This is an HTML version of an attachment to the Freedom of Information request 'Producer Guidelines'.

 
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An assessm
 
ent of whether advertising or promoting third parties is acceptable will be made 
by the Controller responsible for the relevant output in consultation, where necessary, with 
Editorial Policy and Controller, Talent Management.  
   
8   TALENT/AGENT OWNED INDEPENDENT PRODUCTION COMPANIES     
  
Potential conflicts of interest can also arise where an independent production company is 
owned by an on screen presenter or performer or their agent. To avoid such potential 
conflicts: 
 
•  Agents or their production companies should not be commissioned to produce factual 
programmes about the talent they represent unless there is clear editorial justification. 
•  In very exceptional circumstances, where the programme and its subject are of such 
importance and cannot be commissioned unless it is produced with the associated agent 
or talent-owned independent, the issue should be referred to the Controller, Editorial 
Policy.  If the commission is agreed, the commissioning team should ensure objectivity is 
achieved by means of thorough executive production on behalf of the BBC.  An active 
BBC role in all stages of the programme’s production, from research to the final edit, will 
be required. 
•  When commissioning teams receive proposals for factual programmes concerning talent 
from another genre (for example, a factual commission about a sports personality), they 
should seek advice on any connections between the independent producer and talent that 
could provide an editorial conflict of interest.  
•  Commissioning teams should actively review guests and their associated products 
featured on agent-owned independent productions, ensuring: 
  
- Guests from associated talent agencies are always editorially justified  
- Records are kept of all guests on programmes produced by agents and checked with    
   their client-list to avoid a cumulative promotional effect 
 
•  Access to talent should never be accepted if it is directly connected to product promotion 
by the agent’s production company, unless there is clear editorial justification. 
 
CHAPTER 11 
GLOBAL BROADCASTING AND NEW MEDIA 
  
1 GLOBAL BROADCASTING 
2 ONLINE AND NEW MEDIA 
 
1 GLOBAL BROADCASTING 
The BBC’s reputation as a broadcaster is based on adherence to the highest editorial and 
ethical standards, for its international services as well as its domestic ones. Over many years 
the World Service has applied key BBC principles, such as impartiality, accuracy and 
avoiding offence on matters of taste, to radio broadcasting for international audiences. 
  
More recently the BBC has developed international television services bringing news, 
documentaries, drama and entertainment to a wide variety of audiences across the world. As 
the BBC’s role as a global broadcaster grows, upholding the principles of the Producers’ 
Guidelines internationally has become a responsibility for BBC programme makers in many 
programme genres. 
 
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The principles of the Producers’ Guidelines apply to all of the BBC’s output. Much of the 
detailed guidance is universal, but where appropriate, specific guidance is offered for 
programme makers serving international audiences, for example section 9: “Observing Local 
Law”, of Chapter 3: Fairness and Straight Dealing, and section 5: “International 
Audiences”, of Chapter 6: Taste and Decency. 
  
When television programmes are re-edited or reversioned for transmission on the BBC’s 
international channels or on the new domestic television channels programme makers should 
consult Chapter 21: Re Use and Reversioning of BBC Television Programmes. 
  
The BBC’s international television services are commercially funded. The BBC is also 
involved in commercial joint venture television services in the UK. For guidance on those 
issues which apply specifically to commercially funded television channels see Chapter 24: 
Commercial Relationships and Appropriate Programme Funding. 
  
2 ONLINE AND NEW MEDIA 
Many innovative new forms of media are currently being developed, including interactive 
television, and more will emerge in the future. The BBC will apply the values and principles 
embodied in the Producers’ Guidelines to all its new media activity. Both the Producers’ 
Guidelines and the BBC ONLINE Guidelines apply to the BBC’s Online Services. Producers 
should refer to section 6 “Online” in Chapter 6 for guidance on taste and decency issues on 
the Internet, and to Section 9: “Online and New Media” in Chapter 35: Opinion Polls, as well 
as to the BBC ONLINE Guidelines.  
 
CHAPTER 12 
REPORTING SUFFERING AND DISTRESS 
  
1 REPORTING ACCIDENTS AND DISASTERS 
2 DEPICTING TRAUMA 
3 INTERVIEWS WITH THOSE INJURED OR GRIEVING 
4 LIBRARY USE OF SCENES OF SUFFERING 
5 DEAD INJURED AND MISSING 
6 REVISITING PAST EVENTS 
7 TRAGIC EVENTS AND NON FACTUAL PROGRAMMES 
8 FUNERALS 
 
 
1 REPORTING ACCIDENTS AND DISASTERS 
In covering accidents, disasters and disturbances BBC journalists need to balance full, 
accurate reporting against the obligation to avoid causing unnecessary distress or anxiety. 
Emphasis should be placed on providing, swiftly and accurately, basic factual material, such 
as times, location, route or flight number etc. 
  
In the early stages of reporting a disaster it is especially important to source information. First 
estimates of casualty figures often turn out to be inaccurate. If different sources give different 
estimates we should either report the range or go for the source which carries the greatest 
authority and attribute the estimate accordingly. If our earlier reports prove to have been 
pessimistic, corrections should be prompt and prominent without any attempt to conceal the 
mistake. 
  
 
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2 DEPICTING TRAUMA 
 
Long experience of reporting major disasters and all kinds of tragic events has emphasised the 
importance of compassionate coverage in such circumstances. Coverage should not add 
needlessly to the distress of people who already know of their loss, either in the UK or 
elsewhere.  
  
News programmes should follow some basic principles: 
  
• 
The dead should be treated with respect and not shown unless there are compelling 
reasons for doing so 
  
• 
Close-ups of faces or serious injuries should be used very sparingly 
  
• 
Do not concentrate unduly on the bloody consequences of an accident or terrorist attack 
  
• 
Avoid using violent material simply because it is available 
  
• 
The same value should be placed on human life and suffering whether it occurs in the UK 
or internationally 
  
• 
The time of day of transmission, whether it is pre or post Watershed, and the rest of the 
schedule should be taken into account. 
  
Deaths reported in the news are real. The best way to reflect this reality is by taking obvious 
care to respect the privacy of those involved. There are almost no circumstances in which it is 
justified to show executions or other scenes in which people are being killed. 
  
Still photographs can sometimes convey the horrific reality of a situation, without shocking to 
the same degree as moving pictures. The natural sounds whether on radio or television can be 
as disturbing as pictures, and should also be treated with care. Editing out the bloodiest scenes 
need not result in a sanitised version of events. A good script is vital in conveying the reality 
of tragedy. 
  
Editors on continuous news channels need to consider carefully the cumulative effect of the 
multiple use of such images. 
  
Reporting should show sensitivity and care while remaining objective, and should not lapse 
into inappropriate sentimentality, or false compassion.  
  
3 INTERVIEWS WITH THOSE INJURED OR GRIEVING 
People in a state of distress must not be put under any pressure to provide interviews against 
their wishes. Approaches are often best made through friends, relatives or advisers. Just 
because bereaved people may be offered for interview by the police or other authorities does 
not justify use of material which is voyeuristic or profoundly distressing: an important 
purpose must be served by broadcasting it. Thoughtless questions cause distress and do 
damage. When such a question has been asked by others it may be possible to remove it 
without harming the sense of the interview. 
  
 
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Film
 
ing or recording of people who are extremely distressed must not be carried out in such a 
way as to increase their suffering. Editors must be satisfied that use of pictures or sound is 
genuinely important in helping audiences understand the impact of the event. 
  
Audiences are sometimes upset and angered over scenes of suffering even when victims have 
co-operated willingly or have asked for coverage. The public may not know the 
circumstances: a few words of explanation when introducing the scene would prevent 
misunderstanding.  
  
4 LIBRARY USE OF SCENES OF SUFFERING 
Avoid needless or repeated use of traumatic library material, especially if it features 
identifiable people. It should not be used as “wallpaper" or to illustrate a general theme. 
Library pictures of identifiable grieving or distressed people must be used only after referral 
to a senior level in the programme department.  
  
5 DEAD INJURED AND MISSING 
Concern for next-of-kin calls for special care over reports that people have been killed or 
injured or are missing. The BBC has adopted a strong general rule that, as far as reasonably 
possible, next-of-kin should not learn this bad news from a programme. 
  
There may be exceptions for prominent public figures or because of some other special 
circumstances but otherwise names should be left out unless we are satisfied that next-of-kin 
have been told. 
  
News programmes need to be particularly careful over reports from abroad involving British 
people. Names are often released by authorities overseas and carried by news agencies before 
any information has reached next-of-kin, whereas in the UK official sources usually withhold 
names until families have been notified. 
  
The BBC recognises that when names are not given in our broadcast reports, the news may 
cause needless concern among people with close relatives who might have been involved. In 
the choice between difficult options, we believe this is not as bad as the shock caused when 
names are received, for the first time, by way of radio or television. 
  
But we also need to reduce needless anxiety by narrowing the area of concern as quickly as 
we can without identifying individual victims. So we should include details such as airline, 
flight number, place of departure, and destination as early as possible, so that even larger 
numbers of people are not alarmed.  
  
6 REVISITING PAST EVENTS 
Programmes intending to examine past events involving trauma to individuals (including, but 
not limited to, crime) must think through ways of minimising the distress that might be caused 
to surviving victims or to surviving relatives in re-telling the story. So far as is reasonably 
practicable, surviving victims or the immediate families of the dead people who are to feature 
in the programme should be informed of the BBC's plans. Failure to do this may be deemed a 
breach of privacy, even if the events or material to be used were once in the public domain. 
The programme should proceed against the objections of those concerned only if there is a 
clear public interest.  
  
7 TRAGIC EVENTS AND NON FACTUAL PROGRAMMES 
 
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The af
 
termath of a tragic event calls for considerable sensitivity by broadcasters. Scheduling 
changes may be required to ensure that nothing that might cause widespread offence is 
broadcast inadvertently (see section 7 "Dealing With Tragic Events" in Chapter 6: Taste and 
Decency).  
 
8 FUNERALS 
Normally, programmes should cover funerals only with the permission of the family. Good 
reasons are needed if the wishes of the family are to be ignored. We should ensure that 
funerals are covered sensitively, and should avoid intrusive conduct, such as close camera 
shots of people who are grieving 
 
CHAPTER 13 
INTERVIEWING 
  
1 GENERAL 
2 PURPOSE OF INTERVIEWS 
3 EVEN-HANDEDNESS 
4 FAIR DEALING WITH INTERVIEWEES 
5 TONE AND TACTICS 
6 FAIRNESS TO THE INTERVIEWEE AND DEALING WITH EVASION 
7 INTERVIEWING OUR CORRESPONDENTS 
8 EDITING A RECORDED INTERVIEW 
  
1 GENERAL 
Interviews are a vital tool of journalism and programme making. 
  
Where interviewees are to be questioned or tested on matters of controversy it is important for 
editors, researchers and interviewers to think through the editorial issues and structure the 
interview accordingly. 
  
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. Interviewees should be given a fair chance to set out their full 
response to the questions. 
  
 
 
 
2 PURPOSE OF INTERVIEWS 
An interview should have a clear purpose. It should be particular to a given interviewee and 
to a point in time. Beware of inviting people to appear simply because they are major players 
in a running news story, without a clear and cogent idea of what we want to find out from 
them. 
  
Our interviewing should be well informed. Careful preparation by the production team - not 
just the interviewer - is called for. An interview is more likely to break new ground if the 
present position is summarised, and the interviewee discouraged from repeating well known 
positions. We should usually be looking for new information. 
  
 
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Not all interviews will be challenging. Som
 
e are designed to inform, explain or entertain. The 
techniques appropriate to this purpose are different. People interviewed as eye-witnesses or as 
experts may need to be encouraged rather than challenged. 
  
The purposes of a live interview must be realisable in the time available. We should try not to 
leave the audience suspended and frustrated in mid-argument, or irritated by references to 
running out of time. A good interview comes to an orderly conclusion.  
  
3 EVEN-HANDEDNESS 
Anyone expressing contentious views during an interview must be rigorously tested. People 
in power and those seeking it, or those who advocate or criticise policies must be approached 
with a broad consistency of tone. When a testing interview becomes charged, the emotion 
should come from the interviewee, not from the interviewer. BBC interviewers should avoid 
impressions of bias through tone and inflexion or through careless wording. The BBC should 
be known for a dispassionate approach to contentious issues. 
  
Those planning and conducting interviews need to be alert to the range of opposition to 
particular ideas and policies. A politician, for example, may be usefully tested from all 
political viewpoints. 
  
Academics and journalists from other organisations should not automatically be assumed to 
be impartial. It should be made clear to the audience if they are associated with a particular 
standpoint.  
  
4 FAIR DEALING WITH INTERVIEWEES 
It is important that interviewees understand why they are being invited for interview, what 
subjects they are going to be asked about, the context of the programme, and the sort of part 
they will play in it. It will not usually be proper to submit details of actual questions in 
advance, nor to give any undertaking about the precise form of questions. 
  
In the event that an interviewee refuses to give an interview unless questions are rigidly 
agreed in advance or unless certain subjects are avoided, programme-makers must consider 
carefully whether it is appropriate to proceed at all. If they decide to do so they should make 
clear on air the conditions under which the interview was obtained. 
  
Interviewees will sometimes make unreasonable demands. They may try to change the terms 
on which an interview was suggested - perhaps to exclude a pertinent line of questioning. 
They may manoeuvre to vary the circumstances of an interview - perhaps by delaying the 
start of a live interview in order to reduce the time available for follow-up questions. In such 
circumstances, editors and producers should stand their ground, and if necessary withdraw or 
vary the invitation to participate. They will be supported by the BBC (see also Chapter 3: 
Fairness and Straight Dealing).  
  
5 TONE AND TACTICS 
Interviews should be searching and to the point, well-mannered and courteous. They may be 
challenging but not aggressive, hectoring or rude, whatever the provocation.. In a well-
conducted interview, listeners and viewers regard the interviewer as working on their behalf 
  
When interviewing ordinary people, the tone and approach has to be appropriate. They are not 
likely to be experienced in broadcasting. We need to make sure they are not talked down to, 
 
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nor intim
 
idated by brusque questioning.  
  
6 FAIRNESS TO THE INTERVIEWEE AND DEALING WITH EVASION 
Interviewees should be given a fair chance to set out their full response to the questions. 
However, interviewers have to contend increasingly with interviewees who are skilled at 
filibustering, using an interview as a platform and avoiding its proper purpose. 
  
Interruption may be justified but it needs to be well timed and not too frequent. It is less likely 
to discomfort the audience if it comes naturally and after the interviewee has made his or her 
main point - or has manifestly failed to make it. 
  
Evasion should be exposed. This should be done coolly and politely - if necessary by 
repeating the question and explaining to the interviewee and to the audience why the previous 
answer did not address it.  
  
7 INTERVIEWING OUR CORRESPONDENTS 
It is entirely right to call upon BBC correspondents to express their judgement based on their 
knowledge of a subject, but entirely inappropriate to ask them about things of which they 
cannot be sure, or on which they can only speculate. Producers should establish in advance 
exactly how much a correspondent will be able to move a story on or clarify it.  
  
8 EDITING A RECORDED INTERVIEW 
When an interview is recorded for later editing, interviewees should be dealt with fairly. This 
includes telling them that their contribution will be edited. 
  
An interviewee who is being asked to reply to detailed criticism, should be given an 
opportunity to respond to each of the main points aired in the programme. Care should be 
taken to reflect in the edited programme the points of substance made by the interviewee in 
the full recording. Choosing only the weaker responses of an interviewee in preference to 
effective rebuttal is unfair. Overall, a reasonable person, seeing or hearing an interview both 
in full and in edited form, should conclude that it has been edited fairly. 
  
Programmes should be wary of agreeing to treat “as live” an interview which is to be 
recorded. Circumstances may well change before transmission which would make it 
inappropriate for the recording to be used in its entirety. If an agreement is entered into, both 
parties must be clear about what has been agreed and the extent to which editing may be 
appropriate before transmission. 
  
Recorded interviews should be well focused. Where possible they should be of a length 
appropriate to the likely amount of material to be included in the finished programme. Using 
only brief extracts from long and unfocused interviews can cause justified ill-feeling.  
 
CHAPTER 14 
CHILDREN AND PROGRAMMES 
  
1 GENERAL 
2 CONSENT 
3 IMPACT 
4 ANONYMITY 
5 INTERVIEWING TECHNIQUES 
6 LAWS AFFECTING CHILDREN 
 
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6.
  1 The Identification of Children Involved in Legal Cases 
6.2 The Protection of Children Act 
 
1 GENERAL 
Children can be involved in programmes in a number of ways; as actors, interviewees, 
participants in or subjects of a programme and even, occasionally, as programme makers 
themselves. The use of children in programmes often requires handling with great care: it can 
be difficult for programme makers to strike a balance between competing interests - of the 
child, of the parent, and of the audience as a whole. 
  
In the UK and internationally there are various laws designed to protect children. Wherever in 
the world the BBC operates, programme makers must have due regard for the welfare of 
children who take part in their programmes. 
  
We should respect the interests of children as viewers and listeners of BBC programmes too, 
whether these programmes are aimed specifically at them, or at a general audience. Consult 
the Taste And Decency, Violence, and Imitative And Anti Social Behaviour chapters of these 
guidelines, for advice on the BBC’s policies on children’s viewing and listening. Advice on 
the European Directive on the Protection of Minors can be found in section 8 of Chapter 
37:Matters of Law: General. 
 
2 CONSENT 
It will normally be appropriate to seek the consent of parents or legal guardians before 
interviewing children, or otherwise involving them in programmes, and the younger or more 
vulnerable the child, and the more sensitive the subject matter, the more likely it is that 
consent will be essential. If children are to take part in programme making during school 
hours it will normally be necessary to seek the consent of the school in loco parentis. No 
financial inducement should ever be given to parents or guardians with the purpose of 
affecting their decision whether to give consent, although the legitimate payment of expenses 
is acceptable. 
  
A child’s own consent should always be sought about being interviewed or involved in 
programmes and the child’s refusal to take part should not be overridden. Explanation to 
children should be in a language and terms that they can understand. In deciding when a child 
can give consent, the stage of development and degree of understanding as well as 
chronological age should be taken into account. Most children over the age of fourteen and 
some over the age of seven will have the necessary understanding. The consent of minors 
should be confirmed by the parent or guardian. 
  
Programme makers may wish to consult an appropriate professional or an adult who knows 
the child to help them make such judgements. 
  
Where parental consent has been refused, reference should be made to Head of Department 
before taking any decision to go ahead. This can normally be justified only if the item is of 
sufficient public importance and the child’s appearance is absolutely necessary. 
  
In the case of drama involving child performances, if the child is required during school hours 
the consent of the child’s school is required. In law, Local Education Authorities license all 
child performances during school hours. Some education authorities make a very broad 
 
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def
 
inition of what constitutes a performance.  
 
3 IMPACT 
Journalists and other programme makers should consider carefully the impact of the 
programme on a child involved in it - both in the way it is made, and any possible impact it 
may have when broadcast. This applies whether or not we have secured parental consent. 
Children are often eager to help programme makers but may lack judgement about their own 
long term interests. 
  
Programme makers are advised to consult professionals and experts when dealing with 
children and sensitive subjects. BBC Children’s Programmes have developed considerable 
expertise and support systems to protect children before, during and after the programme 
process and can offer advice in this area. 
  
When dealing with dangerous or illegal activity among children, such as drug-taking or 
prostitution, it is often advisable for programme teams to be accompanied by an independent 
agency throughout their contact with the children.  
 
 
In the course of their research, programme makers may come across situations where they 
believe the welfare of a child is being endangered by others. In such cases the child’s interests 
and safety must take priority and programme makers should, in consultation with their Head 
of Department and Editorial Policy, consider reporting what they have found to the relevant 
authority.  
  
4 ANONYMITY 
When factual programmes feature children involved in illegal or anti-social activity 
identification may raise difficult ethical issues. There may be a public interest in identifying 
the children concerned, but the longer term interests of the child may argue for anonymity. 
Programme makers should refer up where they are in doubt about the balance of interest. 
Parental consent may not be a sufficient reason to identify a child if the child’s long term 
future would be better served by anonymity. 
  
When recording anti-social or criminal practices carried out by children with the intention of 
highlighting the practice rather than the individuals the general rule is that individual children 
will not be identified. 
  
When interviewing adults about their own illegal or anti-social behaviour, programme makers 
should think carefully before involving, showing or identifying their children. They should 
consider the impact it might have on them and only proceed if doing so is editorially 
justifiable and the welfare of the child would not be harmed.  
 
5 INTERVIEWING TECHNIQUES 
Interviews with children need particular care. Children can be easily led in questioning and 
are often open to suggestion. Young children in particular may have difficulty in 
distinguishing between reality and fantasy and teenagers do not always have the skills to 
distinguish truth from hearsay and gossip. Programme makers should be careful about 
prompting children and should allow them to speak for themselves. Children should not be 
talked down to or patronised. Where teenagers have been involved in criminal or anti-social 
 
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behaviour, program
 
me makers should be aware they sometimes exaggerate for effect. 
Criminal or anti social behaviour should not go unchallenged. 
  
On extremely sensitive subjects, such as abuse or family breakdown, programme makers 
should consider consulting a professional with experience of interviewing and counselling 
children about the best way of approaching interviews and minimising distress.  
  
6 LAWS AFFECTING CHILDREN 
  
6.1 The Identification of Children Involved in Legal Cases 
There are special laws designed to protect children involved in legal cases. 
  
• 
Youth court proceedings 
In England, Wales and Northern Ireland Youth courts deal with people accused of committing 
offences while under 18. Any matters leading to the identification in youth court proceedings 
of a witness, defendant or other party in those proceedings who is under 18 may not be 
revealed. The restrictions include the naming of schools and of addresses. No picture of a 
person under 18 can be broadcast. Even a picture which doesn’t show the child’s face is 
prohibited. A child involved in criminal proceedings as a defendant ( known as the " accused 
" ), a victim or a witness cannot be identified unless the court makes an order allowing 
identification. 
  
In Scotland there are no youth courts - children are dealt with by the Children’s Panel System. 
Any child involved in a hearing before the Children’s Panel or an associated referral hearing 
before a Sheriff cannot be identified. A child is defined as someone under the age of 16, or 
someone under the age of 18 who is subject to a supervision order. The restrictions outlined in 
the previous paragraph also apply to Children’s Panel/Referral cases. 
  
In contrast, in civil proceedings in Scotland, a child can be identified unless the court makes 
an order preventing identification. Although identification may be legally permissible in such 
civil cases, there may be other ethical or editorial considerations pointing towards preserving 
the child’s anonymity. 
  
• 
Other proceedings involving children 
These may be heard in Magistrates’ Courts, County Courts, or the High Court and deal with 
care proceedings, adoption, guardianship and similar concerns. Restrictions may apply 
preventing the identification of persons under eighteen, who are concerned in such 
proceedings. 
  
It is open to the court to decide whether to ban the identification of a child involved in any 
other proceedings. 
  
• 
Children As Victims of Sexual Offences 
The law also prevents the identification of child victims of sexual offences. Refer to section 
4.3 " Victims of Sexual Offences " in Chapter 37: Matters Of Law: General for further 
details. 
  
• 
Courts Sitting in Private 
It is a usually a contempt to broadcast detailed accounts of proceedings in any court sitting in 
private. This will include proceedings involving wardship, adoption or guardianship of an 
 
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infant. In wardship cases it is not a contem
 
pt to report the court's order or an accurate 
summary of it, unless the court expressly forbids this. 
  
• 
"Custody " 
Note that since the Children Act (1989) the term "custody" has not been a legal concept and 
should not normally be used. Custody has been replaced by contact orders, prohibited steps 
orders, residence orders and specific issue orders.  
  
6.2 The Protection of Children Act 
The Protection of Children Act (1978) covers cases of children filmed or otherwise displayed 
for pornographic purposes. It is an offence under the act to take an indecent photograph of a 
child under the age of sixteen or to involve a child under that age in a photograph that is itself 
indecent even if the child’s role is not. Explicit sexual contact between adults and children 
should not be depicted in any BBC programme. 
  
Programme makers should consult the BBC’s legal advice department if they have any 
queries about the law as it affects children.
  
 
CHAPTER 15 
CRIME 
  
1 GENERAL PRINCIPLES 
1.1 Guidance for news programmes 
1.2 Context 
1.3 Crime reconstruction in news programmes 
1.4 Crime reconstruction in current affairs programmes 
1.5 Paedophiles and Sexual Crime 
1.6 Witnessing illegal activity 
1.7 Library material of crime 
1.8 Running stories 
2 DEALING WITH CRIMINALS 
2.1 Interviews 
2.2 Payments 
2.3 Prisoners and prisons 
2.4 Prevention of Terrorism Act 
2.5 Guilt by Association 
2.6 Victims Of Crime 
3 DEALING WITH WITNESSES 
3.1 Interviews 
3.2 Payments 
 
1 GENERAL PRINCIPLES 
As in any other factual area, we need to report crime in a way which not only gives our 
audiences details of significant events but which also throws light on the issues. We should 
try to increase understanding of crime, with the aim of enabling viewers and listeners to make 
informed decisions about public policy and about their personal circumstances. 
  
Television and radio may add to people’s fear of becoming victims of crime even when, 
statistically, they are very unlikely to be so. It is against this background that we need to 
judge our reporting of crime. 
  
 
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That does not m
 
ean we should "explain crime away". But we do need to keep our crime 
coverage in proportion. 
  
Over time, all our principal news & current affairs programmes, both network and regional, 
must ensure they report the whole picture: the relevant trends as well as the individual events 
that lie behind, and sometimes contradict, the trends. 
  
When a programme concerns a real crime, some of those involved (either offenders, suspects, 
witnesses or relatives) may have changed their names or addresses in order to re-establish 
their lives. Careful consideration should be given to the extent to which we identify them or 
their whereabouts (see also section 1 “Confidentiality” in Chapter 17: Confidentiality and 
Release of Programme Material). 
  
1.1 Guidance for news programmes 
Violent crime may be a tiny proportion of total crime but it occupies a greater proportion of 
our crime coverage. We need to be sensitive to the fears that this might create. When we 
handle crime stories we need to think carefully about why and how we are reporting them, 
and their context. 
  
• 
be alert to the overall proportion of time spent on covering crime, in particular violent 
crime, and to the possible cumulative effect of that coverage 
  
• 
be aware of audience sensitivities when covering crimes that involve violence (see 
section 2 “Real-Life Violence” in Chapter 6: Violence for more guidance) 
  
• 
when selecting a crime story be sure the criteria used are legitimate. Do not suggest 
trends where none exist. For example, do not report one stabbing just because it comes 
after another more newsworthy one. Resist language that falsely implies a link between 
crimes ("tonight's attack comes just two days after......."). 
  
• 
be particularly careful in breakfast bulletins when handling crime stories which have 
already been reported the previous day. Unless there is a development overnight, 
consider whether the story really merits inclusion again 
  
• 
in placing a crime story in a running order judge its significance and scale. Be wary of 
"ringing the changes" in regular summaries by the inclusion of crime stories which, 
though fresh, fail these editorial tests 
  
• 
think carefully about the accuracy and suitability of language when reporting crimes. 
Crime is dramatic enough when it is described factually. Avoid colourful language, 
clichés and unnecessary adjectives 
  
• 
be particularly scrupulous when dealing with criminals, both active and convicted. Any 
programme proposing to interview a criminal active in or wanted in the UK must consult 
Controller Editorial Policy in advance (see section 2.1 of "Dealing with Criminals ") 
  
• 
interviewing witnesses or potential witnesses also needs to be handled carefully. 
Witnesses must not be paid for interviews without prior approval of both the relevant 
Director or Chief Executive and Controller Editorial Policy (see section 3.2 "Dealing 
with Witnesses ") 
 
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• 
in real life, crime is not glamorous. We must not make it so. 
  
1.2 Context 
While news programmes will often report crimes as events, over time we must offer our 
audiences understanding of the issues and trends so that they can appreciate where events are 
exceptional. 
  
• 
we can achieve this by putting crime in general, and some crimes in particular, regularly 
into context 
  
• 
putting crime in context does not mean explaining it away. It means helping audiences 
recognise the wider picture 
  
• 
this takes expertise. Do not rely on any one statistic. People use statistics in ways which 
are partisan. There is no foolproof method of measuring the actual incidence of crime. 
The British Crime Survey published by the Home Office is widely recognised as a non-
partisan source, but people quote from its findings selectively 
  
• 
make use of our own specialist advice. Ask our correspondents who have experience of 
the complex picture revealed (or sometimes obscured) by crime statistics and of the 
arguments that go with them 
  
• 
be cautious when using experts. Satisfy yourself of their credentials and recognise there 
may be others with equal expertise who interpret the facts differently.  
  
1.3 Crime reconstruction in news programmes 
• 
BBC News programmes, network or regional, must not commission reconstructions of 
crime in their on-the-day reporting. They may feature coverage of those staged by the 
police for the purpose of gathering evidence 
  
• 
revisiting the scene of crime does not constitute reconstructing it, nor does an interview 
with a victim or witness, but news programmes must draw the line at portraying the 
events themselves. Borderline cases must be referred to senior editorial staff. 
 
1.4 Crime reconstruction in current affairs programmes 
BBC current affairs programmes, network or regional, must have regard to the following 
principles: 
  
• 
programmes which sometimes use reconstruction as a dramatic story-telling device need 
to apply stricter criteria when it comes to reconstructing crime. Current affairs 
programmes should not use crime reconstructions simply to attract or to entertain 
audiences: the prime purpose of conveying factual information needs to be clear in each 
case 
  
• 
we should not reconstruct detail (including dialogue) which we do not have reason to 
believe occurred (unless for clear and specific editorial reasons). We should not use an 
actor’s portrayal of a character to create dramatic details or an overall tone for which we 
have no verifiable evidence 
  
 
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•  
we should not use incidental music or irrelevant sound effects 
  
• 
camera angles need careful consideration, and so do point-of-view shots. We should not 
frighten audiences with shots that make them feel they themselves are the victim, though 
sometimes it will be necessary to show a scene from the victim's viewpoint. The camera 
will usually appear as an observer of events rather than as a participant 
  
• 
we should reconstruct wounds being inflicted or shots of blood only if they are editorially 
essential. We should avoid unnecessary close-ups of weapons 
  
• 
we should not use slow-motion or other photographic post-production techniques which 
have no clear editorial purpose other than to dramatise 
  
• 
we should not reveal detail that could be used to make a criminal activity more effective 
(see Chapter 8: Imitative and Anti Social Activity) 
  
• 
all reconstructions must be clearly signalled. Audiences must be in no doubt where the 
reconstruction begins and ends 
  
• 
ways should be thought through of minimising the distress any reconstruction might 
cause to victims of crime or their surviving relatives (see also section 2.6 "Victims Of 
Crime"). 
 
1.5 Paedophiles and Sexual Crime 
When paedophiles and other sex offenders have served their sentences and been released back 
into society, strong passions can be aroused in the communities they live in. The BBC has a 
responsibility to report such matters where there is a clear public interest while at the same 
avoiding possible incitement and unjustified infringement of privacy. 
  
The BBC will normally only consider publishing the names or photographs of 
paedophiles or sex offenders who have served their sentences and been released where 
the police have decided to release these details to the general public. The fact of 
publication by other media will not be considered a sufficient justification in itself. Any 
BBC programme or outlet wishing to name an individual in exceptional circumstances, 
when that name has not been made publicly available by the police, should consult 
Editorial Policy in advance. 
  
If it becomes editorially relevant to report on the release of a sex offender, then it will be 
perfectly reasonable to name the town or city where he or she is living. But we should avoid 
giving addresses or details as this may provoke vigilante action. 
  
Where offenders have become very well known, their pictures may be used. Otherwise again 
photographs can lead to attacks on individuals. 
  
Any programmes planning to approach sex offenders for interview in prison, who have been 
convicted of serious offences, should approach Controller, Editorial Policy through their Head 
of Department first – whether the interview is to be undertaken in prison or upon their release 
from prison. 
  
 
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Interviews with paedophiles will be justified 
 
only occasionally and will need strong editorial 
justification. As with any criminal, programme makers should think through ways of 
minimising the distress any interview may cause victims of the crime and their surviving 
relatives. See also section 4 Identification of Crime Victims and Witnesses of Chapter 37: 
Matters of Law: General.  
  
1.6 Witnessing illegal activity 
When investigating criminal activity programme makers may, on rare occasions, want to 
record a specific crime. When that might raise questions of the relationship between the 
programme maker and the criminal, or might entail the programme maker witnessing serious 
criminal activity, it must first be referred to the relevant Editor, Head of Department or 
Commissioning Executive in advance, and to the BBC's programme advice lawyers. 
Controller Editorial Policy must also be consulted. Permission to record or be present at 
illegal activity will be given only if it is clearly in the public interest. 
  
The principles we should follow are: 
  
• 
programme makers must not be involved in commissioning, aiding or encouraging a 
crime 
  
• 
if we witness or record a crime being committed we must not direct the activity in any 
way 
  
• 
if sources have been given a guarantee of confidentiality, steps may be required from the 
very start of the production process to ensure that the undertaking is maintained. Seek 
advice from a BBC lawyer at the earliest possible stage (see also Chapter 17: 
Confidentiality and Release of Programme Material) 
  
• 
neither our research nor our production must constitute an obstruction to the 
administration of justice against the criminals concerned 
  
• 
programmes which have investigated and exposed serious crime will normally wish to 
give proper co-operation to the authorities (even where no legal obligation to do so 
exists) in order to aid a subsequent police enquiry 
  
• 
BBC lawyers must be consulted over any material that may risk prejudicing future 
criminal proceedings. This material may constitute a contempt particularly if broadcast 
close to the date of the trial. 
 
1.7 Library material of crime 
We need to take care in repeating library material relating to crimes or to victims. Every use 
of such material needs a separate decision requiring judgement and taste. 
  
• 
do not use library material of one identifiable crime to illustrate another 
  
• 
it will rarely be appropriate to use pictures of the scene of crime to preview a 
forthcoming inquest or trial 
  
• 
if court proceedings are in progress, use of library material of the crime must be checked 
with a BBC lawyer. 
 
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1.8 Running stories 
Some major crime stories are properly reported over a number of days. However, we need to 
think carefully before reporting them on days when there are no newsworthy developments. 
The fact that we have deployed journalists or resources on the story is never a sufficient 
reason in itself for reporting it.  
 
2 DEALING WITH CRIMINALS 
  
2.1 Interviews 
Interviews with serious criminals who are active or wanted in the UK are justified only 
occasionally. We must be sensitive to the impact they may have on our audience. Programmes 
must be satisfied that they are likely to give the public important information or insight. 
Controller Editorial Policy should be consulted. 
  
The same principles apply when wanted people have fled to countries safe from extradition to 
Britain – and in addition they should not be allowed to celebrate the flouting of justice. 
Remember that wanted people not yet tried are innocent until a court finds them guilty; 
programme makers must be careful to take legal advice if it is proposed to suggest otherwise. 
  
When criminals or former criminals are interviewed they should not be allowed to glamorise 
their wrong-doing nor give details of crimes that could be copied. 
  
Contact with escaped prisoners or people wanted by the police may in some 
circumstances constitute a criminal offence. Any such contact should be referred to 
Controller Editorial Policy. 
  
Internationally, definitions of what constitutes a criminal vary widely. As far as those 
motivated by personal gain are concerned, we apply the same considerations about likely 
audience reaction and the same conditions would apply in interviews. Interviewing political 
dissidents and activists is an important part of providing a full understanding of events. 
Proposals to interview people who use or encourage the use of violence should be referred to 
a senior editor in the department, and if further advice is necessary, to Controller Editorial 
Policy.  
  
2.2 Payments 
Programmes should not make payments to criminals, nor generally to former criminals who 
are simply talking about their crimes. In general, the same should apply to families or 
relatives of criminals or former criminals. 
  
