and producers should inform the press
office of any particularly sensitive problems that occur during a live broadcast (see also
Chapter 32: Phone-Ins and Telephone Services in Programmes).
On Radio 1, the daytime is mainstream and for a wide audience. At breakfast time and until
schools have begun, children are likely to be listening to the network in family groups.
Programme material which may meet with approval from younger adults can be inappropriate
for the youngest in the listening audience. DJs share with parents a special responsibility
when live broadcasting is listened to by audiences with a high proportion of young people or
children.
Daring and lively music and speech are part of the mix, but songs which feature strong
language or explicit content dealing with drugs, violence and sex will normally be
inappropriate. If a radio version exists we will play it, and where appropriate, make clear it is
a radio version. We will also edit to create our own version for radio.
DJs are expected to use wit but take care over innuendo and the choice of subject and
language. They will also be expected to respect their listeners and not take advantage of their
power to lead people where they might not otherwise have gone.
At night and in specialist music programmes, an audience can be assumed to be capable of
making informed choices about its listening, supported by adequate sign posting. Here the full
versions of records may find their place if they pass the quality test and are a genuine
expression of popular culture. Even so, the most offensive language will not normally be
acceptable.
On speech services such as Radio 4, Radio 5 Live and national and local stations, various
programme strands scheduled during the day have established a reputation with their audience
for dealing frankly with adult topics. Given the great predominance of adults in these
audiences, Radio operates with more latitude than Television.
Other programmes on Radio have a lighter or less challenging tone. However, discretion and
care need to be exercised during school holidays over what topics are tackled when, including
65
RFI20080896
the tim
ing of repeats of evening transmissions. Producers should be aware that dates of school
holidays differ across the United Kingdom.
These considerations also apply to national regional and local radio, who should be aware of
the sensitivities of their audiences. World Service will also take them into account in its
programme making and scheduling. As within Television, Controllers and Heads rely on
programme editors and Presentation teams to give warnings about sensitive material to ensure
correct scheduling and signposting.
4
SIGNPOSTS
The BBC has a responsibility to ensure that audiences have enough information on which to
judge if a programme is likely to be one they want to watch or listen to, or if it is suitable for
their children to watch and see. The Watershed is one clear and widely understood indicator
for Television, but there are instances when additional information is necessary.
Whenever a programme contains material that might be offensive to significant numbers of
viewers or listeners, consideration should be given to specific signposting for the material or
broadcasting a warning. Such presentation announcements are often useful and sometimes
vital. Such signposts should be clear and factual, not an instruction to turn off. On television,
the content should not be inappropriately graphic.
Signposts of this type should not usually be required for most pre-watershed programmes.
However, when there is a risk that the audience may be taken by surprise, they should be
alerted - for example, about a particularly graphic news report. Advice can be sought from the
relevant Presentation Department. Programme billings in
Radio Times, Ceefax and other
publicity material are useful as an additional means of signposting.
Channel Controllers and departments responsible for scheduling or presentation need to be
kept informed about potentially sensitive programmes to ensure they are correctly scheduled
and signposted.
The European Council Television Without Frontiers Directive 1997 Article 22.1, Protection
of Minors, requires Broadcasters in Member States to take “appropriate measures to ensure
that television broadcasts … do not include any programmes which might seriously impair the
physical, mental or moral development of minors, in particular programmes that involve
pornography or gratuitous violence”. The BBC must comply with the terms of the Directive.
The Directive also requires Broadcasters to use “acoustic” or visual warnings to alert viewers
to any programmes “which are likely to impair the physical mental or moral development of
minors”. The BBC’s policy is that an “acoustic warning” in the form of a presentation
announcement is the absolute minimum requirement.
It should be clear from the Producers
Guidelines that it is inconceivable that the BBC would wish to broadcast a programme
that might impair, seriously or otherwise, the physical, mental or moral development of
minors. Any programme maker who is in any doubt at all about whether material they are
dealing with might do this should seek urgent advice from their line management, who must
consult Editorial Policy.
See also section 8 of Chapter 37: Matters of Law: General.
4.1 Trails on television and radio
66
RFI20080896
The Guidelines also apply to trails on both m
edia. Care should be taken over scheduling trails
of programmes that are unsuitable for children. For example, television programmes may be
appropriately scheduled after the Watershed; the related trails, on the other hand, may well be
broadcast earlier, when children may be watching. In such circumstances the content of the
trail should be appropriate for children or family-viewing. However, such a trail should
clearly signpost the nature of the programme.
No trail for a post- Watershed programme should be scheduled next to a programme
specifically targeted at children.
5 INTERNATIONAL AUDIENCES
The BBC’s international services, in particular the World Service, have extensive experience
of dealing sensitively with different expectations of taste that operate in cultures across the
world. As the BBC’s role as a global broadcaster grows, particularly on television, this will
become increasingly important for all BBC programme makers. We should not offend
thoughtlessly or through ignorance, the different sensibilities, and sometimes different taboos,
that operate in different parts of the world on matters of taste and decency.
Religion, culture, politics and the law are bound together in different ways across the world.
Programme makers should make every effort to understand how the inherent philosophy of a
country’s people dictates their way of life. Particular care may need to be taken when dealing
with religious beliefs which form a central part of a society’s culture or its political or legal
system. Producers should be aware of the distinction that exists between the cultural
interpretation of religious beliefs, often through local customs, and the beliefs themselves (see
also section 9 Religious Sensibilities and Chapter 21: Re-Use and Reversioning of
Television Programmes).
When programmes originally made for a domestic audience are rebroadcast on international
channels it is important to consider whether any material might offend the sensibilities of the
international audience. But sensitivity to such issues should not compromise or alter
programme making in a way that damages core BBC values such as impartiality and
accuracy. Although audiences overseas may not share the same knowledge, assumptions or
values as those in the UK this should not prevent the expression of contentious views.
Sometimes additional context, explanation or opportunities for foreign viewers or listeners to
discuss the views set out in a particular programme may be needed. Producers may consider
using an additional introduction from a presenter or a phone-in or a discussion following the
programme’s broadcast to give extra context.
6
ONLINE
The BBC should never put anything on the Internet which it would not be prepared to
broadcast.
Web producers should be aware of what may offend the likely audience of any Web site or its
associated programme, and respect those views.
Pages carrying material linked to any broadcast programme must be appropriate to the
programme and its likely audience; no Web site linked to a specific programme should
contain material considered unsuitable for broadcasting in the associated programme
67
RFI20080896
Those planning W
eb pages should be clear about whether they are likely to appeal to a high
proportion of children or young people and choose material accordingly
We should not hotlink from a site whose ‘parent’ radio or television programme is designed
to attract a child audience to one whose ‘parent’ radio or television programme contains
material which is clearly unsuitable for children.
Strong language can give rise to widespread offence. The use of certain, mainly four letter,
words in text on the Internet may be more offensive than using them on radio or television.
Such words may be used only in the most exceptional circumstances and express approval
must be obtained.
Any proposal to use such a word on online services must be referred in
advance to the Director of BBC ONLINE. For BBC News Online express prior approval
must be obtained from the Project Director, Continuous News Multimedia.
Some web pages are specifically designed for an international audience, and careful thought
should be given as to whether pages linked to our domestic services are particularly likely to
attract a significant number of visitors from other countries. Producers of pages should be
aware that cultural sensitivities vary and that audiences in other parts of the world may take
great offence at something which would be unexceptional to a domestic audience. Advice on
the sensitivities of international audiences may be obtained from the relevant Heads of
Region, BBC World Service and from the Head of Online, World Service
Particular care should be taken when putting material on the Web which has been gathered for
radio or television programmes but not broadcast. Careful judgements may need to made
about legal, contractual and other editorial issues, for example anonymity.
Programme makers should also refer to the BBC ONLINE Guidelines.
7 DEALING WITH TRAGIC EVENTS
The aftermath of a tragic event calls for considerable sensitivity and may require scheduling
changes. Every effort must be made to ensure that nothing broadcast on radio and television,
or posted online that might cause widespread offence goes unscrutinised. This includes
acquired programmes such as feature films, repeated programmes and individual episodes of
series and serials as well as new programmes. Pre-recorded programmes should always be
checked before first or repeat transmission, in case the content has been affected by
intervening events. This includes comedy shows where a joke or situation may have become
tasteless due to some subsequent development. Web pages may need to be removed or
altered. Anniversaries of tragic events may also raise similar considerations.
The more direct the impact of a tragedy, the greater the sensitivity needed in taking decisions
of this kind; it is better to err on the side of caution than to compound distress through
insensitivity (see also Chapter 12: Reporting Suffering and Distress).
8 LANGUAGE
Strong language is a subject of deep concern to many people and is one of the most frequent
causes of complaint. Offence is more likely to be caused if audiences are taken by surprise
when strong language occurs without warning, is contrary to the expectations of the
68
RFI20080896
program
me’s audience or feels gratuitous. In the right context strong language may cause
little offence and in some situations it may be wholly justified in the interests of authenticity.
It is more difficult to make judgements about the use of strong language in a pre-Watershed
family serial or soap opera, seen or heard by large audiences composed of people from
different ages and backgrounds. Strong language might sometimes be used, for example when
characters are experiencing great stress. This must be justified by the expectations created for
both individual characters and the series as a whole.
Common sense should enable producers to identify which words are questionable and when
the use of them might be warranted. Programme makers should be aware that terms of racist
abuse are now considered to be offensive by all sections of the audience. Sexual swearwords
and abusive names relating to disabilities can also cause great offence. They should ask
themselves constantly whether the use of strong language will simply alienate a large part of
the audience.
Offence is often caused by the casual use of names considered holy by believers, for example
the use of 'Jesus Christ' or 'God', or of the names held holy by other faiths. In particular, the
use of these names as expletives in drama or light entertainment causes distress far beyond
their dramatic or humorous value. While there is a wide range of attitudes to the use of these
words, it is important for programme makers to be satisfied that their inclusion can be
justified despite the distress that may be caused.