We should also not pay people who may not have committed a crime or been convicted of a 
criminal offence but whose behaviour is either clearly antisocial or whose activities have 
attracted such notoriety that any payment would be inappropriate. 
  
Any case for an exception must be referred through the Head of Department to 
Controller Editorial Policy. Payment of a fee will be approved only for a contribution of 
remarkable importance with a clear public interest which could not be obtained without 
payment.  
  
2.3 Prisoners and prisons 
 
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Program
 
me makers wishing to enter a prison to conduct an interview with a prisoner for 
broadcast will usually seek permission from the prison authorities. Exceptional proposals 
should be discussed by Head of Department with Controller Editorial Policy. 
  
Many prisoners now have access to public telephones, though their use may be restricted by 
prison rules. Programmes which intend to invite a prisoner to initiate a call for broadcast 
purposes must refer to head of department who may consult Controller Editorial Policy. 
  
If a programme receives an unsolicited call from a prisoner for broadcast purposes it should 
not be used live unless there has been time for proper consideration of the nature and context 
of the contribution, and, if necessary, editorial referral. In the case of prisoners convicted of 
serious crimes, particularly crimes of violence, due consideration must be given to ways of 
minimising the possible distress that an interview might cause to a victim or victim’s family. 
  
Where an unsolicited call is pre-recorded before referral can take place, the referral must take 
place before transmission.  
  
2.4 Prevention of Terrorism Act 
In addition to the above, any contacts with criminals who are directly linked to terrorist acts 
in the United Kingdom, may lead to proceedings under the Prevention of Terrorism Act. Any 
proposal to interview such individuals, or representatives of their organisations must be 
referred to Controller, Editorial Policy and time allowed for full consideration of the issues 
involved.  
 
 
  
2.5 Guilt by Association 
Programmes reporting crime should remember that the families of criminals are regarded as 
innocent unless a court deems otherwise. In some senses they may be seen as victims 
themselves. We must not imply guilt by association. Although full reporting of the facts 
surrounding notorious criminals may properly entail reporting of their family circumstances 
we should always try not to cause unnecessary distress to the innocent. 
  
Care should be taken over using library shots of prisoners to illustrate a specific crime or type 
of crime. Individuals should not be clearly identifiable if they were not involved in the crime 
in question.  
  
2.6 Victims Of Crime 
When interviewing criminals programme makers must think through ways of minimising the 
distress any interview may cause to victims of the crime and their surviving relatives. See also 
section 6 “Revisiting Past Events” in Chapter 12: Reporting Suffering and Distress.  
  
3 DEALING WITH WITNESSES 
  
3.1 Interviews 
When interviewing witnesses or potential witnesses in a forthcoming trial is is essential that 
our conduct in no way interferes with the course of justice. When conducting news interviews 
with people who have recently witnessed a crime programme makers should be aware of the 
possibility that such witnesses might commit contempt. 
  
 
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No interviews with witnesses in a trial about any aspect of their evidence should be conducted 
 
once a trial is under way. Any proposal to interview a witness before the end of a trial should 
be referred by Heads of Department to Programme Legal Advice Department and Editorial 
Policy. 
  
Sometimes a witness may claim to have been coached by a journalist and we may need to be 
able to protect ourselves against any unfair accusation. During any recorded interview with a 
likely witness for use in a post-trial programme, producers are advised to make and retain a 
complete recording of the whole interview period, with the knowledge of the interviewee, 
including any pauses in the interview, interruptions, prompting, repeat questions, or re-takes.  
  
 
 
 
3.2 Payments 
 
3.2.1.  To protect both the integrity of the judicial process and the BBC’s reputation while 
criminal proceedings are active, no programme may pay or promise to pay, directly or 
indirectly, any witness or person who may reasonably be expected to be called as a witness 
for their story.  Nor should any payment be suggested or made dependent on the outcome of 
the trial.   
 
Any proposal to step outside this rule must be referred to Controller Editorial Policy. 
 
 
3.2.2. Where criminal proceedings are likely and foreseeable, payments should not be made to 
people who might reasonably be expected to be witnesses unless there is a clear public 
interest, such as investigating crime or serious wrong doing, and the payment is necessary to 
elicit the information.  Where such a payment is made, it will normally be appropriate to 
disclose the payment to both defence and prosecution if the person becomes a witness in any 
subsequent trial.   
 
 
3.2.3 In exceptional cases, only actual expenditure or loss of earnings necessarily incurred 
during the making of a programme contribution may be reimbursed, and then only after prior 
scrutiny and approval by the relevant head of department and Controller, Editorial Policy. 
 
 
 
CHAPTER 16 
RELATIONS WITH THE POLICE 
  
1 MAKING ARRANGEMENTS FOR PROGRAMMES 
2 POLICE MESSAGES AND INFORMATION 
3 "FACILITIES" AND TAG ALONG RAIDS 
4 INDEMNITIES AND ACCESS AGREEMENTS 
5 HI-JACKING, KIDNAPPING, HOSTAGE TAKING AND SIEGES 
6 COVERAGE OF PUBLIC DEMONSTRATIONS 
 
1 MAKING ARRANGEMENTS FOR PROGRAMMES 
 
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  here programmes are visiting places away from base, advice on the appropriate points of 
contact may be sought from the Regions and Nations, local BBC stations or the World 
Service where appropriate. These contacts are often the result of procedures agreed with the 
local police and unnecessary breaches can harm relations for a long time afterwards. Where 
possible, approaches should be made to the local police in good time to get agreement, for 
example, for siting equipment or for obtaining security passes for production teams. Local 
police should be informed if recording in the street is likely to cause an obstruction. 
  
2 POLICE MESSAGES AND INFORMATION 
The BBC helps the public by broadcasting police messages or warnings of traffic problems or 
emergencies. News programmes, especially at regional and local level, will usually carry 
police appeals for information about serious crime. Practical considerations such as time may 
limit what is broadcast.  
  
3 "FACILITIES" AND TAG ALONG RAIDS 
Some police forces, Customs and Excise officers and other public authorities permit groups of 
journalists to accompany them on particular operational duties such as drugs raids. 
Programmes must consider the pros and cons of accepting these invitations. There is a clear 
public benefit in seeing the operations carried out, but there are risks too. The event may be 
aimed principally at gaining favourable publicity; it may offer only partial access to a wider 
operation; and coverage may risk making the media appear part of the operation itself. 
Programme makers should only go on such a raid if they are sure there is a clear public 
interest involved and should think through issues of consent and trespass in advance. 
  
Authorities may try to secure access to untransmitted material recorded during any 
investigation. Programmes need to consider the issues this may raise before they go on any 
operation. 
  
When a considered decision has been taken to accompany police or customs officers or other 
public authorities on raids on private property, especially when going into people’s homes, 
the following should be observed: 
  
• 
Verbal or written consent should be sought from the legal owner or tenant of the 
property, except in exceptional circumstances – either before filming or as soon as 
convenient during filming or immediately thereafter. 
  
• 
Do not rely on others to gain consent. Programme makers should say they are filming for 
the BBC and why, and consent should be recorded on tape whenever possible. 
  
• 
Should consent be refused it is appropriate in most circumstances to withdraw 
immediately. Filming should only continue where there is a strong public interest, such as 
reasonable evidence of criminal activity 
  
• 
Innocent parties should be disguised when identification would imply some form of 
wrongdoing. Programme makers should strongly consider disguising people whose 
consent to be filmed under such circumstances is questionable e.g. minors or people with 
learning difficulties. 
  
• 
There may also be circumstances where we should take steps to ensure that a location 
cannot be recognised, if innocent parties could be identified from that location 
 
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• 
It may be necessary to disguise people for legal reasons e.g. possible contempt of court. 
There may also be issues of defamation. Normally it would be necessary to seek legal 
advice about such footage. 
  
• 
Always consider giving a person an opportunity to reply to allegations. This may not be 
relevant if the subject has been prosecuted and convicted of an offence. 
  
Programme makers should also be aware of the laws of trespass (see Section 5 Chapter 37; 
Matters of Law: General).  
  
4 INDEMNITIES AND ACCESS AGREEMENTS 
Police forces often ask the media to sign written agreements before joining a police operation. 
These agreements usually take the form of legal documents known as "indemnities ". The 
BBC has agreed a standard form of indemnity. Providing that the wording of any agreement is 
precisely that of the indemnity agreed by the BBC and the Association of Chief Police 
Officers programme makers may sign it. Copies of this standard form of indemnity can be 
obtained from the Editorial Policy Unit. 
  
Increasingly other organisations as well as police forces are presenting programme makers 
with access or production agreements. These agreements may cover anything from viewing 
programmes in advance, insurance indemnities, limits on access to people and places, rights, 
re-use and facility fees. It is important that such agreements are referred to TV Locations, 
Production, which will consult with relevant departments about the appropriateness of any 
proposed conditions, including Editorial Policy. Under no circumstances should any BBC 
programme agree to any conditions which surrender editorial control of a programme. 
  
If unacceptable conditions are imposed we will forego the opportunity to cover the event in 
the manner offered, or withdraw from filming completely 
  
5 HI-JACKING, KIDNAPPING, HOSTAGE TAKING AND SIEGES 
Cases of kidnapping in England and Wales are covered by an agreement between the news 
organisations and the Association of Chief Police Officers. The BBC will apply its provisions 
throughout the United Kingdom. When human life is at stake as a result of a kidnapping the 
police force dealing with the matter can ask for a complete news black-out. The procedure for 
such requests is carefully laid down and all editors of BBC news programmes should keep a 
copy of the document that describes the procedure.  
  
In protracted incidents, and where hostages are involved, broadcasters must be aware of the 
danger that anything they say on air may be overheard by the perpetrators. Our reporting must 
be truthful and strictly factual. We must not speculate about what has happened or what may 
happen. We must listen to advice from the police and other authorities about anything which, 
if reported, could exacerbate the situation. Occasionally they will ask broadcasting 
organisations to withhold or even to include some item of information. We would normally 
comply with a reasonable request, but we would never knowingly broadcast something that 
was untrue.  
  
6 COVERAGE OF PUBLIC DEMONSTRATIONS 
Comprehensive coverage of demonstrations is an important part of the BBC’s news coverage. 
There are pitfalls people should be aware of. 
 
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The presence of cameras may influence the way people behave. It is important for BBC 
people on the spot to make a judgement about whether apparently spontaneous activity is 
being staged for the benefit of the cameras. Footage of staged activity in these circumstances 
should not normally be broadcast. If reporting such activity becomes necessary, then 
reference should be made to how it occurred. BBC people who suspect that their presence is 
inflaming a section of the crowd should withdraw at once. 
  
News coverage of a demonstration should offer a comprehensive and impartial view. 
Estimates of attendance need to be treated with due scepticism, and wide disparities reflected. 
It may be helpful to name the source of any estimates. Camera coverage should avoid 
appearing to be on one side or the other, though for purely practical and safety reasons this 
may sometimes be unavoidable. It may be particularly difficult for reporters stuck on one side 
of a confrontation to form a clear overall view, and editors in the newsroom may need to 
ensure that material is put into a wider context. 
  
When covering demonstrations live editors must be constantly vigilant for signs of any of the 
above problems. If violence or disorder becomes graphic or distressing we must be ready to 
cut away, recording material for possible use in an edited report.  
 
 
CHAPTER 17 
CONFIDENTIALITY AND RELEASE OF PROGRAMME MATERIAL 

  
1 CONFIDENTIALITY 
2 REQUESTS FOR UNTRANSMITTED MATERIAL 
2.1 Access to untransmitted material 
3 REQUESTS FOR TRANSMITTED MATERIAL 
 
1 CONFIDENTIALITY 
Promises of confidentiality given to a source or contributor must be honoured. The BBC's 
journalism will suffer if people who give us information on condition that they remain 
anonymous are subsequently identified. 
  
The law affords some recognition to the importance of journalistic confidence, but it gives 
precedence to the interests of justice. In the event of a conflict between the two, the Courts 
may order journalists to divulge the source and may hold in Contempt anyone who refuses to 
do so. 
  
In the end, the decision to reveal a confidence or defy a court and take the consequences must 
be a personal matter for a journalist. The consequences can be extremely serious, and may 
include a term in prison. 
  
It is therefore essential for the BBC and for individual journalists that they do not enter into 
undertakings of confidentiality lightly or without considering the possible consequences. 
Journalists working on stories which may result in criminal prosecutions must be aware from 
the outset that they may be called as witnesses. At the earliest stages of research advice 
should be sought, through the relevant Head of Department or Commissioning Executive, 
from programme lawyers or Controller Editorial Policy. There are various practical ways of 
dealing with confidential sources: 
 
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• 
it may be possible to agree with contributors not to reveal their identities unless and until 
ordered by a Court. This is always a preferable option 
  
• 
it may be possible to establish a source’s authenticity without ever becoming aware of his 
or her identity or information that would lead to it 
  
• 
no document, computer file or other record kept by the journalist or by the BBC should 
identify a source whose identity cannot ever be revealed. This includes notebooks and 
administrative paperwork of all sorts as well as video or audio tapes 
  
• 
there is no legal obligation upon journalists to keep documents or records made during 
the preparation of a programme unless and until they are the subject of a formal request 
from the police or the Courts 
  
• 
notes made in connection with a confidential source should never be made alongside or 
in the same notebook or file as other material which is to be retained 
  
• 
information about a confidential source should not be shared unnecessarily with others on 
the production team who might be ordered to reveal it. 
  
Note that anyone who discovers information which could prevent a terrorist act in the 
UK or lead to the arrest of a terrorist wanted in the United Kingdom is obliged by law to 
reveal it at the earliest opportunity.
 
  
Details of contributors’, such as telephone numbers and addresses should be confidential to 
the BBC and should not be handed on to third parties without the consent of the contributor or 
referral to Editorial Policy. 
  
For further guidance on anonymity see section 8 “Anonymity” of Chapter 3: Fairness and 
Straight Dealing. 
  
2 REQUESTS FOR UNTRANSMITTED MATERIAL 
BBC policy on requests for access to untransmitted material has been developed over a long 
period. 
  
The BBC will not voluntarily allow access to untransmitted material when to do so 
would endanger people who work for the BBC or when it would make it more difficult 
to gather such material in the future. When approached for access to such material, 
programme makers must always refer requests to BBC lawyers and CEP. 
  
This policy is based on two main considerations: the proper protection of BBC staff, and the 
BBC’s continuing ability to record in dangerous situations (civil disorder, riots, wars and 
other conflicts) in the public interest. 
  
In many such situations the media can operate only by virtue of being neutral observers. All 
these situations may involve danger for BBC people. The danger may increase if those being 
recorded regard the programme makers as agents of authority who will automatically 
surrender any material they have recorded. The BBC is not above the law, but it is important 
that in such situations that it is, and is seen to be, independent of it. 
 
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There is a longer term danger that the BBC will be prevented from recording some events, so 
reducing the information given to the public. 
  
In addition there are wider considerations of the BBC’s editorial integrity. This could be 
damaged if other organisations and individuals are allowed access to untransmitted material 
for their own use. For example, untransmitted material should not normally be released to 
organisations for training and public relations purposes.  
  
2.1 Access to untransmitted material 
When asked for any untransmitted material, we must be alert to the possibility that it might 
contain information that could point to the identity of a confidential source. Any request for 
access to such material will be refused. 
  
"Access to" involves two separate acts: 
  
• 
allowing the material to be viewed 
  
• 
allowing it to be taken away for further use, e.g. as evidence 
  
Most requests for untransmitted material come from the police. 
In England and Wales the Police use PACE Orders (under the Police and Criminal Evidence 
Act 1984) to require the release of material for use as evidence in court. In Scotland a warrant 
for material may be granted by a Sheriff, or the Lord Advocate can seek to recover such 
material by petition or order. 
  
Sometimes the BBC allows a viewing by arrangement but requires a legal order for the same 
material to be taken away or used in court. The decision will depend on the nature of the BBC 
interest. Sometimes the BBC will refuse both a viewing and the taking away without a legal 
order because the BBC interest is so delicate or the risks so great. The BBC will usually resist 
requests for untransmitted material when these are merely “fishing” for evidence. 
  
Occasionally the BBC will allow a viewing or a taking away without any legal order because 
of a clear public interest which poses no danger to the BBC, its staff, or its future ability to 
operate freely. 
  
Anyone given a viewing will be told that other people or organisations involved in the case 
will be allowed the same facility. 
  
Sometimes it is appropriate to accede immediately to a legal order. At other times, it is 
necessary to contest such an order and to appeal to higher courts. 
  
Investigating authorities may be interested in untransmitted information in a notebook or in a 
person's memory. Here, the issue of confidentiality may arise (see section 1 “Confidentiality”: 
of this chapter).  
  
3 REQUESTS FOR TRANSMITTED MATERIAL 
These are usually simpler because the material is already in the public domain. However, in 
difficult cases it may be in the BBC's interest not to relinquish even transmitted material. 
  
 
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  hen requests are made for copies of transmitted material in connection with litigation, 
programme makers should bear three points in mind: 
  
• 
they should inform BBC litigation lawyers, who will consult with CEP where appropriate 
  
• 
if the scope of the request is too extensive, they should ask for it to be reduced, and make 
clear that, if it is not, the request might be refused 
  
• 
they should charge a fee or payment which realistically reflects the cost of providing the 
material. 
  
Sometimes listeners, viewers, contributors and others ask for copies of transmitted 
programmes for their own private use. Programme makers should consider each request on its 
merits, bearing in mind the practical difficulties, expense, copyright, legal, and broader 
editorial implications of providing any material. It may be necessary to require a written 
agreement that the material will only be used for private, and not for commercial, purposes.  
 
CHAPTER 18 
TERRORISM AND NATIONAL SECURITY 
  
1 TERRORISM ISSUES 
2 LANGUAGE AND TERMINOLOGY 
3 BOMB WARNINGS 
4 INDIVIDUALS AT RISK 
5 INTERVIEWS WITH TERRORISTS 
6 STAGED EVENTS 
7 NATIONAL SECURITY ISSUES 
8 THE OFFICIAL SECRETS ACT (1989) 
9 DEFENCE ADVISORY NOTICES (formerly D-Notices) 
 
1 TERRORISM ISSUES 
When reporting terrorism the BBC's role is to tell the truth - quickly, accurately, fully, 
responsibly and avoiding speculation. If people are to trust our reporting we must be seen to 
be independent as well as well-informed. 
  
The provisions in this section apply to our reporting of all terrorism. Our reporting of 
Northern Ireland is subject to the same standards, but it sometimes involves additional 
internal referral (see section 3: "Northern Ireland" of Chapter 19: Reporting The United 
Kingdom). 
  
2 LANGUAGE AND TERMINOLOGY 
We must not adopt terrorist language as though it were our own. Terrorist groups use military 
and judicial terms to give themselves status: if we report their use of words like "volunteer", 
"execute", "liberate", "court martial" and so on, we should attribute them. 
  
Reporting terrorist violence is an area that particularly tests our international services. Our 
credibility is severely undermined if international audiences detect a bias for or against any of 
those involved. Neutral language is key: even the word “terrorist” can appear judgmental in 
parts of the world where there is no clear consensus about the legitimacy of militant political 
groups.  
  
 
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3 BOMB WARNINGS 
 
News organisations sometimes receive telephoned warnings from people claiming to have 
planted bombs. It is essential that areas of the BBC where such calls are most likely to be 
received (newsrooms, information offices, switchboards) understand that the absolute priority 
is to pass information received to the emergency services. 
  
If we become aware of bomb alerts at specific locations it may be appropriate for programmes 
to report them even before we know whether they are genuine or merely hoaxes. Editors have 
to balance the need to inform and warn the public against the importance of not giving 
publicity to hoaxers. The prevailing climate, the history of recent terrorist attacks, and 
preliminary advice from the police may help us make that judgement. 
  
Some bomb warnings will prove to be hoaxes. We do not normally report incidents which 
turned out to be hoaxes unless they had a serious and evident effect (such as causing major 
traffic jams). In reporting bomb warnings we never reveal code words used by the callers.  
  
4 INDIVIDUALS AT RISK 
We do not normally report terrorist threats against named individuals unless the threats have 
produced a serious and evident effect (such as the cancellation of a public appearance). 
  
We should be careful when filming the homes of people whose position clearly puts them at 
risk (politicians, military people, judges etc.). We must try not to give details which might aid 
a terrorist attack. This includes exact locations, detailed plans, aerial pictures, readable shots 
of vehicle number plates and so on. We should never reveal details of anti-terrorist devices 
  
We must take care not to identify as possible targets for a terrorist attack people who would 
otherwise not be in danger. This may mean, for instance, withholding the identity of 
individuals, whether civilian or otherwise; withholding the names of firms undertaking work 
for military establishments or withholding the names of animal laboratories, if we have reason 
to believe that revealing them might put them at increased risk.  
  
5 INTERVIEWS WITH TERRORISTS 
The BBC interviews active terrorists only on occasions where we believe the public interest 
in doing so outweighs the outrage and offence such interviews are likely to cause our 
audiences. Any proposal to approach a terrorist or terrorist organisation for an interview must 
have the support of the Head of Department or Commissioning Executive and must be 
referred in advance to Controller Editorial Policy for approval.  
  
6 STAGED EVENTS 
From time to time paramilitary and terrorist groups stage "public appearances", usually to try 
to get publicity. BBC people should never agree to attend "staged" events without reference to 
Heads of Department, Commissioning Executives or Heads of Region. World Service. 
  
In the case of such events being staged in the United Kingdom, or in the case of threats being 
made at events overseas against UK citizens further reference must be made to Controller 
Editorial Policy. No material recorded at such an event is to be transmitted without separate 
reference to Controller Editorial Policy. 
  
In the United Kingdom, groups such as the Animal Liberation Front, which have a history of 
attacks and threats against people, would also come into this category. 
 
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BBC people may find themselves present at a legitimate event when paramilitary groups stage 
an appearance. Sometimes this will be entirely unpredictable, and sometimes it will be likely 
given the nature of the event (e.g. paramilitary funerals). In such circumstances material may 
be recorded but programme editors must refer within departments before deciding to transmit. 
Heads of Department should refer to CEP in any unusual cases.  
 
7 NATIONAL SECURITY ISSUES 
Journalists handling material which may have implications for national security in the United 
Kingdom must reckon with a variety of factors including the Official Secrets Act, the laws on 
confidentiality and the Defence Advisory Notice (formerly D-Notice) system (see Section 9 
below). 
  
Security sensitive matters must be referred through senior editors, to Controller Editorial 
Policy.  
  
8 THE OFFICIAL SECRETS ACT (1989) 
Section One of the Act concentrates on spying and has rarely troubled journalists. Section 
Five makes it an offence to publish information protected by the act. This includes: security 
and intelligence, defence, crime and special investigation, interception of mail and telephone 
calls, and confidential official exchanges between governments and with international 
agencies. The information must have originated from Crown employees or contractors and 
have been disclosed without authority. Journalists risk prosecution if they publish official 
information in these areas without authorisation. 
  
To succeed against a journalist, the prosecution must usually prove that harm was caused or 
was likely to be caused and that the journalist knew this, or had reasonable cause to believe it. 
The tests of harm are not especially stringent. The Act does not admit a public interest 
defence. Journalists can also be prosecuted for aiding and abetting a breach of the Official 
Secrets Act. 
  
Programme makers should seek legal and senior editorial advice at an early stage when 
handling material which falls, or might fall, within its terms. More generally, legal opinion 
should always be one of the factors in a final editorial decision on any security sensitive 
matter.  
  
9 DEFENCE ADVISORY NOTICES (formerly D-Notices) 
The Defence Advisory Notice system offers guidance to the press and broadcasters on 
information which if published might damage national security. The six Notices themselves 
are public documents - copies can be obtained from the Editorial Policy Unit and they are also 
available online at www.btinternet.com/~d.a.notices/. They detail the categories of 
information on which guidance should be sought. DA-Notices are never "slapped" on a story, 
nor are they written in reference to any particular broadcast or publication. They are reviewed 
from time to time by the Defence, Press and Broadcasting Advisory Committee on which sit 
senior civil servants and representatives of the press and broadcasting organisations. 
Controller Editorial Policy represents the BBC.  
  
The Secretary to the Committee deals with enquiries from the media. Normally approaches to 
the Secretary should be made through Controller Editorial Policy. If programmes have made 
enquiries through government agencies about sensitive matters the DA-Notice Secretary will 
 
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som
 
etimes be alerted by the government department concerned and may contact programme 
editors direct. In such cases it is important to inform CEP at once.  
 
CHAPTER 19 
REPORTING THE UNITED KINGDOM 
  
1 GENERAL 
2 STYLE AND LANGUAGE 
3 NORTHERN IRELAND 
3.1 Referral Procedures 
3.2 Staged Events 
3.3 Special Legal Considerations 
 
1 GENERAL 
BBC programmes and services should be relevant and appropriate for all our audiences in all 
parts of the United Kingdom. National and regional differences and sensitivities should be 
taken into account and all parts of the United Kingdom should be reported accurately and 
fairly. 
  
Audiences in different parts of the United Kingdom can approach BBC programmes in 
different ways and with different expectations. Audiences in different places have their lives 
shaped by different cultural backgrounds, different life experiences and different civic and 
political institutions. 
  
There are already big differences in legal systems across the UK. In education, health and 
social services the wide variations in policy that already exist are likely to become more 
marked. All should be reported with particular care. 
  
If not everyone is affected equally by a story or issue this should be made clear, normally in 
the first sentence. In News programmes it will usually be appropriate to flag this up in the 
headline as well. News Correspondents should try to make at least one reference to whom the 
story affects in any subsequent package. Though sometimes there will be a more sophisticated 
way than simply stating which parts of the UK a story applies to e.g. in a story about schools, 
pointing up the differences in approach to the curriculum in different parts of the country. 
  
There are differences in the religious institutions between England and Wales and Scotland 
and Northern Ireland. 
  
Programme makers should be aware that school holidays are different in different parts of the 
UK (see also section 2 of Chapter 6: Taste and Decency) 
  
Programme makers with particular queries should take advice from the relevant Newsrooms. 
  
Northern Ireland raises particular sensitivities, which are dealt with in section 3. 
  
2 STYLE AND LANGUAGE 
Programme makers should always think about how words or pictures will sound or look to 
different audiences in different parts of the United Kingdom. A particular story may not affect 
all parts of the UK equally. If it does not this should be made clear. 
  
 
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Our coverage should be accurate, precise and 
 
consistent. Geographical locations should be 
described in a consistent way. Give as much detail as is reasonable. 
  
The word “nation” can mean different things to different people. When the word is used it 
should be made clear what is meant. It can be clearer to use United Kingdom or “the UK”. 
  
Pronunciation of names and places should be correct. BBC newsrooms and the BBC 
Pronunciation Unit can give advice. 
  
Stereotypes should be avoided. Clichéd and lazy images or phrases should not be used as 
shorthand for describing places (for further guidance on stereotypes in humour and drama see 
Chapter 6: Taste and Decency). 
  
The correct names for the new Parliament and Assemblies and the new political posts in them 
should be used. They are the Scottish Parliament, the National Assembly for Wales and the 
Northern Ireland Assembly 
  
Detailed advice on style and language is contained in The Changing UK booklet, but the 
following specific points should be considered: 
  
• 
 groups which have “National” in their title do not always have a remit across the UK. 
The National Union of Teachers may be the biggest teaching union in England and 
Wales but it has no remit in Scotland, where the largest teaching union is the Educational 
Institute of Scotland 
  
• 
be accurate and consistent when using graphics and insets. For example, as we would 
never consider using an English flag to illustrate a story about exam results in English 
schools and we should never consider using a Scottish flag as an inset on a Scottish 
education story 
  
• 
take care when talking about “north, south, east and west…” Yorkshire may be the North 
if you are watching or listening in Southampton but not if you are in Inverness or 
Carlisle. If we mean the North of England we should say so 
  
• 
be consistent in describing where places are. Give as much detail asis reasonable 
  
• 
the prefix Anglo- describes an English relationship with something and should not be 
used as shorthand for the UK’s relationship with something. However, when its usage is 
so common as in, say, the Anglo-Irish Agreement (though this is not its official title) 
then it would be perverse to use another phrase 
  
• 
job titles can be different. In Scotland, the word Depute (as in Depute Head at a school) 
is widely used. It is a word that may be unfamiliar to audiences in other parts of the UK. 
So in scripting it is acceptable to refer to someone as: "her deputy”. However we should 
not change Depute to Deputy when using the official title 
  
• 
the use of the word Principality as a substitute for Wales can sound out of touch to 
Welsh audiences (except of course when talking about the Prince of Wales and Wales as 
a principality in that respect) 
 
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• 
while interviewees may refer to Northern Ireland as Ulster our journalists should not use 
Ulster as a synonym. (Ulster is one of the four provinces of Ireland. It consists of nine 
counties - the six in Northern Ireland and three in the Republic of Ireland) 
  
• 
the term “province” is often used synonymously with Northern Ireland and it is fine to 
make secondary references to “the province” 
  
• 
be careful when using the word “British” and “English”. They are not interchangeable. 
Say “British” when you mean “British” and “English” when you mean “English” 
  
• 
while some people in Northern Ireland regard themselves as “British” others regard 
themselves as “Irish”. When referring to the population as a whole we should use the 
term “the people of Northern Ireland” (but not “the Northern Irish”) 
  
• 
avoid using the word “mainland” when talking about Great Britain in relation to 
Northern Ireland. 
 
3 NORTHERN IRELAND 
Reporting of Northern Ireland is seen by audiences at home and internationally as a litmus 
test of the BBC’s fairness and independence. Extra care must be taken to avoid even the 
impression of partiality - both in terms of labelling the people and organisations involved, and 
in gauging the importance of individual events. 
  
In laying down special referral procedures relating to programming about Northern Ireland 
we are also determined to do all we can to protect the people who work for the BBC, and who 
live in what is often a sharply divided community. 
  
It is of cardinal importance that programme makers from elsewhere seek advice from and 
discuss with local staff their programme plans affecting Northern Ireland. This does not mean 
that any responsibility for the programme is passed to BBC Northern Ireland: it continues to 
rest with the originating department. 
  
At many times in recent decades violence has hit the headlines. But life in Northern Ireland 
reflects all the range and diversity of activity we cover elsewhere. We must explore and report 
that life, and not always in the context of "the Troubles".  
 
 
For specific advice on reporting terrorism, including staged events by terrorist groups see 
Chapter 18: Terrorism and National Security 
  
3.1 Referral Procedures 
On-The-Day Journalism 
Network News programmes retain a permanent presence in Belfast, but the contact point for 
all matters arising on the day is the Head of News and Current Affairs, Northern Ireland. 
  
Longer Term Programme Proposals 
All news programmes must consult the Head of News and Current Affairs Northern Ireland. 
  
 
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All other proposals for program
 
mes or programme items dealing with Northern Ireland or 
touching on Irish issues in general must be referred to Controller, Northern Ireland. Referral 
means a formal, usually written, submission of programme plans in whatever detail C.N.I. 
requires. This should take place at an early stage in the planning process. 
  
In the event of a serious disagreement between C.N.I. and a programme department, referral 
should be to Controller Editorial Policy. 
  
The Editors of Radio Times and BBC On Air magazine must ensure that material appearing in 
their publications conforms to understandings reached with Controller, Northern Ireland, or 
C.N.I.’s nominee. In addition, Heads of Presentation and Heads of Publicity are responsible 
for ensuring that publicity, promotion and presentation are in the forms agreed. 
  
Any material published Online about Northern Ireland should observe the same principles as 
other BBC programmes. Particular care should be taken about use of graphics. Controller 
Northern Ireland or C.N.I.’s nominee should be consulted.  
  
3.2 Staged Events 
From time to time paramilitary groups stage "public appearances", usually to try to get 
publicity. BBC people should never agree to attend "staged" events without reference through 
Heads of Department or Commissioning Executives to Controller Editorial Policy. No 
material recorded at such an event is to be transmitted without separate reference to 
Controller Editorial Policy. 
  
BBC people may find themselves present at a legitimate event when paramilitaries stage an 
appearance. Sometimes this will be entirely unpredictable, and sometimes it will be likely 
given the nature of the event (e.g. paramilitary funerals). In such circumstances material may 
be recorded but programme editors must refer within departments before deciding to transmit. 
Heads of Department should refer to CEP in any unusual cases.  
  
3.3 Special Legal Considerations 
The provisions of prevention of terrorism legislation impose obligations on all citizens to 
provide information about, and to refrain from dealing with, criminals or terrorists in 
Northern Ireland. There is no exemption for journalists. 
  
The Northern Ireland (Emergency Provisions) Acts could also have an important bearing on 
programme makers. 
  
N.B. At the time of the publication of these Guidelines the Government had announced plans 
to reform all forms of terrorist legislation. BBC Programme Legal Department will be able to 
brief on any subsequent changes in the law. 
  
Programme makers whose plans might bring them into areas where the criminal law 
imposes obligations must seek guidance, through Heads of Department or 
Commissioning Executives, from BBC lawyers, and from Controller Northern Ireland 
or Controller Editorial Policy. 
 
CHAPTER 20 
RECORDING THE NATURAL WORLD 
  
 
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1 GENERAL 
 
2 FILMING NAMED ANIMALS 
3 LIFE CYCLE PORTRAYAL 
4 LOCATION 
5 CAPTIVE SEQUENCES 
6 VISUAL TECHNIQUES 
7 RECONSTRUCTION AND SIMULATION 
8 FILMING ANIMALS AND THE LAW 
9 ETHICAL CONSIDERATIONS 
 
1 GENERAL 
Natural History programmes have a duty to uphold the same values of truth and accuracy that 
apply to all factual output. Audiences should never be deceived or misled by what they see or 
hear. 
  
In the same way that there are perfectly acceptable conventions used in the production of 
factual programmes (see section 8 “Staging and Re-Staging of Events” in Chapter 2: 
Impartiality and Accuracy), similar conventions can apply in Natural History programme 
making that neither deceives nor misleads the audience. 
  
There will be times when it is appropriate to share these Natural History filming techniques 
with the audience. This should increase audience appreciation of the value of particular "real" 
sequences filmed in the wild and distinguish them from material filmed in captive situations 
or controlled conditions. 
  
 
 
 
2 FILMING NAMED ANIMALS 
Television production methods in wildlife film making rely on single camera location 
shooting. This sometimes means that when a programme is singularly identifying or focusing 
on a named animal, it is not always possible to record all the shots at one time. 
  
Where insufficient material of a significant natural event has been recorded it may be 
necessary to use additional shots or cutaways of the named animal recorded at a different time 
to the main action to produce a workable sequence. This technique has long been part of the 
accepted grammar of Natural History programme making. As long as the material depicts 
natural events in the animal's life cycle, it is perfectly acceptable to combine and compress 
these events to tell a biological story truthfully. But programme makers should not show 
action that is significant to the narrative of the film using shots of an apparently identical 
animal and portray it as the named animal. 
  
Where insufficient material of a routine natural event has been recorded, the use of additional 
shots of an identical (substitute) animal for insignificant bridging shots or cut-aways may be 
justified in order to produce a workable sequence. This is an acceptable artifice so long as the 
shots are used to illuminate the routine event and do not in any way distort the meaning of it. 
But we should not state that the shots are of the same animal. Commentary should never 
suggest the viewers are seeing something they are not.  
  
3 LIFE CYCLE PORTRAYAL 
 
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Many wildlif
 
e programmes aim to tell the life story of an animal or plant and to reflect in 
detail different aspects of this natural cycle. Unfortunately the realities of survival in the 
natural world and/or the life span of the animal often mean it is impossible to film an 
individual consistently. It is acceptable for programme makers to use footage of several 
different animals or plants to evoke the life cycle from cradle to grave. Again audiences 
should not be led to believe they are seeing the same animal throughout the programme, for 
example by giving the "composite" animal a name. 
  
Some types of Natural History films are deliberately anthropomorphic and tell intentionally 
dramatised stories of a fictional family of animals and their predators. This is a perfectly 
acceptable way of informing and entertaining viewers so long as the set-up is totally clear. It 
may be appropriate for programme makers to think about telling the audience at the start of 
the programme that what they will see, although dramatised, is nevertheless based on 
scientific fact.  
 