The inclusion of strong language is a matter for judgement by individual producers, in
consultation with Heads of Department or Commissioning Executives when necessary. The
most offensive language should not be used on television before 9pm, and if used thereafter it
should be only after due consideration.
The practice on radio is different. The speech channels, overwhelmingly the preserve of adult
audiences, include challenging drama, comedy and factual programmes throughout the day. .
The inclusion of sensitive topics and strong language depend less on time of day than on
editorial merits and clear signposting of programme contents. On the music networks - and
elsewhere - when substantial numbers of young people and families are listening, care is
needed with language and topic matter.
Certain, mainly four-letter, words must not be used on television, radio or online
without advance reference to and approval from Channel and Network Controllers of
the domestic services, in the World Service the relevant Regional Head, or in Worldwide
Television, the Director of Broadcasting. On online services referral must be made to the
Director of BBC ONLINE. For BBC News Online pages prior approval must be
obtained from the Project Director, Continuous News Multimedia. 9 RELIGIOUS SENSIBILITIES
Programme makers dealing with religious themes should be aware of what may cause
offence. Programme makers and schedulers of international services should consider carefully
the varying sensitivities of audiences in different parts of the world. What may be
unexceptional in a U.K. programme may raise strong feelings elsewhere. Advice can often be
given by the departments dealing with religious programmes in both domestic and
international services, or by the relevant World Service language sections.
69
RFI20080896
Deep of
fence will also be caused by profane references or disrespect, whether verbal or
visual, directed at deities, scriptures, holy days and rituals which are at the heart of various
religions - for example, the Crucifixion, the Gospels, the Koran and the Jewish Sabbath. It is
against the Muslim religion to represent the Prophet Mohammed in any shape or form.
Language must be used sensitively and accurately and be consistent in our description of
different religions. Use of a term such as “Islamic Fundamentalist” has to pass the test of
whether we would talk about Christian or Hindu Fundamentalism.
Particular care should be taken with programmes to be broadcast on the principal holy days of
the main religions to ensure that unnecessary offence is not caused by material that might be
more acceptable at other times.
What constitutes blasphemy and how seriously it is viewed, varies within and between
different religions and cultures. Blasphemy is a criminal offence in the UK and advice should
be sought, through Heads of Department or Commissioning Executives, from Editorial Policy
and lawyers in any instance where the possibility of blasphemy may arise.
10 SEX
The portrayal and depiction of sex will always be a part of both drama and factual
programmes because of the important part it plays in most people’s emotions and experience.
In this, as in most areas of taste, public attitudes have shifted over time. Broadly, audiences in
the United Kingdom have become more liberal in their acceptance of sexually explicit
material while attitudes around the world are mixed. Even so programme-makers
broadcasting to diverse audiences in their homes, are not as free as film-makers, theatre
dramatists and novelists whose audiences are self-selected.
Adults who accept frank portrayal of sex and sexuality in other formats or on television in the
later evening often demand different standards at other times. Those watching with children
before 9pm expect programme makers to observe the Watershed by exercising appropriate
restraint. Context, the intention of the production, the expectations of the audience, the
Watershed and signposting are all vital.
When sexual subjects feature in news, documentaries and discussion programmes,
programme makers must observe the need for careful scheduling, labelling and signposting.
Sensitive handling can help prevent the most delicate of subjects from causing widespread
offence. Sensationalism should be avoided and extremes of sexual behaviour should not be
presented as though they are the norm.
Some drama series, factual and discussion programmes have shown that they are able to deal
with difficult material and adult storylines in a way that is acceptable to a pre Watershed
audience. However, sensationalism in choice of subject and explicitness in the treatment of
sexual themes should be avoided.
We use the Watershed to try to ensure that adults view what is intended for adults. Sexual
activity is linked to moral decisions, therefore its portrayal should not be separated from an
acknowledgement of the moral process.
Drama and factual programmes have a part to play in illuminating the darker side of human
nature. Sometimes themes and images are explored which may shock. The tests to apply are
intention, (are we illuminating?), and judgement (does our portrayal demean or degrade?). We
70
RFI20080896
m
ust draw the line well short of anything that might be labelled obscene or pornographic. For
example, real, as opposed to simulated, sexual intercourse should not be shown.
We try to operate by certain basic rules that apply to all programmes that deal with sexual
activity:
•
programmes should be adequately and clearly signposted
•
scenes should have a clear and legitimate editorial purpose and not be gratuitous
•
sexually explicit material will not appear before the Watershed, nor at
inappropriate times too close to the Watershed
•
there are limits to explicit portrayal at any time
•
material involving sexual violence or sadism will be treated with particular care and
circumspection.
Sexual scenes that will disturb or shock should occur only for good dramatic reasons. In
particular, viewers remain concerned about the depiction of sexual violence against women
and sadistic sexual material. Such material demands careful consultation within departments
and with Channel Controllers or, at their request, Chief Adviser Editorial Policy.
Care should also be taken not to reflect in an unthinking way stereotypes of either male or
female behaviour or apply different standards to male or female nudity. Sexuality is a
universal human attribute: depiction of sex should not be linked solely or inevitably to the
physical attractiveness of the characters involved.
Attitudes to homosexuality differ both domestically and internationally. Research suggests
that in Britain audiences are becoming more tolerant of the portrayal and discussion of
homosexuality, and while some international audiences are more liberal, some are more
conservative. Nevertheless programme makers should be mindful that a significant part of the
audience is critical of any depiction of homosexual acts.
10.1 Sexual innuendo
Sexual innuendo can be verbal or visual. Although what is said or acted out is implied rather
than explicit, the producer’s obligation to make judgements about taste and decency remain.
Material should be appropriate to the programme’s place in the schedule and judgements
should be sensitive to the listening or viewing audience.
10.2 Children
Explicit sexual conduct between adults and children should not be depicted. The Protection of
Children Act 1978 makes it an offence to take an indecent photograph of a child under the age
of sixteen or to involve a child below that age in a photograph which is itself indecent even if
the child's role is not.
11
COMEDY AND ENTERTAINMENT
71
RFI20080896
Com
edy enjoys special licence. It flourishes on departures from the norm, and exploiting
people's misfortunes. Even so it must be well judged, not gratuitous, unnecessarily cruel or
designed to harm or humiliate a person or group. General relaxation about sexual matters does
not justify crudity.
When jokes are made about physical or mental disability, there is a danger of causing great
distress to some and offence to a wider audience. Even where no malice is intended, this type
of joke may seem like using humiliation as a form of entertainment. Remember too that jokes
about real-life tragedy may be extremely painful for people close to the event and might
offend a wider audience.
11.1 Stereotypes
There is also a need for sensitivity over jokes based upon race, religion, age, disability or sex.
Remember that groups of people who are the targets of such jokes might be hurt by them.
Stereotyping needs judging with care. Irish jokes and Jewish jokes, for example, have the
potential to injure as well as upset when told by an outsider. When told by an Jewish or Irish
person they can reveal insight and affection as well as an awareness of the weaknesses and
strengths of the community in question. It's a matter of tone and context.
If comedy conveys a sense of superiority or prejudice it has gone too far. Minorities are by
definition vulnerable. The raw power of words can sometimes be more harmful than many
people realise.
11.2 Religion
The issues raised in section 9(Religious Sensibilities) apply with full force in comedy.
On religious sensibilities, Editorial Policy should be consulted if clarification is needed.
Producers in the international services should be aware of attitudes in the countries and
regions to which their programmes are broadcast.
11.3 Light Entertainment and Game shows,
Game shows, people shows and light entertainment can be both popular and enjoyable
without breaching standards on taste and decency. Crudeness is unacceptable; language and
sexual innuendo have to be judged according to the scheduling and the likely audience at
home. Be careful not to promote sexual, racial or other stereotypes.
Game shows and People shows are the points where the BBC most evidently comes into
contact with its mass audience. It is important that these programmes set the standard for the
way the BBC treats people. We must not patronise them or exploit them, nor be seen to
humiliate them (see also Chapter 22: Game Shows and Competitions).
12 ACQUIRED PROGRAMMES
The principles of this chapter and of Chapter 7: Violence apply equally to acquired
programmes. The content of films or drama not originally commissioned by the BBC cannot
be controlled in the same way, but nonetheless it must conform to BBC editorial standards.
Some feature films, whether made in Britain or abroad, are suitable only for adult audiences.
The British Board of Film Classification categorises every film for cinema or video release in
72
RFI20080896
the UK. W
hile these classifications offer some guidance to their suitability for showing on
BBC Television, they cannot be accepted without question. Tastes change and films once
regarded as wholly unsuitable may become acceptable; but some films may never be
acceptable on television. Special care must be taken over the acquisition of films which have
an ‘18 ‘certificate.
Acquired programmes need to be double checked in detail prior to transmission to identify
any need to edit, to place the programme after the Watershed, or to issue a warning in the
billings, and/or on air.
Some viewers object strongly to any editing of feature films. The BBC will try to ensure that
any editing interferes as little as possible with the original intentions of the film maker. In
addition, after the Watershed on BBC TWO, films which have received a certification for
showing in cinemas or on home video will normally be shown unedited.
Programme makers who need further advice on taste and decency issues should consult
their Head of Department or Commissioning Executive, who can seek further guidance
and support from Chief Adviser, Editorial Policy. CHAPTER 7
VIOLENCE
1 GENERAL
2 REAL-LIFE VIOLENCE
2.1 Violence in the News
2.2 Violence in Factual Programmes
2.3 Violence Involving Animals
3 VIOLENCE IN FICTION
3.1 Adult Drama
3.2 Acquired Programmes
3.3 Children and Violence
3.4 Violence Against Women
4 SCHEDULING, WARNINGS AND THE WATERSHED
1
GENERAL
It is clear that screen violence does upset many people and, in excess, it can be accused of
desensitising viewers. Audiences remain concerned about the portrayal of violence, especially
violence they perceive as realistic and therefore true to life or violence that is close to their
own experience.