4 LOCATION 
In Natural History programmes, which aim to provide a portrait of animals or plants living in 
a particular place, programme makers can legitimately use material filmed at different times 
and different locations. It is important however to present a fair and accurate picture of what 
is being portrayed. It would not be acceptable to film at one location and claim to be at 
another. Also programme makers should not introduce animals to a location that is not their 
natural home.  
  
5 CAPTIVE SEQUENCES 
In wildlife film making it is sometimes impractical or unsafe to film certain biological 
processes or animal behaviour in the wild. In some cases filming could endanger the wild 
animal or its offspring. In such circumstances it is ethically and editorially justifiable to use 
captive animals to portray what happens naturally in the wild. However it should never be 
claimed that the captive sequence was actually recorded in the wild or in the actual location 
depicted in the film.  
  
6 VISUAL TECHNIQUES 
Some Natural History films deliberately and legitimately use stylised and visual devices. For 
example, in a Natural History programme illustrating principles of biology or ecology it 
might be desirable to use time lapse techniques under laboratory conditions to show the 
audience what the eye can’t normally see. Likewise computer generated graphics or enhanced 
real images can bring sequences to the screen that would be impossible to produce in any 
other way. However, where there is a risk of misleading or confusing the audience, such 
techniques need to be clearly labelled or sign-posted in commentary.  
  
7 RECONSTRUCTION AND SIMULATION 
Natural History programme makers sometimes use reconstruction as a story telling device. 
Reconstruction, which is where single events based on corroborated personal testimony are 
quite explicitly re-enacted, is a technique that must be clearly labelled. Reconstruction is used 
when people are involved and when the cameras were not present at the original event. Refer 
to section 7” Reconstruction” and section 8 “Staging and Restaging Events” in Chapter 2: 
Impartiality and Accuracy for more detailed guidance on these subjects. 
  
Simulations are different from reconstructions because they are not based on a single 
verifiable event. Instead they seek to give the viewer an impression of natural conditions or 
 
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phenom
 
ena, based on testimony and evidence that may have been compiled from different 
sources at different times. Simulations are permissible when it would have been impossible to 
film the original event due to its rare or dangerous nature. They recreate natural conditions or 
phenomena in which animals, and sometimes people, appear. When it is proposed to simulate 
sequences, programme makers should consider using a variety of sign-posts in order to inform 
audiences about their techniques. These might be a combination of presentation 
announcements, appropriate use of commentary, innovative post production techniques and 
labels in the body of the film, or, as a last resort, an explanatory caption in the end credits. 
  
In cases where reconstruction or simulation is proposed as a story telling device in natural 
history programmes, production should not proceed without referral to the Head of the 
Natural History Unit. 
  
There may be occasions where re-staging routine events involving animals may be justified 
and may not need to be labelled. However all such interventions require carefully balanced 
judgements. Producers should also refer to section 9: “Ethical Considerations”.  
  
8 FILMING ANIMALS AND THE LAW 
Programme makers working with animals must be aware that animal welfare is controlled by 
specific acts of law which if not followed could result in prosecution and criminal conviction. 
In the United Kingdom the following are just four examples of illegal activity: 
  
• 
capture of any birds for filming purposes 
  
• 
feeding live mammals, birds and reptiles to any other animal 
  
• 
tethering or restricting a vertebrate by any means to attract a predator 
  
• 
cruel goading of an animal to fury 
  
In the UK bull fighting, dog fighting and cock fighting are illegal. Broadcasting such scenes, 
whether recorded here or overseas, will be rarely justified and must be referred to the Head of 
Department, Head of ICG or relevant National Controller. It may be acceptable if it is in the 
public interest and is filmed as “actuality”. See also Section 11 “Use of Animals” in Chapter 
37: Matters of Law: General.  
  
9 ETHICAL CONSIDERATIONS 
Programme makers should never be involved in any filming activity with animals which 
could reasonably be considered cruel i.e. filming which may cause physical harm, anxiety, 
consequential predation or lessened reproductive success. However, there are times when, in 
the public interest, programme makers may be justified in recording the harming of animals 
by third parties for the purpose of gathering evidence or to illustrate malpractice, cruel, anti-
social or controversial behaviour. Permission for such filming should be referred to the Head 
of Department, Head of ICG or the relevant National Controller. 
  
For detailed advice on the portrayal of violence involving animals, see Section 2.3 of 
Chapter 7 Violence. 
  
 
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For all film
 
ing with animals it is important to seek expert advice and to make a detailed 
assessment of the risks and potential welfare problems. In so doing the following should be 
considered: 
  
• 
the effect the type of filming will have on the animal e.g. filming from a hidden position; 
filming at night; stunt filming 
  
• 
the amount and proximity of contact with the animal 
  
• 
hazards posed by the animal and to the animal - what could go wrong? 
  
• 
length of time it is reasonable to film the animal without causing distress 
  
• 
animals can cause infection and infestation; allergic reactions; injuries and phobias 
  
• 
age and experience of those people involved in the filming 
  
The Natural History Unit can offer further advice on the handling and filming of animals.  
 
CHAPTER 21 
RE-USE AND REVERSIONING OF BBC TELEVISION PROGRAMMES 
  
1 GENERAL 
2 LOGGING CONCERNS 
3 CLEARANCE FOR REUSE, CONTRACTS AND RIGHTS 
4 ACCURACY 
5 SCHEDULING 
6 SENSITIVE PROGRAMMES 
7 LOCAL SENSITIVITIES AND INTERNATIONAL AUDIENCES 
8 SUFFERING, DISTRESS AND TRAUMA 
9 CRIMINAL ACTIVITY 
10 SURREPTITIOUS RECORDING 
 
1 GENERAL 
These guidelines state good practice when BBC television programmes are repeated, 
reversioned, or reformatted for use on either BBC or Joint Venture Channels. 
  
When archive programmes are rescheduled and/or edited, they must comply with the 
BBC Producers’ Guidelines whether for transmission in the UK or overseas. 
  
Commercial channels, whether broadcasting to the UK, or broadcasting from the UK to 
international audiences, must also comply with the ITC Programme Code. 
  
All the guidance below also applies when excerpts of programmes are used. Particular 
attention must be paid to the context within which clips are to be re-used, including their use 
in trails. When appropriate, captions should be used to date excerpts. 
  
These guidelines do not apply to programme or library sales. 
  
2 LOGGING CONCERNS 
 
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Any re-version or re-form
 
at of a transmitted programme should be logged, including details 
of all changes to picture, sound and commentary. When programmes are edited for length or 
for any other reason, care must be taken to ensure that they are still accurate, impartial, 
balanced and fair. The re-edited programme must comply with any legal agreements that 
applied to the original. 
  
Originating production departments (and independent production companies) are responsible 
up to the point of first transmission for ensuring that all potential concerns about the re-use of 
material at home or overseas are logged and attached to post-production paperwork. Legal 
and rights constraints, contributor sensitivities, surreptitious recording and any use of 
reconstruction should be recorded. 
  
Broadcasters should ensure that the originating production or commissioning department is 
informed in good time of plans to schedule programmes and must ensure that post-production 
paperwork is checked for any restrictions on use.  
  
3 CLEARANCE FOR REUSE, CONTRACTS AND RIGHTS 
Broadcasters, or those to whom they delegate responsibility, should ensure that any 
programmes or excerpts of programme material which they plan to re-use can be cleared for 
that use, and have been cleared prior to transmission. When non-news programmes want to 
use news material they should always consult the relevant news library. 
  
Artists’ contracts should be checked for conditions agreed for re-use. Where there are no 
artists’ contracts, producers need to be aware that their programmes are likely to be re-used 
and inform contributors of this at the time they record their contribution. Wherever possible it 
is desirable for producers to obtain consent and rights from key contributors in writing. Where 
this is inappropriate or impossible, or where consent and rights have been restricted, 
producers must refer to their Head of Department or Commissioning Executive. 
  
Legal scrutiny of a repeated programme should be as careful as it was at the time of the 
original transmission. It is no defence in a defamation action to argue that material has 
already been shown. Special care should be exercised in relation to questions of contempt, for 
example if someone featured in an original transmission is arrested prior to its repeat. 
  
Re-use of archive material must take into account any findings from the Programme 
Complaints Unit, which are binding on the BBC, and from the Broadcasting Standards 
Commission, of which the BBC would want to take careful account. If it is proposed to re-
broadcast a programme which has been the subject of an upheld complaint, the relevant chief 
executive (normally Chief Executive Broadcast) should be consulted in advance.  
  
4 ACCURACY 
Archive material can quickly become out-dated and inaccurate. New facts may emerge and 
contributors’ opinions may change over time. Sometimes it will be justified to show such 
programmes unaltered. However, where programmes have become factually inaccurate, it 
must be made clear that the programme is no longer up-to-date. Captions, commentary and 
billings should be used as appropriate. On-air information may also be given when necessary. 
Post-production paperwork must also be checked so that any use of reconstruction can be 
clearly labelled prior to transmission.  
  
5 SCHEDULING 
 
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Particular care should be taken when program
 
mes are rescheduled to make sure they are 
suitable for the new slot. Material, including strong language, suggestive dialogue, explicit 
sexual scenes and violent content, may need to be edited. All BBC television channels in the 
UK, both public service and commercial, must observe the 9p.m. Watershed policy. The post 
Watershed period runs from 9.00p.m. until 5.30a.m. the following morning.  
  
6 SENSITIVE PROGRAMMES 
When repeats of documentary material, drama documentary or factual reconstruction are 
scheduled, programme makers should consider whether any contributors, or people portrayed, 
need to be contacted for contractual or legal purposes, or for reasons of courtesy. Post-
production paperwork must be checked. Where necessary, key contributors should be 
informed of the repeat, preferably by the original production or commissioning department. 
Care should be taken not to suggest that permission to re-transmit is being sought, unless the 
original contract so requires.  
  
7 LOCAL SENSITIVITIES AND INTERNATIONAL AUDIENCES 
Overseas services need to take local sensitivities into account as regards both content and 
scheduling. Decisions to broadcast material should be made with due consideration for those 
featured. Issues such as privacy and fairness must be taken into account, including potential 
distress, damage and/or danger to contributors, and anonymity ensured when appropriate. 
Matters of taste and decency and offence to local audiences may also arise. However, in 
considering local sensitivities, the BBC should do nothing which detracts from its core 
commitment to due impartiality and accuracy as laid out in Chapter Two of the Producers’ 
Guidelines (see also section 5: “International Audiences” in Chapter 6: Taste and Decency).  
  
8 SUFFERING, DISTRESS AND TRAUMA 
There are a minority of programmes involving illness, death, emotional trauma or intimate 
personal revelation. In such cases, the current status of significant participants must be 
considered. Some programme material becomes less sensitive with the passage of time. 
However, when re-use may cause damage and/or distress to the individuals concerned, their 
next-of-kin or those close to them, the views of contributors or their relatives should be 
sought where possible. It is preferable that this approach is made by the original production or 
commissioning department. There may be instances where there is sufficient public interest to 
override objections to re-use. Such decisions should always be referred to senior management 
who will need to consider contributor issues, including the likely impact of re-using the 
material on the channel concerned, and the public interest. 
  
If contributors to such programmes object to re-use, or if they cannot be located owing to the 
passage of time, the basis on which consent was originally given must be carefully 
considered. People may be sensitive to material that depicts them as children at an age when 
they were unable to give informed consent on their own account. In all such circumstances, 
broadcasters must be satisfied that the grounds for repeating such material are defensible and 
should seek further guidance. 
  
Where the material covers criminal activity, broadcasters should attempt to inform any 
victims of serious crime or their next-of-kin before re-use if this is appropriate. The 
programme should normally proceed against the objections of those concerned only if there is 
a clear public interest.  
  
9 CRIMINAL ACTIVITY 
 
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Consideration should also be given to the stigm
 
atising effect of repeating material that reveals 
an individual’s criminal past. The intention to transmit such material, especially if there are to 
be many repeats or trails, raises questions about fairness. Broadcasters may need to consider 
re-editing material, granting anonymity to individuals and/or providing new sequences or 
updated information via a caption.  
  
10 SURREPTITIOUS RECORDING 
Before broadcasters re-use material recorded surreptitiously, they should reconsider public 
interest, privacy and fairness issues. The re-use of any surreptitiously recorded material must 
be referred to senior management before transmission and a log kept of any decision. 
  
In the case of commercial channels complying with the ITC Guidelines, such reconsideration 
must be logged by channel managers at each transmission.  
 
CHAPTER 22 
GAME SHOWS AND COMPETITIONS 
  
1 GENERAL 
1.1 Competitions run by others 
2 SELECTING CONTESTANTS FOR QUIZZES AND GAME SHOWS 
3 TREATING CONTESTANTS FAIRLY 
4 SAFETY 
5 PRIZES 
6 DONATED PRIZES 
7 ORGANISATION OF COMPETITIONS 
7.1 Jointly Organised Competitions 
7.2 References to BBC Magazines 
8 PRIZES IN JOINTLY ORGANISED COMPETITIONS 
9 ENTRY FORMS AND RULES 
10 LEGAL CONSIDERATIONS AND PREMIUM RATE LINES 
11 CO-SPONSORED EVENTS 
12 ITC RESTRICTIONS 
 
1 GENERAL 
Game shows, quizzes and viewer or listener competitions should be conducted in a manner 
which is fair, honest, legal and decent. Careful consideration should be given to matters of 
taste in game shows to avoid offence. 
  
A variety of programmes may from time to time run quizzes, or viewer or listener 
competitions. There should always be a clear editorial purpose for any competition which is 
included in a BBC programme. 
  
The BBC does not normally run game shows or viewer or listener competitions where prizes 
are offered purely on the basis of chance. In quiz or game shows any significant prizes should 
be awarded on the basis of games or questions which are a test of skill, knowledge or 
judgement appropriate to the participants and the target audience. Viewer and listener 
competitions should always involve a genuine test of skill, knowledge or judgement 
appropriate to the audience. 
  
It is important that members of the public do not have to pay or 
 
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buy anything in order to take part in a BBC qui
 
z programme or game show. They should also 
not be asked to buy anything in order to enter a viewer or listener competition. For guidance 
on phone-in competitions see section 10 below. 
  
Exceptionally, when a game is organised as part of an official BBC fundraising appeal such as 
Children in Need it may be acceptable to ask for a donation to the charitable appeal. Any such 
arrangement must be checked well in advance with Editorial Policy and Programme Legal 
Advice Department. (See also section 10 below) 
  
When running competitions and awarding prizes, the BBC needs to maintain its editorial 
independence and should take care not to promote any service, product or publication. We 
should not normally offer prizes of branded products or services, which are referred to 
editorially elsewhere in the programme. 
  
Questions in competitions, quizzes or game shows should not refer to any branded goods or 
services that are provided as prizes. 
  
For guidance on coverage of the National Lottery see Chapter 23. 
  
1.1 Competitions run by others 
Programmes must not promote any competition which is not organised by the BBC or in 
conjunction with the BBC. 
  
For advice on suitable coverage of outside events which include contests and awards 
ceremonies see Chapter 28 Covering Outside Events.  
  
2 SELECTING CONTESTANTS FOR QUIZZES AND GAME SHOWS 
There are a range of ways of choosing suitable contestants for game shows. However, steps 
should be taken to screen out contestants who are clearly unsuitable such as those who have 
been convicted of very serious offences. It is advisable to ensure that contestants sign a 
formal declaration to ensure that they conform to the criteria we require of them and that they 
are aware of the terms of their appearance on the show. Advice should be sought from the 
Programme Legal Advice Department and Editorial Policy may also be consulted.  
  
3 TREATING CONTESTANTS FAIRLY 
Members of the public who take part in quiz or game shows should be treated honestly and 
fairly. It is also important to consider their dignity. They probably have never been on 
television or radio before and we must take care not to exploit or patronise them and to treat 
them sympathetically. We should explain what is going to happen and, if they are going to 
appear as figures of fun, they need to feel a party to the joke rather than the object of it. It is 
particularly important to be cautious with contestants who have been volunteered by family or 
friends as subjects of escapades, which are covertly recorded (for further guidance on secret 
recording in entertainment programmes see section 9 of Chapter 5: Surreptitious 
Recording)
  
Where game shows or entertainment shows involve contributors recounting anti-social 
activities, this should only involve minor matters. Clearly the BBC must not be seen to 
endorse serious wrongdoing.  
  
4 SAFETY 
 
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W
  e should not put contestants to any significant risk to their health or safety and participants 
must not be asked to do anything which involves danger to life. Where games and 
competitions are physically demanding it may be appropriate to ask participants to complete a 
medical questionnaire to ensure their fitness to take part. 
  
We must take care to minimise and control any inherent risks and a suitable risk assessment 
should be carried out. BBC producers should consult the appropriate BBC safety manager 
about safety checks and procedures. For independent productions the Commissioning 
Executive must check that the company has appropriate health and safety arrangements and 
access to a competent person to advise on health and safety matters (see also section 12 
“Health and Safety” of Chapter 37: Matters of Law: General). 
  
Programmes must ensure that the participant recognises and accepts any risks which may be 
involved. So that the audience does not think we are acting irresponsibly it may sometimes be 
appropriate to make it clear on air that we have taken suitable safety precautions and that the 
participant is aware of any risks.  
  
5 PRIZES 
BBC programmes should normally pay for the prizes they offer in game shows and viewer 
and listener competitions. Programme makers should aim to offer original, rather than 
expensive prizes. It is inappropriate to spend Licence Fee or Grant in Aid money on prizes of 
excessive value. 
  
If there is a range of prizes there should be a range of brands or suppliers. Shots of brand 
logos should be avoided and programmes should not normally refer to brand names or give 
details about the manufacturer or supplier of a prize. In exceptional circumstances some 
details may be given on the grounds that description of the prize would be inadequate without 
them, but there must be no element of plugging. 
  
Cash prizes should be avoided in viewer and listener competitions and should never be 
offered in children’s programmes. Any proposal to offer a cash prize in a game show or 
studio-based competition must be referred to the Head of Department or Commissioning 
Executive and the output Controller should also be informed.  
  
6 DONATED PRIZES 
We should aim to pay for competition prizes and only modest donated prizes should normally 
be accepted such as theatre tickets, football tickets, books, records or CDs. We may accept 
prizes of visits to special events, including the hospitality offered at the event, but 
programmes should pay for the travel and accommodation costs involved. 
  
Donations of modest household or consumer goods or services may occasionally be accepted, 
but only with the approval of the Head of Department 
  
Donations of more substantial prizes are permissible only in exceptional circumstances which 
do not bring the BBC’s editorial integrity into question. For example it might be possible to 
accept a more substantial prize if offered by an educational institution or a research 
foundation. Such prizes can be accepted only with the written approval of the Head of 
Department who may wish to consult Editorial Policy. 
  
 
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If program
 
mes accept donated prizes, the changes should be rung to ensure that the BBC does 
not appear to favour any institution or company. If tickets are accepted we must avoid giving 
undue prominence to one particular performer or company. 
  
Programmes must never give an assurance that there will be an on-air credit or any publicity 
in exchange for the donation of a competition prize. Prizes should be described in an 
informational, non promotional manner. The name of the supplier should not normally be 
given and the brand name should be mentioned only if it is strictly necessary editorially. In 
such cases only one reference should be made. Television programmes should take all 
reasonable steps to avoid showing brand logos.  
  
7 ORGANISATION OF COMPETITIONS 
The BBC must ensure that any game show or competition is organised in a proper manner 
which would bear public scrutiny.  
  
7.1 Jointly Organised Competitions 
Occasionally a viewer or listener competition may be run jointly with a suitable outside body 
such as an academic or artistic institution. Programmes should not mount viewer and listener 
competitions in conjunction with commercial organisations. However, in exceptional 
circumstances, it may be possible to join with a publication or other media organisation to run 
a competition for a co-sponsored educational award or an award for skills associated with 
broadcasting such as journalism, music or drama. Local radio stations may join with a local 
publication to present an award for service to the community. It is not possible to run any 
other type of on-air competition with a publication. (for advice concerning off-air 
competitions organised with publications see section 15 of Chapter 24: Commercial 
Relationships and Appropriate Programme Funding).  
  
Programmes should obtain the written approval of the Head of Department before any 
agreement is reached for a jointly organised competition. Chief Adviser Editorial Policy 
(Multimedia and Commercial) should also be consulted. The BBC must pay a substantial part 
of the costs of any jointly organised competition and no money from the outside organisation 
should flow into any programme budget.  
  
7.2 References to BBC Magazines 
There are restrictions on mentions of BBC magazines in programmes. If BBC programmes 
run a viewer or listener competition in association with a BBC magazine the programme 
should not refer to the magazine. For detailed guidance see Chapter 27: On-Air References 
to BBC Publications, Products and Services. 
  
Any proposal to mention a BBC magazine in relation to an awards ceremony or an outside 
event must be referred to Chief Adviser Editorial Policy (Multimedia and Commercial). For 
detailed guidance see Chapter 28: Covering Outside Events.  
  
8 PRIZES IN JOINTLY ORGANISED COMPETITIONS 
The same guidelines apply as for competitions organised solely by BBC programmes. The 
organisers should only accept modest donated prizes from a third party. No mention of a third 
party donor should be given on air. 
  
From time to time a BBC publication may print details about a programme competition. 
However, a BBC publication may not accept large donated prizes from a third party for any 
 
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on-air com
 
petition.  
  
9 ENTRY FORMS AND RULES 
If a viewer or listener competition requires entry forms, these must be available by 
telephoning, writing or e-mailing the BBC or the relevant programme. Forms may also be 
available at BBC premises. No information should be given on air about entry forms or 
further details being available in any publication or via any other outlet. 
  
Although BBC publications may include details about programme competitions, no radio or 
television programme should tell viewers or listeners that there are entry forms or competition 
details in the Radio Times or any other BBC magazine. 
  
However, World Service Radio may tell listeners that entry forms are available in their 
publication BBC on Air. Such references are not permissible in BBC Worldwide television 
programmes. (See section 12 below on ITC Restrictions.) 
  
Any game show or competition must have clear rules, which conform to legal requirements. 
The rules and terms of entry to any competition should be checked with the Programme Legal 
Advice department.  
  
10 LEGAL CONSIDERATIONS AND PREMIUM RATE LINES 
There may be a number of legal issues to be addressed when organising competitions and 
producers should seek the advice of the Programme Legal Advice Department about the 
arrangements for any new type of competition or game show
  
In particular, producers should be aware of the legal constraints imposed by the Lotteries and 
Amusements Act 1976. The Act may be contravened if a viewer or listener competition is 
based on a game of chance and some sort of donation, purchase or contribution is made to 
enter. 
  
The use of premium rate telephone calls for a competition may be deemed to be the making of 
a financial contribution to enter. If premium rate lines are used, skill must be required to win; 
otherwise the competition may be interpreted as gambling or a lottery. Competitions which 
involve predictions about future events are not normally permissible. Producers should refer 
to the Programme Legal Advice Department before arranging any competition involving 
premium rate lines. 
  
See also Chapter 32: Phone Ins and the Use of Telephone Services in Programmes.  
  
11 CO-SPONSORED EVENTS 
From time to time, the BBC mounts public events, particularly in the arts field, which are co-
sponsored by outside bodies. Such events may be run as contests or competitions, for example 
a co-sponsored contest for best singer or best musician. For further guidance see Chapter 28: 
Covering Outside Events.  
  
12 ITC RESTRICTIONS 
In addition to these guidelines, the ITC Code of Programme Sponsorship and the ITC 
Programme Code include further detailed provisions concerning game shows, prizes, viewer 
competitions, jointly run competitions and entry forms. These ITC provisions must be 
observed by any commercially funded BBC Joint Venture television service broadcast in the 
 
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United Kingdom
 
 or any BBC commercially funded international channel uplinked from the 
UK 
 
CHAPTER 23 
COVERAGE OF THE NATIONAL LOTTERY 
  
1 GENERAL 
2 DETAILED PROVISIONS 
3 USE OF LIBRARY PICTURES OF LOTTERY PROGRAMMES 
 
1 GENERAL 
The National Lottery is an institution which is regulated by Act of Parliament. It interests 
millions of our viewers who either buy lottery tickets or who are recipients of Lottery grants. 
National Lottery draws are national events and the BBC covers these draws as a service to 
viewers and listeners. 
  
2 DETAILED PROVISIONS 
All trails for programmes which carry National Lottery draws or games should be promotions 
for the BBC programme not the National Lottery. They should not include or reflect Lottery 
logos, Lottery advertising slogans, the music from Lottery adverts or any elements of Lottery 
advertising or any advertising undertaken by the Lottery Operator, currently Camelot. 
  
We should not use elements of Lottery advertising campaigns in our Lottery programming. 
Official National Lottery logos may appear on the Lottery draw machines themselves and the 
stand they are placed on as these are elements of the draw itself controlled by the Lottery 
Operator. No lottery logos or elements of them should appear elsewhere on the set or in the 
programme. There should be no lottery logos on the programme’s superimposed graphics. 
  
In order to avoid directly promoting the purchase of Lottery tickets or cards, BBC lottery 
programming and trails for lottery programming should not show Lottery tickets or cards on 
air and should not give details about how and where they may be purchased. It is, however, 
acceptable for the mechanism of Lottery draws to be explained on air in a non promotional 
manner. Some indication may be given of the chances of winning a prize. 
  
Though the term “National Lottery” may be used on air where appropriate there should be no 
on-air credits for the Lottery Operator. Any on-air reference to the Lottery operator should be 
for sound editorial reasons. 
  
Children under sixteen should not be present in the studio and lottery programming should 
not be specifically aimed at children under sixteen. 
Purchase of a lottery ticket must not be a pre-requisite of being on the show. The audience of 
a lottery programme must not have paid to attend or take part in the show. 
  
The prizes for the National Lottery’s own draws or games which are covered by the BBC are 
provided by the National Lottery prize fund. Apart from the prizes for the National Lottery’s 
own draws or games any other prizes should be provided by the BBC. The National Lottery 
Operator’s promotional budget should not be used to pay for any BBC programme prizes. 
  
 
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The Lottery Operator is responsible for the costs of running and adm
 
inistering Lottery draws 
and the provision and maintenance of all necessary equipment. All broadcasting and 
programme costs must be paid for by the BBC. 
  
The BBC will pay for the expenses of any programme contestants who take part in BBC game 
shows which include Lottery draws. 
  
The BBC retains editorial control over all BBC programmes and trails which feature National 
Lottery draws or games. 
  
The BBC retains right of approval over all promotional material or activities bearing the BBC 
brand or featuring BBC programmes which carry National Lottery draws or games.  
  
3 USE OF LIBRARY PICTURES OF LOTTERY PROGRAMMES 
Other BBC programmes proposing to use library pictures of BBC lottery programming to 
illustrate items about the Lottery should be careful not to confuse the programmes which 
cover it with the Lottery itself. The Lottery itself is a matter for government, the Lottery 
Regulator and the Lottery Operator. Programmes which cover Lottery draws are a matter for 
the BBC. The only element which is controlled by the Lottery Operator is the mechanism for 
the draws. 
  
Programmes wishing to illustrate stories purely about the Lottery itself should not use library 
pictures of Lottery programmes beyond shots of the draws. They should not use pictures of 
the presenters or titles, or use the title music without consulting Editorial Policy. They should 
also consult the Programme Legal Advice Department who will advise on legal restrictions 
concerning pictures from Lottery programmes and the use of the Lottery logos. 
  
The relevant Lottery programme production team may approve use of footage of parts of 
Lottery programmes which are purely entertainment, such as musical acts, if no reference is to 
be made to the Lottery.  
 
CHAPTER 24 
COMMERCIAL RELATIONSHIPS AND APPROPRIATE PROGRAMME FUNDING 
  
1 GENERAL 
2 BBC COMMERCIAL POLICY GUIDELINES 
3 INDEPENDENT PRODUCTIONS 
4 ADVERTISING AND SPONSORSHIP 
5 ITC REGULATION 
6 BBC ADVERTISING AND SPONSORSHIP GUIDELINES 
7 COVERAGE OF SPONSORED EVENTS 
8 SPONSORSHIP OF BBC EVENTS 
9 BBC ORCHESTRAS 
10 CO-PRODUCTIONS 
11 CO- FUNDING 
11.1 Suitable Co-Funding Partners 
11.2 Credits 
11.3 Support Material 
12 HOSTED PROGRAMMES 
13 JOINT EDITORIAL INITIATIVES 
14 ON-AIR PROMOTIONS 
15 OFF AIR PROMOTIONS WITH PUBLICATIONS 
 
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16 COMMERCIAL PRODUCTS ASSOCIATED WITH PROGRAMMES 
 
17 NATIONAL AND LOCAL RADIO 
18 COMMERCIAL REFERENCES REGISTER 
 
1 GENERAL 
The BBC operates in an increasingly commercial broadcasting market, involving many 
relationships with a commercial dimension. However, the BBC must clearly retain its 
reputation for editorial integrity whilst reflecting a real world. 
  
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. They should never have reason to suspect that 
the BBC’s integrity has been compromised by any financial pressure or commercial 
inducement from any outside organisation or interest group.  
  
2 BBC COMMERCIAL POLICY GUIDELINES 
The Producers’ Guidelines are concerned with editorial issues and the BBC’s programme 
making activities and any on-air references to commercial products or organisations. Advice 
on the BBC’s commercial activities and exploitation of the BBC brand can be found in the 
BBC’s Commercial Policy Guidelines. They cover questions such as the acceptability of BBC 
commercial ventures and how they should be undertaken, use of the BBC brand, promotional 
activities and fair trading.  
  
3 INDEPENDENT PRODUCTIONS 
The Producers’ Guidelines apply to all independent productions made for the BBC and 
contracts between the BBC and independent producers must reflect this. Contracts must also 
ensure that the BBC knows and agrees all sources of funding before the commission is 
confirmed. BBC commissioning executives responsible for supervising independent 
productions should ensure that independents are fully aware of guidelines concerning 
editorial integrity and the financing of programmes. The BBC must approve all promotional 
material for any independent production made for the BBC.  
  
4 ADVERTISING AND SPONSORSHIP 
No BBC service funded by the Licence Fee or Grant-in-Aid may carry advertising or 
sponsored programming. 
  
The BBC’s international commercially funded channels and BBC Joint Venture channels are 
permitted to take advertising and some programme sponsorship in accordance with relevant 
guidelines and codes of practice.  
  
5 ITC REGULATION 
All UK commercial television services are regulated by the ITC, for this reason BBC 
commercially funded television services uplinked from the UK are required to conform to all 
relevant ITC codes as well as to the BBC Producers’ Guidelines. On the whole, the 
Producers’ Guidelines are more exacting and comprehensive than the ITC Programme Code, 
but those responsible for output on BBC commercial channels should ensure that they are 
aware of the provisions of The ITC Programme Code as well as The ITC Code of Advertising 
Standards and Practice, ITC Rules on Advertising Breaks and The ITC Code of Programme 
Sponsorship. 
  
 
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BBC Knowledge is a special case. It is a publicly funded channel, but at its launch in June 
 
1999 it was temporarily placed on a commercial multiplex. While on this multiplex the 
channel should be treated in regulatory terms in the same way as others on that multiplex and 
should be consistent with ITC as well as BBC guidance. In most cases conforming to the 
BBC Producers’ Guidelines will satisfy all ITC requirements, but there are specific issues 
relating to on air references to support material see section 13 ITC Regulated Services of 
Chapter 31: Programme Support Services and Support Material;.  
  
6 BBC ADVERTISING AND SPONSORSHIP GUIDELINES 
In order to guarantee its own editorial integrity and impartiality the BBC has drawn up its 
own guidelines on standards for advertising and sponsorship for its commercial television 
service. These guidelines embody core BBC principles and contain some provisions not 
specified by the ITC Codes, for example the BBC will not carry religious advertising or take 
sponsorship for programming giving general consumer advice. 
  
Specific BBC guidelines have been drawn up for the BBC’s Joint Venture Commercial 
Channels in the UK and for BBC International Television Channels. There are also specific 
guidelines for jointly branded international channels and BBC branded television channels 
broadcasting to specific countries and uplinked from outside the UK . 
All these guidelines are available from Editorial Policy.  
  
7 COVERAGE OF SPONSORED EVENTS 
The BBC covers a wide range of sporting fixtures and other outside events. Many of these are 
now supported by sponsorship. For guidance on appropriate coverage see Chapter 28: 
Covering Outside Events.  
  
8 SPONSORSHIP OF BBC EVENTS 
From time to time the BBC mounts outside events for which it may accept co-sponsorship 
from an outside body. Money from an outside sponsor can only be used to enhance the event 
itself and must not be used to pay for any element of the broadcast coverage. For detailed 
guidance see Chapter 28: Covering Outside Events.  
  
9 BBC ORCHESTRAS 
BBC Orchestras may seek commercial support and sponsorship for aspects of their work 
which go beyond broadcasting, for example in undertaking education and outreach projects, 
giving public concerts or making national or international tours. The core broadcasting 
activity of the orchestras, however, should not be sponsored and any arrangement that could 
reasonably be perceived as direct sponsorship of the orchestra’s broadcasting activities should 
not be accepted. The BBC should retain the right of advance approval for all promotional 
material and activities associated with any sponsored orchestral event or project.  
  
10 CO-PRODUCTIONS 
For co-productions, funding is provided in exchange for broadcasting and other rights. The 
BBC may consider co-productions with other broadcasting companies, recognised programme 
and film distributors, independent producers, record or video companies and audio publishers. 
The BBC may also arrange co-productions with theatres, ballet, opera or music companies or 
other institutions involved in education and the arts. 
  
The BBC should not enter into co-production arrangements with any organisation whose 
activities could lead to doubts about the editorial integrity of the programme. 
 
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Co-productions should not provide a back door for sponsors and BBC producers should make 
sure they are aware of any funding, sponsorship or promotional agreements which potential 
co-production partners have with third parties. The same applies to any arrangements 
proposed by an independent producer. Concerns about funding arrangements for co-
production partners should be reported to the Head of Department or Head of the Independent 
Commissioning Group. 
  
Credits for co-production partners should be simple and non-promotional. Television 
producers should refer to the BBC Television Credit Guidelines.  
  
11 CO- FUNDING 
In strictly limited cases and for strong public interest reasons it may be appropriate to 
supplement licence-fee or grant-in-aid funding for programmes with grants from appropriate 
non-commercial outside bodies. Such co-funding must not give rise to any suspicion that the 
BBC’s editorial independence or integrity has been compromised or that it is willing to 
broadcast sponsorship messages. 
  
Co-funding differs from co-production in that it is not undertaken with conventional co-
production partners and is not in exchange for broadcasting rights. 
  
On the BBC’s domestic services co-funding would not be appropriate for programmes aimed 
at a general audience The subject matter of any co-funded programme must be 
uncontroversial and uncontentious and outside the area of public or political debate. Co-
funded programmes must be designed to meet the specific needs of a limited or clearly 
defined section of the audience. Such outside funding should only be considered when it 
might seem questionable to meet the entire cost of programming of such a specific nature 
from the licence fee. For example co-funding might be acceptable for specialised educational 
or minority language broadcasts. 
  
World Service Radio takes co-funding for some educational programming and for “lifeline” 
programming which provides an emergency service of humanitarian information for 
audiences severely affected by war or major disaster. 
  
Co-funding must never be accepted for news, current affairs or consumer advice 
programming on any BBC domestic or international service. 
  
All co-funding projects must be approved in writing by the Director of Education, or relevant 
Director. Controller Editorial Policy should also be consulted.  
  
11.1 Suitable Co-Funding Partners 
Funds must not be accepted from any organisation whose interests or activities could lead to 
doubts about the objectivity of the programme. Suitable co-funders might include publicly 
funded bodies, charities, charitable trusts or voluntary bodies. Commercial funded charitable 
trusts might be acceptable in some cases as long as the trust is run at arm’s length from any 
commercial interest. Funding from any UK government body or European Union body must 
be treated with great caution in order to protect the BBC’s impartiality and independence. 
Although it may be legitimate for international agencies to co-fund certain programmes, funds 
must not be accepted from individual foreign governments. 
  
 
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The BBC retains total editorial control over any co-funded production and it is essential that 
 
programmes do not promote the funder or the funder’s image. 
  
Further detailed guidance is available from Editorial Policy.  
  
11.2 Credits 
For reasons of transparency we should always acknowledge the source of co-funding on air. 
There should be a single non promotional reference, with no element of advertising. 
  
A credit for the co-funder should be at the end of the programme. For television programmes 
the credit should be in the final captions, there should be no verbal reference and the co-
funder’s logo should not be used. Television producers should also refer to the BBC 
Television Credit Guidelines.  
  
11.3 Support Material 
Programme co-funders may also meet some or all of the costs of support material. The source 
of funding for support material should not be given on air unless there is a particularly strong 
editorial reason to do so, though a credit may be included on the support material itself. Those 
responsible for arranging support material should also consult Chapter 31: Support Services 
and Support Material for further detailed guidance.  
  
12 HOSTED PROGRAMMES 
In certain specific cases where there is some specific educational need such as vocational 
training for a targeted small audience it may be acceptable for the BBC to transmit 
programmes which have been made and funded by outside bodies. These programmes are 
placed in off-peak slots targeted at specific niche audiences. 
  
Any such programme must be accurate and impartial and must not have any political purpose. 
It must meet the standards of the Producers’ Guidelines and must also conform to the BBC’s 
detailed guidelines for such programmes available from Editorial Policy. The BBC will retain 
final editorial control over any hosted programme and must approve the programme before 
transmission. 
  
Programme providers should be non-profit making, non-commercial bodies such as official 
training bodies, official bodies representing the professions and voluntary organisations. 
  
Director of Education and Chief Executive Broadcast must approve the areas of BBC output 
where it is acceptable to take such programming.  
  
13 JOINT EDITORIAL INITIATIVES 
Programmes may sometimes enter into a joint editorial initiative with an outside body such as 
an educational institution. This initiative may take the form of mounting an event or running a 
competition for an award. In exceptional cases for clear editorial reasons, such an initiative 
may be undertaken with a magazine or newspaper, though the initiative must not require BBC 
viewers or listeners to purchase the publication. It is essential that no money from the outside 
body goes into any programme budget. 
  
Any joint editorial initiative must be agreed in advance by the Head of Department who 
should consult Editorial Policy. Further detailed guidance can be found in section 7.1, 
“Jointly Organised Competitions” of Chapter 22: Game Shows and Competitions and 
 
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section 7.3, “Joint Debates and Forum
 
s” of Chapter 28: Covering Outside Events.  
  
14 ON-AIR PROMOTIONS 
The BBC cannot agree to give on-air promotion for an outside organisation or publication in 
return for their promotion of the BBC or a BBC programme or BBC service. Any such 
arrangement would be contrary to the terms under which the BBC is permitted to broadcast. 
When organising joint editorial initiatives with outside bodies, care needs to be taken to 
ensure that they are not compromised by any agreement for mutual promotion.  
  
15 OFF AIR PROMOTIONS WITH PUBLICATIONS 
Off-air promotions for programmes should be treated with great caution as it is essential that 
they reflect the BBC’s editorial values. From time to time, newspapers or magazines may 
wish to run competitions or other interactive promotions in association with BBC 
programmes. Such arrangements are only rarely acceptable. Any such promotions must be 
editorially driven and the BBC must not enter into the arrangement for financial gain. There 
must be no mention on air of the newspaper or magazine and associated advertising should 
not imply BBC endorsement of the publication. 
  
Interactive promotional competitions arranged with publications require the prior approval of 
the relevant Director and the Chief Adviser, Editorial Policy (Multi-media and Commercial) 
should also be consulted. Detailed guidelines are available from Editorial Policy.  
  
 
 
16 COMMERCIAL PRODUCTS ASSOCIATED WITH PROGRAMMES 
The BBC produces a range of commercial products which arise from programmes and which 
support, extend and enhance the service offered to the public. BBC products must not be 
promoted within programmes. However there are special on-air trails for BBC publications, 
videos, tapes and CD Roms which complement an associated BBC programme and extend 
access to its subject matter. Such products need to reflect the BBC’s core values and 
standards and must conform to the BBC’s Commercial Policy Guidelines. There can be no on 
air promotion for other BBC merchandise associated with programmes (see Chapter 27: On 
Air References to BBC Products, Services and Publications). 
  
Particular care must be taken if independent producers have rights to develop merchandise 
associated with programmes. The BBC’s reputation for integrity could be compromised by 
inappropriate arrangements concerning commercial products or retailers as there is a risk of 
implied endorsement by the BBC. Contracts with independent producers should stipulate that 
the BBC must approve any promotional material related to associated merchandising. All 
such commercial activity licensed by the BBC must conform to the BBC’s Commercial 
Policy Guidelines.  
  
17 NATIONAL AND LOCAL RADIO 
The BBC’s radio stations in the Nations and BBC local radio stations welcome local 
participation in their activities, but they must not accept any sponsorship for programmes nor 
can they accept money or facilities in exchange for broadcast publicity. 
  
In exceptional circumstances, editors may consider offers of practical help from appropriate 
bodies of a non-political or non controversial nature for programmes concerning matters such 
as education, the arts or religious affairs. They should not accept assistance from local 
 
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councils. Editorial control m
 
ust remain with the BBC and there must be no implication that 
the BBC is favouring any religious denomination or outside organisation. All proposals for 
outside support must be approved by the Director, National and Regional Broadcasting.  
  
18 COMMERCIAL REFERENCES REGISTER 
Each Directorate maintains a current register of co-sponsored events, sponsored support 
material, sponsored support services, co-funding, co-sponsored competitions, donated 
competition prizes and sponsored events covered in programmes. The purpose of this register 
is to ensure that the BBC is aware of the level of its overall involvement with any outside 
organisation.  
 
CHAPTER 25 
PRODUCT PROMINENCE AND FREE OR REDUCED COST PRODUCTS AND 
FACILITIES 
  
1 PRODUCT PROMINENCE 
1.1 Product Placement 
1.2 Undue Prominence of Branded Products and Services in Programmes 
1.3 Products used as props 
1.4 Reviewing Products and Services 
1.5 Testing Products 
1.6 Details of products 
1.7 Books and Other Publications 
1.8 Commercial Recordings 
1.9 Use of Commercials 
2 USE OF FREE OR REDUCED COST PRODUCTS 
2.1 Consumer and lifestyle programmes 
2.2 Supply of Props 
3 USE OF FREE OF REDUCED COST FACILITIES 
3.1 Holiday and travel programmes 
3.2 Media facility and fact finding trips 
4 CREDITS 
5 ONLINE, CEEFAX AND DIGITAL TEXT SERVICES 
 
1 PRODUCT PROMINENCE 
BBC programmes need to reflect the real world and from time to time reference will be made 
to commercial products and commercial concerns. However, programmes must never give the 
impression that they are endorsing or promoting any product, service or company. 
  
References in programmes to all products and services must be editorially justifiable and not 
promotional. 
  
We should always have good reasons for naming a particular company, product or service in a 
news or factual report. We must remain on guard against featuring too readily any story which 
has been generated on behalf of a commercial company. A skilful public relations company 
may make simultaneous approaches to several programmes. The BBC’s reputation for 
impartiality is not enhanced if the same commercially-orientated story appears on several 
programmes over a short period of time. Journalists and producers should think carefully 
about editorial justification, integrity and labelling before deciding whether to use material 
provided by a commercial company (see also Chapter 26: Material Supplied by Outside 
Organisations).  
  
 
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Presenters, reporters and production staff should have no substantial connection with products 
 
and firms featured in stories they are covering (see Chapter 10: Conflicts of Interest).  
  
1.1 Product Placement 
A product or service must never be included in sound or vision in return for cash, services or 
any consideration in kind. This is product placement and it is expressly forbidden in BBC 
programmes. It is illegal to make any such arrangements in the UK or anywhere else within 
the European Union.  
  
1.2 Undue Prominence of Branded Products and Services in Programmes 
References to trade and brand names should be avoided where possible and made only if they 
are clearly justified editorially. No undue prominence should be given to any branded product 
or service and there must be no element of plugging. When featuring branded products or 
services, we must take great care not to give an impression that the programme is being 
influenced in any way by a commercial concern. Television shots should not linger on a brand 
name or logo unless justified for strong editorial reasons. 
  
No BBC programme must ever accept free or reduced cost products or services in 
return for an on-air credit or any visual or verbal reference to the product or the 
provider (see also section 3). 
  
For BBC ONLINE, a hot link must never be included in return for cash, services or any 
other consideration in kind.
 Editorial references to companies or outside organisations 
should not normally contain any use of their logo. For further advice, see the BBC ONLINE 
Guidelines.  
  
1.3 Products used as props 
In drama, comedy and entertainment, programme producers have to consider whether there is 
a really strong editorial justification for using branded products. If products are used, as 
props, setdressing or elsewhere in drama or entertainment they must be varied as much as 
possible to ensure that there is no suggestion of a particular brand being promoted. As far as 
possible, labels and logos should be turned away from the cameras and close-ups, which show 
the branding, should be avoided. Verbal references to brands may be more intrusive than 
visual ones and should be used sparingly both on television and radio. It is hard to justify a 
simultaneous visual and verbal reference to a branded product used as a prop and if possible 
verbal references to the brand should not be included in any scene which includes a product in 
vision (for further guidance on the supply of props see section 2.2).  
  
1.4 Reviewing Products and Services 
Consumer programmes and many other types of programmes frequently review products or 
services. Care should be taken to cover a range of products. If for some strong editorial reason 
one product or service is reviewed in detail, there should normally be reference to others 
which are comparable. Where this is not possible on some holiday and travel programmes, 
every effort should be taken over a period of time to mention a range of tour operators. 
  
Where a consumer programme reviews a product or service, it may be editorially appropriate 
for Ceefax, digital text or the online support page to give non-promotional details of the 
products reviewed. Pages reviewing products or carrying details of products should never 
give an impression of BBC endorsement. See the BBC ONLINE Guidelines for specific 
 
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advice about hotlinks to the sites of the m
 
anufacturers, suppliers or retailers of any goods or 
services mentioned. 
  
Companies which have received a favourable review may wish to state this in their 
promotional literature or point of sale displays. This may be acceptable in some limited 
circumstances, though no impression should be given of BBC endorsement and no BBC logos 
should be used (for further guidance see sections 4.26 and 4.27 of the BBC’s Commercial 
Policy Guidelines).  
  
1.5 Testing Products 
The type of testing featured in programmes may vary from experts deciding which product 
tastes best to a programme undertaking carefully controlled experiments. A range of products 
should be featured and the precise nature of the tests should be made clear. It is important that 
we report the results in a non-promotional manner . We should simply say how products have 
fared in the test and which may be good value. Every effort should be made to ensure that 
where outside experts are used to assess products they have no vested interest in promoting 
any of them.  
  
1.6 Details of products 
We do not normally give details of how to obtain products. We should only do so where it is 
strictly editorially justifiable, and we should cover a full range of suppliers.  
  
 
 
1.7 Books and Other Publications 
Mentions of publications within programmes should be editorially justified and there must be 
no element of promotion. If experts from magazines or newspapers are interviewed, care 
should be taken over time to vary the publications whose experts are featured (for further 
guidance on references to BBC publications, see Chapter 27: On Air References to BBC 
Products, Services and Publications). 
  
Chat shows and people shows often interview celebrities who have recently published a book, 
however, we should take care that the interview focuses on the person and the subject matter 
of the book, rather than appearing to encourage people to go out and buy it. Television 
programmes should not normally show a close up or still of the book cover unless the 
programme includes a measured and critical review of the work in question. An item which 
merely marks the publication date or interviews the author does not necessarily count as a 
review. 
  
Credits are normally given when books are reviewed. If material is quoted from a book under 
review, there is an obligation under the Copyright Act to mention the title and author. 
Reference is also usually made to the publisher. Details about publications under review 
should normally be given within the programme itself, rather than in continuity 
announcements (see also Chapter 40: Matters of Law: Copyright and Other Intellectual 
Property Rights).  
  
1.8 Commercial Recordings 
It is important that we are not seen to plug particular recordings or artists on our music 
programmes. Though presenters may express a personal view about a recording, they should 
not urge listeners either to buy it or not to buy it .It is essential that the music played is chosen 
 
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for sound editorial reasons and that the choice is not im
 
properly influenced by any record 
company or music promoter. 
  
Specialist music presenters are employed on Network Radio because of their knowledge of a 
particular area of music and the credibility this gives them with the audience. However, as 
they are key figures in their respective genres, in some cases they do have some financial 
connection with the music industry. Where this is the case such a connection must be 
registered with the network and all playlists must be approved in advance by the Head of 
Music Policy (or equivalent) for the network.  
  
1.9 Use of Commercials 
Programmes may use excerpts from television or radio commercials only for sound editorial 
reasons such as consideration of how a company is promoting itself or how advertisers 
promote products. Great care must be taken to ensure that the BBC does not appear to be 
promoting any product or service by showing sections from advertisements. 
  
There are also copyright considerations concerning use of advertisements which must be 
checked with the Intellectual Property Department. 
  
Advice on the use of BBC presenters, characters or brands in non BBC commercials can be 
found in Chapter 10: Conflicts of Interest and Chapter 29: Advertising, Promotional 
Activities and the BBC Brand.  
  
2 USE OF FREE OR REDUCED COST PRODUCTS 
Products used by BBC programmes must be selected for sound, non promotional reasons. 
Products which are actually featured on programmes must be selected on editorial grounds. 
Products which are not shown, but are used as part of the programme making process, must 
be selected on grounds of suitability. 
  
In order to resist commercial pressures and to retain its impartiality, the BBC should normally 
pay for the goods it uses. However programmes may take advantage of the BBC’s size and 
purchasing power to negotiate discounts providing these discounts are in line with similar 
discounts offered to other large organisations. 
  
Only a few specific programme areas may accept free or substantially reduced cost products 
(see 2.1 and 2.2 below). 
  
We do not normally credit the suppliers of products. Any on-air reference to products should 
be for very sound editorial reasons (see section 4 below).  
  
No products or services should be used or accepted as the result of any inducement or 
pressure from the provider. 
Under no circumstances should those working for the BBC receive personal benefits 
from the providers of goods or services.
  
  
2.1 Consumer and lifestyle programmes 
Consumer and lifestyle programmes which review or feature a wide range of products may 
under certain circumstances accept products free or at considerably reduced cost. This is 
permissible because the very large number of products featured enables programmes to ensure 
that they are not favouring any particular product or supplier. 
 
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• 
Any programme which accepts free or reduced cost products must keep an accurate 
record of all such arrangements. This should include details of the product, when and 
how it was used and what information if any was included on support material. The 
producer must be able to demonstrate that no supplier or manufacturer is being favoured 
or discriminated against. It is essential that products are not featured merely because they 
can be secured free or at a very reduced cost 
  
• 
Suppliers should be reminded in writing of the BBC policy in this area and should be 
informed that there can be no question of the product being accepted in exchange for an 
assurance of an on-air reference 
  
• 
No guarantee can be given that the product will be reviewed in a favourable light, or that 
it will feature in the programme at all 
  
• 
Suppliers should not be afforded an editorial say in the programme nor a preview of it 
  
• 
Programme makers should be wary of the promotional dangers posed by unsolicited 
offers of free or reduced cost products from manufacturers or suppliers. Any placement 
of products in exchange for reduced cost is prohibited (see section 1.1 above) 
  
Heads of Department are responsible for ensuring that proper records are kept and that the 
acceptance of any reduced cost products is appropriate within the terms of these guidelines 
(see section 3 below for guidance on facilities and trips).  
  
2.2 Supply of Props 
In drama and entertainment care must be taken to ensure that products supplied by any 
outside agencies or other organisations are selected only at the producer’s initiative. Suppliers 
of props, set dressing or clothing should be informed that there is no guarantee that the 
product will be used or that it will be shown in a favourable light. Props should not be 
accepted from suppliers if they are subject to editorial restrictions on their use. 
  
If any programme accepts props free or at greatly reduced cost accurate records of all such 
arrangements should be kept in accordance with section 2.1 above.  
  
3 USE OF FREE OF REDUCED COST FACILITIES 
Programmes should pay for travel, accommodation and other facilities. Discounts can only be 
accepted if they are in line with discounts offered to other large organisations. 
Trips should only be accepted free in exceptional circumstances when acceptance is the only 
way to cover a significant event (see section 3.2 below)  
  
3.1 Holiday and travel programmes 
Holiday or travel programmes which regularly review a range of travel facilities and 
accommodation must not accept trips free and must pay a significant contribution towards the 
costs. They must never cover holidays offered by one company merely because they are 
offered to them at a particularly advantageous rate. A range of tour operators should be 
covered in the course of a series. Detailed records must be kept of all facilities which have 
been accepted at a reduced cost in accordance with 2.1 above.  
  
3.2 Media facility and fact finding trips 
 
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From
 
 time to time, BBC programmes and people working on them receive invitations from 
public or private bodies to go on expenses paid trips. These may be for the purposes of 
gathering material for broadcasting (i.e. a media facility trip), or they may be for briefing and 
background information. These invitations can come from a variety of different organisations 
e.g. the British Armed Forces, foreign governments, lobbying groups, the European 
Commission. The following principles should be observed:  
  
• 
Such invitations must not be accepted by individuals or programmes if their acceptance 
might adversely affect the BBC’s editorial integrity or its reputation for impartiality 
 
• 
Any programme maker proposing to accept the offer of either a media facility or a fact 
finding trip must receive the approval in advance of their Head of Department 
 
• 
The BBC should be free to decide who, if anyone, accepts the invitation. Where 
invitations are open only to named individuals rather than programmes, the presumption 
should be against acceptance. 
  
The BBC will not accept an offer of a free place or places on a media facility trip to gather 
material unless it is the only way to report a significant event, such as an inaugural flight or 
voyage or military operation. Where a trip is open to a range of media, the programme must 
be satisfied that the trip is editorially necessary. The programme should point out in writing 
that it is not normal policy to accept such trips and should offer to make a realistic 
contribution to the costs involved. 
  
If a commercial operator provides the facility, there should not normally be any reference - 
verbal or visual - to the operator. If there is a clear editorial need to make a reference, it must 
avoid promoting or endorsing the operator. In those rare circumstances where a reference to 
the commercial operation is considered editorially justifiable it must be discussed with and 
approved in advance of transmission by the Head of Department. 
  
On briefing and fact-finding trips, the BBC must take care that its editorial integrity would 
not be compromised by the acceptance of such a trip. Any acceptance needs to be able to pass 
the test of public reaction were the nature of the trip to be publicised. Again, the BBC should 
offer to make a realistic contribution (e.g. air fares) towards the costs involved. If such an 
offer is refused the presumption should be against acceptance.  
  
4 CREDITS 
In some specific cases, the BBC may decide to give a credit to the provider of services 
whether they have been secured at full or reduced cost. For example, it may be editorially 
necessary to credit a research library or the supplier of archive material. In some cases the 
BBC will have negotiated supply of information from an outside supplier and a credit will be 
required (see Chapter 26: Material Supplied by Outside Organisations). 
  
Heads of Department have the discretion to authorise a credit where there is strong editorial 
justification, and the credit does not promote or endorse the product or service. The company 
logo or type face should not be used as part of the programme’s graphics nor in any end 
credits. 
  
Any credits in support material should be editorially justifiable, non promotional and should 
not be in exchange for free or reduced cost facilities. 
 
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The granting of a credit is at the BBC’s discretion. Under no circumstances can 
programme makers agree to a credit as a precondition for the offer of free or reduced 
cost products or services.
  
  
5 ONLINE, CEEFAX AND DIGITAL TEXT SERVICES 
The BBC ONLINE Guidelines give further details on references to products and services and 
on appropriate hot-links. 
  
There are also detailed guidelines for references on digital text and Ceefax to products, 
services and publications.  
 
CHAPTER 26 
MATERIAL SUPPLIED BY OUTSIDE ORGANISATIONS 
  
1 INFORMATION FROM OUTSIDE SOURCES 
1.1 Varying the sources of outside information 
1.2 Crediting outside information 
1.3 Crediting a recognised library, archive or research institute 
1.4 Computer credits in sports coverage 
2 RECORDINGS SUPPLIED BY OTHERS 
3 VIDEO OR AUDIO NEWS RELEASES 
4 EMERGENCY ANNOUNCEMENTS 
4.1 Police SOS Messages 
5 GOVERNMENT INFORMATION FILMS AND OFFICIAL MESSAGES 
 
1 INFORMATION FROM OUTSIDE SOURCES 
BBC programmes use a considerable amount of information supplied by others, including 
commercial and non-commercial organisations. Examples include weather reports, sports 
results, exchange rates, and pop charts. News bulletins also draw on information provided by 
reputable news agencies. 
  
Much of this information, including news agency copy, is paid for. However, when it is 
provided free particular care has to be taken to ensure that the BBC does not promote the 
supplier. 
  
Care should also be taken that the supplier of the information does not make improper use of 
its relationship with the BBC for promotional purposes. The BBC must have right of approval 
over any use of the BBC’s name in the supplier’s promotional material. 
  
1.1 Varying the sources of outside information 
In some cases we rely on a single source for a particular type of information. For example a 
programme might include financial information supplied by a particular bank. Where 
practicable we should vary the source of such information over time if there are other 
suppliers which are equally reliable. 
  
However, in the case of information supplied by official departments or local authorities, it 
may not be necessary to vary the source, even if equally accurate information is available 
elsewhere.  
  
1.2 Crediting outside information 
 
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It is often appropriate to state the source of outside inform
 
ation for sound editorial reasons: 
  
• 
to enable the viewer or listener to assess its authority, or accuracy. For example we would 
name organisations which have conducted opinion polls or we would say that we have 
obtained weather information from the Met Office 
  
• 
to indicate that this is information which is unique to one supplier and cannot be obtained 
elsewhere 
  
• 
to make it clear that the BBC has not verified the information. We might name a news 
agency as a source if we were relying solely on a report from one agency. 
  
The decision on whether to mention the source or to give a formal credit, such as a caption or 
an announcement, must be made on editorial grounds. We must not accept information free or 
at reduced cost in return for providing on air or off air publicity to the supplier. All references 
to the suppliers of information must be brieffactual and non promotional. There must be no 
element of plugging. No logo of an information provider should appear in any visual credit. 
Television producers should also refer to BBC Television guidelines for opening and closing 
screen credits. 
  
There may be occasions when the BBC decides to enter into a formal contractual agreement 
with an information supplier. This agreement may include a provision that the BBC will 
reflect the source of the information. Any formal agreement about credits should be made for 
editorial rather than commercial reasons. Arrangements of this kind should be made only with 
the approval of the relevant Director or Chief Executive. 
  
(See also Chapter 25: Product Prominence and Use of Free or Reduced Cost Facilities)  
  
1.3 Crediting a recognised library, archive or research institute 
Occasionally it may be appropriate to credit outside institutions, such as libraries, which have 
provided information or considerable research assistance. Decisions about credits should be 
separate from any financial arrangements.  
  
1.4 Computer credits in sports coverage 
Guidelines have been agreed among members of the European Broadcasting Union for credits 
given to companies which provide timing or computer-based services for sports coverage (see 
also Chapter 28 Covering Outside Events).  
  
2 RECORDINGS SUPPLIED BY OTHERS 
Many BBC programmes use pictures or sound recorded and provided by other organisations 
or individuals. We cannot always vouch for the circumstances under which such material was 
recorded so we should take particular care in how we use it. 
  
In many cases material is supplied by other reputable broadcasters or agencies on a 
contractual or reciprocal basis. If it is provided by people who may have a personal or 
professional interest in its subject matter we must be certain we are using it for the best 
editorial reasons and avoid giving the impression that we endorse a product, organisation or 
cause. In general material supplied by interested parties should be labelled to make its 
provenance clear. 
  
 
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Program
 
me makers should assess the overall editorial value of such material rather than 
simply its pictorial impact. Video from the emergency services may raise serious issues of 
privacy and intrusion - for instance where victims or patients are concerned. 
  
Programme makers may be asked to sign contracts before being given such material, and they 
may contain unacceptable editorial restrictions. Seek advice through Heads of Department, 
from Editorial Policy and Programme Legal Advice before agreeing. 
  
For guidance on use of CCTV footage see section 6 of Chapter 4: Privacy.  
 
3 VIDEO OR AUDIO NEWS RELEASES 
Increasingly, official bodies, commercial companies and campaigning organisations provide 
broadcasters with video or audio news releases or other material. Sometimes the material will 
have been recorded by the organisation itself, sometimes by others acting on their behalf. 
Such material may purport to cover stories from an objective standpoint, but is usually slanted 
to promote the viewpoint of the supplier. We do not normally use any extracts from such 
releases if we are capable of gathering the material ourselves. If we do use such material for 
sound editorial reasons we should always ensure that it is clearly labelled on air. 
  
The following points should also be borne in mind: 
  
• 
we should not normally use video or audio releases of news events or news conferences 
from which the BBC has been deliberately excluded by the organisers. If, in exceptional 
cases, such material is used, its source and status should be made clear on air, as should 
the fact that we were prevented from gathering it ourselves 
  
• 
we should not normally use any interviews or sound clips from such releases. When there 
are powerful reasons to do so the source of the material must be made clear on air 
  
• 
we must be wary of using a News Release to illustrate a story about the organisation 
which provided it, particularly if it gives an unrealistic or overly favourable impression of 
the organisation. We should normally use such material only to illustrate the way in 
which the company or organisation is promoting itself 
  
• 
sequences which include incidental music or commentary provided by the supplier 
should be used only to show how the company or organisation tries to portray itself 
  
• 
if we use any Video News Release material to illustrate a more general story, we must try 
to select shots which do not promote the supplier or their products. We should try to use 
it in conjunction with other illustrative material 
  
• 
we should not accept any editorial restrictions which the supplier places on use of the 
material. 
 
4 EMERGENCY ANNOUNCEMENTS 
Requests are sometimes received from British or foreign governments or from official bodies 
for the broadcast of emergency announcements. The BBC gives careful consideration to such 
requests in the light of the emergency in question. Local Radio should be especially ready to 
assist the police and other official bodies in informing the local community about serious 
 
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accidents and em
 
ergencies.  
  
4.1 Police SOS Messages 
From time to time, BBC Radio will broadcast police SOS messages. These messages must 
adhere to strict guidelines: reference should be made to the Head of Presentation, Radio.  
 
5 GOVERNMENT INFORMATION FILMS AND OFFICIAL MESSAGES 
The Central Office of Information makes films for broadcast on television. The BBC will 
broadcast only genuinely non-political public information under these arrangements. 
Broadcasting and Presentation decides which films will be broadcast and where they will be 
scheduled. 
  
There is provision for government departments to approach broadcasters to relay official 
messages or information films about issues which involve a degree of public or political 
controversy. Any such approach must be referred through Controller Editorial Policy and 
Chief Executives to the Director-General. Such material will normally be accepted only if the 
BBC is satisfied that the public interest requires this type of initiative and that the information 
can be conveyed in a manner consistent with the BBC's commitment to accurate, thorough 
and balanced treatment.  
 
CHAPTER 27 
ON- AIR REFERENCES TO BBC PRODUCTS, SERVICES AND PUBLICATIONS 
  
1 GENERAL 
2 TRAILS 
3 BBC MAGAZINES 
3.2 Mentions of magazines within programmes 
3.3 Events organised by BBC Magazines 
4 BBC MAGAZINES: REFERENCES ON RADIO AND ONLINE 
5 COMPETITIONS RUN IN ASSOCIATION WITH BBC MAGAZINES 
6 ON AIR REFERENCES TO OTHER BBC MERCHANDISE 
6.1 Local Radio Campaigns 
6.2 Online 
7 CEEFAX AND DIGITAL TEXT SERVICES 
8 REFERENCES TO BBC COMMERCIAL TELEVISION CHANNELS 
9 COMMERCIALLY FUNDED BBC ONLINE SITES 
 
1 INFORMATION FROM OUTSIDE SOURCES 
BBC programmes use a considerable amount of information supplied by others, including 
commercial and non-commercial organisations. Examples include weather reports, sports 
results, exchange rates, and pop charts. News bulletins also draw on information provided by 
reputable news agencies. 
  
Much of this information, including news agency copy, is paid for. However, when it is 
provided free particular care has to be taken to ensure that the BBC does not promote the 
supplier. 
  
Care should also be taken that the supplier of the information does not make improper use of 
its relationship with the BBC for promotional purposes. The BBC must have right of approval 
over any use of the BBC’s name in the supplier’s promotional material. 
  
1.1 Varying the sources of outside information 
 
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In som
 
e cases we rely on a single source for a particular type of information. For example a 
programme might include financial information supplied by a particular bank. Where 
practicable we should vary the source of such information over time if there are other 
suppliers which are equally reliable. 
  
However, in the case of information supplied by official departments or local authorities, it 
may not be necessary to vary the source, even if equally accurate information is available 
elsewhere.  
  
1.2 Crediting outside information 
It is often appropriate to state the source of outside information for sound editorial reasons: 
  
• 
to enable the viewer or listener to assess its authority, or accuracy. For example we would 
name organisations which have conducted opinion polls or we would say that we have 
obtained weather information from the Met Office 
  
• 
to indicate that this is information which is unique to one supplier and cannot be obtained 
elsewhere 
  
• 
to make it clear that the BBC has not verified the information. We might name a news 
agency as a source if we were relying solely on a report from one agency. 
  
The decision on whether to mention the source or to give a formal credit, such as a caption or 
an announcement, must be made on editorial grounds. We must not accept information free or 
at reduced cost in return for providing on air or off air publicity to the supplier. All references 
to the suppliers of information must be brieffactual and non promotional. There must be no 
element of plugging. No logo of an information provider should appear in any visual credit. 
Television producers should also refer to BBC Television guidelines for opening and closing 
screen credits. 
  
There may be occasions when the BBC decides to enter into a formal contractual agreement 
with an information supplier. This agreement may include a provision that the BBC will 
reflect the source of the information. Any formal agreement about credits should be made for 
editorial rather than commercial reasons. Arrangements of this kind should be made only with 
the approval of the relevant Director or Chief Executive. 
  
(See also Chapter 25: Product Prominence and Use of Free or Reduced Cost Facilities)  
  
1.3 Crediting a recognised library, archive or research institute 
Occasionally it may be appropriate to credit outside institutions, such as libraries, which have 
provided information or considerable research assistance. Decisions about credits should be 
separate from any financial arrangements.  
  
1.4 Computer credits in sports coverage 
Guidelines have been agreed among members of the European Broadcasting Union for credits 
given to companies which provide timing or computer-based services for sports coverage (see 
also Chapter 28 Covering Outside Events).  
  
2 RECORDINGS SUPPLIED BY OTHERS 
 
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Many BBC program
 
mes use pictures or sound recorded and provided by other organisations 
or individuals. We cannot always vouch for the circumstances under which such material was 
recorded so we should take particular care in how we use it. 
  
In many cases material is supplied by other reputable broadcasters or agencies on a 
contractual or reciprocal basis. If it is provided by people who may have a personal or 
professional interest in its subject matter we must be certain we are using it for the best 
editorial reasons and avoid giving the impression that we endorse a product, organisation or 
cause. In general material supplied by interested parties should be labelled to make its 
provenance clear. 
  
Programme makers should assess the overall editorial value of such material rather than 
simply its pictorial impact. Video from the emergency services may raise serious issues of 
privacy and intrusion - for instance where victims or patients are concerned. 
  
Programme makers may be asked to sign contracts before being given such material, and they 
may contain unacceptable editorial restrictions. Seek advice through Heads of Department, 
from Editorial Policy and Programme Legal Advice before agreeing. 
  
For guidance on use of CCTV footage see section 6 of Chapter 4: Privacy.  
 
3 VIDEO OR AUDIO NEWS RELEASES 
Increasingly, official bodies, commercial companies and campaigning organisations provide 
broadcasters with video or audio news releases or other material. Sometimes the material will 
have been recorded by the organisation itself, sometimes by others acting on their behalf. 
Such material may purport to cover stories from an objective standpoint, but is usually slanted 
to promote the viewpoint of the supplier. We do not normally use any extracts from such 
releases if we are capable of gathering the material ourselves. If we do use such material for 
sound editorial reasons we should always ensure that it is clearly labelled on air. 
  
The following points should also be borne in mind: 
  
• 
we should not normally use video or audio releases of news events or news conferences 
from which the BBC has been deliberately excluded by the organisers. If, in exceptional 
cases, such material is used, its source and status should be made clear on air, as should 
the fact that we were prevented from gathering it ourselves 
  
• 
we should not normally use any interviews or sound clips from such releases. When there 
are powerful reasons to do so the source of the material must be made clear on air 
  
• 
we must be wary of using a News Release to illustrate a story about the organisation 
which provided it, particularly if it gives an unrealistic or overly favourable impression of 
the organisation. We should normally use such material only to illustrate the way in 
which the company or organisation is promoting itself 
  
• 
sequences which include incidental music or commentary provided by the supplier 
should be used only to show how the company or organisation tries to portray itself 
  
 
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•  
if we use any Video News Release material to illustrate a more general story, we must try 
to select shots which do not promote the supplier or their products. We should try to use 
it in conjunction with other illustrative material 
  
• 
we should not accept any editorial restrictions which the supplier places on use of the 
material. 
 
4 EMERGENCY ANNOUNCEMENTS 
Requests are sometimes received from British or foreign governments or from official bodies 
for the broadcast of emergency announcements. The BBC gives careful consideration to such 
requests in the light of the emergency in question. Local Radio should be especially ready to 
assist the police and other official bodies in informing the local community about serious 
accidents and emergencies.  
  
4.1 Police SOS Messages 
From time to time, BBC Radio will broadcast police SOS messages. These messages must 
adhere to strict guidelines: reference should be made to the Head of Presentation, Radio.  
 
5 GOVERNMENT INFORMATION FILMS AND OFFICIAL MESSAGES 
The Central Office of Information makes films for broadcast on television. The BBC will 
broadcast only genuinely non-political public information under these arrangements. 
Broadcasting and Presentation decides which films will be broadcast and where they will be 
scheduled. 
  
There is provision for government departments to approach broadcasters to relay official 
messages or information films about issues which involve a degree of public or political 
controversy. Any such approach must be referred through Controller Editorial Policy and 
Chief Executives to the Director-General. Such material will normally be accepted only if the 
BBC is satisfied that the public interest requires this type of initiative and that the information 
can be conveyed in a manner consistent with the BBC's commitment to accurate, thorough 
and balanced treatment.  
 
CHAPTER 28 
COVERING OUTSIDE EVENTS 
  

1 GENERAL 
2 COVERAGE OF SPONSORED EVENTS 
2.1 Titles 
2.2 Placards carrying the name, logo, or slogans of the sponsor 
2.3 On-air credits for sponsors of events 
2.4 Presentations 
2.5 Credits for sports events 
2.6 Tobacco Sponsorship 
2.7 Events organised by outside organisations and sponsored by BBC Magazines 
3 ADVERTISING AT OUTSIDE EVENTS 
4 ADVERTISEMENTS ON CLOTHING AND BACKDROPS 
5 RELATIONS WITH EVENT ORGANISERS 
6 PROMOTION OF NON-BBC EVENTS 
7 BBC ORGANISED EVENTS 
7.1 Performance Based BBC Events 
7.2 Detailed Provisions for Organising Co-sponsored BBC Events or Exhibitions 
7.3 Promotions by event sponsors 
7.4 Joint debates and forums 
 
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7.5 Coverage of events or
 
ganised by BBC Magazines 
7.6 Programme related events 
8 ON AIR PUBLICITY FOR OUTSIDE EVENTS 
 
1 GENERAL 
The BBC covers a wide range of outside public events, such as sporting events and concerts. 
All programme and broadcasting costs for coverage of any event must be borne by the BBC 
or shared with other broadcasters. 
  