Most audiences expect any violent scenes in news, factual programmes and television drama
to serve a moral or a social point. In feature films and occasionally in comedy, there is some
acceptance that certain types of stylised screen violence can be entertaining.
Consideration should be given to the time of day when any violent sequences are shown.
Particular care must be taken to ensure the suitability of scenes of violence shown before the
9.00 p.m. Watershed and excessive violence should be avoided altogether. Trails shown
before the Watershed should not include unsuitable material. See also section 2 of Chapter
6:Taste and Decency.
73
RFI20080896
Editors and producers can becom
e very involved in the material they work with and it is
always necessary to step back and think about its impact. It is important, for example, to
consider:
•
whether a violent incident is appropriate within its context
•
the impact of violent episodes on the viewer at home seeing them for the first time
•
the cumulative effect if programmes containing violence are scheduled close together, or
the programme is to be repeated frequently.
2
REAL-LIFE VIOLENCE
2.1 Violence in the News
Television's ability to show events throughout the world almost instantaneously brings
responsibilities. The volume of harrowing and distressing material now available to
newsrooms could dominate news programmes if not well handled. A bulletin needs to be
considered as a whole, for its total impact on the audience, and not simply as a series of
isolated stories.
There is a balance to be struck between the demands of truth and the danger of desensitising
people. With some news stories a sense of shock is part of a full understanding of what has
happened. However, the more often viewers are shocked, the more it will take to shock them.
Some of this material will involve images of the aftermath of violent acts, rather than the act
itself (see section 2 “Depicting Trauma” in Chapter 12: Reporting Suffering and Distress).
In reporting real life events involving violence, the use of earlier recordings of similar
incidents, (as, for instance, in reporting the latest outrage by a terrorist group), or as
“wallpaper”, should be considered with great caution and must always be strictly relevant.
Particular care needs to be exercised in the editing of pictures for bulletins likely to be seen
by vulnerable groups such as children. Care should also be applied to decisions about the
frequency with which scenes of violence are repeated in succeeding bulletins, particularly in
daytime hours, when children could be watching.
2.2 Violence in Factual Programmes
Most of the principles applying to violence in the news apply to other factual programmes.
The same considerations about transmission times apply. When using library material,
producers should avoid routine use of images that have become stereotypes. Scenes
containing excessive violence may only cause revulsion and diminish the overall
effectiveness of a sequence.
2.3 Violence Involving Animals
Audiences may be sensitive to violence involving animals. Such violent scenes must have a
justified editorial purpose.
However, there is a distinction in the animal world between aggressive behaviour among the
same species and predatory attacks, by one species on a different species. Both types of
74
RFI20080896
violence are fundam
ental to animal behaviour. The evidence is that audiences have less
objection to displays of aggression between animals of the same species, such as conflicts
between males for dominance. Scenes of predatory behaviour that are likely to cause distress
need to be handled with care and without unnecessary detail.
Particular care must be taken in dealing with scenes in which humans appear to inflict
violence on animals. It may sometimes be helpful to consider an on air announcement to
make it clear that no harm was done.
The law governs the use of animals in programmes. In the United Kingdom, bull-fighting,
dog-fighting and cock-fighting are illegal. Broadcasting such scenes, whether recorded here
or overseas, will rarely be justified and must be referred to the head of department (see also
Chapter 20: Recording The Natural World)
When broadcasting for an international audience we should also be aware of the religious
importance of some animals, and that offence can be caused by appearing to ridicule or
otherwise demean them.
3
VIOLENCE IN FICTION
3.1 Adult Drama
Drama must be able to explore important issues truthfully, and violence is part of both nature
and society. However, where a theme is likely to involve scenes of strong violence, they
should be identified in advance by the producer and director so that potential problems can be
resolved at the script stage. There should be consultations within departments, and if
necessary with channel Controllers or, at their request, Chief Adviser Editorial Policy.
Programme makers should ask whether the violent incident and the detail shown are essential
to the story or whether it has been included simply for its own sake. The use of violence
should never be gratuitous.
The degree and type of violence, and the detail that can be shown, depends upon context.
Audiences are sometimes willing to view disturbing material so long as it has a clear moral
context. This is not because they enjoy it but because they recognise it as being true to life.
For example, serious drama demands more of audiences; they in turn respect the challenge of
a violent or distressing scene if they are convinced of its dramatic purpose.
However, audiences may enjoy a good deal of violence in action-packed thrillers, but expect
its nature and style to be as far removed from reality as the story. Similarly in comedy,
audiences may enjoy stylised violence (e.g. slapstick) as long as the humorous context is
clear.
When programme makers are required to make judgements about the portrayal of violence
they should be aware that viewers judge the strength of screen violence on the basis of a
variety of factors. When one or more of these factors are combined the scene will be
perceived as being more violent.
Programme makers should take particular care when violence involves one or more of the
following:
75
RFI20080896
•
situations close to the audiences own experience, or which they perceive as being true to
life
•
domestic and sexual violence
•
scenes where women and children are portrayed as victims
•
scenes of extreme or sustained violence of any sort
•
the context appearing to encourage approval of violence
•
suicide or attempted suicide.
Programme makers should be aware of the sophisticated understanding viewers have of
different production techniques used in the portrayal of screen violence. When graphic close
ups, strong language, sound effects atmospheric music, and reactions from onlookers are used
together the cumulative effect should be considered carefully.
The
consequences of violent acts should not be overlooked, otherwise there is danger of
seeming to sanitise them. For example, a blow to the head must not, in a realistic setting, be
seen as a trivial matter without serious consequences.
It is important to take particular care when dealing with weapons that might encourage
imitation, especially the use of easily accessible weapons such as knives, hammers or pokers,
or methods that might suggest how violence can be made more effective (see also Chapter 8:
Imitative and Anti Social Behaviour).
Violence is not always physical. Verbal aggression can be profoundly disturbing, particularly
when the words used have sexual power. Care must be taken to ensure suitability for the
intended time of transmission, particularly if audiences are likely to include children.
3.2 Acquired Programmes
Many of the general points made about BBC drama apply to acquired programmes. The
content of films or drama not originally commissioned by the BBC cannot be controlled in the
same way, but nonetheless it must conform to BBC editorial standards. For detailed guidance
see section 12 “Acquired Programmes” in Chapter 6: Taste and Decency.
3.3 Children and Violence
There is evidence that violence in circumstances resembling real life is more upsetting than
violence in a fantasy setting. Children may feel particularly distressed when violence occurs
in a familiar setting or between familiar figures. For instance, violence in the home between
characters resembling their parents, or towards characters or pets, with which the child can
sympathise, should be avoided. Children can also be particularly distressed by violence
involving animals.
The dangers of imitation are particularly real among children. Extra care should be taken, for
example, over karate chops or the use of weapons that are easily accessible such as ropes or
knives or bottles. Criminal acts, if shown, should not become lessons in "how to do it ". It is
also important not to conceal the consequences of real-life violence.
76
RFI20080896
3.4
Violence Against Women
Violence against women in drama should not encourage the notion that women are to be
exploited or degraded through violence or are, other than exceptionally, willing victims of
violence. Rape is nothing but a tragedy for its victim and it would be wrong to suggest
otherwise.
Violence against women should not be portrayed as an erotic experience. Where in rare cases,
a link between violence and sexual gratification is explored as a serious theme in drama, any
depiction must be justified by its context and not simply designed to arouse.
Similar sensitivities apply to violence against children.
4
SCHEDULING, WARNINGS AND THE WATERSHED
When factual programmes or drama are to include violent scenes, consider issuing warnings
to prevent the audience from being taken unawares. This is a key to avoiding widespread
offence. Remember that the nature of the programme may be signposted through trails,
publicity, promotional material and listings. These are not however, a substitute for clear and
unambiguous on-air warnings. If a programme is tough to watch, viewers should be told.
Programme departments should alert the channel controllers and presentation departments in
advance when they judge a warning is required so that the overall amount of violence in the
schedule can be kept under review.
On television, the Watershed is the pivotal point in the evening schedule. Particular care
should therefore be given to avoid the depiction of unsuitable violence in the early evening
including trails for post Watershed programmes.
Programme makers should also refer to the section 2: Television : The Watershed, in Chapter
6 Taste and Decency and to Chapter 12: Reporting Suffering and Distress.
International services should aim to apply a Watershed policy as fully as possible but these
services may serve many different time zones and so a flexible interpretation of the
Watershed may be needed. Programmes should observe the general principles the BBC
maintains on the use of distressing and violent images.
Chief Advisor Editorial Policy is available to offer advice to Heads of Department and
Commissioning Executives on the portrayal of violence.
CHAPTER 8
IMITATIVE AND ANTI SOCIAL BEHAVIOUR
1 GENERAL
2 CRIME AND VANDALISM
3 IMITATION AND CHILDREN
4 SUICIDE
5 DRUGS
6 SOCIAL AND ANTI-SOCIAL BEHAVIOUR
7 SEAT BELTS
8 HYPNOTISM
1 GENERAL
77
RFI20080896
Audiences are concerned about the possibility of people im
itating behaviour they see or hear
on television and radio. We should try to ensure that any life threatening, anti-social, or
criminal behaviour portrayed in BBC programmes does not encourage copycat actions.
2 CRIME AND VANDALISM
Particular care should be taken when dealing with vandalism, the use of weapons or criminal
techniques. It is important to avoid revealing too much detail or ways in which such activity
can be made more effective.
3
IMITATION AND CHILDREN
Children's play is often influenced by what they see on television. In programmes made for
children or likely to be popular with them, we need to avoid showing actions or techniques
which could lead to dangerous imitation.
Smoking and drinking in children's programmes should generally be avoided. It is advisable
to discourage smoking and drinking by pop stars, actors and others who are admired by
children when they appear in interviews for television.
Hanging scenes are not suitable for children's output. Any decision to show a hanging scene
before the Watershed should be referred to the Department Head. Care should also be taken
about the amount of detail shown in any hanging scene, even if it is to be shown later in the
evening.
Inventive and unusual methods of inflicting pain and injury, particularly when capable of easy
imitation with objects readily available in the home, such as knives or hammers, should not
appear in children's programmes. Also, remember the danger of suffocation from plastic bags.
Where hazardous activities such as climbing or motorcycling are portrayed in programmes
aimed at children, warnings should be given of the dangers of imitation without expert
supervision.
4 SUICIDE
In drama, unnecessary concentration on suicide methods should be avoided. Particular care
should be taken in making editorial judgements about any drama that seems to exploit or
glorify suicidal behaviour and actions or to overemphasise the “positive” results of a person’s
suicide.
Suicide is a legitimate subject for news reporting but the factual reporting of suicides may
encourage others. Reports should avoid glamorising the story, providing simplistic
explanations, or imposing on the grief of those affected. They should also usually avoid
graphic or technical details of a suicide method particularly when the method is unusual.
Sensitive use of language is also important. Suicide was decriminalised in 1961 and since
then the use of the term “commit suicide” is considered offensive by some people. “Take
one’s life” or “die by suicide” are preferable alternatives.
When suicide features as a subject in factual programmes it should be treated in an informed
and sensitive way.
It may be the case that both factual and drama programmes that feature suicide have a
profound effect on the audience. In this case, programme makers should think about
78
RFI20080896
providing a helpline or som
e other form of support material (see also Chapter 32: Phone Ins
and Telephone Services in Programmes and Chapter 31: Support Services and Support
Material).
The Chief Executive of the Samaritans is happy to be consulted by producers who want
advice on the depiction of suicide.
5 DRUGS
Attitudes to drug use vary within the UK and internationally. Factual programmes wishing to
investigate the use of drugs will often need to address issues of anonymity, the protection of
children and how the drug use is portrayed. It may be necessary to make clear the legal and
social context for a full understanding of the story. It should be remembered that filming
contributors using illegal substances e.g. smoking cannabis could result in a criminal
investigation.
6 SOCIAL AND ANTI-SOCIAL BEHAVIOUR
The acceptability of common forms of social behaviour like smoking or drinking tends to
alter over time. There is a difficult balance to be struck by programme makers between the
danger of encouraging potentially damaging habits, particularly amongst the young, and the
need to reflect the range of public attitudes and behaviour realistically.
In both drama and factual programmes there are cases where smoking is essential to a
character or story. But in general programmes, such as a studio debate, smoking is likely to be
objectionable. Contributors can be reminded of such issues before recording begins.
Similar judgements have to be made about the portrayal of drinking. Factual programmes
should deal accurately and fully with all aspects of the issues involved. Fiction should offer a
realistic reflection of the place of alcohol in social life. Producers must be sensitive to the
anti-social aspects of excessive consumption.
Producers may need to be aware of religious sensitivities about smoking and drinking,
particularly when making a programme for international broadcast. For example, associating
a person who may be perceived to be a Muslim with tobacco or alcohol, may take on added
significance for the audience.
7 SEAT BELTS
The law normally requires drivers and passengers, in the front and back seats, to wear seat
belts. We should show the law being observed unless there are good reasons for not doing so.
Similar considerations apply to the use of mobile phones while driving.
8 HYPNOTISM
The main danger to be avoided is doing any harm to people at home. Demonstrations of
hypnotism for public entertainment are regulated by the Hypnotism Act 1952. The Act
requires such demonstrations to be licensed and prohibits their being carried out on anyone
under the age of 18. The provisions of the Act are relevant to any televised demonstration of
hypnotism at, or in connection with, an entertainment to which the public are admitted.
Any producer considering a demonstration of hypnosis should consult the Head of
Department. Hypnotism acts in variety shows should be treated with care. Even those
79
RFI20080896
designed to ridicule the subject could conceivably harm
people at home, quite apart from the
questions of taste involved. Any risk of hypnosis being induced in susceptible viewers should
be minimised. In particular, a hypnotist should not be shown performing straight to camera.
Chief Advisor, Editorial Policy is available to offer advice to Heads of Department and
Commissioning Executives on issues involving imitative and anti-social behaviour.
CHAPTER 9
PORTRAYAL
1 GENERAL
2 COMMON CONCERNS
2.1 Under-representation on air
2.2 Hurtful or inaccurate stereotypes
3 WOMEN
4 ETHNIC MINORITIES
4.1 Terminology
4.2 Misleading images
5 DISABILITIES
5.1 Terminology
5.2 Common concerns
5.3 Interviewing people who are blind or visually impaired
6 PORTRAYAL OF RELIGIOUS GROUPS
7 SEXUAL ORIENTATION
7.1 Stereotyping
7.2 Acknowledging sexuality
7.3 Terminology
8 OLDER PEOPLE
1 GENERAL
The BBC has a responsibility to serve all sections of society in the United Kingdom. Its
domestic services should aim to reflect and represent the composition of the nation. Globally
we should apply the principles of fair portrayal to all our international services, which should
strive to present balanced pictures of the people and countries covered.
We should try and give a full and fair view of people and culture in the United Kingdom and
across the world. BBC programmes and services should reflect and draw on this diversity to
reflect life as it is. By doing so we introduce new talent, perspectives, faces and voices
enriching our programmes for our audiences.
When portraying social groups, stereotypes should be avoided. But we must also beware the
danger of depicting a society that does not exist. The BBC is not in the business of social
engineering. Where prejudice and disadvantage exist we need to report and reflect them in our
programmes. But we should do nothing to perpetuate them.
When describing different groups a good rule of thumb is to ask how people describe
themselves: there have to be good reasons for calling them something different.
For further advice on portrayal of the different nations that make up the United Kingdom see
Chapter 19: Reporting The United Kingdom.
2 COMMON CONCERNS
80
RFI20080896
Som
e concerns are common to all groups who feel under represented and inadequately
portrayed in programmes.
2.1 Under-representation on air
People from all groups should be represented in the full range of our programmes.
Programmes should draw their participants or casts from a broad range, and not concentrate
unreasonably on able-bodied white men. The BBC has specialist programmes, programme
departments and the BBC Diversity Database on which programme makers can draw to widen
the range of people represented. The Broadcast Equality Unit can be consulted for further
advice.
2.2 Hurtful or inaccurate stereotypes
People should appear in the full range of roles that reflect reality.
BBC programmes should not categorise black people as criminals, women as housewives,
disabled people as victims, gay people as ineffectual, old people as incapable, or people of
any particular profession, vocation or walk of life as inevitable figures of fun.
3 WOMEN
Women form the majority of the population in the UK. In spite of laws and changing attitudes
women are still discriminated against in some respects and are often under-represented in
programmes. Older women are particularly under-represented in programmes and their
portrayal is often limited.
Use of non-sexist language is one way to avoid perpetuating the impression that certain
activities are the preserve of one sex only.
For many words which refer to a time when women were barred from many types of work
(firemen, policemen, taxmen, newsmen, manning) there are comfortable alternatives which
are not sexist (firefighters, police officers, tax inspectors, journalists, staffing).
Some people are uncomfortable at the use of some non-sexist terms. It is always possible to
re-write a sentence to avoid both sexism and political correctness. However, we should
respect people's wishes about how we refer to them. If someone calls himself or herself the
"Chair" of an organisation it is not for us to make them Chairman or Chairwoman or vice
versa.
4 ETHNIC MINORITIES
It is narrow-minded to identify people only by ethnic origin or colour when they have a host
of other characteristics. Colour should be mentioned only when it is relevant. Ask yourself
each time: would you say "white" in similar circumstances?
4.1 Terminology
The phrase “ethnic minority” is not a universal shorthand for “black”. White people can also
be ethnic minorities
Geographic or ethnic origin is often more relevant than colour of skin...' Bangladeshi',
'Jamaican', 'West Indian', ‘Nigerian’ and so on
81
RFI20080896
'B
lack' should not normally be used to include Asians. Refer to 'black and Asian people' or
'Asian, African and Caribbean people'. Just as we do not say ‘Non-blacks’ we avoid 'Non-
whites'.
Many people in Britain of African and Caribbean origin prefer to be called “black British“.
Use the term 'black people' rather than 'blacks'.
A good rule of thumb is to ask how people describe themselves: there have to be good reasons
for calling them something different.
4.2 Misleading images
Most ethnic minority people living in Britain are British nationals. A large and growing
proportion was born here. They are an integral part of British society.
Black and Asian people suffer considerably from negative stereotyping. Programmes must not
allow offensive assumptions or generalisations in scripted material, and interviewees who
express them need to be challenged wherever possible.
5 DISABILITIES
Consideration of the representation and portrayal of people with disabilities is a complex
subject not least because what constitutes a disability is extremely wide. 1 in 4 of the UK
population either has a disability or is related to or cares for a disabled person. Disability is
even more prevalent in the developing world. People with disabilities are consistently under
represented in programmes.
Programmes can be sensitive to the rights and dignities of disabled people without losing
editorial integrity or strength. People with disabilities should not be patronised. Stereotyped
thinking that characterises people with disabilities as either 'brave heroes' or 'pitiable victims'
often causes offence.
Programme makers should be aware of BBC policies on subtitling, guidelines for visually
impaired television viewers and any other relevant BBC guidance that deals with the
BBC’s obligations under the Disability Discrimination Act 1995.
5.1 Terminology
Euphemisms are not necessary. Plain, matter-of-fact language is appreciated.