The event organiser may pay for all costs associated with the mounting of the event, including 
performance rights and fees. The costs for mounting the event may be defrayed by 
sponsorship but sponsors and event organisers must not pay for any programme costs. The 
BBC can take no money from a sponsor or organiser for coverage of an outside event. 
  
The BBC has a tradition of mounting public events in the arts and mounting events associated 
with programmes. For guidance see section 7 below. 
  
2 COVERAGE OF SPONSORED EVENTS 
When covering sponsored events, programme makers should ascertain whether the event is 
free-standing. Events we cover should not be created by a sponsor merely to attract broadcast 
coverage. The BBC should not allow its coverage to be used as a vehicle for the sponsors’ 
goods, services or opinions. Producers must never agree to display or mention the sponsor’s 
goods or services. 
  
The BBC’s contract for the broadcasting of all outside sponsored events should be with the 
event organiser or the organiser’s nominee, not with the sponsor.  
  
2.1 Titles 
The incorporation of the sponsor’s name into the title of some sporting events has become 
established, but the BBC does not necessarily use the sponsor’s name in the title of the 
programme covering the event. Sponsors’ names are not as frequently incorporated into the 
titles of artistic events and their use in programme titles may be inappropriate.  
 
2.2 Placards carrying the name, logo, or slogans of the sponsor 
Sponsor banners or placards are established features of sporting events, and reflections of 
sponsor messages painted on the pitch are also now being frequently used. Sponsor messages 
should not be so prominent that they distract from the action of the event and they should not 
be placed between the viewer and the action. The number and type of banners acceptable will 
depend on the event and the size of the venue. Detailed guidance can be obtained from the 
Head of BBC Sport, the Controller Television Sport or the relevant National Controller. 
  
Banners and prominent sponsor messages are not common in the more formal environment of 
theatres or concert halls and are unlikely to be appropriate during the coverage of arts events, 
such as concerts or recitals. 
  
In covering an awards ceremony, some discreet signage for the sponsor may be acceptable, 
but all reasonable efforts must be taken to ensure that it is not to be included in the main 
shots. When covering such award ceremonies producers should refer to their Head of 
Department, who would normally consult Chief Adviser, Editorial Policy (Multimedia and 
Commercial).  
  
 
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2.3
   On-air credits for sponsors of events 
The BBC seeks to credit fairly the enabling role played by event sponsors. It is essential that 
any credits make it clear that it is the event that has been sponsored and not the programme. 
All decisions on credits rest with the BBC. Normally only the prime sponsor will be credited, 
but there are some occasions when more than one sponsor may be acknowledged. Crediting 
more than two sponsors should be avoided. 
  
There should normally be a maximum of two verbal credits for the overall event sponsor and 
they should be delivered in a non-promotional style. When coverage lasts for many hours, the 
Head of Department will decide on appropriate verbal credits. 
  
On television there may also be a single visual reference in end credits. The event sponsor’s 
logo should not be used. Written credits must appear in the same style and type as other 
programme credits. Credits should always be agreed with the Head of the Department 
responsible for coverage. 
  
When covering events outside the sports area, television producers should refer through their 
Head of Department before making any commitments concerning credits.  
  
2.4 Presentations  
The presentation of an award by someone associated with the sponsor is an accepted part of 
many sporting competitions and artistic award ceremonies. The BBC should endeavour as far 
as possible to limit the number of sponsor references during such presentations. Normally 
there should be only one mention of the sponsor in the introduction to the presentation and if 
possible the person presenting the award should be asked to restrict themselves to a single 
reference to the sponsor. If the design of the award or trophy itself prominently reflects the 
sponsor’s name, slogans or logo care should be taken to ensure that it does not dominate main 
shots.  
  
2.5 Credits for sports events 
Television Coverage 
As the sponsor’s name is often reflected visually at a sports ground, a written end credit is not 
usually given for sports coverage. However, if a sponsor’s name is incorporated into the title 
of a sports event, it is acceptable to include the name of the sponsor on the scorecard or 
results information. 
  
The suitability of credits will vary according to the type and duration of the event. Some 
major international sporting events may require specific types of credits. Advice may be 
obtained from the Head of BBC Sport or the Controller Television Sport. 
  
Television News 
Event sponsors should be mentioned only for sound editorial reasons. Detailed guidelines for 
sports events are available from the Sports News Organiser, Television News. 
  
Radio Credits 
Detailed guidelines have been drawn up for sponsor credits for sports coverage on Network 
Radio and for mentions of sponsors in news bulletins. These guidelines are available from the 
Managing Editor, BBC Sport. 
  
Computer Credits 
 
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Guidelines have been agreed am
 
ong members of the European Broadcasting Union for 
broadcasting credits to be given to companies which provide timing or computer-based 
services for sports coverage. Both radio and television editors should take care to restrict 
these credits as far as is reasonably possible within the terms of the relevant agreements.  
  
2.6 Tobacco Sponsorship 
A number of major sports events are sponsored by tobacco companies. Particular care must be 
taken in the coverage of such events. 
  
Coverage of tobacco sponsored sports events in the United Kingdom is subject to official 
regulation. However, the BBC has its own more stringent restrictions on coverage of sport 
sponsored by tobacco companies in the UK and retains the right to impose further conditions. 
The BBC will not sign new contracts to cover tobacco-sponsored sports or other tobacco 
sponsored events which it has not previously covered. 
  
Programme makers wishing to cover a sports event which attracts a significant degree of 
tobacco sponsorship should consult Head of BBC Sport or Controller Television Sport about 
any further BBC restrictions. 
  
Stills in News and Current Affairs Programmes 
When selecting stills, care should be taken to try to minimise tobacco images. For example, 
when selecting stills of Formula One racing drivers to illustrate a general point, if possible 
pictures should be used from races in countries where cars and drivers’ clothing are not 
permitted to carry tobacco sponsors’ names. 
  
Non-Sporting Events Sponsored by Tobacco Manufacturers 
Tobacco sponsorship is less frequent for arts events decisions about coverage are made on an 
individual basis. Any proposed coverage of a non-sporting tobacco sponsored event should be 
referred to the Head of Department and the relevant Controller. Advice should also be sought 
from Chief Adviser (Multimedia and Commercial) Editorial Policy. 
  
Events sponsored by tobacco related brands 
Some tobacco brand names, have been used for non – tobacco products. Any proposal to 
mount coverage of an event sponsored by a tobacco related brand should be referred to 
the Chief Adviser Editorial Policy (Multimedia and
 Commercial).  
  
2.7 Events organised by outside organisations and sponsored by BBC Magazines 
There are particular restrictions on references on television to BBC magazines. 
  
In exceptional circumstances a BBC magazine may sponsor an established outside event 
mounted by a non - BBC organisation. In such circumstances it may be possible to mention 
the magazine’s role as sponsor but any coverage must not give more prominence to the BBC 
magazine than that given to other sponsors of similar events (see sections 2.2 – 2.5 above). 
Since the BBC must ensure compliance with its undertaking to the OFT, Chief Adviser 
Editorial Policy (Multimedia and Commercial) must be consulted about any such 
sponsorship at a very early stage before any commitment is made. Reference should also 
be made to Chief Adviser about proposals for sponsorship by any other type of BBC 
commercial publication or service.
 
  
 
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For guidance on coverage of an event which has been directly staged by a BBC m
 
agazine see 
section 7.3 below.  
  
3 ADVERTISING AT OUTSIDE EVENTS 
There are often advertising boards at outdoor events. In negotiating contracts with event 
organisers the BBC must stress that it does not wish coverage of sport or any other event to be 
used as a vehicle for advertising. Advertising of a party political nature is unacceptable at any 
event covered by the BBC, and this should be made clear to events organisers. 
  
Producers responsible for coverage should make every effort to ensure that the advertising 
does not interfere with the action of the event. Cameras should follow the action and not 
dwell on any perimeter or billboard advertisements 
  
Advertisements painted onto the pitch can severely interfere with the viewing of the event, 
where ever possible cameras should not dwell on them (see also 2.2 above). In negotiating 
contracts with event organisers, the BBC should seek to restrict any such advertisement. 
  
Further advice may be obtained from the relevant Head of Department, Controller Television 
Sport or the relevant Controller. 
  
4 ADVERTISEMENTS ON CLOTHING AND BACKDROPS 
Sponsorship now forms such an integral part of sport that in some cases it is impossible to 
avoid showing some reflection of sponsors on clothing or on backdrops at press facilities. 
  
However, the BBC should try to avoid giving undue prominence to sponsors’ or advertisers 
signage. Close-ups of advertisements on the clothing of participants should be avoided where 
at all possible.  
  
5 RELATIONS WITH EVENT ORGANISERS 
Even when events are not sponsored, the BBC may need to take care to ensure that coverage 
does not unduly promote the event organiser. For example events organised by pressure 
groups or charities should be treated carefully. 
  
There must be no suggestion that BBC coverage of the event is an endorsement of one charity 
over another. BBC coverage should not be used as a method of direct fundraising except for 
BBC nominated appeals such as Children in Need and Comic Relief. The BBC reserves the 
right not to include the name of a charity in the title of the broadcast programme. Any such 
proposal should be referred to the Department Head and the Charity Appeals Secretary, 
advice may also be sought from Chief Adviser, Editorial Policy (Multimedia and 
Commercial). See also Chapter 30: Social Action Programming, Campaigning Groups and 
Charities.  
  
6 PROMOTION OF NON-BBC EVENTS 
Sponsors or events organisers may run promotions or advertising campaigns to publicise an 
event which the BBC is covering. This may well give details of the BBC’s scheduled 
coverage. Such advertising should not exploit the BBC’s name in support of the event 
organiser or the sponsor. If this happens, the BBC may decide to withdraw from coverage.  
  
7 BBC ORGANISED EVENTS  
The BBC may be involved in staging several types of event. 
 
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These include events mounted primarily for programme coverage, such as concerts. In general 
these events are organised by production departments. 
  
The BBC may also be involved in staging events such as exhibitions which are a showcase 
for BBC brands. These events are usually mounted by BBC Worldwide. Even when these 
events or exhibitions are not covered by BBC broadcast services, they still need to conform to 
these guidelines. The event must properly reflect the values and editorial standards of the 
programme or service that it is promoting. If these events are mounted in conjunction with a 
BBC magazine it is essential that any coverage conforms to the BBC’s undertaking to the 
Office of Fair Trading (see section 7.5 below). 
  
See also the BBC’s Commercial Policy Guidelines sections 4.29-4.34.  
  
7.1 Performance Based BBC Events 
In its role as patron of the arts and of innovative and original entertainment, the BBC may 
wish to mount a range of freestanding musical, theatrical and other events. These freestanding 
performances are staged at outside venues with an audience. The BBC may also wish to 
broadcast coverage of these events. In some circumstances it is acceptable to supplement the 
cost of mounting the event, but only the event, with co-sponsorship from a suitable outside 
body. 
  
It is essential that money from the co- sponsor is used only to enhance the event itself and no 
sponsorship money may be used to pay for any broadcast coverage. Clearly separated 
accounts must be kept to show the distinction between event costs and broadcasting costs. No 
money from the co-sponsor may go into the programme budget. 
  
The contractual and commercial arrangements must not lead to any suggestion that the BBC’s 
broadcast programmes have been sponsored. 
  
It is essential that the choice of co-sponsor is appropriate. Any proposal for co-sponsorship 
should be agreed with the Head of Department in consultation with the Chief Adviser 
Editorial Policy (Multimedia and Commercial). See also detailed provisions in section 7.2 
below and section 2.3 concerning on air credits.  
  
7.2 Detailed Provisions for Organising Co-sponsored BBC Events or Exhibitions 
The following guidelines should be observed for the staging of any a BBC event or 
exhibition. They apply to all such events irrespective of whether they are likely to be covered 
on air by the BBC. 
  
• 
the BBC should not enter into a sponsorship arrangement with any partner whose 
commercial activities could call the suitability of the association into question 
  
• 
any commercial sponsorship should normally be associated with the company or 
organisation’s generic name or brand. We would not normally accept sponsorship 
directly tied to one specific product made by the sponsor 
  
• 
any organisation involved in organising or financing the event must be consistent with 
the overall values and reputation of the BBC and the choice of sponsor should not cast 
any doubt over the editorial integrity of any associated programme 
 
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• 
there should be no direct connection between the sponsor’s activities and the event theme 
or that of a related programme or service 
  
• 
there must be no suggestion either implicit or explicit, that the BBC or a BBC programme 
endorses any third party products or services 
  
• 
there must be clear separation between the sponsor’s brand and the BBC brand, sub brand 
or programme brand 
  
• 
it is not acceptable for the sponsor’s name, logo or slogan to appear in the title of the 
BBC event 
  
• 
any broadcast event held on BBC premises may not be sponsored 
  
• 
events connected with news or current affairs programmes may not be sponsored 
  
• 
events based on consumer advice programmes dealing with a range of topics may not be 
sponsored 
  
Any proposal for outside sponsorship of a BBC event should be referred well in advance 
to the Chief Adviser Editorial Policy (Multimedia and Commercial) who will advise on 
suitability of sponsors and appropriate arrangements.
 The Commercial Policy directorate 
representative should also be consulted for events involving BBC Worldwide.  
  
Arrangements and credits for sponsored events must be agreed with the Head of Department 
and all publicity material for the event must be approved by the BBC before it is published.  
  
7.3 Promotions by event sponsors 
Care must be taken to ensure that sponsors do not use their sponsorship to imply any BBC 
endorsement. While sponsors may wish to publicise the event the BBC must approve all such 
publicity material in advance. The material should always focus on the event rather than the 
sponsor’s involvement. There must be clear separation of brands and it must be clear that the 
BBC does not endorse the sponsor’s brand, product or service.  
  
7.4 Joint debates and forums 
Occasionally programmes may wish to organise an event such as a debate or forum in 
conjunction with an outside body. Such a debate or forum may be mounted with an academic, 
educational, professional or artistic institution. They should not be mounted in conjunction 
with a commercial organisation, though in exceptional circumstances for clear editorial 
reasons they may be mounted with a suitable publication. The choice of partners for the 
mounting of any such joint event should be referred to Editorial Policy and approved by the 
relevant Director of Television or Radio or equivalent. 
  
See also Chapter 24: Commercial Relationships and Appropriate Programme Funding. 
  
7.5 Coverage of events organised by BBC Magazines 
If programmes cover a BBC event which is mounted in conjunction with a BBC magazine, 
great care has to be taken to ensure that any coverage does not promote the magazine or could 
be deemed an encouragement to buy the magazine. Such an event must be covered only for 
 
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editorially robust reasons. References to the m
 
agazine should be avoided as far as possible 
and producers should avoid shots of magazine logos. Cameras should not dwell on any other 
symbols or words on display which clearly represent the magazine. Live coverage of events 
should be planned to advance to minimise the risk of incidental shots showing placards or 
symbols carrying magazine logos. 
  
Coverage of such events must comply with the OFT undertaking about promotion of 
BBC magazines and the Chief Adviser, Editorial Policy (Multimedia and Commercial) 
must be consulted about coverage in advance
 (see also Chapter 27: On-air References to 
BBC Products, Services and Publications). 
  
Careful consideration should be given to covering directly comparable events mounted by 
others to ensure that we are not giving preferential treatment to BBC commercial events.  
  
 
7.6 Programme related events 
BBC Worldwide may run events connected to individual BBC programmes. Programme 
producers should ensure that any on-air mention of the event is clearly editorially justifiable. 
While programmes may legitimately cover such BBC events and give details of them, such 
coverage should not put a BBC commercial event at an unfair advantage over a commercial 
rival.  
  
8 ON AIR PUBLICITY FOR OUTSIDE EVENTS 
Care must be taken when giving any information in programmes about events organised by 
the BBC or other bodies. Information should be editorially justified and non promotional. 
  
Continuity announcements will not normally carry information about events apart from giving 
details of the BBC’s on air coverage. However, some details may be given in continuity 
announcements about special public service events run by the BBC.  
 
CHAPTER 29 
ADVERTISING, PROMOTIONAL ACTIVITIES AND THE BBC BRAND 
  
1 GENERAL 
2 PROTECTING THE BBC’S BRANDS AND PROPERTIES FROM EXPLOITATION BY 
ADVERTISERS 
3 PROMOTIONAL ACTIVITIES UNDERTAKEN BY INDIVIDUALS ASSOCIATED WITH THE 
BBC 
3.1 Promotions undertaken by presenters, reporters or programme experts 
3.2 Promotional activities undertaken by artists 
3.3 Artists who perform as BBC owned characters in programmes 
3.4 Artists and producers who own rights to characters and formats in programmes 
broadcast by the BBC 
 
1 GENERAL 
The BBC needs to ensure that outside interests and commercial companies do not undermine 
its brand values of impartiality and integrity. It is therefore essential that no advertising or 
promotion by an outside company or organisation gives the impression of BBC endorsement 
of their product or service. 
  
 
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In m
 
any cases we can and should take action to prevent exploitation by advertisers of the 
BBC brand and BBC properties such as programme titles, formats and characters. In other 
cases careful judgements need to be made about how far we can restrict the activities of artists 
and performers. The lawyers in the BBC’s Intellectual Property department can advise on the 
BBC’s legal position in relation to any advertising. See also Chapter 4 of the Commercial 
Policy Guidelines. 
  
2 PROTECTING THE BBC’S BRANDS AND PROPERTIES FROM EXPLOITATION BY 
ADVERTISERS 
The BBC will not normally agree to its name, initials, logos, channel names, programme 
titles, formats or characters being used by commercial advertisers or in any promotions for 
outside organisations. 
  
Some very limited exceptions may be permitted for testimonials and point of sale material for 
goods or services used, tested or reviewed by the BBC (see BBC Commercial Policy 
Guidelines Chapter 4 sections 25 – 27). 
  
Any other proposed exceptions must be referred to Controller, Editorial Policy who will 
consult Chief Executive, BBC Broadcast.  
  
3 PROMOTIONAL ACTIVITIES UNDERTAKEN BY INDIVIDUALS ASSOCIATED WITH THE 
BBC 
Presenters, programme experts, actors and other artists who appear on BBC programmes may 
of course wish to undertake non-BBC advertising or promotional work. 
  
But the acceptability of this work to the BBC will depend the nature of the individual’s 
contribution to BBC programmes and the nature of the promotion. Heads of Department will 
initially make judgements about the acceptability of any promotional work in line with the 
principles set out in this chapter and the guidelines set out in Chapter 10: Conflicts of 
Interest. In cases of difficulty Editorial Policy and BBC Broadcast or BBC News 
management should be consulted. 
  
However if individuals do appear in promotions or adverts it is essential that they do not refer 
to the BBC or any BBC programmes in which they appear 
  
3.1 Promotions undertaken by presenters, reporters or programme experts 
Regular presenters or reporters in News must not associate themselves with the advertising, 
promotion or endorsement of any non BBC product, service or company. 
  
Presenters or reporters on other BBC programmes should not undertake advertising or 
promotional work associated with the subjects of any of the programmes in which they 
appear. 
  
Care should also be taken to ensure that expert contributors to programmes do not undertake 
promotional work that might give rise to doubts about their objectivity or compromise the 
programmes in which they appear. They may be able to endorse products that are not 
connected to the theme of their BBC programmes, but expert contributors who give consumer 
advice must under no circumstances advertise or endorse products in the area on which they 
give advice. 
  
 
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For further detailed guidance it is essential to consult section 5 and 6 of 
 
Chapter 10: Conflicts 
of Interest.  
  
3.2 Promotional activities undertaken by artists 
In certain cases the commercial value an artist can derive arises largely from the prominence 
achieved from their connection with BBC programmes. We must ensure that these 
associations are not exploited inappropriately. 
  
Some artists who appear in BBC programmes carry out advertising and promotional activities 
for non BBC products in addition to their BBC commitments. It is a fundamental requirement 
that such outside work must pose no risk to the BBC’s reputation. Such activities must not 
suggest BBC endorsement of outside organisations, products or services (see also Chapter 
10: Conflicts of Interest). 
  
Before contracting artists and experts there must be comprehensive and open discussions to 
establish what, if any, commercial work they are committed to, or are considering, to avert the 
risk of editorial compromise.  
  
3.3 Artists who perform as BBC owned characters in programmes 
Where the BBC owns the rights to characters, we ensure that the artists who play them do not 
undertake, in those roles, any advertising or promotional activity which may suggest an 
association between them, the BBC and the programmes in which they appear. The standard 
Equity contract stipulates that the artist should not appear in an advert or promotion which 
associates them with “their” character without the written permission of the BBC. 
  
However, we do not wish to prevent professional performers from carrying out commercial 
work outside their commitments to BBC programmes. It may therefore be acceptable for 
actors and professional performers to appear in promotions or advertisements for products or 
services providing they do not appear as ‘their’ BBC character and the advertisements or 
promotions do not replicate or reflect BBC programmes. Such work must not bring the BBC 
into disrepute and should not imply BBC endorsement.  
  
3.4 Artists and producers who own rights to characters and formats in programmes broadcast by the 
BBC 
In some cases, particularly in entertainment, the artists own the rights to characters they 
perform in programmes, or these rights are held by someone outside the BBC; independent 
production companies may also own the rights to characters and formats that are used for 
BBC programmes. Advertisers may seek to use such characters and formats in promotional 
campaigns and in such cases we would ask to be consulted. It should be clear that such 
commercial activities associated with these characters must exclude anything which might be 
harmful to the BBC or its reputation; for example, advertisements or promotions for tobacco. 
Similarly, we ask them to avoid involvement in any television advertisements at times which 
coincide with the broadcasts of the related BBC programmes. We may also feel it is 
appropriate to offer advice on proposed advertisement scripts. In the unlikely event of the 
unwillingness of an artist or producer to co-operate, this may make it more difficult to 
contract them in future.  
 
CHAPTER 30 
SOCIAL ACTION PROGRAMMING, CAMPAIGNING GROUPS AND CHARITIES 
  
 
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1 SOCIAL ACTION PROGRAMMING 
 
2 IMPARTIALITY AND SOCIAL ACTION PROGRAMMES 
3 CAMPAIGNING GROUPS 
4 CHARITIES AND CHARITABLE APPEALS 
4.1 Emergency Appeals 
4.2 Appeals Charter and the Charities Act 
4.3 Specific BBC Fundraising Projects 
4.4 Outside Fund Raising Events 
4.5 Joint Initiatives 
4.6 Programmes and Items about Charitable Work 
4.7 Fact Sheets and Further Information 
4.8 National and Regional Broadcasting 
4.9 Premium Rate Telephone Calls 
 
 
1 SOCIAL ACTION PROGRAMMING 
Social action programming differs from other programming in that it not only raises 
awareness of important social issues, but also encourages the audience to take action. Director 
Radio, Director Television, Director Education, the relevant National Controller or equivalent 
must approve plans for any social action initiative. 
  
Social action programming covers areas of social need such as health, social welfare and adult 
education. Producers need to be sure that they offer adequate back-up for such programmes 
(see Chapter 31: Support Services and Support Material). Further guidance on support 
services for Social Action programmes is available from the BBC’s Social Action Co-
ordinator or the Head of Learning Support, Education. 
  
2 IMPARTIALITY AND SOCIAL ACTION PROGRAMMES 
Such programmes require the utmost care and the BBC must always be seen to set its own 
social action agenda and decide on its own priorities. Social action programming may 
sometimes coincide with government campaigns but it is important that we maintain a proper 
arms length relationship with governments and individual politicians. The BBC must not be 
thought to be acting on behalf of the government in any area of possible controversy. Even 
when the cause is non controversial politicians may try to gain advantage through association 
with a BBC campaign and we must guard against this. In particular we must take care to 
ensure that politicians and lobbyists do not use BBC programme settings or brands for 
political advantage. 
  
Social action programming should maintain a sceptical approach to its subject matter and 
should ask awkward questions where appropriate. News and factual reporting of BBC social 
action campaigns needs to maintain clear objectivity.  
  
3 CAMPAIGNING GROUPS 
To protect the BBC’s independence and integrity we need to ensure that we do not get 
involved with campaigning programming which is politically contentious. Programmes 
should not embrace the agenda of a particular campaign or campaigning group and we need to 
take great care in all our programming that we treat campaigning groups objectively. Any 
proposal to mount programmes in association with a particular campaigning group must be 
referred well in advance to the Controller, Editorial Policy. 
  
In coverage of campaigning issues where there are several pressure groups or lobbying 
organisations we should be careful to remain even handed in our coverage of the range of 
 
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groups involved.  
 
  
4 CHARITIES AND CHARITABLE APPEALS 
The BBC broadcasts regular appeals for charitable causes on BBC Television and Radio 4. 
The responsibility for allocating these appeals rests with the BBC Governors and the BBC 
Appeals Advisory Committee (AAC). The AAC also advises on general policy matters 
relating to BBC appeals. 
  
The AAC is appointed by the Governors and consists of specialist external advisers who 
represent a broad range of interests across the charitable field. The AAC aims to spread 
appeals as widely and equitably as possible among suitable charities and makes 
recommendations to the Governors on the allocation of appeals. Detailed guidelines 
concerning the broadcast appeals are available from the Appeals Secretary. 
  
There are also charity appeals in Northern Ireland, Scotland and Wales which are allocated by 
Appeals Advisory Committees in the Nations (see section 4.8 below on National and 
Regional Broadcasting). 
  
When serious emergencies occur, there is a special approval procedure for any emergency 
broadcast appeal (see section 4.1 below on Emergency Appeals.) In addition the BBC is 
involved in specific fund-raising projects such as Children in Need and Comic Relief which 
are also subject to scrutiny by the AAC and the BBC Governors. BBC programmes made as 
part of such fund-raising projects should take care to avoid campaigning on controversial 
areas of public policy. 
  
Apart from these specific BBC wide fund-raising projects, programmes should not endorse 
particular charities or make any appeal for funds. It is important that programmes do not give 
any particular charity an advantage over others and do not distort the careful balance which 
the AAC seeks to achieve in regular appeals. The BBC should normally avoid programme 
proposals intended to promote charitable causes. See section 4.5 below on Joint Initiatives.  
  
4.1 Emergency Appeals 
The BBC may decide to broadcast a special appeal when a serious emergency occurs. 
Requests for emergency appeals must be made through the BBC Secretary. Such appeals need 
to be approved by the Chairman on behalf of the Board of Governors. Emergency appeals are 
usually also broadcast by other broadcasters. If the emergency is in the United Kingdom, a 
public fund must have been set up to meet the needs of the victims. Appeals for emergencies 
abroad are normally given on behalf of the United Kingdom Disasters Emergency Committee, 
which is composed of U.K. charities involved in overseas relief work. 
  
Any proposal to use a BBC journalist to present an international, national or regional 
emergency appeal must be considered with great care at a senior level to ensure that the 
objectivity of our journalism is not compromised.  
  
4.2 Appeals Charter and the Charities Act 
The BBC and ITV, together with others involved in broadcast appeals, have drawn up a 
charter of good practice for television and radio appeals. This takes account of the 
requirements of the Charities Act (1992). Copies of the charter can be obtained from 
Broadcasting Support Services. Local radio producers can obtain further specific guidelines 
from the Directorate Secretary, National and Regional Broadcasting. In Northern Ireland, 
 
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W
  ales and Scotland advice can be obtained from The Secretary.  
  
4.3 Specific BBC Fundraising Projects 
Separate guidelines exist for the BBC Children in Need appeal. Copies of the guidelines and 
further advice can be obtained from the Director, Children in Need and the relevant 
Directorate representative. In the Nations these guidelines are available from the Children in 
Need Trust National Co-ordinator. 
  
Advice on coverage of other BBC wide fundraising projects such as Red Nose Appeal should 
be sought from Editorial Policy.  
  
4.4 Outside Fund Raising Events 
Any proposal to give broadcast coverage to an outside fund-raising event, such as a major 
charity pop concert, must be notified to the Appeals Secretary at an early stage. In the 
Nations, The Secretary must be notified. The BBC may appear to be associated with the cause 
concerned and the implications may need to be discussed with the AAC or its Chair. 
Producers should also refer to Editorial Policy for advice on the nature of any on-air coverage 
(see also section 5 Relations with Event Organisers in Chapter 28: Covering Outside 
Events).  
  
4.5 Joint Initiatives 
There is a danger that the BBC’s balanced approach may be distorted by programmes 
launching campaigns or aligning themselves with specific charities. In exceptional 
circumstances directorates may decide to schedule programmes which are connected to a 
campaign, but the decision to schedule such programmes must be made at Director or Chief 
Executive level. A proper balance must be struck between competing charities and causes. 
Advice should be sought at an early stage from the Appeals Secretary or The Secretary in the 
Nations.  
  
4.6 Programmes and Items about Charitable Work 
None of the BBC’s news outlets, whether international, national or regional, should associate 
themselves with direct appeals on behalf of a charity. News programmes must be perceived as 
objective and should not be involved in any campaigning or fund- raising activity. The fact 
that an Emergency Appeal is to be broadcast may be judged newsworthy enough to be 
reported in a news programme, but the programme should not itself make or endorse the 
appeal. 
  
If a news report is likely to produce a large public response from people wishing to give 
donations, the BBC Information Office should be alerted so that it can provide the name and 
address of the charity concerned. 
  
Documentary or magazine programmes which feature a charity or charitable venture should 
take care to treat the subject objectively and must avoid any direct or indirect appeal for 
funds. Any discussion of the charity’s financial needs or targets must be justified strictly on 
editorial grounds. Care should be taken not to promote one charity when there are also others 
working in the same field. BBC dramas should also not appear to endorse any charity or 
charity appeal. 
  
 
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Program
 
mes concerned with a range of issues from medical problems to wildlife may also 
draw on the expertise of charities but they should draw on as wide a range of expertise as 
possible and not endorse any particular charity. 
  
On-air references to charities should be given only for clear editorial reasons. Addresses or 
telephone numbers should not normally be given. Any references to charities in programme 
credits should be cleared with the Appeals Secretary, or The Secretary in the Nations and 
where appropriate with Broadcasting and Presentation. 
  
If unsolicited donations are sent to the BBC as a result of a programme, they should be 
acknowledged and passed on to the appropriate charity, or if this is not feasible returned to 
the sender.  
  
4.7 Fact Sheets and Further Information 
Domestic Services 
If a fact sheet or literature is produced in association with a programme, we should not 
normally distribute it through any particular charity. Normally it should be distributed by the 
BBC. If any charity is mentioned on the fact sheet, all other significant organisations working 
in the field should also be listed. 
  
Advice on support material, helplines and other support activities which may involve charities 
can be obtained through Heads of Department from the Appeals Secretary or The Secretary in 
the Nations. See Chapter 31: Support Services and Support Material. 
  
A number of local radio stations organise back-up services in conjunction with Community 
Service Volunteers. Advice on suitable partnership arrangements with CSV can be obtained 
from National and Regional Broadcasting. 
  
BBC World Service and BBC Worldwide Television 
To enable efficient distribution abroad, fact sheets and support material for World Service 
Radio programmes and Worldwide Television programmes may be distributed via appropriate 
charities, non-governmental agencies or other international agencies. Advice on this should 
be sought from Directorate Secretary, World Service or Head of Programming, International 
Networks, BBC Worldwide.  
  
4.8 National and Regional Broadcasting 
The Nations have a number of scheduled appeals on television and radio for nationally and 
regionally based charities. Appeals Advisory Committees in Northern Ireland, Scotland and 
Wales allocate these appeals and scrutinise arrangements. The Secretary in each Nation is 
responsible for the administration of the relevant AAC. 
  
There must be no charity appeals in any national or regional news programmes on radio or 
television. From time to time other national and regional television or radio programmes may 
wish to be associated with a charitable initiative or emergency appeal which is of specific 
relevance to the Nation or Region. In the Nations, The Secretary should be consulted in 
advance. Any such proposal in the English regions should be notified in advance to National 
and Regional Broadcasting which will notify the Appeals Secretary. The Chair of the AAC 
may also be consulted. 
  
 
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Local radio stations are som
 
etimes involved with appeals and other initiatives connected with 
charities at a local level. This is part of their involvement in the community, but producers 
must take care to ensure that appeals are never broadcast as part of the news output of 
stations. The guidelines in this chapter apply to all such activities. There are also further 
specific guidelines for National and Regional Broadcasting. 
  
Local Radio Advisory Councils have been given formal responsibility by the Board of 
Governors to advise stations on appeals and in some cases charitable trusts have been 
established to handle appeals. However, any major appeal or charitable initiative planned by a 
local radio station must be notified to the Director National and Regional Broadcasting before 
it is undertaken. The Appeals Secretary and the Chair of the AAC will be consulted if 
necessary.  
  
4.9 Premium Rate Telephone Calls 
Normally the BBC avoids using premium rate telephone lines in connection with any fund-
raising activity with which it is directly involved. However, there may be occasions when 
programmes using premium rate calls for votes or competitions may wish to donate any net 
revenue to charity. Such donations are controlled by the Charities Act 1992. Heads of 
Department should consult Editorial Policy about the suitability of any arrangements. (For 
more advice on premium telephone lines, see Chapter 32: Phone-ins and the Use of 
Telephone Services in Programmes)  
 
CHAPTER 31 
PROGRAMME SUPPORT SERVICES AND SUPPORT MATERIAL 
  
1 GENERAL 
2 COPING WITH DEMAND 
3 HELPLINES AND BBC AUDIENCE LINES 
3.1 Audience Feedback and Confidentiality 
4 AUTOMATED INFORMATION SERVICES 
5 FACTSHEETS AND BOOKLETS 
6 FUNDING FOR SUPPORT SERVICES 
7 OUTSIDE FUNDING FOR PROGRAMME SUPPORT SERVICES 
8 CREDITS FOR SUPPORT MATERIAL 
9 JOINT INITIATIVES 
10 DISTRIBUTION OF SUPPORT MATERIAL 
11 TRAILS 
12 ONLINE SERVICES 
13 ITC REGULATED SERVICES 
 
1 GENERAL 
The BBC offers a range of off-air support services for its programmes. These give viewers 
and listeners the opportunity to extend their knowledge, enjoyment and understanding of BBC 
programmes and offer advice and support to them in dealing with issues raised in our output. 
  
The range of support services available includes fact sheets, helplines, information lines, 
booklets, audiotapes and videos, information on Ceefax, CD Roms, information on the 
Internet and off-air events such as roadshows. 
  
Support services may be offered free or on a cost recovery basis. They must not be designed 
to make a profit. Any publication or service designed to make a profit is a commercial venture 
and is subject to the BBC’s Commercial Policy Guidelines. 
 
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Though support services provide a useful backup, it is important to remember that only a 
small proportion of the audience takes advantage of such services. Producers should ensure 
that the programmes are meaningful and enjoyable by themselves. Producers must avoid 
getting involved in the provision of support services which are not directly linked to particular 
programmes. 
  
BBC support services should not promote any particular agency, charity or organisation and 
they should not carry advertisements for any merchandise supplied by any organisation or 
company. Where possible we should give details of the range of agencies which may offer 
help or advice. If information is given about products we should give a range of comparable 
products and not promote any manufacturer or supplier. 
  
2 COPING WITH DEMAND 
Support services should only be offered if we are confident that we can cope with the likely 
demand – whether in print, on the phone or via e-mail. This is particularly important if we 
offer a telephone helpline after a sensitive programme. There must be sufficient telephone 
capacity and a sufficient number of trained staff or trained volunteers to offer a high quality 
service to viewers or listeners. Early planning is vital.  
  
3 HELPLINES AND BBC AUDIENCE LINES 
A telephone helpline staffed by trained people can provide information or support concerning 
issues raised by BBC programmes or it may refer callers to suitable advice agencies. When a 
programme has dealt with distressing issues, helpline staff can provide support or advice on 
obtaining counselling. In other cases a helpline may offer factual information about the issues 
discussed in the programme and give advice on where further information can be obtained. It 
is essential that all the information provided is impartial and objective and gives details of a 
wide range of agencies, charities and statutory organisations. No agency should be promoted 
at the expense of others. 
  
BBC Audience Lines provides helplines and action lines for Radio, National and Regional 
Broadcasting and Learning Support. Other areas may use BBC Audience Lines or other 
service providers. Care must be taken to ensure that any outside agency which runs a helpline 
is capable of providing an objective, high quality service. Heads of Department should seek 
advice from the Head of Learning Support or Editorial Policy. 
  
We do not generally trail helplines run by charities or pressure groups though it may be 
appropriate to do so in cases where one group, such as The Samaritans, offers a particular 
service. Any proposal to trail a helpline provided by an outside organisation or charity should 
be referred to Editorial Policy. 
  
Helplines are usually offered on freephone numbers. Premium rate lines must never be 
used for helplines. 
  
Programmes should consider well in advance if helplines will be needed and budget 
accordingly. The use of lines should be discussed with the Head of Learning Support or the 
Audience Lines manager (see also Chapter 32: Phone Ins and Telephone Services in 
Programmes).  
  
3.1 Audience Feedback and Confidentiality 
 
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Take-up of support services such as helplines can help the BBC to get a better picture of the 
 
needs, interests and concerns of viewers and listeners. However, there are issues concerning 
confidentiality if we publicise comments from particular callers or distribute details about 
them widely within the BBC. 
  
In some cases callers are eager to tell their stories and are keen for them to be developed into 
programme items. But it is essential that we make it clear on what terms we are gathering 
information from people. Callers who voluntarily “opt-in” to give their story to the BBC 
should know what to expect. 
  
Those organising helplines may alert programmes or programme areas to stories but they 
should never distribute callers’ names or telephone numbers generally throughout the BBC. 
Programme makers, who are interested in the story , will be required to ring Audience Lines 
or any other provider of the service to obtain any personal details.  
  
4 AUTOMATED INFORMATION SERVICES 
Programmes may from time to time wish to offer “dial and listen” information services. The 
recorded message must be simple, factual and non-promotional and directly relevant to the 
programme. The duration of calls should be kept to a minimum. For strong public service 
reasons, such lines may sometimes give information about goods or products featured on a 
programme, but they must not promote any commercial product, retailer or supplier. Details 
of how to obtain merchandise should be given only if the merchandise is not widely available. 
Information lines must never be used as a means of selling BBC commercial merchandise or 
any other commercial merchandise. 
  
A range of telephone call rates is available including national call rates and local rates. 
Premium rate lines should not be used for information lines associated with social action 
programmes or for programmes concerned with education or welfare issues. Further advice is 
available from BBC Audience Lines. See also Chapter 32: Phone Ins and the Telephone 
Services in Programmes.  
  
5 FACTSHEETS AND BOOKLETS 
When the BBC produces fact sheets or booklets, they should offer accurate and objective 
information, which does not promote any particular agency, charity or other organisation. 
Where possible, they should give details of a range of agencies which may be able to offer 
help or advice. If fact sheets accompany consumer programmes all details must be given in a 
non-promotional manner. We should aim to include a range of comparable products.  
  
6 FUNDING FOR SUPPORT SERVICES 
Careful judgements need to be made as to whether support services should be free or charged 
on a cost recovery basis. If programmes wish to offer such services free, consideration must 
be given as to whether it is justified to use licence fee or Grant-in- Aid funds or whether 
financial support should be sought from outside organisations. Support services paid for 
principally by the Licence Fee or Grant- in- Aid must offer a genuine educational, social, 
cultural or other public service benefit to the target audience. 
  
If it is decided to charge on a cost recovery basis for support services or support material, 
advice should be sought from the Directorate Commercial Policy representative (see also the 
BBC’s Commercial Policy Guidelines).  
  
 
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7 OUTSIDE FUNDING FOR PROGRAMME SUPPORT SERVICES 
 
Seeking funds for support services from an outside organisation may enable programmes to 
offer support services free or at a reduced cost to the licence payer. However, the BBC must 
not accept funding from any individual or organisation whose interests or commercial 
activities could lead to doubt about the objectivity of the programme or the support service. 
Support services for news, current affairs or consumer advice programmes should not 
normally receive any funding from outside organisations. 
  
Funds for support services may be sought from government departments, agencies, publicly 
funded bodies, charities, professional associations, certain trade associations and independent 
trusts. Acceptance of funds from commercial bodies must be treated with great caution. No 
support material may be used to promote any outside body. 
  
If outside funding is agreed, editorial responsibility for the support material must rest entirely 
with the BBC.  
  
8 CREDITS FOR SUPPORT MATERIAL 
There should be no on-air credits for the outside funding organisation and no credit on any 
telephone line. However, print material may carry a discreet credit. If telephone support lines 
are sponsored, the sponsor should not normally be credited, unless there is a particularly 
strong editorial reason to do so. Advice may be sought from Editorial Policy. For ITC 
regulated services including BBC KNOWLEDGE see section 13.  
  
9 JOINT INITIATIVES 
Where particular expertise is required, the BBC may wish to offer support material or support 
services in conjunction with an appropriate outside body which is well respected in the field, 
such as a charity or educational institution. The BBC must remain editorially responsible for 
the broadcast programme. 
  
But if there is joint editorial responsibility for the support material or support service, the 
outside body may be credited on print material. The body should only be mentioned on air if 
there are sound editorial reasons for an on-air reference (see also section 10 below on 
distribution of support material). 
  
Sometimes we may wish to offer as support material a leaflet or booklet produced entirely by 
a reputable charity or agency, or a helpline may be provided by a reputable outside agency 
(see section 3 above). In such cases there may be strong editorial reasons for stating on air 
which body is responsible for the support material or helpline. Heads of Department can seek 
advice on this from the Head of Learning Support or Editorial Policy. 
  
If we distribute material produced by others we must ensure that we are not unduly promoting 
any particular charity or agency when there are other comparable organisations working in the 
same field. We must not distribute material which contains appeals for money. The only 
exceptions to this rule are in connection with approved BBC charity appeals broadcasts or 
recognised BBC charity campaigns such as Children in Need.  
  
10 DISTRIBUTION OF SUPPORT MATERIAL 
Support material is normally distributed by programmes or through Learning Support. Some 
Local Radio stations work in partnership with local voluntary organisations to produce and 
distribute support material. In addition, programmes may also wish to distribute tapes or 
 
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booklets, produced by the BBC, via publications or m
 
agazines. In such cases we should take 
care that the publication is editorially appropriate. Editorial Policy should be consulted on 
suitable partnership arrangements. The BBC should approve all promotional material which 
includes any reference to the tape or booklet. We should choose publications which are 
available from a range of outlets so as to avoid any suggestion of BBC endorsement of a 
particular retailer. It is essential that we do not refer on air to any publication or retailer 
involved in the distribution of the material. This restriction applies to BBC publications as 
well as to publications published by others. See also Chapter 26: On Air References to BBC 
Products, Publications and Services. 
  
If support material is available as a “give away” with a publication, it must also be available 
elsewhere. Viewers and listeners, who contact the BBC to obtain the material, should not be 
asked to pay more than they would pay if they bought the magazine. 
  
See section 4.2 of Chapter 32: Phone-Ins and the Use of Telephone Services in 
Programmes for advice about the use of premium rate calls for the distribution of support 
material.  
  
11 TRAILS 
Support services and back-up material may be trailed within programmes and in continuity 
announcements providing the material or service is free or provided on a cost recovery basis. 
  
On television, all information concerning support services should be included within 
programmes or their closing credits, if possible. Mentions of support services within 
continuity announcements are at the discretion of Broadcasting and Presentation. If a 
programme considers it necessary to trail a helpline in a continuity announcement, 
Broadcasting and Presentation should be warned at the earliest opportunity. 
  
It may be useful to say within a programme that details about support material or a support 
service will be given at the end of the programme to allow viewers or listeners time to find a 
pen. 
  
Trails for any BBC back-up material designed to make a profit are subject to very tight rules. 
Such material cannot be trailed within television programmes and trails in continuity 
announcements are subject to tight restrictions (see Chapter 26: On Air References to BBC 
Products, Services and Publications).  
  
12 ONLINE SERVICES 
It may be appropriate to provide support services online via the Internet if this is a suitable 
method of reaching the relevant target audience. Support material should appear on the 
BBC’s publicly funded Internet pages, not on any commercially funded pages. The standards, 
which apply to the BBC’s broadcast services, apply also to BBC material on the Internet. See 
the BBC ONLINE Guidelines for detailed advice.  
  
13 ITC REGULATED SERVICES 
The ITC Code of Programme Sponsorship requires on-air sponsor credits for support 
material. The following BBC guidance for our commercial television services also applies. 
There may only be a discreet written credit in the same font as any other text displayed. 
Logos may not be used. There should be no verbal credit. There should be no reference to the 
 
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outside funders of support m
 
aterial within the programme and it should be clear that it is only 
the support material and not the programme that has outside funding. 
  
BBC KNOWLEDGE is a special case. It is temporarily on a commercial multiplex and 
therefore needs to be treated equally, in regulatory terms, with others on that multiplex, 
notwithstanding that it is a BBC public service channel. While this service stays on the 
commercial multiplex, on air credits for sponsors of support material should be consistent 
with ITC rules on such credits for its commercial services.  
 
CHAPTER 32 
PHONE-INS AND THE USE OF TELEPHONE SERVICES IN PROGRAMMES 
  
1 GENERAL 
2 PHONE-INS 
3 WHICH TYPE OF CALL TO USE 
4 PREMIUM RATE TELEPHONE NUMBERS 
4.1 General 
4.2 Financial and Technical Requirements 
4.3 Paying for Support Material via Premium Rate Calls 
4.4 Price Messages and Call Cut Offs 
4.5 Children’s Services 
4.6 Phone Services and Competitions 
4.7 Voting by Phone 
4.8 Donations to Charity and Charity Appeals 
4.9 Services not controlled by the BBC 
5 EVENT INFORMATION LINES 
5.1 Event Information Lines Provided by the BBC 
 
1 GENERAL 
Telephone services can be used to enhance programmes by allowing the public to give their 
point of view or to interact directly with programmes. Both Factual and Entertainment 
programmes use telephone lines in a wide variety of ways in order to provide individual 
contributions to programmes or to get an immediate mass response from thousands or even 
millions of people. 
  
Telephone information lines can provide useful back-up information for the audience and 
helplines offer advice and support (see also Chapter 31: Support Services and Support 
Material). 
  
2 PHONE-INS 
Phone-ins play an important role in BBC programming. They allow the public direct access to 
air their own views and to question politicians and other public figures. 
  
BBC phone-ins are generally live in order to provide genuine spontaneity. This means that 
producers must constantly be alert to the possibility of callers breaking the law or causing 
widespread offence in matters of taste, decency or language. To minimise the risks involved, 
potential contributors should be called back and should not normally be put straight on the air. 
  
Producers should ensure that presenters are properly briefed on the law and BBC guidelines, 
and are able to extricate the programme from a difficult situation with speed and courtesy. 
When the subject matter of a phone-in programme leads a producer to anticipate particular 
problems, callers, as well as presenters, should be briefed before they go on air. 
 
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Presenters and producers should also be aware that the law might differ in different parts of 
the United Kingdom (see Chapter 19: Reporting the United Kingdom).  
  
3 WHICH TYPE OF CALL TO USE 
Programme makers will normally use local rates for local and regional programme phone-ins 
and the national rate for UK wide phone ins. In some cases local calls rates may be used for 
calls from all over the UK, but the cost of this to the BBC needs to be justifiable. 
  
The freephone rate is appropriate for helplines or where the BBC is offering an essential 
service. It may also be used then the caller is being asked to help the BBC on some way. 
  
Premium rate calls are used for a variety of reasons and are subject to detailed guidelines 
below. Premium rate lines should never be used for phone-in discussion programmes or 
helplines. 
  
It may be advisable to state on air what sort of rate is being used. 
Programmes must always specify when a premium rate line is being used (see section 
4.3 below).  
 
4 PREMIUM RATE TELEPHONE NUMBERS 
  
4.1 General 
Using premium rate telephone numbers may sometimes be the only way to offer certain 
services to programmes as these numbers enable large volumes of calls to be handled. Using 
premium numbers may be the only viable way to register mass audience reaction quickly, as 
with voting for the Eurovision Song Contest. As premium rate numbers can sometimes 
generate profits, it is particularly important that we only use them for clear editorial 
objectives and that the cost to the public is kept a minimum. 
  
When using premium rate telephone numbers, such as those beginning 0891, programme-
makers should remember: 
  
• 
licence fee payers should be able to get enjoyment from a programme without being 
encouraged to pay more by making a premium rate call 
  
• 
before a premium rate line is provided, production staff should have established that a 
similar service cannot be provided on a non-premium rate service 
  
• 
durations should be kept to a minimum. Most calls should last no more than a minute; in 
many cases they will be shorter. We should not encourage people to ring back or ring 
another premium rate number 
  
• 
premium rate lines should never be used for phone-in discussion programmes or for 
helplines. They should also not be used for ‘dial and listen’ information lines associated 
with education, welfare, or social action programming (see Chapter 31: Support 
Services and Support Material). 
  
 
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•  
independent productions made for the BBC may use premium rate telephone lines only 
with the express permission of the Commissioning Executive responsible for supervising 
the production. 
  
• 
programmes may choose an appropriate provider for the service, subject to the 
arrangements outlined below. 
 
4.2 Financial and Technical Requirements 
Under no circumstances should programmes use premium rate lines with the aim of 
generating revenue. 
  
Arrangements in the telephone industry mean that use of premium rate lines may generate a 
profit, however in order to guard against premium rate lines being used inappropriately the 
BBC has restricted the percentage of revenue raised by premium rate lines which can be 
returned directly to production departments or independent producers. Guidelines concerning 
these financial arrangements are available from BBC Commercial Policy. 
  
All service providers and programmes must comply with the Code of Practice issued by the 
independent supervisory body, ICSTIS. Programmes should ensure that any provider of a 
premium rate service signs a contract which ensures that they will comply with the BBC’s 
financial and technical requirements. They must be able to provide enough line capacity to 
cope with the likely volume of calls.  
  
4.3 Paying for Support Material via Premium Rate Calls 
Where a programme wishes to offer programme support material on a cost recovery basis, it 
may be appropriate, for convenience to the recipient, to defray the cost of producing and 
delivering the support material by using a premium rate number. The total amount should be 
strictly limited. Every care must be taken to calculate costs so as to break-even, not to 
generate revenue. If this cannot be done, the method should not be used. One drawback is the 
relatively high percentage of lost orders because of transcription difficulties. Producers should 
refer to their Head of Department before making any arrangements.  
  
4.4 Price Messages and Call Cut Offs 
It is essential that the cost of ringing in on a premium rate line is made clear on air: 
  
• 
the maximum cost of a call should be given or in some cases it may be more appropriate 
to give the cost per minute along with the maximum cost which can be incurred. The 
prices given must include VAT and should cover all relevant time periods 
  
• 
on television the information should be given in vision. The caption must be horizontal 
and the characters should be clearly visible. The charge must be shown simultaneously 
with the telephone number. In some cases it may be advisable to voice the information as 
well 
  
• 
on radio, where the price message can only be voiced, it must be done explicitly, not as 
an aside 
  
Call cut-offs automatically end a call after a given time. They protect the caller from running 
up heavy charges. Call cut-offs should normally be used on any premium rate services run in 
 
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association with BBC program
 
mes.  
  
4.5 Children’s Services 
For all children’s services, call cut-offs must be used. 
  
• 
children must be told on air to seek permission from parents or bill-payers before calling 
  
• 
the cost of calls for children’s services should normally be no more than the cost of 
writing in 
  
• 
if in exceptional circumstances calls last more than a minute the message needs to begin 
by telling children that permission should have been obtained. 
 
4.6 Phone Services and Competitions 
Programmes must never use premium rate competitions as means of making money. If 
questions are too simple, the suspicion may be aroused that the competition is designed as a 
money making venture. All BBC competitions involving viewers or listeners must provide a 
genuine test of knowledge, judgement or skill appropriate to the target audience (see also 
Chapter 22: Game Shows and Competitions). 
  
The Lotteries and Amusements Act 1976 prevents broadcasters from running gambling or 
lotteries. If premium rate lines are used, skill must be required to win, otherwise the 
competition may be considered to be gambling or a lottery. Producers must refer to the 
Programme Legal Advice Department before arranging any competition involving premium 
rate lines. 
  
The cost of a call for a competition should not normally be more than the cost of writing in. 
Viewers and listeners should be given sufficient information on air about how to enter rather 
than having to rely on information provided on the premium rate line.  
  
4.7 Voting by Phone 
Call cut offs must be used. Programmes should guard against using the results of a phone-in 
poll as a valid opinion poll. For further detailed guidance on the limitations of phone-in polls, 
see Chapter 35: Opinion Polls.  
  
4.8 Donations to Charity and Charity Appeals 
If programmes wish to give some of the proceeds from premium rate calls to charity they 
must first check what is permissible under the Charities Act. Guidance should be sought from 
the Programme Legal Advice Department. 
  
The BBC provides opportunities for broadcast appeals by charities in accordance with the 
charity appeals procedure (See Chapter 30) Once appeal slots have been granted, it is for the 
charities concerned to decide whether to use premium rate numbers, but the BBC must ensure 
that the appeal includes appropriate details of the cost of the calls.  
  
4.9 Services not controlled by the BBC 
BBC programmes should not give out premium rate numbers for services which are not under 
the BBC’s editorial control except for numbers associated with a broadcast charity appeal. 
Those responsible for pages on Ceefax or digital text services should take care that they do 
 
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not include num
 
bers for non-BBC services.  
  
5 EVENT INFORMATION LINES 
The BBC may trail telephone numbers for lines provided by the BBC or outside organisations 
which give ticket information and other details about events. These lines may be trailed on-air 
only if they give information about events or performances which will be covered by BBC 
programmes. The information given on-air must be brief and non promotional and the lines 
should not be described as ‘ticket-hotlines’. Premium rate information lines should not be 
trailed. The line should not be used as a means of buying tickets by credit card though it may 
refer callers to another number for telephone sales. Any proposal to trail an event information 
line must be referred to the relevant output Controller. 
  
There should be a maximum of one verbal and one visual reference to the telephone number 
in any television programme. In a radio programme there should be a maximum of two verbal 
references. However there may be a verbal trailer earlier in the programme saying that the 
number will be given later.  
  
5.1 Event Information Lines Provided by the BBC 
BBC channels or programmes may provide their own information lines about outside concerts 
or other performances which they are covering. These should not be premium rate lines and 
none of the costs should be met by an outside event organiser or event sponsor. Such lines 
must not be used as means of buying tickets by credit card, though the telephone number of 
the relevant box office may be given.  
 
CHAPTER 33 
POLITICS AND POLITICIANS 
  
1 POLITICAL IMPARTIALITY 
2 POLITICAL INTERVIEWS 
2.1 Interviews With Party Leaders 
2.2 Payment To MPs 
3 PARLIAMENTARY BROADCASTING 
3.1 Parliament at Westminster 
3.2 The Scottish Parliament 
3.3 The National Assembly for Wales 
3.4 The Northern Ireland Assembly 
3.5 The European Parliament 
3.6 Legal Protection 
 
1 POLITICAL IMPARTIALITY 
The BBC’s Charter and Agreement sets out certain principles, which are central to the BBC’s 
coverage of politics. 
  
• 
it requires programmes to “contain comprehensive, authoritative and impartial coverage 
of news and current affairs in the United Kingdom and throughout the world to support 
fair and informed debate at local, regional and national levels” 
  
• 
it requires the BBC to treat controversial subjects with “due accuracy and impartiality, 
both in the Corporation’s news services and in the more general field of programmes 
dealing with matters of public policy or of political or industrial controversy”. 
  
 
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In practice this m
 
eans that the BBC aims over time, to give due prominence to all the main 
strands of argument and to all the main parties. Although the government of the day will often 
be the primary source of news, the voices and opinions of opposition parties must also be 
aired and challenged. 
  
All networked coverage must also reflect the different disposition of political parties in 
Scotland, Wales and Northern Ireland. For this reason specific party labels are preferable to 
general descriptions of ‘the opposition’. The exception to this is in phrases like “the Official 
Opposition” and titles like ‘The Leader of the Opposition’ which in the Westminster context 
has a formal and specific meaning. 
  
The agreement (5.1.c) also explicitly commits the BBC to refrain from 
“expressing the opinion of the Corporation on current affairs or matters of public policy”. 
This does not mean that judgements may not be made by correspondents – indeed these are an 
important part of the BBC’s service to its audience. It does mean that a broadcaster’s personal 
views on any aspect of public policy should not be evident on air (see also section 2.2 of Part 
One of Chapter 2 Impartiality and Accuracy). 
  
2 POLITICAL INTERVIEWS 
Requests for political interviews should be unambiguous about the programme and context 
for which they are intended. 
  
When a politician is invited, but refuses or is unable to appear, this should not normally act as 
a veto on the appearance of other politicians or outside speakers holding different views. 
However, there may be occasions where the refusal of a key player to take part, invalidates 
the idea behind the programme proposal. 
  
Anyone has a perfect right to refuse to appear in a programme. It is not normally necessary to 
mention such a refusal on air. However when the audience might reasonably ask why an 
individual, viewpoint or party is not represented, it may be appropriate to explain that they 
were invited and chose not to take part. Programmes should refrain from speculating about 
the reason for such a refusal. 
  
Politicians or indeed other contributors will sometimes try to place conditions upon 
programmes before agreeing to appear. Any arrangements must stand public scrutiny and 
must not prevent the programme asking questions that audiences would reasonably expect to 
hear asked. In particular if the location for a programme is chosen not for editorial reasons, 
but for logistical ones (e.g. availability in that place in that time of the politician in question), 
producers should ensure that the context and the immediate environment are determined by 
the BBC and not chosen by the contributors for possible party advantage. 
  
Politicians often possess expertise outside the political field, which makes them valuable 
contributors to, even presenters of, programmes across a wide range of subjects and genres. 
However care must be taken to ensure that the BBC’s casting decisions, made on valid 
editorial and programme grounds, do not give any politician such prominence as to give them 
undue advantage over their opponents. Such considerations cannot be confined to election 
campaigns. The dates of many elections are known months in advance; politicians and 
potential candidates can gain undue advantage long before an election campaign actually 
starts. Producers in any doubt on the appropriateness of inviting any contributor or presenter 
who carries an overt party political label should consult the Chief Political Adviser. 
 
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Programmes where invitations to politicians as guests are exceptional rather than regular 
practice, should seek the advice of the Chief Political Adviser at an early stage of programme 
planning.  
  
2.1 Interviews With Party Leaders 
Except for brief news interviews, any BBC programme proposing to interview any of the 
leaders of parties in the United Kingdom must refer to the Chief Political Adviser in advance. 
The Chief Political Adviser should also be notified whether such invitations are refused or 
accepted. 
  
The referral ensures that: 
  
• 
the BBC as a whole is robust and consistent in its dealings with the party leaders 
  
• 
at all times of high demand for one or more party leaders, bids are rationalised within the 
BBC 
  
• 
over time, due weight is given to appearances by all party leaders. 
 
2.2 Payment To MPs 
MPs at Westminster, Members of the European Parliament, Members of the Scottish 
Parliament, Assembly Members of the National Assembly of Wales and the Northern Ireland 
Assembly and politically active members of the House of Lords, who appear on BBC news 
programmes, will not normally be paid for their contributions. Their appearances on radio or 
television to express political views are part of political life, and payment is not appropriate. 
This applies when they answer questions on subjects such as public policy, international 
affairs, party politics or constituency issues. 
  
If their contribution to a programme is outside the normal course of their duties, politicians 
may be paid a fee which reflects the amount of preparation required, the length of time spent 
making the contribution, and the value of the contributor's particular degree of expertise. The 
fee should not exceed that which might be paid to other individuals for similar contributions. 
  
Programmes sometimes secure the services of an politicians for a substantial period to make a 
number of contributions whether on political or other matters during the course of a 
programme. In these circumstances a fee may be paid which would recognise, among other 
things, that contributors may have to decline other offers including invitations from other 
broadcasters. 
  
For any contribution politicians may be paid a "disturbance fee" to cover factors such as 
substantial travel time to a BBC location or attendance during unsociable hours (after 10pm, 
before 8.00am, or on Sundays). However this will usually be a nominal amount and must 
relate to real inconveniences. It must not be used to circumvent the guideline on payment of 
fees. 
  
Politicians who hold government office or executive office in any elected assembly or who 
have party front bench responsibilities do not qualify for a fee under any circumstances, 
including a disturbance fee. Those who chair Parliamentary Committees and leaders of 
 
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political parties do not qualif
 
y either.  
  
3 PARLIAMENTARY BROADCASTING 
  
3.1 Parliament at Westminster 
There are rules laid down by Parliament for the broadcasting of proceedings in both Houses. 
These cover, for instance, the nature of shooting and editing. The pictures from both the 
House of Commons and the House of Lords are made available for the broadcasters by the 
Parliamentary Broadcasting Unit. 
  
Broadcasters are allowed to use the pictures and sound under certain conditions including: 
  
• 
no internal editing of speeches. When using use two sections of a speech, a definite break 
must be provided to make clear the two sections are not continuous. 
  
• 
no graphic enhancement or alteration of the pictures. For example one or a group of MPs 
must not be highlighted and the framing must not be changed 
  
• 
no speeding up or slowing down of the pictures or sound. 
  
If in doubt seek detailed guidance from Political Programmes at Millbank. 
  
Parliamentary material can be used only in news and factual programmes or for educational 
purposes. No Parliamentary recording may be used in light entertainment, or fictional or 
drama programmes, or programmes of political satire. Parliamentary material may be used in 
the factual parts of magazine programmes but must always be kept separate from musical, 
fictional or humorous items. 
  
Parliamentary committees can usually be broadcast even if they are sitting away from 
Westminster, but the broadcasters have to commission coverage in advance. Again BBC 
Political Programmes at Millbank can help.  
  
3.2 The Scottish Parliament 
As with Westminster, actuality can only be used in news and factual programmes. No 
recording may be used in light entertainment, as fictional or drama programmes or 
programmes of political satire. 
  
The rules for coverage are however much more relaxed than those for 
Westminster. The guiding principle is that of the “gallery surrogate”: that television viewers 
should be given the chance to witness everything they could see if they were in the public 
gallery of the Parliament itself. For example: 
  
• 
internal editing is allowed but “broadcasters should not distort the meaning of MSP 
speeches in edits” 
  
• 
cutaways are allowed 
  
• 
the arrival of prominent members in the Chambers and shots of the public gallery are 
allowed. 
  
 
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A full copy of the rules of coverage and details of how to obtain access to BBC recordings are 
 
available from the Editor of the Scottish Parliament Unit in BH Glasgow.  
  
3.3 The National Assembly for Wales 
The same conditions apply on use of material in non-news programmes as those in 
Westminster and Scotland. The Code of Conduct is similar to that in Scotland with the 
exception that no demonstration or interference by the public can be shown. A full copy of the 
code, is available from BBC Wales’ political editor and anyone seeking access to BBC 
recordings should contact the News Organiser in the BBC Wales’ political unit in BH 
Llandaff.  
  
3.4 The Northern Ireland Assembly 
The same conditions apply on use of material in non-news programmes as those in 
Westminster.  
  
3.5 The European Parliament 
BBC Westminster can also advise programme makers about how to obtain Coverage from 
sittings of the European Parliament or its committees. Up-to-date information about recent 
and forthcoming business is available from the BBC Political Research Unit based at 
Millbank.  
  
3.6 Legal Protection 
Most statements made in Parliament at Westminster, in the other devolved parliaments and 
assemblies in the United Kingdom and in the European Parliament, enjoy qualified privilege 
when they are reported fairly and accurately. This gives a defence to libel, but it does not 
extend to reporting things shouted by non-Members in the Public Gallery or things said by 
Members overheard talking among themselves. There is no defence of privilege available for 
reporters or broadcasters when they repeat what is said in Parliament where there is a risk of 
contempt. There is no automatic legal protection against the risk of contempt during a live 
relay of a Parliament or Assembly, but the Speaker or Deputy Speaker is normally quick to 
intervene to stop remarks which risk contempt. There is no qualified privilege for members 
who repeat allegations outside the house. 
  
Chief Political Adviser is available to offer advice on all aspects of political editorial 
matters.
  
 
CHAPTER 34 
BROADCASTING DURING ELECTIONS 
  
1     ACHIEVING BALANCE 
2   MINOR PARTIES 
3   CONSTITUENCY REPORTS 

USE OF CANDIDATES IN ISSUE BASED PROGRAMME PACKAGES 
5 DEVOLUTION 
6   ONLINE 
7 AUDIENCE 
PROGRAMMES 

PARTY LEADER INTERVIEWS 
9   OPINION POLLS 
10   VOX POPS 
11   E-MAILS 
12   GUIDELINES FOR POLLING DAY 
 
 
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There is no area of broadcasting where the BBC’s com
 
mitment to impartiality is more closely 
scrutinised than in reporting election campaigns. 
Election 2001 will present us with a number of specific new challenges: – 
• 
Devolution has changed the political map of the UK. We are effectively dealing with 3 
main parties in England, and a different combination of 4 main parties in Scotland, Wales 
and Northern Ireland. In addition minor parties, have had significant electoral successes 
under PR elections which have taken place since 1997.  
• 
This will be the first full Online election.  
• 
The abolition of Section 93 of the RPA will enable programme makers to make far more 
extensive use of candidates and we will have new guidelines to ensure fairness 
particularly in constituency reports.  
These guidance notes which supplement Chapters 2 and 34 of the Producers’ Guidelines, 
have been drawn up following extensive consultation with a wide range of BBC 
programme makers across the UK who will have to make them work in practice. They 
are intended to offer a framework within which – 
• 
Journalists can operate in as free and creative an environment as possible.  
• 
Whilst scrupulously delivering to audiences impartial reporting of the campaign which 
gives them fair coverage and rigorous scrutiny of the policies and campaigns of all 
parties.  
• 
This guidance is intended to assist programme makers, editors and the BBC as a whole to 
achieve fairness.  
They apply to all BBC programmes and outlets. Programmes which do not usually cover 
political subjects or normally invite politicians to participate should consult the Chief 
Political Adviser before finalising any plans to do so. 
 
1.  Achieving Balance 
Daily News magazine programmes (in the nations, regions and UK wide) must achieve an 
appropriate and fair balance in coverage of the main parties in the course of each week of 
the campaign.   
As a working shorthand for the General Election Campaign we will take the main parties in 
England to be Labour, Conservative, Liberal Democrats; In Scotland these three plus the 
SNP, in Wales these three plus Plaid Cymru; in Northern Ireland the Ulster Unionists, the 
SDLP, the DUP and Sinn Fein. 
Network programmes must ensure that SNP and/or Plaid Cymru are featured in a fair 
proportion of items on subjects on which they have distinctive policies.  See also Section 5 on 
devolution. 
• 
This means that each strand (e.g. a drive time show  on radio) is responsible for reaching 
its own targets within the week and cannot rely on other outlets at different times of day 
(e.g. the breakfast show) to do so for it.  
• 
Single programmes should avoid individual editions getting badly out of kilter.  There 
may be days when inevitably one party dominates the news agenda e.g. when the main 
party manifestos are launched, but in that case care must be taken to ensure that coverage 
of similar prominence and duration is given to the other manifesto launches on the 
relevant days.  
• 
Every edition of the multi-item programmes which cover the campaign e.g. the Regional 
6.30 – 7.00 slot, should refer in at least one item to each of the main parties.  
• 
News 24 and television and radio summaries will divide the 24 hour day into blocks and 
aim to achieve balance across a week in each one.  
 
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•  
Weekly programmes, or running series within daily sequence programmes, which focus 
on one party or another should trail both forwards and backwards so that it is clear to the 
audience that balance is built in over time.  
• 
Particular care should be taken over coverage of high profile issues like Europe where 
there is a multi-faceted debate within and between the parties to ensure a balance of 
views is maintained.    
 
 2.  Minor Parties  
 
Minor parties  embrace a wide range, from parties which have elected representatives in the 
European Parliament,  the Scottish Parliament, the Northern Ireland Assembly, to those who 
have not stood before, or who have stood many times with little electoral success. Relevant 
factors to take into account in deciding how much coverage a party should get are significant 
levels of previous electoral support, evidence of current support and the number of candidates 
being fielded. 
The following guidance is aimed at ensuring minimum coverage for all those parties. It does 
not set a maximum. There may well be regional variations in the relative strength of the minor 
parties and this ought to be reflected in the coverage. 
• 
The manifesto launch of all parties who are standing in at least one sixth of the seats UK 
wide should be covered on BBC1, BBC2, R1, R2, R4, R5Live, & News 24, in all 
summaries in the hours following the launch, and with some reference to content in the 
main news programmes which follow (e.g: the 1, 6, or 10 0n BBC1, WATO on R4, Drive 
on R5,  the news belt on Newsnight on BBC2).  BBC Parliament will also carry them.  
• 
All daily news and current affairs network programmes should ensure that the policies of 
each of these parties are explained, and analysed, in at least one substantial item during 
the course of the campaign.  
• 
All regional programmes in England which report the election should cover the manifesto 
launch of all parties who are standing in more than one sixth of the constituencies  in that 
region. There should be at least one other substantive item on each of these parties during 
the campaign.   
• 
All Programme Strands in Scotland, Wales and Northern Ireland which report the 
election should cover the manifesto launch and do at least one other substantive item in 
the course of the campaign, on all parties standing in one sixth of the seats in those 
nations. They should also include a contribution from these parties in some items on 
those subjects on which they have distinctive policies.  
• 
The audience will be referred, as appropriate to the full list of parties standing on Ceefax, 
BBC News Online and/or the national and city sites.  
 
3.  Constituency reports  
 
Section 93 of the RPA has been abolished but the BBC has a legal obligation to adopt a code 
of practice in its constituency coverage. All other broadcasters in the UK will adopt the same 
code. 
The abolition of Section 93 of the RPA means that there is no legal distinction for us between 
the period before close of nominations and the period after it. It also means that candidates 
who withhold their consent from constituency reports or debates can no longer effectively 
exercise a veto over all other candidates. 
However, this does not weaken in any way the BBC’s obligations to fairness. So when the 
election is called the following guidelines come into effect immediately.  
 
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•  
to be impartial, constituency reports or debates should give due weight to candidates of 
the main parties. This means that if any candidate takes part in an item about a specific 
constituency, then candidates of each of the main parties should be offered the 
opportunity to take part.  As a working shorthand for the General Election Campaign we 
will take the main parties in England to be Labour, Conservative, Liberal Democrats;  In 
Scotland these three plus the SNP, in Wales these three plus Plaid Cymru; in Northern 
Ireland the Ulster Unionists, the SDLP, the DUP and Sinn Fein.  
• 
to be authoritative, it is right to make some distinction in the weight of the contribution 
between these candidates and others. Constituency reports or debates should also include 
some participation from candidates representing parties with either previous significant 
electoral support (for example parties which have gained a few seats in other recent 
elections or individuals who have been elected before under another label) or parties with 
evidence of significant current support. Where a party or an individual is mounting a 
significant campaign in a particular region, this should be reflected appropriately in the 
coverage.   
• 
to be comprehensive and fair, full-length constituency reports or debates should include a 
list of all candidates standing. If a constituency is being reported on several times on the 
same channel in a day, it may be enough to broadcast the full list once a day. Audiences 
should also be directed to the full list of candidates on Ceefax and Online.  
• 
programmes may decide to use either candidates or party representatives. But if the 
candidate from one of the parties is invited to take part, the other participants should, 
where at all possible, also be candidates. In exceptional circumstances if a candidate is 
genuinely unavailable the opportunity may be offered instead to a suitable party 
representative from within the constituency (eg: party official, agent or Councillor) but it 
should be made clear to the audience that the missing candidate(s) was invited and why 
they were unable to take part. If a party declines to put forward any representative the 
item/programme will go ahead without them.  
• 
advice as to which parties currently fall into which category can be sought from the Chief 
Political Adviser. We will take care to ensure that particularly in those cases where a 
particular constituency is featured often, we do not give undue prominence to any single 
candidate over time.  
 