•
‘The disabled’ can be perceived as offensive. It defines people as a problem group and
denies individuality. ‘Disabled people’ is acceptable to some, but others prefer ‘people
with disabilities’. BBC programmes use both
•
Never refer to ‘the handicapped’. Words like ‘invalid’, ‘spastic’, ‘retarded’ or ‘defective’
cause widespread offence
•
Terms such as ‘the blind’ or ‘the deaf’ are often disliked. ‘'Crippled with’, ‘victim of’,
‘suffering from’, ‘afflicted by’ should be avoided. ‘People who have’ or ‘a person with’
will usually be clear, factual, and inoffensive
82
RFI20080896
•
However some people with disabilities will describe themselves bluntly as ‘ blind’, ‘deaf’
or ‘crippled’. We should respect their right to call themselves what they wish, while
trying to avoid offence
•
People with an intellectual disability are now normally described as 'people with learning
difficulties'. 'Mental handicap' is acceptable to some people, but others dislike it because
they believe it carries a stigma
•
'Learning difficulties' should not be confused with 'mental illness'
•
Try to be precise about deafness. Use 'deaf/partially deaf/deafened/hard of hearing'. 'Deaf
and dumb' is not acceptable
•
Some people who use wheelchairs often dislike the terms 'confined to a wheelchair' or
'wheelchair-bound' on the grounds that wheelchairs provide mobility, not confinement. A
person who 'uses a wheelchair' or 'is in a wheelchair' is preferable.
5.2 Common concerns
Disability is an everyday phenomenon, though it may not always be apparent. The BBC
should reflect that in its fictional and factual output. People with disabilities should be able to
take part in entertainment programmes without, of course, our needing to make reference to
the fact on air. People should be described in terms of their disability only when it is relevant.
5.3 Interviewing people who are blind or visually impaired
During interviews, be sensitive to the difficulties that may be experienced by people who are
blind or have very poor vision. In television, help visually impaired interviewees to present
themselves as they would wish. Explain where any items of equipment are that could be a
safety hazard.
6
PORTRAYAL OF RELIGIOUS GROUPS
People and countries should not be defined by their religions unless it is strictly relevant.
Particular religious groups or factions should not be portrayed as speaking for their faith as a
whole. Thoughtless portrayal can be offensive, especially if it implies that a particular faith is
hostile or alien to all outside it. For example, footage of chanting crowds of Islamic activists
should not be used to illustrate the whole Muslim world.
Words such as “fundamentalist”, and “militant” should be used with great care. What may be
a fair description of one group may not be true of all similar groups. Use of a term such as
“Islamic Fundamentalist” has to pass the test of whether we would talk about Christian or
Hindu Fundamentalism (see also section 5 International Audiences and section 9 Religious
Sensibilities of Chapter 6: Taste and Decency).
7 SEXUAL ORIENTATION
BBC programmes must not be vehicles for prejudice. Lesbians and gay men can be
particularly subject to thoughtless and offensive stereotyping.
Gay and lesbian people, and those who are bi-sexual, make up a significant minority entitled
to be served and treated fairly by the BBC. Programme makers should remember that
homosexuals play a full range of roles in society. They have the same right as others to see
83
RFI20080896
that range truthfully portrayed.
7.1 Stereotyping
Stereotyping is a particular danger if the gay characters we portray are present only because
of their sexuality or if their sexuality is their main distinguishing characteristic. Remember
that sexual orientation may be an incidental characteristic. We must not confuse
homosexuality with transvestism or trans-sexualism, neither of which relates specifically to a
person's sexuality.
Programmes must not allow offensive assumptions or generalisations in scripted material, and
interviewees who express them need to be challenged with vigour.
7.2 Acknowledging sexuality
When relevant, there should be straightforward reference to the publicly- acknowledged
homosexuality of well-known people and their acknowledged partners. This might occur, for
example, in profiles, obituaries and other contexts where it is strictly relevant or where
heterosexual relationships would be considered similarly relevant. However, it is not for the
BBC to force matters of sexuality into the open. We have a strong regard for privacy in this as
in other matters.
7.3 Terminology
Be sensitive to the effect of language. 'Homosexual' has wide currency. 'Gay and lesbian' is
often preferred and is certainly acceptable. There is no place in factual programmes for our
use of words like 'queer', 'dyke', 'fairy' or 'poof': when contributors use them in a pejorative
way they should be challenged wherever possible.
When they are used by characters in drama programmes they are just as sensitive as racial
abuse and should be considered accordingly.
8 OLDER PEOPLE
Many old people lead vigorous and fulfilling lives. Images that concentrate on them as living
on the margin, dependent, frail, sexually inactive
and passive, ignore the reality that people
past the usual age of paid employment and family-rearing are often busy, active and useful.
Reference to age does not necessarily tell us anything about ability, interests, state of mind or
health. It should be included only when it is relevant. The BBC places no general upper age
limit on participation in programmes, whether in the audience or as contestants, competitors
or artistes. The only criterion should be ability to do what is required.
Chief Adviser, Editorial Policy is available to offer advice and support to Heads of
Department and Commissioning Executives on the whole range of issues involved in
portrayal. CONFLICTS OF INTEREST (Revised 20th January 2004)
1 GENERAL
2 MAINTAING IMPARTIALITY
3 ACCEPTABILITY OF OUTSIDE COMMITMENTS
4 POLITICAL ACTIVITIES
5 COMMERCIAL, BUSINESS AND FINANCIAL INTERESTS
6 PERSONAL BENEFITS
7 ON-AIR TALENT AND COMMERCIAL ADVERTISING
84
RFI20080896
8 TALENT/AGENT OWNED INDEPENDENT PRODUCTION
COMPANIES
1 GENERAL
The BBC’s reputation for impartiality and objectivity is crucial. The public must be able to
trust the integrity of BBC programmes and services. Our audiences need to be confident that
the outside activities of our programme makers or presenters do not undermine the BBC’s
impartiality and that editorial decisions are not influenced by any commercial or personal
interests.
Conflicts of interest can arise for anyone who appears on air or has responsibility for the
content of a programme or service or associated activity. Presenters, reporters, producers,
editors and researchers are all affected. There may be particular sensitivities concerning on-
air talent. For editorial staff the greater the level of responsibility the greater the need to
avoid any possible conflict of interest. Each programme department or team will need to
identify its area of vulnerability.
The BBC should be satisfied that everyone involved in editorial decisions and programme
making is free from inappropriate outside commitments. The principles apply equally to
freelances or staff. It is also important that independent producers should not have any
interests which could undermine the integrity and impartiality of the programmes or websites
which they produce for the BBC.
It may also be appropriate to consider whether the position of families and close personal
contacts presents a likely conflict of interest.
When drawing up contracts for presenters, freelances and production staff, the provisions of
these guidelines should be taken into account.
BBC production and editorial staff are required to declare any personal interest which may
affect their work with the BBC. These interests will be registered with Human Resources and
copied to the relevant manager or Head of Department. Interests should be declared on a
Declaration of Personal Interest Form. The staff handbook “Conflict of Interest” available on
gateway or from Human Resources Departments gives further details. Production and
editorial staff will be asked to up date their declarations on a regular basis.
Freelance presenters, reporters, producers and researchers will be required to declare any
personal interests which may affect their work with the BBC.
2 MAINTAINING IMPARTIALITY
2.1 News and Current Affairs News, and current affairs programmes may deal with any issue, cause, organisation or
individual. People who work on these programmes should have no outside interests or
commitments which could damage the BBC’s reputation for impartiality, fairness and
integrity.
Presenters and reporters primarily associated with the BBC
85
RFI20080896
Those known to the public prim
arily as presenters of, or reporters on, BBC news
programmes or programmes about current affairs, must be seen to be impartial. It is
important that no off-air activity, including writing, the giving of interviews or the making of
speeches, leads to any doubt about their objectivity on-air. If such presenters or reporters
publicly express personal views off-air on controversial issues, then their on-air role may be
severely compromised. It is crucial that in both their BBC work and in non BBC activities
such as writing, speaking or giving interviews, they do not:-
• state how they vote or express support for any political party
• express views for or against any policy which is a matter of current party political debate
• advocate any particular position on an issue of current public controversy or debate
• exhort a change in high profile public policy.
If, in an exceptional case, such a presenter or reporter writes or speaks off-air in favour of
one position on an issue of current public controversy, this could give rise to concerns about
impartiality. The relevant Director or Head of Department should give very careful
consideration as to whether there is an actual conflict of interest and whether they should
declare their interest on-air or not present items or conduct interviews on the issue.
Permission must be sought from the relevant Director, Head of Department or their nominee
before outside writing or speaking commitments are undertaken about current affairs or
matters of current public controversy or debate.(See section 3 below).
When making judgements about what off-air activities are acceptable, the Director or Head
of Department should take into account the degree to which a news or current affairs reporter
or presenter is directly identified with the BBC and therefore how far their views are likely to
be construed to be the views of the BBC. There may be particular constraints on those who
bear titles such as “BBC…Editor” or “BBC…correspondent”.
Occasional presenters whose primary identity is not the presentation of News and Current
affairs programmes
In some cases, the BBC may employ as presenters people whose primary occupation or
identity is not the presentation of broadcast news or current affairs. These presenters may be
newspaper editors, newspaper correspondents, columnists, writers or academics and in some
cases they will be known to hold specific views on current topics. Use of such freelance
presenters should not undermine the BBC’s reputation for impartiality and it may be
advisable in some cases to state on air what their main occupation is or the position which
they hold. If relevant it should be made clear that they hold partial views on a particular
topic. Such presenters should not be used to present news bulletins, nor would they normally
be used as presenters of major daily current affairs programmes.
Editors, producers and researchers
These concerns and restraints about off-air activities also apply to editors, producers and
researchers on news and current affairs programmes. It is important that they do not make
public statements or write articles about public policy issues in a way that could undermine
the perceived impartiality of their role or the programmes they produce. They must seek the
permission of their Head of Department or Director before undertaking any non-BBC activity
of this kind.