4.  Use of Candidates in issue based programme packages  
 
The abolition of Section 93 of the RPA also gives far greater freedom to programme 
makers to use candidates in issue pieces. Indeed, giving candidates of all parties a higher 
profile during the campaign was one of the key arguments used to secure the abolition of 
the RPA. National figures who are also candidates have always been able to appear as 
party representatives. Now, for the first time, regional television and local radio can use 
candidates far more freely to discuss local issues, but this in no way absolves us of our 
responsibility to be fair between the parties.  
 
In order to achieve fairness across the board, when programmes decide to use a local 
candidate in a package or debate, the other participants should where at all possible, also be 
local candidates. But candidates do not have to be from the same constituency – they can 
come from different constituencies within a region. In local issue round-tables where all the 
participants are candidates, references to eg: local hospitals, bypasses etc, which would have 
been difficult under the RPA, will now be allowed. 
 
 
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However, if a candidate is being interviewed as a national spokesperson, we should not allow 
 
them to gain an unfair advantage over their constituency opponents by making repeated plugs 
for their own constituency. This can best be achieved by politely advising them in advance of 
our policy on this, editing out such references if pre-recorded and swift intervention by the 
interviewer, if live. 
 
Callers to phone-ins must still be checked to see if they are candidates. Before the abolition of 
the RPA this would have precluded them from appearing as such. Now they can be 
encouraged to contribute, but the audience must be clear that they are speaking not as 
ordinary members of the public but as contributors with a stated political agenda. Care must 
be taken that over time programmes are not giving undue preference to one candidate over 
another. 
The aim of all these guidelines is to encourage vigorous debate and a higher profile to 
candidates of all parties in general without giving unfair advantage to one candidate over 
another. 
 
5.  Devolution  
 
This is the first UK General Election since Devolution.  In Scotland, the Scottish Parliament, 
not Westminster, is now in charge of most domestic matters such as education, health and 
criminal law, most aspects of home affairs and the environment.  In Northern Ireland the 
Assembly is in charge of education, health, and social services, agriculture, environment, 
urban and regional development.  In Wales the National Assembly is in charge of education, 
agriculture and health. 
 
• 
It is essential to make clear to the audience which issues will be influenced by the 
outcome of the election in each part of the UK. The BBC should be frank with its’ 
audience about the changed nature of the campaign in the nations.  Indeed it may be 
newsworthy to raise this as an  issue.  
• 
However, it is unrealistic to expect that candidates and parties in Scotland, Wales and 
Northern Ireland  will confine themselves strictly to matters reserved to Westminster, 
such as defence, foreign affairs, the macro economy and social security and there is no 
indication at this stage that the UK General Election will be less keenly fought in the 
Nations.  The contest will be a mixed blend:  partly Westminster issues, partly a 
plebiscite on  the performance of the parties in the Scottish Parliament, National 
Assembly for Wales and Northern Ireland Assembly.  Programmes should reflect that 
blend to our audience, while making clear who does what in the new political set-up.  
• 
The Scottish Parliament, National Assembly of Wales and the Northern Ireland Assembly 
may well be in session during the UK General Election campaign, though they are 
unlikely to sit on polling day itself. All relevant programmes will continue to cover these 
proceedings on news merit, but the guidelines on balance on the main parties, and other 
parties with elected representatives in  those bodies will apply.  
• 
Civil Servants in the devolved institutions will continue to process policy decisions and 
announcements during the UK election.  We will report such announcements on news 
merit, but all four of the main parties in each nation should be given the opportunity to 
comment on them.  
• 
Network programmes, in order to report fully the UK to the UK, should ensure that they 
cover the key election stories in Scotland, Northern Ireland and Wales.  In doing so the 
guidance on party balance in those nations must be followed.  
 
 
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6.
    Online  
 
This is the first online general election.  
• 
All editorial content must comply with the same guidelines on balance, use of candidates 
etc. which apply to television and radio programmes and monitoring should be carried 
out on the same basis as for programmes.  
• 
BBC News Online, the Nations’ and English regions’ sites (in close liaison with each 
other to ensure a consistent BBC wide approach) will publish a complete list of 
candidates by constituency.  Programmes will refer to this list as a matter of course at the 
end of full constituency reports.   
• 
BBC News Online and Regional sites will list links to any party site, provided that it does 
not give strong grounds for concern that this breaches the BBC taste and decency 
guidelines or the law e.g. defamation or incitement to racial hatred.  
• 
We will not link to the sites of individual candidates, unless there is a very strong 
editorial justification on news grounds and then only for a limited period (e.g. because 
major player publishes policy on his/her website which contradicts manifesto on their 
party’s website).  
• 
Any speeches which are carried in full will be selected on news value, bearing in mind 
the need for balance between the parties.   
• 
Forums and message boards: Care must be taken to ensure that forums and message 
boards are vehicles for lively debate and not hi-jacked by organised campaigns of one 
particular group or party. This is not easy to achieve but we are more likely to succeed if:  
• 
Open ended message boards on political issues are avoided during the campaign. Hosts 
will be required to initiate topics with appropriate questions and to steer threads so as to 
encourage effective debate about the issues.  
• 
The topics are set by journalists and are based on the issues not personalities. Sites which 
do not usually engage in political issues should seek the advice of the Chief Political 
Adviser before doing so.  
• 
Poll type questions which attempt to quantify support for a party, politician, or policy 
issue should be avoided.  
• 
Pre-moderation or hourly postmoderation (e.g. in the case of Nations, the English 
Regions and Radio sites) will check that messages are not completely stacked in the 
direction of one party or another. The maximum time any message may be up before 
being checked on a postmoderated board is one hour. But this should not be taken as the 
acceptable norm. It may be necessary to check more frequently.  
• 
All moderators and hosts should know how to use BBC Online’s escalation strategy 
where appropriate, to protect a postmoderated message board from e.g. nuisance or 
abuse. For example, they should know how to switch a board from postmoderation into 
premoderation, at short notice. This will ensure that if necessary an organised campaign 
can be blocked.   
Revised rules to effect this policy and make it transparent to all users, will be posted on 
all BBC message boards at the beginning of the election campaign. 
• 
Journalists and moderators will have to make fine judgements between remarks that 
constitute robust political debate and personal abuse.  The rule of thumb should be if we 
would not broadcast it on radio or TV, it should not be online.  Filters for taste and 
decency and personal abuse will operate as usual but they should not be relied on as a 
substitute for effective moderation.  
• 
Any live chat or online audio or video interviews by politicians should be subject to the 
same criteria on balance and fairness as applies to radio and TV interviews. The criteria 
are set out in these guidelines.  
 
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7.  Audience Programmes  
 
All programmes planning live audiences should consult the Chief Political Adviser to discuss 
how they plan to select the audience and to achieve an appropriate balance. All such 
procedures must stand up to public scrutiny. 
 
8.  Party Leader Interviews  
 
In order to ensure that our audiences are served as well as possible during the campaign by a 
balanced package of robust interviews across a range of outlets, bids will be co-ordinated well 
in advance of the election so that a coherent and realistic BBC proposition is put to the party 
leaders. 
With the exception of newsgathering interviews gathered on news value on the day, all bids 
for party leader interviews must be referred to the Chief Political Adviser before parties are 
approached. Unsolicited offers should not be accepted without consultation with senior 
managers and a reference to the Chief Political Adviser. 
 
9.  Opinion Polls  
 
During the campaign our policy takes into account three key factors: 
• 
that polls should not be ignored during the campaign. They are part of the story and 
audiences should be informed about them;  
• 
but, context is essential, and so is the language used in reporting them;  and  
• 
polls can be wrong. There are real dangers in only reporting the most “newsworthy” polls 
– i.e. those which, on a one-off basis, show dramatic movement.  
 
So, the rules about reporting polls (chapter 35 of Producers’ Guidelines) need to be 
scrupulously followed. They are: 
• 
not to lead a news bulletin or programme simply with the results of a voting intention 
poll;  
• 
not to headline the results of a voting intention poll unless it has prompted a story which 
itself deserves a headline and reference to the poll’s findings is necessary to make sense 
of it;  
• 
not to rely on the interpretation given to a poll’s results by the organisation or publication 
which commissioned it: look at the questions, the results and the trend;  
• 
to report the findings of voting intentions polls in the context of trend.  The trend may 
consist of the results of all major polls over a period or may be limited to the change in a 
single pollster’s findings.  Poll results which defy trends without convincing explanation 
should be treated with particular scepticism and caution;  
• 
not to use language which gives greater credibility to the polls than they deserve:  polls 
“suggest” but never “prove” or even “show”'  
• 
to report the expected margin of error if the gap between the contenders is within the 
margin.  On television and online, graphics should always show the margin of error;  
• 
to report the organisation which carried out the poll and the organisation or publication 
which commissioned it.  
 
In addition, during the campaign the BBC will: 
• 
pre-select the main polls;  
• 
report the selected polls on a regular basis on the same outlets throughout the campaign;  
 
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•  
report even single polls in context.  For example, on television the graphic will never be 
separated from the explanatory piece;  
• 
Take particular care with newspaper reviews. Polls should not be the lead item in a 
newspaper review and should always be reported with a sentence of context (e.g: “that’s 
rather out of line with other polls this week”).  
 
The Producers’ Guidelines make it clear that care must be taken to ensure that a poll 
commissioned by the BBC is not used to suggest a BBC view on a particular policy or issue.  
It is particularly important that a BBC poll is not used to imply BBC intervention in a current 
controversy.  For this reason we will not commission voting intention polls in any medium 
during the election campaign. 
 
Detailed guidance as to how this policy should be implemented in practice will be issued by 
the Chief Political Adviser before the start of the campaign. 
 
10.  Vox Pops  
 
The value of Vox pop to programmes is to allow different sides of an issue in question to be 
expressed through the voices of the man and woman in the street.  But the context should 
always make it clear that they are an expression of one side of an argument, not an indication 
of the weight of opinion on either side of it.  It follows that special care must be taken with 
vox pops during an election campaign to edit them in such a way as to ensure different sides 
of the issue are covered. 
 
11.  E-mails  
 
The same principle applies to any e-mails we broadcast.  E-mails offer immediacy and 
interactivity to many programmes but they too are an expression of opinion, not an indication 
of the weight of opinion on one side or the other of a question.  What matters is the balance of 
what we broadcast, not the balance of those we receive. 
 
Programme makers should be particularly alert during an election campaign to organised e-
mail campaigns by parties and pressure groups.  During this period they should ask e-mail 
contributors to include their address and telephone number so that checks can be run if 
necessary, if mass mailings are suspected. 
 
12  Polling Day Guidelines 
 
The BBC ceases to report election campaigns at 6am (5 GMT) and restricts coverage to 
factual accounts of the days events until the polls close at 10pm (9GMT). Judgements as to 
what can or cannot be said should be based on the principle that while the polls are open, 
nothing in our output should be construed as influencing the ballot.  
 
Factual accounts of the days events would include 
• 
The weather.  
• 
Turnout. But beware of jumping to big conclusions from the evidence of one polling 
station.  
• 
The new postal voting rules.  
• 
Pictures of national figures voting for example, party leaders are fine but those candidates 
where the main interest centres on the contest in their constituency are not.  
 
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•  
Online. Although all the archived material remains available, the front page will be 
cleared of all campaign coverage, and these guidelines apply to all new material. This 
applies to all programme sites as well.  
• 
Message Boards will be closed down for the day and re-open after the polls close at 
10pm.  
 
CHAPTER 35 
OPINION POLLS 
  
1 COMMISSIONING OPINION POLLS 
2 REPORTING OPINION POLLS 
3 POLLS AT ELECTION TIMES 
4 POLLS FOR USE IN ELECTION RESULTS PROGRAMMES 
5 SURVEYS 
6 PHONE-IN POLLS AND STUDIO AUDIENCES 
7 FOCUS GROUPS AND PANELS 
8 VOX POPS 
9 ONLINE AND NEW MEDIA 
  
 
1 COMMISSIONING OPINION POLLS 
There are many circumstances where polls may add value to programmes and augment our 
journalism but care must be taken to ensure that a poll commissioned by the BBC is not used 
to suggest a BBC view on a particular policy or issue. It is particularly important that a BBC 
poll is not used to imply BBC intervention in a current controversy. Only in very rare 
circumstances does the BBC commission or sponsor opinion polls purporting to sample party 
political support or voting intentions in the electorate at large. Joint polls with other 
organisations often carry particular problems of impartiality in presentation and should be 
avoided. 
  
Any proposal to commission an opinion poll on politics or any other matter of public 
policy for any BBC service should be referred to the Chief Political Adviser for 
approval. Technical advice should also be sought from the Political Research Unit. 
  
2 REPORTING OPINION POLLS 
The following rules for reporting the findings of voting intention polls in the United Kingdom 
conducted by any polling organisation must be rigorously applied: 
  
• 
do not lead a news bulletin or programme simply with the results of a voting intention 
poll 
  
• 
do not headline the results of a voting intention poll unless it has prompted a story which 
itself deserves a headline and reference to the poll’s findings is necessary to make sense 
of it 
  
• 
do not rely on the interpretation given to a poll’s results by the organisation or 
publication which commissioned it: look at the questions, the results and the trend 
  
• 
report the findings of voting intentions polls in the context of trend. The trend may 
consist of the results of all major polls over a period or may be limited to the change in a 
 
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single pollster’s findings. Poll results which defy trends without convincing explanation 
should be treated with particular scepticism and caution 
  
• 
do not use language which gives greater credibility to the polls than they deserve: polls 
“suggest” but never “prove” or even “show” 
  
• 
report the expected margin of error if the gap between the contenders is within the 
margin. On television and online graphics should always show the margin of error 
  
• 
report the organisation which carried out the poll and the organisation or publication 
which commissioned it 
  
• 
report the dates of the fieldwork and draw attention to events which may have had a 
significant effect on public opinion since it was done (e.g. “The poll was carried out last 
Monday, before the party announced.....”).  
 
3 POLLS AT ELECTION TIMES 
As with all political reporting, special care has to be taken in reporting polls at election times. 
  
BBC policy takes into account three key factors: 
  
• 
polls should not be ignored during the campaign. They are part of the story and audiences 
should be informed about them 
  
• 
but, context is essential, and so is the language used in reporting them 
  
• 
polls can be wrong. There are real dangers in only reporting the most “newsworthy” polls 
– i.e. those which, on a one-off basis, show dramatic movement. 
  
So, in addition to the stipulations about polls in general (see previous section) coverage of 
polls at election times will: 
  
• 
pre-select the main polls 
  
• 
report the selected polls on a regular basis on the same outlets throughout the campaign 
  
• 
report even single polls, in context. For example, on television the graphic will never be 
separated from the explanatory piece. 
  
Detailed guidance as to how this policy should be implemented in practice will be issued by 
the Chief Political Adviser before the start of the campaign.  
  
4 POLLS FOR USE IN ELECTION RESULTS PROGRAMMES 
In spite of the considerable thought and effort which has gone into refining the methodology, 
exit polls have not proved a sufficiently reliable way of predicting the results of elections. Our 
journalistic credibility is based on the audience’s expectation that information the BBC 
broadcasts is accurate. 
  
Polls carried out on polling day, by whatever method, have their limitations and should be 
seen for what they are - a device to sustain the programme until the real results come in. They 
 
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m
  ay give an indication of the way things are going, but because of the pitfalls of sampling 
error, should always be used in bands, as in “it looks as if x are to be the biggest party with 
between x and x seats”. A precise seat projection should wait for sufficient real results to 
establish the actual trend.  
  
5 SURVEYS 
Surveys of small specific groups like MPs or health authorities when used responsibly can be 
a very useful way of informing our audience and gathering information, but like opinion polls 
they must be both conducted and reported with care and after seeking appropriate advice. 
Contact should be made at an early stage both with Political Research Unit, who will advise 
as to whether the survey is practical, and from the Chief Political Adviser, who will advise on 
the necessary thresholds for responses and on appropriate content. 
  
Surveys must never be reported as polls. The audience should be in no doubt about the status 
of the information they are receiving. Their remits should not be translated into percentages 
but reported in straight numbers e.g.: “Of the 81 MPs in this group we spoke to 60, of whom 
40 were in favour of x and 20 were opposed to it”.  
  
6 PHONE-IN POLLS AND STUDIO AUDIENCES 
Phone - in polls (unlike professionally conducted polls using the telephone) rely on people 
telephoning in to register a vote. Phone-in polls may accurately be described as “straw polls” 
even when the subject is serious. Programmes which want to carry them out need to 
understand their severe limitations. They do not sample opinion; they are simply a programme 
device which illustrates certain viewpoints. A programme’s audience is self-selected and is 
never representative of the population . When asked to give views on a topic, a minority, 
again self-selected, responds. If voting takes place during an extended period it may 
encourage repeat voting by people who feel strongly about the issue. 
  
Questions in phone-in polls should be as neutrally worded as the context calls for. Slanted 
questions give slanted results. 
  
Phone-in polls must never be used by programmes as a means of gathering serious 
information on party political support. In other contexts, phone-in polls may produce 
interesting, even impressive results (“Ten thousand of our listeners/viewers called in and they 
are four to one in favour of ...”). But we should make clear that the results have no wider 
significance. 
  
The results of phone-in polls are not even remotely indicative of wider opinion, and 
programmes must not treat them in any way which implies that they are. Consequently 
publicity should not be sought for the results of phone-in polls outside of the programmes in 
which they are conducted. BBC News programmes should not normally report the results of 
phone-in polls. 
  
Programmes which feature phone-in polls on the same subject taken at different times (for 
example at the start of the programme and again at the end) must not present the results in 
such a way as to suggest that they demonstrate a shift in opinion by the people who voted. 
  
Straw polls of the views of studio audiences should be treated with similar care. No claims 
should be made for the significance of the views expressed beyond that they represent the 
opinions of those in the audience at the time, even on those occasions where the audience has 
 
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been selected to be broadly representative of, for exam
 
ple, party allegiance. Again, questions 
need to be properly framed.  
  
7 FOCUS GROUPS AND PANELS 
The same principles apply to the use of panels or focus groups. It is inappropriate to imply 
that the views of panels, however carefully selected, could represent the views of the entire 
population, and they must not be used as a means of trying to estimate party support in the 
electorate at large. Panels or focus groups, when properly selected, may be more 
appropriately used to examine why certain views are held rather than the extent to which they 
are held. 
  
The advice of the Chief Political Adviser should be sought before commissioning any focus 
group research on political party issues and the methodology should be checked with the 
Political Research Unit.  
  
8 VOX POPS 
Vox pop interviews do not even remotely indicate wider public opinion. Their value to 
programmes is to allow different sides of an issue in question to be expressed through the 
voices of the man and woman in the street. But the context should always make it clear that 
they are an expression of one side of an argument, not an indication of the weight of opinion 
on either side of it. It follows that great care must be taken with vox pops on politics or 
matters of public policy to edit them in such a way as to ensure both sides of the issue are 
covered.  
  
9 ONLINE AND NEW MEDIA 
The principles outlined in this chapter apply with equal force to online sites and to other new 
forms of interactive voting (e.g. interactive television). 
  
Interactivity of every sort is part of the central appeal of any online site. However, on BBC 
sites, especially News Online and programme sites which may relate to political or public 
policy issues, care has to be taken that expressions of opinion are not translated into anything 
that could be construed either as the BBC’s opinion or as an accurate representation of public 
opinion as a whole. So any summary of online voting or expression of opinion must: 
  
• 
not be called a poll 
  
• 
not be reported in BBC editorial content, whether on or off the site 
  
• 
not be expressed in percentage terms. The results should be expressed in terms of how 
many hits the yes button has received and how many the no button. 
  
Any summary of online voting or expression of opinion about political or public policy issues 
must include a disclaimer the effect that “This is not a representative poll and the figures do 
not purport to represent public opinion as a whole on this issue”.  
 
CHAPTER 36 
PARTY BROADCASTS
 
 
There is no formal legal obligation on the BBC to make airtime available for party broadcasts 
but in the absence of political advertising in the UK it has traditionally offered unmediated 
 
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airtim
 
e to the political parties as one element in the range of sources of political information 
available to the audience. 
  
There are series of election broadcasts in the campaigns for General Elections, and elections 
to the European Parliament, Scottish Parliament, the National Assembly for Wales, the 
Northern Ireland Assembly and Local Authorities throughout the UK. 
  
In addition, broadcasts are offered to the parties at key points in the annual political cycle, for 
example the Budget and the Queens Speech. 
  
Party broadcasts are quite separate from the BBC’s own journalism and their transmission 
does not imply BBC support for the views contained in them. Parties make these broadcasts at 
their own expense and are responsible for their content. However they do have to abide by 
ground rules laid down by the BBC and the ITC, which include an obligation to observe the 
law, for example on libel, incitement to racial hatred and violence and to the broadcasters’ 
own guidelines on taste and decency. These ground rules are available on request from the 
Chief Political Adviser. 
  
In truly exceptional circumstances giving rise to widespread national anxiety or concern, the 
BBC and ITV (Channel 3), provide the opportunity for a direct address to the nation by the 
Prime Minister or relevant senior minister should this be requested. In this event appropriate 
arrangements, in as short a time span as possible will be made for responses by the leaders of 
the opposition parties. 
 
CHAPTER 37 
MATTERS OF LAW: GENERAL 
  
1 GENERAL 
2 WHO TO CONTACT 
3 INJUNCTIONS AND INTERDICTS 
4 IDENTIFICATION OF CRIME VICTIMS AND WITNESSES 
4.1 Identification of children 
4.2 Courts Sitting in Private 
4.3 Victims of Sexual Offences 
4.4 "Jigsaw" Identification 
5 TRESPASS 
5.1 The law in Scotland 
6 REPORTING OF COMMITTAL PROCEEDINGS 
7 OBSCENE PUBLICATIONS ACT 
8 EUROPEAN DIRECTIVE: TELEVISION WITHOUT FRONTIERS 
9 RACIAL DISCRIMINATION 
10 DATA PROTECTION ACT 
11 CONFIDENCE 
12 USE OF ANIMALS 
13 HEALTH AND SAFETY 
13.1 Flashing Images and Repetitive Patterns on Television (“Strobing”) 
13.2 Images of Very Brief Duration 
14 REPEATED PROGRAMMES 
15 FURTHER ADVICE 
 
1 GENERAL 
 
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Great problem
 
s can be caused for programme makers by legal difficulties they are unaware 
of. It is vitally important to seek the views of BBC lawyers whenever problems are 
encountered or suspected. 
  
No summary can cover all the legal issues affecting broadcasting. Producers would do well to 
familiarise themselves with one of the following books; McNae's Essential Law for 
Journalists
 or Media Law by Robertson and Nicol, or the 6th Edition of Scots Law for 
Journalists
 by McKain, Bonnington and Watt. But even these are no substitute for specific 
legal advice. 
  
There are significant differences between the legal systems of England and Wales and those 
of Scotland and Northern Ireland. The Channel Islands and the Isle of Man are different 
again. If not observed these differences can cause serious problems. 
  
There may be occasions, especially overseas, where providing accurate, impartial and fair 
coverage makes it impossible to remain within the law locally. 
  
Where such cases arise, producers must first consider what effect breaking the law might have 
on the BBC, on people concerned in the area, and on our future coverage of the region. The 
Head of Department or Commissioning Executive and BBC Lawyers should be consulted, 
and if necessary Controller, Editorial Policy. Where our coverage has been distorted or 
censored by local laws, this must be made clear to the audience (see also section 9 “Observing 
Local Law” in Chapter 3: Fairness and Straight Dealing).  
  
2 WHO TO CONTACT 
Any programme maker can consult BBC lawyers at any stage of production. The earlier the 
consultation the better, if necessary as soon as the programme idea is conceived. Repeated 
consultation may be called for. 
  
On matters involving Scottish law consult the in-house lawyer at BBC Glasgow. 
  
Advice on foreign legal matters can be obtained through the Legal Adviser’s Division, which 
keeps a list of lawyers in various countries. 
  
Lawyers in the LEGAL ADVISER'S DIVISION work in six departments: 
  
• 
PROGRAMME LEGAL ADVICE DEPARTMENT: helps programmes to minimise the 
risk of libel and to avoid breaking the law. 
  
• 
LITIGATION: deals with problems that arise after a programme has been broadcast, as 
well as attempts at prior restraint and outside requests for programme material for legal 
purposes. 
  
• 
REGULATORY: deals with EC law, procurement and sponsorship. constitutional 
matters arising under the Charter and Agreement and the Broadcasting Acts, competition, 
regulation of the broadcasting and telecommunications industries, TV licensing, Data 
Protection and European Law including Human Rights, Freedom of Information and 
public procurement law. 
  
 
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•  
INTELLECTUAL PROPERTY: gives advice on all aspects of the protection and 
exploitation of the BBC’s intellectual property rights and the infringement of such rights. 
  
For copyright advice on contributions to specific TV and radio programmes, programme 
makers should consult the lawyers (Legal Affairs Section) in the Rights Group in BBC 
Production. 
  
• 
COMMERCIAL: legal advice, drafting and negotiation involving major commercial 
contracts, corporate commercial compliance, joint ventures, IT contracts, contracting 
out/tender documentation, confidentiality agreements, commercial contracts with news 
agencies, radio sports contracts, insolvency and Company Law. 
  
• 
The WORLDWIDE LEGAL DEPARTMENT provides a comprehensive legal service to 
BBC Worldwide 
 
 
 
 
3 INJUNCTIONS AND INTERDICTS 
An injunction, in Scotland an interdict, is a legal Order by a judge directing a party to do or 
refrain from doing things specified in the Order. 
  
Anyone, whether individuals or organisations, can seek an injunction or interdict if they think 
their interests or reputation are about to be damaged by a programme. Applications are often 
associated with claims for breach of contract or breach of confidence, and may sometimes be 
sought for defamation. 
  
Orders against programmes are sometimes sought outside court hours: we may have little or 
no warning. They can be granted and enforced over the telephone at night or at the weekend. 
Breach of an injunction or interdict is viewed seriously by the court. Fines and/or prison 
sentences can be imposed on offenders. 
  
In addition to injunctions aimed at particular programmes, injunctions may be granted to 
prevent the media generally giving certain information, for instance the identification of 
children in wardship or childcare proceedings. Such injunctions will usually be notified to all 
programme areas by Programme Legal Advice Department. 
  
Care should be taken when there is an injunction or interdict against another part of the media 
preventing their publishing certain information. If we broadcast the same material we would 
not be in breach of the injunction but might be in contempt of court. If in doubt, seek the 
advice of BBC lawyers.  
 
Programme-makers dealing with highly contentious factual subjects, or with people or 
organisations with a history of litigation, must be alert to the possibility of injunctions. 
  
Producers must be able to organise at short notice evidence to help the BBC resist 
applications for injunctions.
 
  
The Programme Legal Advice Department must be consulted at the earliest possible 
stage in any case where there is a risk of a BBC programme being served with an 

 
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injunction.
 
  
  
4 IDENTIFICATION OF CRIME VICTIMS AND WITNESSES 
In legal cases where the law or editorial policy requires the protection of the identity of 
individuals, producers should note that anonymity plainly means no name, no address and no 
photograph. It also means no strong clues. 
  
When contributors ask for anonymity 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 situations require careful judgement. Err on the side of caution where anonymity is 
concerned, but do not suppress valid journalism unnecessarily. 
  
There is a range of cases where the identity of one or more of those involved, including 
witnesses, may not be reported. A breach of such a ruling would be contempt of court.  
  
4.1 Identification of children 
There are various laws protecting children from being identified in court proceedings. 
Refer to Chapter 14; Children And Programmes for full details.
  
  
4.2 Courts Sitting in Private 
It is a contempt to broadcast detailed accounts of certain proceedings in courts sitting in 
private. This will include proceedings involving children, e.g. wardship, adoption or 
guardianship, or proceedings where the court sits in private for national security reasons. In 
wardship cases it is not a contempt to report the court's order or an accurate summary of it, 
unless the court expressly forbids this.  
  
4.3 Victims of Sexual Offences 
The BBC does not normally reveal the identity of victims of sexual crimes. This has long 
been BBC policy and, in England and Wales it is now required by law. 
  
The law prevents the identification of victims of rape and other sex crimes, including incest, 
underage intercourse, child abuse, buggery and indecent assault. 
  
Judges may, on occasion, lift the restriction. At the request of the defence, they can do this to 
get witnesses to come forward and to ensure a fair trial, or to allow the reasonable reporting 
of a case of public interest. If a victim were identified in another, unrelated, criminal case, 
then the reporting of that case would not be restricted. 
  
Victims can be identified if they agree to it. The consent should be in writing and must not be 
the result of any pressure. 
  
The courts may be asked at times to restrict more information on the grounds that it would 
lead to the identification of the victim.  
  
4.4 "Jigsaw" Identification 
It is not enough that we do not name the victims of sexual crime. We need to take special 
precautions to avoid what is known as the "jigsaw effect". This happens when different news 
 
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organisations give different facts about the vi
 
ctim, which can then be pieced together. The 
risk is at its highest when reporting sexual crime within the family, where naming the accused 
and the alleged offence could in effect identify the victim. In 1993 most newspapers and 
broadcasters agreed in principle that in such cases we will report the name of the 
accused/convicted person but we will refer to the crime merely as "a serious sexual offence". 
Where the accused and the victim are related, if we identify the accused we should refer to the 
victim merely as "a young woman", "a child" and so on.  
  
The objective, however, is to protect the victim. In some individual cases some sections of the 
media have published details of the offence. In these circumstances it may be necessary for 
the BBC to follow suit and avoid naming the offender. One way or another, we must not 
complete the jigsaw. In such situations Programme Legal Advice and Editorial Policy should 
be consulted. 
  
In other cases where there is a danger of the jigsaw effect, we should avoid any detail that 
might, with corroborating facts, lead to identification. Take care not to give an address, any 
link with another person in the story, or any link between the victim and the scene of the 
assault. 
  
These restrictions may make it difficult or impossible to convey in our reporting the incidence 
of certain sexual crimes by reference to individual cases. Programmes should still address 
these issues but without referring to identifiable instances.  
  
5 TRESPASS 
Trespass can be defined as unauthorised entry onto private property. This should never be 
taken lightly by programme makers. However, in most cases trespass is a civil offence. It is 
usually a matter between the BBC and the lawful occupier and there is no question of 
programme makers committing a criminal act. 
  
In general, we should ask for permission before entering private property. But private 
property can be anything from an individual’s home to a public shopping precinct, and no 
blanket rule can apply. Programmes must be satisfied that, where permission has not been or 
could not be granted, it is appropriate in the circumstances for the BBC to proceed. 
  
Whenever we are on private property and are asked by the legal occupier to leave, we should 
do so promptly. 
  
In some circumstances trespass can also be a criminal offence. The law is designed to cover 
demonstrations and large gatherings of people on private land. Normal journalistic activity 
seems unlikely to lead to a prosecution. But the law could affect coverage of demonstrations 
and “doorstep" interviews on private land. 
  
Programme makers intending to gather material on private land in the open air without 
permission should: 
  
• 
ensure their activities do not impede or obstruct people going about their lawful business 
  
• 
keep the numbers of BBC people present to an absolute minimum 
  
• 
remain on private land for the minimum amount of time necessary 
 
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• 
limit verbal contact with those going about their lawful activity so that our questioning of 
them does not disrupt that activity 
  
Police officers present at the scene have powers to order people to leave private land if they 
reasonably believe that criminal trespass may be committed. If programme makers are present 
on private land in the open air and are asked to leave by police they should do so 
immediately, and should not return. The very act of returning could itself constitute a criminal 
offence. 
  
Programme makers in doubt about gathering material on private land in England, Wales, and 
Northern Ireland without permission should consult the Programme Legal Advice Department 
and, through Heads of Department or Commissioning Executives, Controller Editorial Policy.  
  
5.1 The law in Scotland 
The laws of trespass in Scotland are different from those of England and Wales, though the 
Criminal Justice and Public Order Act of 1994 does apply in Scotland and creates the same 
trespass offences in Scotland as in England, Wales and Northern Ireland. Traditionally the 
law of trespass is interpreted more liberally in Scotland with free access to the Scottish 
countryside, irrespective of ownership, being regarded as the norm. Nevertheless programme 
makers should generally ask for permission before entering private property and observe the 
guidelines in section 5 of this chapter. Programme makers may seek advice from the BBC’s 
solicitor in Scotland, who is based at Broadcasting House, Glasgow.  
  
6 REPORTING OF COMMITTAL PROCEEDINGS 
Reporting of committal proceedings in England and Wales is restricted by the Magistrates 
Court Act 1980 and earlier legislation. Restrictions may be lifted by the court on application 
by the accused. If they are not, only the following categories of information can be reported: 
  
• 
the name of the court and the names of the magistrates 
  
• 
the names, addresses, occupations and ages of the defendant and witnesses 
  
• 
the offence in the charge 
  
• 
the names of counsel and solicitors 
  
• 
the decision of the court on whether to commit for trial 
  
• 
the charges on which the defendant is committed 
  
• 
the court to which the defendant is committed 
  
• 
the date and place to which any committal is adjourned 
  
• 
whether bail is granted or refused - but not the reasons for refusal. 
 
7 OBSCENE PUBLICATIONS ACT 
The Obscene Publications Act applies to broadcasting as well as printed material. It is an 
offence to broadcast anything that would "tend to deprave and corrupt". Such a broadcast 
 
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could be defended in court if it was "in the interests of science, literature, art or learning, or of 
 
other objects of general concern". 
  
Producers should also be aware of undertakings on taste and decency given by the BBC 
outlined in the Agreement attached to the Corporation’s Charter (see also Chapter 6: Taste 
and Decency).  
  
8 EUROPEAN DIRECTIVE: TELEVISION WITHOUT FRONTIERS 
The European Commission TV 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”. Articles 22.2 and 22.3 also require Broadcasters to use 
“acoustic” or visual warnings to alert viewers to other programmes “which are likely to 
impair the physical mental or moral development of minors”. The BBC must comply with the 
terms of this directive. 
  
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 feels that any material they are dealing with might do this should seek urgent 
advice from their line management, who must consult Editorial Policy. 
  
The BBC’s guidelines on content warnings, presentation announcements, and use of the 
Watershed are outlined in Chapter 6: Taste and Decency.  
  
9 RACIAL DISCRIMINATION 
Section 70 of the Race Relations Act, 1976, makes it "an offence to publish or distribute 
written matter which is, or to use in any public place words which are, threatening, abusive, 
or insulting in a case where hatred is likely to be stirred up against any racial group". 
  
An offence can be committed even if there is no intent on the part of the speaker or writer. 
Journalists must exercise particular caution when reporting events or issues in this area which 
are contentious (e.g. an inflammatory speech by a politician). The Attorney-General must, 
however, consent to the launching of a prosecution under this section. 
  
Programmes are also subject to the provisions of the Public Order Act that make it an offence 
to stir up racial hatred or to possess racially inflammatory material. No action can be taken 
against a programme without the consent of the Attorney General but there is provision for 
"search and seizure" of programme material. This could cause difficulties at a time of racial 
tension.  
  
10 DATA PROTECTION ACT 
The Data Protection Act 1998 gives people certain rights in relation to information stored 
about them. The Act applies to all electronic systems for storing information, including 
images and sound recordings. There is a limited media exemption for material aquired for 
“journalistic, artistic or literary” purposes. 
  
 
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me makers with any queries about the Data Protection Act should contact the BBC’s 
Data Protection Officer. Any formal requests for information under the Act must be dealt 
with by the Data Protection Officer. Where there is a danger of a prosecution under the Act 
programme makers should contact Programme Legal Advice and the Editorial Policy Unit.  
  
11 CONFIDENCE 
The law recognises various categories of confidential relationship. These occur mainly in the 
world of commerce and employment, and in domestic life. Confidential information generated 
or disclosed within such relationships is protected by law, and it is ultimately for the courts to 
decide whether the information is confidential. A threatened breach of confidence may be 
subject to an injunction. Moreover, if the BBC is notified of an order against another media 
defendant, it will be bound by it and will risk being in contempt of court if it fails to observe 
the terms of the order. Confidence may also attach to formats or ideas for programmes 
submitted to the BBC by third parties. 
  
In news broadcasting, there will often be a public interest defence, and it is generally a good 
defence that the material is in the public domain.  
  
12 USE OF ANIMALS 
Animals performing in programmes must be registered in accordance with the Performing 
Animals (Regulation) Act, 1925. Owners and trainers whose animals are used in a programme 
must comply with the registration provisions of the Act. They should be asked to show their 
registration certificates before their contract with the BBC starts. Local Environmental Health 
Officers require notification of any wild animals brought into the studio.  
  
13 HEALTH AND SAFETY 
An extensive body of law, civil and criminal, covers the health and safety of employees and 
the public. Advice is given in a range of BBC publications. Advice should also be sought 
from the Manager Safety Services, or from BBC lawyers. 
  
Should any material be obtained by recklessly or wilfully endangering a member of the 
production team, an artist or a member of the public, the BBC may decide not to transmit the 
material and may take disciplinary action. Those responsible may also be liable to 
prosecution.  
  
13.1 Flashing Images and Repetitive Patterns on Television (“Strobing”) 
Fast cutting and flashing or intermittent lights in television programmes can cause problems 
for some viewers who have photosensitive epilepsy. It is estimated that about one person in 
four thousand is susceptible. Many of those who experience seizures have their first while 
watching television. People under 20 are the most susceptible group and many are 
unaware of their susceptibility.
 
  
Television presents some inherent risk because it is a flickering medium. But that risk can be 
reduced by following some basic rules, which have been endorsed by BBC Occupational 
Health. 
  
Programme content should not flash, flicker or change at a frequency greater than three times 
per second. This applies where there is a visible change in brightness of more than ten percent 
of the screen area. 
  
 
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Prom
 
inent and regular patterns - especially light and dark bars and checks which cover a large 
proportion of the screen - should be avoided. Flickering or reversing patterns are particularly 
hazardous. Those which flow smoothly do not cause problems. 
  
Flashing or flickering images involving red are dangerous and should be avoided. 
  
Where it may be difficult to minimise the effects, for example with a live news report, and 
there is significant risk, viewers should be given an appropriate warning. But this should not 
be used as a substitute for careful shooting and editing. 
  
For further guidance, contact Presentation Control 
  
13.2 Images of Very Brief Duration 
Section 5.1 (f) of the Agreement associated with the BBC’s Charter states that BBC 
programmes should not "include any technical device which, by using images of very brief 
duration or by any other means, exploits the possibility of conveying a message to, or 
otherwise influencing the minds of, persons watching or listening to the programmes without 
their being aware, or fully aware, of what has occurred.” Any programme maker who feels 
their programme might contain such images should consult their editor, line manager or 
commissioning executive, who can contact Editorial Policy for further advice.  
  
14 REPEATED PROGRAMMES 
When repeated, programmes should be subject to the same legal scrutiny as when they were 
originally transmitted. Special care should be exercised in relation to questions of contempt, if 
someone featured in an original transmission is arrested prior to its repeat. 
  
It is no defence in a defamation action to argue that material has already been shown (see also 
Chapter 21: Re-Use and Reversioning of Television Programmes).  
  
15 FURTHER ADVICE 
Programme makers who are in doubt about any aspect of the law as it applies to programmes 
should consult the Programme Legal Advice Department.  
 
CHAPTER 38 
MATTERS OF LAW: DEFAMATION 
  
1 GENERAL 
2 PICTORIAL DEFAMATION 
3 NEGATIVE CHECKS 
3.1 General 
3.2 Problem Areas 
 
1 GENERAL 
If we broadcast something about an individual, a group or an organisation which is 
defamatory we may commit libel. The risk exists whether the defamatory statement is scripted 
or spoken off-the-cuff, and the BBC is liable no matter who speaks the words in its 
programmes - and no matter whether the programme is a factual programme or a drama, made 
'in house' or by an independent, or wherever in the world it is broadcast. 
  
The tests normally applied by the courts to determine if a statement is defamatory include: 
  
 
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does it reduce a person in the eyes of right-thinking people? 
  
• 
does it cause a person to be shunned or avoided? 
  
• 
does it expose the person to hatred, ridicule or contempt? 
  
• 
does it injure them in their office, profession or trade? 
  
 
The principal defences to libel are: 
  
• 
Justification ("veritas" in Scotland): proving that the statement is true. 
  
• 
Fair comment on a matter of public interest: showing that the statement was an honest 
opinion based on provable fact, was not prompted by malice, and was on a matter of 
public interest. 
  
• 
Privilege: statements made during broadcasts of fair and accurate reports of judicial and 
parliamentary proceedings and public meetings will haveprivilege in libel proceedings. 
This means that for normal purposes we are safe to report comments made as part of 
parliamentary proceedings or of court proceedings, in certain state documents, or made 
during the course of meetings which are freely open to the general public. 
  
These are complicated defences which apply to a wide range of programmes and reports. If 
anything in your programme is potentially defamatory, you should seek the help of the 
Programme Legal Advice Department. 
  
2 PICTORIAL DEFAMATION 
It is possible to defame people by juxtaposition of words and pictures. This may happen by 
the careless use of general background shots (or "wallpaper"). For example: 
  
• 
a general view of a football crowd, in which individuals are clearly identifiable, with a 
commentary about hooligans 
  
• 
a general view of a children's playground, in which children are recognisable, with a 
commentary about child abuse 
  
• 
a graphic of holiday brochures, with a commentary about holiday companies going bust 
  
• 
a general view of Muslims, in which individuals are clearly identifiable, with a 
commentary about alcohol 
  
Another way of pictorially defaming people is in the use of imprecise shots: the picture of a 
plain clothes policeman handcuffed to an arrested man, in which it is not clear which man is 
the criminal; or the picture of a suburban house which is an alleged bomb factory, in which 
the numbers of two houses are both shown, and it is not clear which house is being referred 
to.  
  
3 NEGATIVE CHECKS 
  
 
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3.1
   General 
The negative check system tries to ensure that a name invented for a BBC programme or 
publication does not exist in reality or that its use is not defamatory. Expensive legal action 
could result from misusing a real name. 
  
Negative checks for all output areas are carried out by the Information Research Library at 
Television Centre. 
  
A wide range of items can be checked including addresses, flight numbers, clubs, companies, 
products and trade names, dentists, doctors, lawyers, MPs, judges, schools, shops, ships, and 
so on. 
  
The checking system takes about two weeks. It is best not to ask too early because clearances 
can become outdated. When a name is submitted, two alternatives should also be included. 
  
Use of some names may infringe the rights of third parties. The checking system includes a 
basic trade mark search but further advice should be obtained from the Intellectual Property 
Department if the position is unclear.  
  
3.2 Problem Areas 
In the Register of Limited Companies some small firms are listed by area. If a name is to be 
checked in the Companies Register the precise setting and location of the production should 
be included; so, too should the period (i.e. 1920s, 1950s etc). 
  
At the Driver and Vehicle Licensing Agency in Swansea fictitious car numbers are available 
but they must not be used on public roads. To do so is an offence. 
  
Registered trade marks can sometimes mistakenly be used as generic terms. Apart from 
giving uncalled for publicity when the context is favourable or neutral, there is a risk of legal 
action when registered trade marks are used generically. Rather than use a term such as 
"Hoover", "Outward Bound ", or "Portakabin" we should use the proper generic "vacuum 
cleaner", "activity holiday" or "portable building".  
 
 
The Intellectual Property Department can advise whether terms which are in common use are 
registered as trade marks.  
 
CHAPTER 39 
MATTERS OF LAW: CONTEMPT 
  
1 WHAT IS CONTEMPT OF COURT? 
2 THE DANGERS OF COMMITTING CONTEMPT 
3 DEFENCES AGAINST CONTEMPT 
 
1 WHAT IS CONTEMPT OF COURT? 
Contempt of Court arises if an action or statement gives rise to a substantial risk that the 
course of justice will be seriously impeded or prejudiced. All courts exercising the judicial 
power of the state are covered by contempt, from the Coroner's and Magistrates Courts to the 
House of Lords. Contempt rules also apply to some Royal Commissions and Tribunals. 
  
 
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Courts possess considerable powers in this area and use them
 
 frequently. In Scotland, the law 
is robustly applied. For example, Scottish courts almost invariably regard publication of a 
picture of a defendant (known in Scotland as an " accused ") as a serious contempt of court. 
  
Generally contempt risks arise only when proceedings are 'active'. In most criminal cases the 
‘active’ period starts with the arrest of a suspect or the issue of a summons; in most civil 
cases, it starts when arrangements are made for a hearing. There are exceptions to this, 
especially in Scotland. The 'active' period ends once sentence is passed in criminal cases and 
when judgement is given in civil cases. Consult BBC lawyers in cases of doubt.  
  
2 THE DANGERS OF COMMITTING CONTEMPT 
For BBC journalists, the main hazards during the active period are: 
  
• 
broadcasting pictures or comment which could influence those involved (witnesses, 
judges, jurors, lawyers and parties in the action). A detailed account of evidence likely to 
be given in a case would run the risk of contempt if broadcast during the active period 
  
• 
broadcasting material which could affect the way in which one of the parties conducts the 
case 
  
• 
broadcasting an interview with a witness before the case is over 
  
• 
having dealings with witnesses (e.g. interviews, or negotiations over possible interviews) 
which might influence or be thought likely to influence their evidence 
  
• 
speaking to a juror in a case, about the case (see below) 
  
• 
reporting what a judge has forbidden to be reported 
  
• 
speculating about the outcome of a case 
  
• 
commenting on a case due for retrial 
  
• 
repeating what is said in court in the absence of the jury. 
  
A particular risk of contempt arises where there is a proposal to talk to a juror about 
the case they are involved in. This applies at any time before, or during the hearing - 
and applies whether or not the report is actually transmitted. After the case is over it 
may be permissible to interview jurors but it is a serious offence, for them and for the 
BBC, if they discuss the deliberations (i.e. statements made, opinions or arguments 
expressed or votes cast by jurors) in the jury room. This applies whether or not such 
comments are broadcast. Any proposal to speak to a juror in a case must be referred to 
Programme Legal Advice. 
  
Although journalists run the most obvious risks, contempt may be committed in other kinds of 
programmes, for example in a dramatisation of contemporary court proceedings. Any 
department dealing with a real case must take care. 
  
See also section 3 “Dealing With Witnesses" in Chapter 15: Crime.  
  
 
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3 DEFENCES AGAINST CONTEMPT 
 
The defence of public interest is of very limited value in cases of contempt. Judges may 
overlook minor or unintentional acts. They may also resist attempts by third parties to use 
contempt as a means of preventing the broadcasting of material of proper interest to the 
public. 
  
There is a statutory right to provide a fair, accurate and contemporaneous account of court 
proceedings heard in public, but this right is qualified. Judges have the freedom to postpone 
the reporting of an entire case or certain details of it. Reporting is also constrained by 
statutory restrictions on coverage of committal hearings in magistrate’s courts, and of 
preparatory hearings in Crown Courts, and by restrictions relating to courts dealing with 
sexual offences, juvenile and matrimonial matters (see also Chapter 14: Children And 
Programmes). 
  
Programme makers who feel they may be in danger of committing contempt of court should 
consult the BBC’s Legal Advice Department.  
 
CHAPTER 40 
MATTERS OF LAW: COPYRIGHT AND OTHER INTELLECTUAL PROPERTY 
RIGHTS 
  
1 GENERAL 
2 COPYRIGHT, MORAL RIGHTS AND PERFORMERS’ RIGHTS 
2.1 Copyright works 
2.2 Use of Copyright Material without Permission 
2.3 Music Copyright 
2.4 Video and film copyright 
2.5 Moral rights 
2.6 Performers’ Rights 
3 TRADE MARKS 
4 PATENTS AND PROGRAMMES FEATURING INVENTIONS 
5 PASSING OFF 
6 CONFIDENTIALITY 
 
1 GENERAL 
“Intellectual Property rights” are the legal rights that protect the products of the human 
intellect. They include statutory rights of copyright, moral rights, performers’ rights, trade 
marks, patents and designs, and rights to prevent “passing off” and breach of confidence. 
  
The Intellectual Property Department in Legal Adviser’s Division gives advice on all 
aspects of the protection and exploitation of the BBC's intellectual property rights, and 
the infringement of such rights. 
  
2 COPYRIGHT, MORAL RIGHTS AND PERFORMERS’ RIGHTS 
The laws of copyright exist to protect and reward creators and owners of original work, 
including books, films, and songs. Copyright is one of the most complex areas of the law 
affecting programmes. There are no simple answers to some copyright problems. 
  
Producers wishing to commission or clear copyright works for use in BBC programmes 
or to contract performers must seek advice from the Rights Group in BBC Production. 
Rights Group will generally provide the contracting service and contact should be made 

 
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w
  ith them as early as possible.  
  
2.1 Copyright works 
Copyright exists in a wide range of creative works, for example: 
  
• 
literary works: scripts, novels, poems, essays, letters, lyrics or newspaper articles 
  
• 
paintings, photographs and other visual images 
  
• 
sculptures, models, architecture and works of artistic craftsmanship 
  
• 
tables (eg timetables), compilations, databases and computer programs 
  
• 
dramatic works, plays, dance and mime 
  
• 
music 
  
• 
sound recordings, including gramophone records, CDs, audiocassettes and any other sort 
of recording 
  
• 
any recording that can produce moving images, eg film, video and videodiscs, or moving 
images generated on computer displays 
  
• 
radio or television broadcasts (terrestrial and satellite), cable programmes and online 
services 
  
• 
the typographical arrangement of a published work. 
 
2.2 Use of Copyright Material without Permission 
Copyright may not have to be cleared if the work or the use of it falls under the categories 
below. However, these possible exceptions should always be checked with the Rights Group. 
  
• 
works that are "out of copyright" 
  
• 
insubstantial part: some short extracts of copyright works can be used without consent - if 
they are "insubstantial" parts of the whole work 
  
• 
fair dealing: there are exceptions in the 1988 Act which allow fair dealing with a 
copyright work for certain purposes. These include criticism or review (with a suitable 
acknowledgement), or reporting current events 
  
The main UK broadcasting organisations have signed an agreement governing the use of each 
other’s sports footage in news programmes. Programme makers working in this area should 
consult the Sports News Access Code Of Practice 
  
• 
incidental inclusion: copyright in a work is not infringed by its incidental inclusion in a 
radio or television programme, for example a news report or location shot which 
incidentally includes a painting in the background 
  
• 
spoken words e.g. interviews 
 
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• 
artistic works in public places: This exception does not apply to paintings (or other 
graphic works) or photographs 
  
• 
other exceptions: Ideas as such are not protected by copyright. A succession or 
combination of ideas such as the plot of a novel may however qualify, and the law of 
confidentiality may also apply 
 
2.3 Music Copyright 
The Music Copyright section in the Rights Group will advise on all aspects of music and 
recordings of music to be included in BBC programmes. 
  
The BBC has various special arrangements for the music it includes in its output. Music 
Copyright covers three main areas:  
  
Payment of composers/writers 
The BBC has agreements with the societies that collect royalties on behalf of composers (the 
Performing Rights Society and the Mechanical Copyright Protection Society). These 
agreements allow the Corporation to broadcast and record the PRS/MCPS repertoire. No 
advance clearance is needed, nor are any direct charges made to programmes for this material. 
However, programmes containing "dramatico-musical" works (such as operas, ballets, 
musicals) and parodies and burlesques are not included. 
  
All music (even an insignificant or background use) must be reported on the programme’s 
music reporting form. 
  
Commercial Gramophone Records, CD's Tapes etc. 
The BBC has agreements with Phonographic Performance Limited which collects royalties on 
behalf of most record companies. These agreements allow the Corporation (with certain 
limitations) to broadcast and dub (re-record) commercial sound recordings made by PPL 
members. For advice on the current limitations, please consult Music Copyright. 
  
Material can be broadcast in return for the appropriate payment. There is no exemption for 
review purposes. Special clearance may be needed for recordings, which are not subject to 
these agreements. 
  
Special clearance may be needed for recordings which are not subject to these agreements and 
for records dubbed into television programmes that will be sold outside the UK. The use of all 
commercial sound recordings must be reported on the music reporting form. 
  
Specially Commissioned Music 
The Music Copyright section within Rights Group is responsible for all music specially 
commissioned by the BBC.  
  
2.4 Video and film copyright 
Extracts from commercially produced films or videos are subject to a number of rights 
agreements. Advice on use of material and relevant payment should be sought from 
Television Programme Acquisition Department.  
  
2.5 Moral rights 
 
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These are the rights to be credited as author or director, not to have one’s work subjected to 
 
“derogatory treatment”, not to have work incorrectly attributed, and of privacy in relation to 
privately commissioned photographs, videos and films. 
  
Advice on moral rights should be sought from the Rights Group.  
  
2.6 Performers’ Rights 
A similar right to copyright also exists in performances, for example: dramatic performances 
(including dance or mime), musical performances, readings or recitations of literary works, a 
performance of a variety act or similar presentation. 
  
The Rights Group will advise on all aspects of the contracting of performers for BBC 
programmes. Consent is required from the performer for the recording, broadcast or 
subsequent exploitation of the performance. Note that sound recordings or footage acquired 
from other producers or broadcasters may contain performances which require clearance.  
  
3 TRADE MARKS 
Trade marks are distinctive names, words or logos which identify a product or service as 
originating from a particular source. 
  
When deciding on a programme title or character name, producers should consider: 
  
• 
might the name infringe a third party's rights? (see also section 3 “Negative Checks” in 
Chapter 38: Defamation) 
 
• 
does any outside party - for example a performer or independent production company - 
consider that they might have rights in the title? 
 
• 
might the BBC wish to register the title as a trade mark (advisable for a long-running 
series or where “spin-off” products are envisaged)? 
  
Please refer any queries on trade marks to the Intellectual Property Department.  
  
4 PATENTS AND PROGRAMMES FEATURING INVENTIONS 
Patents grant monopoly rights to new inventions. 
  
Care should be taken by programmes intending to invite members of their audience to submit 
ideas for possible inclusion. The act of submitting an idea could be interpreted as making it 
available to the public, unless a confidentiality agreement is in place, and could therefore 
invalidate any subsequent patent application. 
  
Programme makers should consider whether any ideas submitted could amount to a new 
invention, and contain enough detail to describe the invention fully. If so, it may be necessary 
to incorporate a brief warning about possible patent implications into any material (i.e. on 
screen announcements, telephone hotlines) that solicits such ideas. Any material received 
should be treated in strict confidence and should not be broadcast without the specific consent 
of the contributor. 
  
Please refer any queries on patents to the Intellectual Property Department.  
  
 
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5 PASSING OFF 
 
Broadly speaking,” passing off “ means taking advantage of someone else’s reputation to 
promote a product or service. The BBC’s rights may be infringed where a third party makes a 
misrepresentation that is damaging to its reputation and goodwill. This may occur through 
unauthorised use of a well known programme name, or by suggesting that the BBC has 
endorsed a product, for example by advertising it "as featured" on a BBC programme. But 
care should be taken by BBC Producers to avoid the use of a programme title which suggests 
a connection with a product or service in which a business reputation has been built up by 
someone else. 
  
Please refer any queries on passing off to the Intellectual Property Department.  
  
6 CONFIDENTIALITY 
The law recognises various categories of confidential relationship. These occur mainly in the 
world of commerce and employment, and in domestic life. Confidential information generated 
or disclosed within such relationships is protected by law. A threatened breach of confidence 
may be subject to an injunction. Moreover, if the BBC is notified of an order against another 
media defendant, it will be bound by it and will risk being in contempt of court if it fails to 
observe the terms of the order. Confidence may also attach to formats or ideas for 
programmes submitted to the BBC by third parties, and care should be taken always to put in 
place appropriate contractual arrangements. 
  
Any queries on breach of confidence should be referred to the Intellectual Property 
Department.  
 
CHAPTER 41 
RELATIONS WITH THE PUBLIC AND THE PRESS 
  

1 GENERAL 
2 DEALING WITH ENQUIRIES 
3 COMPLAINTS 
4 KEEPING PROGRAMMES 
5 RELATIONS WITH THE PRESS 
5.1 General 
5.2 BBC Publicity Departments 
5.3 Publicity Material 
5.4 The Corporate Press Office 
5.5 Controversial issues 
5.6 Letters And Articles for Publication 
 
1 GENERAL 
As a public institution the BBC must account to the public for all its dealings. 
  
We have to monitor and respond to public concerns, whether these concerns arise in letters, 
phone calls or e mails, are raised through the press or other media, or through more formal 
means. It is also important to have opportunities for the public to express opinions about 
programmes both on air and online. We should try and ensure that every experience of 
dealing with the BBC is a positive one. 
  
 
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Most of the unsolicited contacts the BBC attracts are from
 
 people stimulated by, and 
supportive of, our programme making. They want more information about something which 
interests them. 
  
Members of the public make no distinction between programmes made by BBC “in house” 
and those made by independent production companies. The BBC is accountable for all of 
them. Independent productions must make adequate arrangements for follow up enquiries or 
complaints. 
  
2 DEALING WITH ENQUIRIES 
Letters, phone calls and e-mails from the public are an important source of information and 
the BBC aims to respond quickly and courteously to comments and questions. 
  
In the first instance unsolicited enquiries from the public are dealt with by the BBC’s 
Information Centre in Belfast (or the Scottish and Welsh BBC Information teams), who will 
then liase with the relevant department about enquiries that require a more detailed response. 
Where appropriate, factual information can be provided about programmes in advance to 
BBC Information, to help them deal with enquiries. 
  
The telephone number for the BBC’s Information Line should not be trailed on air. 
Programme makers who wish to solicit contacts from audiences should use the BBC’s 
Audience Lines based in Glasgow (see Chapter 32: Phone Ins and Telephone Services in 
Programmes). 
  
Where practicable, we should answer all letters, particularly when viewers or listeners raise 
important questions and complaints, as soon as possible. Where a reply cannot be sent 
promptly, a holding letter or e mail should be sent, explaining the reasons for the delay. 
Replies should be courteous and sensitive. Where there has been a genuine error it is best to 
make a frank admission and offer an apology if appropriate. 
  
If viewers’ and listeners' letters, phone calls or emails are to be quoted on air, permission to 
broadcast them should be asked for. The selection of extracts for broadcasting and voices to 
read them needs to be done with care, to avoid charges of trivialising or patronising the 
audience 
  
In the World Service, most letters and e-mails about programmes which require answers are 
dealt with by International Audience Correspondence who also deal with telephone enquiries.  
 
Sometimes requests are made for BBC programme material both transmitted and 
untransmitted. For detailed guidance on these issues consult Chapter 14: 
Confidentiality And Release Of Programme Material.
  
  
3 COMPLAINTS 
Complaints warrant a well-judged and prompt reply. We should ask whether a point made is 
reasonable. If it is we should do something about it. If it is not we should reject it - 
courteously. 
  
Remember that viewers and listeners have a right to expect our programmes to have been 
made in accordance with these Producer Guidelines. If we have departed from them we will 
need to explain the reasons why. 
 
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The BBC’s Programme Complaints Unit deals with serious complaints (see Chapter 42). 
Before referring a member of the public to the PCU, the unit should be contacted to establish 
whether the complaint is within its remit. 
  
It is important to alert BBC lawyers, through Heads of Department or Commissioning 
Executives, to enquiries which threaten legal action.  
  
4 KEEPING PROGRAMMES 
The BBC and other broadcasters are obliged by law to keep recordings of all programmes 
broadcast. Television recordings have to be kept for 90 days from broadcast; radio recordings 
for 42 days. When a programme is repeated the period starts from the day of the repeat. 
  
These recordings are called for to meet the needs of the Broadcasting Standards Commission 
when they consider complaints (see Chapter 43 )and also to satisfy the requirements of the 
law on obscene publications and on racially inflammatory material.  
  
5 RELATIONS WITH THE PRESS 
  
5.1 General 
The Press is a major source of information to the public about the BBC. The Press and Media 
also provide the BBC with information about its audiences’ opinions and attitudes. Good 
relations are obviously important. All our dealings with the media should adhere to high 
standards of integrity. Statements, information and publicity material, must uphold BBC 
values such as fairness, accuracy and impartiality (see section 5.3).  
  
5.2 BBC Publicity Departments 
Publicity departments provide a specialist link between programme makers and the press and 
media. They help producers win attention for their programmes. They also have expertise in 
dealing with sensitive issues. It is sensible to involve publicity people at an early stage, either 
in publicising a programme or coping with interest on a controversial matter.  
  
5.3 Publicity Material 
The BBC often puts out advance press releases and publicity material to publicise its own 
programmes. This is an important part of drawing the audience’s attention to BBC 
programmes. However it is important that in rightly trying to sell our own programmes we do 
not do so in a way which either unfairly distorts or over-simplifies the content of the 
programme. The impact of a programme over which a great deal of careful judgement has 
been exercised, in getting the emphasis and tone of the programme just right, can be negated 
or obscured by a careless or over-hyped press release. BBC publicity material must adhere to 
the same principles of fairness and impartiality as the programmes which such material 
publicises. 
  
In particular, care should be taken to ensure that in publicity material: 
  
• 
quotes from contributors are used in a way which takes account of the context in which 
they are used in the programme. 
  
• 
where important elements of context have been included in the programme this is also 
reflected in the press release 
 
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• 
in programmes with a long lead time it may sometimes be necessary to remind 
contributors that publicity material about the programme may be released in advance of 
the programme 
  
• 
any reporting of the results of polls and surveys in press releases meets the Producer’s 
Guidelines on the reporting of polls (see Chapter 35: Opinion Polls) 
  
Programme and publicity teams should also be aware that press releases can sometimes raise 
as many legal issues as the programme itself. Programme Legal Advice should be asked to 
look at any publicity material about a programme which has required legal clearance.  
  
5.4 The Corporate Press Office 
The Corporate Press Office deals with the media on all corporate matters and also handles 
general queries from newspapers. 
  
Outside normal office hours, and up to 11pm every night, the Corporate Press Office acts as 
the spokesman for all matters relating to the BBC’s activities. The Press Office should be 
informed of developments in any running BBC story so that comments made to the media on 
behalf of the Corporation are well informed and up to date.  
  
5.5 Controversial issues 
BBC programmes can be controversial. This can be known in advance or anticipated; but it 
can also come without warning before or after transmission. Advance publicity can 
sometimes be damaging and must be calculated carefully. 
  
Producers should make sure that publicity departments and BBC Information are fully 
informed about any actual or likely controversy and know who to get in touch with for further 
information. All contacts with the press on controversial matters - whether to do with BBC 
policy or programmes - should be handled through Press and Publicity. BBC contracts of 
employment are specific about relations with the press and media, particularly speaking to or 
writing for the press. Copies of programmes or of scripts should not be released without 
approval. In an increasingly competitive broadcasting environment, information is valuable 
and should not be used carelessly. Inexperienced programme people should be forewarned 
against attempts to get information and material. Before speaking to the Press or media, 
approval should be sought from Press and Publicity, who will consider, and advise on, the 
wider implications of commenting or making a statement.  
  
5.6 Letters And Articles for Publication 
BBC people intending to write letters and articles dealing with BBC issues should seek 
approval from their Head of Department (see also Chapter 10: Conflicts of Interest). Letters 
should also be cleared by Press and Publicity. Press officers can advise on style, tone and 
timing and help ensure that letters are published.  
 
CHAPTER 42 
PROGRAMME COMPLAINTS UNIT 
 
Viewers and listeners with serious complaints about what is broadcast by BBC licence fee 
funded services on television, radio and online may write to the Head of Programme 
Complaints, based in the BBC Secretary's office. The Head of Programme Complaints is 
 
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responsible for ensuring prom
 
pt investigation and reply. Programme makers are expected to 
co-operate fully with the Head of Programme Complaints’ enquiries. 
  
The Programme Complaints Unit provides a clear route for complainants who wish to take it. 
However, the fact that complaints can ultimately be dealt with centrally does not lessen the 
need for programme makers to reply promptly and adequately to letters addressed to them. 
When complainants are dissatisfied with the programme makers response it may be 
appropriate to refer them to the PCU- but always check with the Unit first, to establish 
whether the complaint is within its remit. 
  
The Governors' Programme Complaints Appeals Committee considers appeals from 
viewers and listeners who have complained about what we have broadcast and who are 
dissatisfied with the response from the Head of Programme Complaints or the relevant 
Directorate. Programme makers are expected to co-operate with the Committee's proceedings. 
The point of contact is the secretary to the Governors' Complaints Appeals Committee in the 
BBC Secretary's office. 
  
The BBC’s Board of Governors publish a quarterly bulletin outlining complaints that have 
been upheld. Where a complaint is upheld the bulletin also shows what action is being taken 
as a result. The bulletin is a public document, which is available on the BBC’s public web 
site. 
  
The Programme Complaints Unit does not deal with complaints about World Service or the 
BBC’s commercial and international television services. Serious complaints about 
programmes broadcast by the World Service are dealt with by the Chief Executive, World 
Service. Complaints about the BBC’s commercial and international television services are 
dealt with by the Head of Programming, International Networks, BBC Worldwide. 
 
CHAPTER 43 
THE BROADCASTING STANDARDS COMMISSION 
  
1 Publication of codes 
2 Complaints 
3 Who can complain? 
3.1 Fairness and infringement of privacy: 
3.2 Sex, violence and matters of taste and decency. 
4 What happens if the complaint is upheld? 
5 What other actions are taken? 
 
The Broadcasting Standards Commission publishes guidance on programme matters and 
considers complaints from the public about programmes. 
  
1 Publication of codes 
Under the Broadcasting Act 1996, the Commission has a duty to publish a code relating to 
broadcasting standards, offering guidance on the portrayal of violence, sexual conduct and 
general standards of taste and decency. All broadcasters in Britain are required to “reflect the 
general effect “ of this code, and its provisions have been taken into account in the 
preparation of the BBC’s Producers’ Guidelines. The BSC also has a duty to draw up 
guidance on fairness and privacy, and it also commissions research and other studies.  
  
2 Complaints 
 
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mission will consider complaints relating to 
  
• 
unjust or unfair treatment in a programme 
  
• 
unwarranted infringement of privacy in, or in connection with the obtaining of material 
included in, a programme 
  
• 
the portrayal of violence or sexual conduct in programmes 
  
• 
other matters of taste and decency. 
 
3 Who can complain? 
  
3.1 Fairness and infringement of privacy: 
Complaints about unfair or unjust treatment and infringement of privacy are referred to as 
“fairness” complaints. These may be lodged only by, or on behalf of a person or organisation 
“affected” by the programme concerned. However, complaints may be made on behalf of 
those affected - including those who have died within the preceding five years. The 
Commission may refuse to entertain a fairness complaint if it considers that the complainant 
has no “direct interest” in the matter, but it may interpret this latter phrase broadly. 
  
Similarly, in considering “unwarranted infringement of privacy” the key word will be 
“unwarranted”. Secret recording, for instance, may or may not be considered justified 
according to the circumstances. It is also possible that programme material gathered in a 
public place may be challenged on the grounds of infringement of privacy. The way that 
programme makers act in gathering material may constitute breach of privacy even if the 
material is not transmitted. 
  
The Commission cannot entertain a complaint if it is already the subject of court proceedings 
in the UK. However, complainants do not have to waive their legal rights in applying to the 
Commission and, because the line between unfairness and defamation is unclear, a complaint 
could be a rehearsal for a court action.  
  
3.2 Sex, violence and matters of taste and decency. 
Anyone may complain to the Commission about matters of taste and decency - “standards” 
complaints - within two months of the last transmission of a television programme and within 
three weeks of the transmission of a radio programme. The Commission has the power to 
extend these deadlines if it considers it appropriate to do so. The complainant does not need to 
have any direct interest other than to feel that the programme has breached standards of taste 
and decency.  
  
4 What happens if the complaint is upheld? 
If a complaint about fairness or standards is upheld, the Commission has the power to require 
broadcasters to publish a summary of the complaint and its findings on the complaint. The 
broadcaster may be required to publish the finding in the Press as well as on the air. The 
Commission normally requires publication for upheld fairness complaints, but it is very 
unusual for it to require publication for an upheld standards complaint.  
  
5 What other actions are taken? 
 
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mission has no power to punish other than to require the broadcasting and/or 
publication of findings as set out above. 
  
If it is proposed to re-broadcast a programme which has been the subject of a complaint 
upheld by the Commission, the Chief Executive Broadcast should be consulted about what 
changes, if any, are appropriate in the light of the finding. 
  
The contact point in the BBC for the cases before the Commission is The Head of 
Programme Complaints.
  
  
 APPENDIX 
  
Section 5.1 (c) of the Agreement associated with the BBC’s charter requires the BBC to do all 
it can to secure that all programmes : 
  
“ treat controversial subjects with due accuracy and impartiality, both in the Corporation’s 
news services and in the more general field of programmes dealing with matters of public 
policy or of political or industrial controversy, and do not contain any material expressing the 
opinion of the Corporation on current affairs or matters of public policy other than 
broadcasting and matter contained in programmes in either House of Parliament or 
proceedings of a local authority or a committee of two or more local authorities ;” 
  
Paragraph 5.2 also states : 
  
“ In applying paragraph 5.1(c) a series of programmes may be considered as a whole.” 
  
In order to fulfil the provisions of 5.1(c) above the Agreement requires the BBC to draw up 
an impartiality and accuracy code. The relevant sections of the Agreement are as follows : 
  
Section 5.3: 
  
“ The Corporation shall - 
  
(a) draw up, and from time to time review, a code giving guidance as to the rules to be 
observed in connection with the application of paragraph 5.1(c) in relation to its services and 
programmes; and 
  
(b) do all that it can to secure that the provisions of the code are observed in the provision of 
services and programmes 
  
and the Corporation may make different provisions of the code for different cases and 
circumstances." 
  
5.4 The rules specified in the code referred to in subclause 5.3 shall in particular, take account 
of the following matters:- 
  
(a)that due impartiality should be preserved on the part of the Corporation as respects major 
matters falling within paragraph 5.1(c) as well as matters falling within that provision taken as 
a whole; and 
  
 
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(b) the need to determ
 
ine what constitutes a series of programmes for the purposes of 
subclause 5.2. 
  
5.5 The rules so specified shall, in addition, indicate to such extent as the Corporation 
considers appropriate:- 
  
what due impartiality does and does not require, either generally or in relation to particular 
circumstances; 
  
the ways in which due impartiality may be achieved in connection with programmes of 
particular descriptions; 
  
the period within which a programme should be included in a service if its inclusion is 
intended to secure that due impartiality is achieved for the purposes of paragraph 5.1(c) in 
connection with that programme and any programme previously included in that service taken 
together; and 
  
in relation to any inclusion in a service of a series of programmes which is of a description 
specified in the rules:- 
  
(i) that the dates and times of the other programmes comprised in the series should be 
announced at the time when the first programme so comprised is included in that service, or 
  
(ii)if that is not practicable, that advance notice should be given by other means of subsequent 
programmes so comprised which included material intended to secure or assist in securing, 
that due impartiality is achieved in connection with the series as a whole; 
  
and those rules, shall, in particular, indicate that due impartiality does not require absolute 
neutrality on every issue or detachment from fundamental democratic principles.” 
  
Chapter 2 of the Producers Guidelines constitutes the BBC’s code as specified in 5.3 (a) 
above. Cross references given within Chapter 2 are for convenience to point to related 
guidance in the Producers’ Guidelines. This related guidance does not constitute part of the 
Impartiality and Accuracy Code. 
 
 
 
 
 
 
 
 
 
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