86
RFI20080896
2.2 Serious factual programmes In general the same constraints apply as for news and current affairs. The objectivity of the
programme, programme maker or presenter must not be undermined by any outside
commitment or activity. However, if a programme maker, editor or reporter only works in
one area, such as science, then it may be acceptable for them to express an opinion publicly
on a totally unrelated area such as the arts. Heads of Department must judge what is
appropriate.
2.3 Consumer and Lifestyle Programmes People working on these programmes, either as presenters or producers, must have no
commercial or other links which could appear to influence their attitude towards any product,
service or company. (see section 5 below Commercial Interests.) Any non-BBC activity
undertaken by presenters, such as writing or advertising should not undermine their integrity,
in particular they should not promote or advertise any product they might review on air (see
section 7 below on Commercial Advertising.)
2.4 Other programming In all other areas it is essential that programme makers and on-air talent do not undermine
their own integrity and the integrity of their programmes by off- air involvement in
inappropriate activities or commercial interests.
2.5 Presenters of Factual Programmes Appearing in Drama Presenters of factual programmes should be aware that simulating their normal role in drama
or comedy might carry risks for their own credibility and the credibility of the programmes in
which they usually appear. Any proposal to use a current BBC news presenter to present a
fictional bulletin must be approved by the head of the relevant news department who should
also specifically read and clear the script. It is important that there is no danger of the
audience confusing fiction with reality.
3 ACCEPTABILITY OF OUTSIDE COMMITMENTS
3.1 Writing Commitments Programme makers, editorial staff, reporters and presenters may all wish to undertake
journalistic work or write books. Any such activity should not bring the BBC into disrepute
or undermine the integrity or impartiality of BBC programmes or presenters.
Programme makers and editorial staff
No BBC staff journalist can write a regular newspaper or magazine column dealing with
current affairs or matters of current public policy debate or political or industrial controversy.
The only circumstances in which BBC staff journalists may write such an article will be in
the context of BBC marketing for one of its programmes, or in support of the BBC or its
interests, where the article has been submitted in good time to a divisional manager
responsible for vetting such articles, and sent in for publication by the BBC Press Office or
syndication after publication by BBC News Online.
87
RFI20080896
Non-controversial colum
ns, covering such matters as restaurant or cultural reviews may be
agreed, subject to the vetting procedure set out above.
Presenters and freelance reporters
The same rules apply to news and current affairs freelance presenters and reporters in News,
Global News and Nations and Regions, except where the relevant divisional Director has
agreed in advance and that the individual does not derive their main external status from their
work for the BBC.
In other programme areas, the relevant Director or Head of Department should normally ask
to see articles about subject matter which could give rise to a conflict of interest.
In some cases, with permission from the relevant Director or Head of Department, presenters
or reporters may write a book about a current topic provided it is not likely to compromise
the integrity or impartiality of the BBC. In such cases, if the viewpoint expressed turns out
to be controversial or one-sided, editors should consider whether to allow the presenter to
cover on-air the issue which they have written about. If there is any possibility of a conflict
of interest, the relevant Director or Head of Department should give very careful
consideration as to whether there is an actual conflict and whether they should declare that
interest on air or not present items or conduct interviews on the issue.
Letters to the press
Programme makers, editorial staff, reporters and presenters primarily associated with the
BBC should also clear with Heads of Department any letters to the press if they deal with the
subject matter of the programmes, any political, public policy or controversial issue, or relate
to the BBC or broadcasting. Even presenters who only occasionally present programmes for
the BBC should normally clear letters relevant to the subject matter of their programmes if
they are to be published around the time of transmission.
3.2 Public speaking and other public appearances Programme makers, those with editorial responsibility and any other BBC employees should
seek permission from their Head of Department before undertaking outside public
appearances or public speaking commitments. It is important that no such commitment
should be seen to undermine the objectivity or integrity of the BBC or its programmes.
Public appearances which are promotional for a particular commercial concern are unlikely
to be acceptable.
Presenters
Presenters of BBC programmes may well gain a significant proportion of their income from
off-air public appearances. However, presenters in all genres must guard against appearances
which undermine their on-air role. Promotional appearances have to be considered very
carefully and must not imply BBC endorsement. Presenters should consult the relevant
Heads of Department about any appearance connected with the subject matter of their
programme.
Presenters of News and Current Affairs programmes
88
RFI20080896
In the case of those known to the public prim
arily as presenters of, or reporters on, BBC
news programmes and programmes about current affairs, there is a greater possibility of
conflict of interest. Care must be taken to ensure that they remain impartial when speaking
publicly (see section 2.1 above) and do not promote any political party, campaigning
organisation or lobby group which may jeopardise their status as an impartial broadcaster.
The chairing of conferences may well be acceptable, but it is essential that the conference is
not a promotional exercise or one-sided on an issue of public controversy. They should
consult the relevant Head of Department about the suitability of public appearances and
conference work. The onus is on the presenters and reporters to inform the relevant Head of
Department about the range of public appearances which they undertake.
3.3 References to the BBC BBC people, freelances or presenters clearly associated with BBC programmes should not
speak or write publicly about the BBC without specific, prior approval from the relevant
Head of Department or Director. BBC people should also clear any references to the
broadcasting industry.
As well as concerns about bringing the BBC into disrepute, it should be borne in mind that
the BBC cannot be seen to endorse outside organisations and it is essential that no
promotional use is made of the BBC’s name or brand.
3.4 Media Training It may be appropriate for BBC presenters, editorial people or programme makers to speak
publicly at conferences or to interested bodies about broadcasting.
However, there are considerable dangers of a conflict of interest if BBC people train
individuals or organisations in how to present themselves on television, radio or online.
Producers, editors and journalistic staff must obtain permission from their manager before
undertaking any outside training work. Presenters, producers and editors should not train
people they are likely to interview or who are likely to appear on the programmes for which
they are responsible. We should ask freelance presenters about their commitments in this
area to ensure there is no conflict of interest.
Presenters involved in News, Current Affairs, topical programmes or consumer programmes
should not interview anyone they have trained and it is very unlikely that it will be acceptable
for producers or editorial people in these areas to undertake any outside coaching on how to
appear on air.
3.5 Charities and campaigning organisations Any work undertaken for a charity should not imply BBC endorsement for a particular cause,
or endorsement of one charity over another. There are particular difficulties if the charity
deals with matters of controversial public policy and is a campaigning organisation.
Programme people in all areas should be careful of involving themselves in lobbying
campaigns.
Presenters and editorial people in news, current affairs, topical and consumer programmes
should take particular care and they should not normally associate themselves with any
campaigning body, particularly if it backs one viewpoint in a controversial area of policy. It
89
RFI20080896
is unlikely to be appropriate for a news presenter to front a cam
paign for a charity or
campaigning body as this could undermine the BBC’s reputation for impartiality.
Heads of Department should be consulted about any work for charities and campaigning
groups and advice may be sought from Editorial Policy. For further guidance see Chapter
30: Social Action Programming, Campaigning Groups and Charities. There are separate
guidelines for the BBC Children in Need Appeal.
4 POLITICAL ACTIVITIES
Some individuals wish to become involved in political activity and they will be free to do so
when it is consistent with the nature of their work for the BBC and the BBC’s public service
obligations. Political activity is not acceptable if it is likely to compromise the BBC’s
impartiality or undermine public confidence in the BBC. Judgements about what it
acceptable will reflect individual circumstances and advance discussion with managers is
vital.
Staff should declare any active political involvement on the Declaration of Personal Interest
form. In some cases it will also be appropriate to declare the political activities of close
family members.
The Chief Political Adviser is responsible for providing advice to individuals and to
Divisions in order to ensure fairness and consistency in dealing with these matters.
4.1 Levels of Political Involvement
Anyone is entitled to be a member of a political party or organisation.
However, active political involvement and commitments can give rise to conflicts of interest
for people who are involved in programme making or have any editorial responsibilities in
any BBC service, particularly if they deal with political or public policy issues.
Active political involvement can give rise to questions about the impartiality of the
individual, the impartiality of the area in which they work and the impartiality of the BBC.
Individuals should inform their manager about any political involvement so that it can be
fully considered in the light of the guidance below. If individuals or managers have any
doubts they can seek advice from the Chief Political Adviser.
There are three general considerations:
• the level of political involvement
• the nature and level of the individual’s job
• the extent of involvement in editorial decisions, programme making and/or BBC policy
In any individual case it will be necessary to consider:
• whether they are known to the public or whether their contribution is acknowledged on-
air or on-line during the course of a programme or through beginning or end credits
• the level of the individual’s political involvement at national or local level:
- being publicly identified as a candidate or prospective candidate for a parliamentary
assembly or local authority election; no matter that the date of the election is not
confirmed;
90
RFI20080896
- holding office in a party political organisation which impacts on party politics as it
affects elected bodies;
- speaking in public on matters of political controversy and matters of controversial
public policy;
- expressing views on matters of political controversy and matters of controversial
public policy in books, articles, leaflets and letters in the press;
- canvassing on behalf of a political party or candidate for election
- promoting a partisan view on an issue put to local or national referendum
• The nature and level of their work. In some cases, if they wish to maintain their level of
political activity, it may be necessary to move them to a less sensitive position
• The type of programme. News and current affairs programmes for international, national,
regional and local output are subject to the most stringent tests of impartiality. For more
general output considerations will be less stringent but the managers will consider the
implications for those in more senior editorial roles, those involved in presentation and
those who are or might become known to the public.
4. 2 Elections
Anyone who intends to seek nomination as a candidate for election at national or local level
should notify their manager at the earliest opportunity so that the implications can be
discussed. They may not be able to undertake high level or high profile programme
responsibilities whilst seeking nomination as a candidate.
When an individual has been selected to stand for election at national or local level and
becomes a prospective candidate, he or she may not engage in programme work which could
be linked to political issues, even if the date for the election has not been confirmed.
Prospective candidates campaign actively to obtain support, and as such become the focus of
public attention.
An individual who has been selected as a candidate must notify their manager, who will
inform the Chief Political Adviser. A list of all BBC prospective candidates will be
maintained. Individuals who currently hold an elected position in Local Government at any
level must ensure that their manager is notified. The manager will inform the Chief Political
Adviser.
When BBC employees stand for election for the European Parliament, the UK Parliament,
the Scottish Parliament, Welsh Assembly or the Northern Ireland Assembly unpaid leave of
up to six weeks is granted for the period to the election date. The leave is unpaid in order to
avoid any suggestion that the BBC is subsidising the individuals’ election campaign.
Individuals may stand for local government elections provided there is not a conflict of
interest with their programme duties. They will be expected to conduct their campaign
activity in their own time and ensure that there is no conflict with their BBC duties. Polling
day itself should be taken as unpaid leave.
Presenters and regular contributors who are candidates for elections should not appear in any
programmes in their normal programmes roles during election campaigns or when elections
they are involved in are imminent. This avoids unfair publicity for them at a critical time.
They may of course appear as candidates under the usual election rules (see The BBC
Election Guidelines which are available on gateway.)
91
RFI20080896
Outside election periods, the BBC will not discriminate against politically active people on
the grounds that they gain publicity from working for the BBC. The appropriateness of a role
will be dependent solely on whether there is a conflict of interest with programme making or
policy making responsibilities. When an individual is seeking nomination or has been
selected as a candidate, but prior to the election campaign, it may be necessary to transfer the
person immediately to less sensitive activities. In these circumstances the individual must be
placed in gainful employment and not sent home on paid leave. In addition it will be the
responsibility of the Director of the relevant Division or their nominee to ensure a suitable
alternative substantive job is found within four weeks of the individual being moved to less
sensitive work.
If individuals are unsuccessful in seeking nomination or decide not to pursue their candidacy,
they may return to their original substantive job. However if an individual’s actions in
pursuing nomination as a candidate have been such that the BBC’s reputation for impartiality
could be undermined should they return to their original job, they would continue in a
suitable alternative job.
If an individual is elected to the European Parliament, UK Parliament, the Scottish
Parliament, Welsh Assembly or Northern Ireland Assembly he / she will be required to resign
from the BBC immediately.
If an individual is not elected he/she may return to work immediately but there may have to
be an appropriate gap in time before resuming the original substantive job. However if the
actions of the individual in seeking election have been such that the BBC’s reputation for
impartiality could be undermined should they return to their original substantive job, the
person may be placed in a less sensitive job (at the same grade and salary). In the event of
such a decision becoming necessary there will be full discussion of the issues with the
individual concerned and the advice of the Chief Political Adviser will be sought to ensure
consistency.
If a family member or close personal contact is standing for election, it is acceptable for an
individual to express personal support, but there should be no use of the BBC’s name and
where support extends to political support the considerations outlined above apply.
4.3 Non-political voluntary public office
This may be acceptable even for editorial people in news programmes. This includes school
governorships and being a magistrate. Programme people should be very careful about
involving themselves in controversial matters of public policy related to organisations which
campaign on political or public policy issues.
5 COMMERCIAL, BUSINESS AND FINANCIAL INTERESTS
It is essential that the integrity of BBC programmes or other editorial output is not
undermined by the commercial, business or financial interests of any programme makers,
journalists, or presenters. There must never be any suggestion that commercial or financial
interests have influenced BBC coverage or the subject matter of programmes or the choice of
items.
The onus is on the journalist, programme maker or presenter to let the BBC know if
they have any interests which could be perceived as a conflict of interest.
92
RFI20080896
BBC production and editorial staff are required to declare any personal interest which may
affect their employment with the BBC. These interests should be declared on a Declaration of
Personal Interest Form (see section 1) and further advice is given in the staff handbook
“Conflicts of Interest”.
Declarations should include
• any directorships or any consultancy work for outside organisations
• any significant shareholdings, loans (other than private mortgages) or financial interests
which they, their partners or dependant relatives have and which may in any way
constitute a conflict of interest or affect the impartiality or perceived impartiality of their
work
• any holding whatsoever of shares, debentures or securities held for investment purposes
when the holding exceeds 5% of the company
• any shareholding, securities or debentures in media related companies Very senior BBC
people (for instance those at Controller level and above) may be required to sell any
financial interest in other broadcasting or related organisations.
Freelances, are also asked to declare any commercial interests which may impinge on their
work with the BBC. Independent producers should make a declaration at the time of
commissioning.
Significant shareholdings should be declared by all programme people if they are in any way
connected with the area in which they work or the subject matter which they cover. Some
people working in news, current affairs and factual programming may be involved in
investigations about a wide range of topics and may be required to declare any significant
holding in any organisation. Managers will give specific advice about the detail and range of
the declarations required for those working in their area.
The area of most sensitivity is financial journalism where additional rules apply. Anyone
who is working on an edition of a current affairs programme or factual programme which is
dealing with finance or business is in effect involved in financial journalism and should
follow the specific guidance in section 5.3 below. On no account must early information
acquired in the course of BBC programme work be used to trade ahead of the markets. It is
illegal and unethical.
Heads of Department will be aware of other particular sensitivities in their areas and will ask
for particular detailed information concerning some financial or commercial interests (see
section 5.2 below on music production).
Although efforts should be made to declare any interests well in advance, in some cases
people will be asked to work on stories or programmes at relatively short notice and may find
that they have some financial connection with the area to be covered. It is essential that
presenters, reporters and production teams should have no significant connection with
products, businesses or companies featured in the programmes they make or the stories they
are covering. If they have any financial, commercial or business interest which might
involve a conflict of interest or might be perceived to involve a conflict of interest they must
inform their editor or Head of Department as soon as possible. If the editor or Head of
93
RFI20080896
Departm
ent considers that there could be a real or perceived conflict of interest, they should
deploy another journalist or programme maker.
5.1 Presenters In some cases the commercial activities or interests of presenters could lead to a conflict of
interest. To avoid this, when contracts are negotiated, presenters should be asked to declare
any commercial interests which may impinge on their on air-role or which are connected
with the subject matter of the programme they present. Such information is kept entirely
confidential by the BBC. In some cases, particularly for presenters of journalistic or factual
programmes, commercial interests may be deemed incompatible with their on-air role.
5.2 Popular Music In popular music programming, some key presenters have links with the record industry and
particular care needs to be taken with regard to commercial interests. A range of safeguards
are in place in BBC Radio music networks and in BBC Television and Online to ensure that
those working in these areas declare all relevant outside interests, and do not allow those
interests to influence their choice of music. In BBC Radio 1 tracks with which a DJ has any
commercial connection are clearly highlighted in advance to the Editor of Music Policy.
5.3 Financial Journalism There are additional constraints on financial journalists. People working in financial
programmes for the BBC should register all their shareholdings and other financial interests
or dealings. Clear advice on this is given in the BBC Guidelines for Financial Journalism
which are on gateway (see BBC Guidelines for Financial Journalism) and available from the
Editor, Economics and Business Centre.
These additional guidelines for financial journalists protect the integrity of the BBC’s output
in this area. It is also important to remember that there are particular legal constraints which
affect financial journalism. As stated earlier, it is illegal to use financial information acquired
in advance to trade ahead of the markets.
It is also illegal to promote financial services without proper authorisation from the relevant
regulatory authorities. It is vital that no BBC financial journalist ever calls their integrity into
question by appearing to promote any financial product or investment, especially if they or
members of their immediate family have a financial interest in that product or investment.
6 PERSONAL BENEFITS
Individuals must not accept personal benefits or benefits for themselves, their family or close
personal relations from organisations or people with whom they might have dealings on the
BBC’s behalf. Unacceptable personal benefits would include goods, discounts, services,
cash, loans, gratuities, or entertainment outside the normal scope of business hospitality.
Accepting significant hospitality from individuals or organisations outside the BBC could
lead to a conflict of interest. Anyone working for the BBC should consult their Head of
Department before accepting such hospitality.
Strict rules apply to the acceptance of free or reduced cost facilities by programmes: see
Chapter 25: Product Prominence and the Use of Free and Reduced Cost Facilities.
7 ON-AIR TALENT AND COMMERCIAL ADVERTISING
94
RFI20080896
Increasingly advertisers and m
anufacturers are seeking to employ presenters to endorse
products. Although the BBC does not seek to place unnecessary constraints on talent, it is
essential that promotional activities do not constitute a conflict of interest and do not
undermine the editorial integrity of presenters or the programmes they present.
This section outlines what outside promotional work may be undertaken by those who
“front”, “anchor” or present BBC radio or television programmes in any genre. It applies to
the whole range of presenters from news presenters to those who host entertainment
programmes, but the nature of the presenter’s on-air role will affect what is appropriate and
section 7.2 below outlines what is acceptable for presenters in each genre.
Any presenter who appears on-air in a journalistic capacity will have considerable
restrictions on what, if any, promotional activities they may undertake. There will be fewer
restrictions on entertainment presenters or lifestyle presenters providing their integrity and
the integrity of the programme they present is not undermined.
•
Contractual arrangements The guidance in this section should be reflected in contractual arrangements for regular
presenters or presenters of a series of programmes. On-air talent should be made aware of
these guidelines and presenters who work for the BBC other than on an occasional basis
should be required to consult the BBC before undertaking any outside advertising work.
Some existing contracts may not reflect the principles of these guidelines, but renewed
contractual arrangements should conform to them.
7.1 Basic Principles for non-BBC Promotional Work by Presenters in all Genres
• No advertising campaign or advertisement should give the public reason to doubt the
objectivity of BBC presenters
• there should be no conflict of interest between the presenter’s on-air activities and the
promotion of a particular product or service
• the product or service they promote must not be shown, featured, reviewed or discussed
in the programmes they present
• no presenter should replicate their on-air role to endorse a product or service either in
traditional advertising or on any personal or third party website
• no promotional activity should undermine the values of the BBC brand
• some key presenters who are on long term contract or who have long standing
associations with the BBC may be subject to particular restrictions on their promotional
activities. There may be fewer restrictions on a presenter who is seen as an independent
outsider, who presents a few programmes or a one-off series, but who is not considered
in the main as a BBC presenter
• presenters in all genres will often be permitted to undertake some promotional activities
for a book they have written, whether or not it is published by the BBC. However, such
promotions must not undermine the programme they present or jeopardise the
presenter’s reputation for objectivity or impartiality
• the BBC may need to be more cautious in allowing presenters to undertake television or
radio advertising than advertising in newspapers or on billboards as television or radio
adverts will more clearly replicate their role in a BBC programme.
7.2
Presenters’ outside promotional activities – guidance for specific genres
95
RFI20080896
•
News, current affairs and business programmes
Presenters and reporters on news, current affairs and business programmes are not
permitted to take part in any promotions, endorsements or advertisements for third
parties.
•
Serious factual programmes outside news and current affairs
Presenters or reporters who appear in serious factual programmes which consider
controversial public policy or matters of political or industrial controversy would not
normally be permitted to take part in any advertisements for third parties. The degree to
which they are regarded as an objective journalist in their on-air role will affect decisions
as to whether any outside promotional work is permissible at all. It would not be
appropriate for presenters or reporters who are involved in investigative programmes to
undertake any outside promotional work.
In other cases the key consideration must be that presenters or reporters should not be
allowed to undertake promotions for any product or service related to the subject matter
of the programme they present. If their on-air role is restricted to a particular subject area
they might be permitted to advertise something entirely unrelated.
•
General consumer programmes
Presenters and reporters on consumer programmes which cover a wide range of topics,
such as Watchdog, may not undertake any promotional work for third parties as there is
no product or service outside the remit of the programme.
•
Consumer programmes about specific topics
These are programmes which provide serious journalistic analysis on a particular topic
or which undertake consumer reviews in a specific area. Presenters of such programmes
may only be permitted to undertake promotions for products entirely unassociated with
the subject matter of the programme.
•
Lifestyle programmes
These are non journalistic programmes which do not undertake specific reviews. Areas
of lifestyle programming include makeovers, gardening programmes and cookery.
Presenters of lifestyle programmes
Sometimes lifestyle programmes give a degree of consumer advice and this will affect the
presenter’s ability to undertake promotional activities. Lifestyle presenters who give advice
on what branded products to buy or use should not undertake any advertising in any medium
for products or retailers associated with the subject matter of their programmes. Presenters
who give clear objective advice on how to solve problems should not advertise products or
services which aim to solve these specific problems.
Presenters of lifestyle programmes, such as makeovers, which refer to specific branded
products should not advertise any products which might be featured. For example, some
makeovers give details in astons of which paint or other materials are used. In these cases the
presenters should not advertise brands of paint or other materials used.
No lifestyle presenter should undertake radio or television advertising for a product or
retailer associated with the subject matter of their programmes. Nor should they undertake
any off-air advertising for products related to the subject matter of their programmes.
However, in some cases, lifestyle presenters who do not give consumer advice may
undertake off-air adverts for retailers who sell products covered in their programmes. Such
adverts for retailers should not feature any particular branded or own brand product directly
96
RFI20080896
related to the subject m
atter of the programme they present. (See also section below on
advertising presenters’ own products).
Chefs and Cookery Presenters
Television cooks or chefs should not undertake any radio or television advertising for any
product or retailer associated with the subject matter of their programmes. They should also
not undertake any off-air advertising for specific branded food products. However, if chefs
do not give consumer advice on air, they may undertake some off-air advertising in this area
as long as it does not compromise their on-air role. Television chefs who do not give
consumer advice may undertake off air adverts for a food retailer, provided the advert does
not feature any particular branded or own brand food product. The advertisements should not
replicate their programmes in any way and should not use recipes from their programmes.
Producers should ensure that the retailer’s products are not used, shown or referred to in their
programmes.
Lifestyle presenters, including chefs, may undertake advertisements in any medium for
products which are not associated with the subject matter of their programmes. However,
these advertisements must not replicate their on-air role or imitate the programme in any
way.
Presenter’s Own Products
Increasingly lifestyle presenters are developing their own products associated with their on-
air role and in some cases are distributing these products through their own websites, as well
as by more traditional means. Presenters can develop their own products, but care needs to be
taken to ensure that such products do not give rise to a conflict of interest. Presenters on long
term contract should be asked to inform the BBC about any products they are developing. In
no circumstances, however, should presenters’ own products be shown or referred to in any
of their programmes.
Advertising of presenters’ own products
Any promotion of such products needs to be treated with great care to ensure that the
presenter’s objective role is not undermined. The BBC would not agree to presenters
advertising their own products on television or radio as such adverts would tend to replicate
the presenter’s on-air role.
However lifestyle presenters who do not give consumer advice may be able to advertise their
products in newspapers, magazines, on billboards or online, providing they do not use these
products or ones closely resembling them in their programmes.
If lifestyle presenters give advice on specific problem solving, in order to preserve their
reputation for objectivity, they should not undertake any on-air or off-air adverts for products
aimed to solve the specific problems about which they give on-air advice.
Where both on-air and off-air advertising is ruled out, point of sale promotions and
promotions on the presenter’s own website are usually acceptable.
However any promotions
on their websites must not be used to exploit their BBC connections - no material from their
97
RFI20080896
BBC program
mes may be used and they should not sell products on their websites when they
are featured on their programmes.
•
Sport The suitability of any commercial activities undertaken by sports presenters will depend on
the nature of their on-air role, the nature of the programme and whether they are perceived
primarily as a sports journalist, a sports entertainment presenter or a sportsman/woman who
also presents programmes. Careful judgements need to be made about the acceptability of
any advert which is related to sport in any way. Presenters who are clearly undertaking
sports journalism should not advertise sports products, such as sports kit, or do adverts for
sports sponsors. However, they may advertise products not directly associated with sport or
sports sponsorship.
•
Children’s Programmes Presenters of children’s programmes should not promote products directly connected to the
subject matter of the programmes they present. They also should not undertake any
advertisements for products specifically aimed at children or products likely to be harmful to
children such as alcohol.
•
Entertainment Entertainment presenters should not appear in adverts which are closely associated with the
subject matter of any programme they present or which mimic the style of the programme.
(See section 7.7 below concerning style of permitted advertisements.)
7.3 Advertising Commitments and the Editorial Agenda As is made clear in section 7.2 above, it is essential that products or services which a
presenter promotes should not be shown or featured in a programme they present. When
engaging talent, consideration should be given as to whether their existing advertising
commitments will undermine the programme’s editorial agenda. There are dangers to the
editorial integrity of a programme if a presenter’s promotional activities distort the agenda of
a programme by forcing the programme to omit items or change what it covers.
Entertainment programmes
In exceptional circumstances producers of an entertainment programme may think that it is
editorially justifiable to make a joke about a presenter’s outside promotional activities, or a
guest on a programme may make such a joke. On the whole it is advisable to avoid such
jokes as it may be difficult to ensure that they are non-promotional for the product or service
advertised.
7.4 Unsuitable Products or Services Even when there is no obvious conflict of interest with the presenter’s on-air role, there are
some products or services which the BBC would not wish its presenters to promote as the
association might be damaging to the BBC’s reputation. This prohibition would include
tobacco or tobacco products, escort agencies and sex chat lines.
98
RFI20080896
7.5 Timing of Advertisements
Some presenters are only contracted to the BBC for specific time periods to coincide with
series of programmes which they present. However, as far as possible, contractual safeguards
concerning advertisements should also cover the periods when programmes are repeated.
7.6 Guidance for Contributors to programmes Consideration also needs to be given to promotional work undertaken by contributors who
appear in programmes regularly, but who are not engaged as presenters. The BBC is not in a
position to restrict the advertising activities of these outside contributors and in many cases it
would be unreasonable to do so. However, the BBC should not use contributors who
undertake promotional work which could give rise to doubts about their objectivity. In
particular expert contributors who give specific advice about what to buy should not endorse
products or services in the areas on which they give advice.
Some contributors, who are not main presenters, may play a significant role in every
programme in a series. In such cases the BBC may decide that they need to be subject to the
same restrictions as presenters in that genre.
7.7 Style of Advertisements Any adverts in which BBC presenters appear should not copy or make play of BBC
programmes as it is important that no impression is given that the BBC is endorsing any
commercial product or service. It is also important that the style of the advert does not bring
the BBC into disrepute.
The following key points should be observed
• No advert should replicate, imitate or pass off BBC programmes, titles or logos
• No adverts should replicate or pass off the role the presenter plays in the programme
• Adverts should not replicate editorial elements of a programme e.g. BBC television chefs
should not feature recipes from their programmes in any adverts
• No music or graphics associated with the programme should be used
• Adverts should not replicate the look of the programme. There should be no use or direct
imitation of BBC programme sets or the key venues used in the presenter’s programme
• No adverts should refer to the BBC or any of its services or programmes
• There should be no use of more than one BBC presenter from the same programme in
any advert for an outside product. It is also unlikely to be acceptable for several
presenters from different BBC programmes to appear in the same advert
• The overall style of the advert should not be tasteless and should not bring the BBC into
disrepute.
7.8 Actors and artists who perform in programmes Actors should not appear in television adverts in a way which directly replicates their on air
role in BBC programmes. For detailed advice on this issue
see
section 3.3. of Chapter 29
Advertising, Promotional Activities and the BBC Brand.
For advice on advertising by artists who own rights to characters and formats which are used
for BBC programmes see Chapter 29, section 3.4.
7.9 Who decides what is appropriate?
99
