These notes give high level advice on the completion of each section of the compliance form along with references to the BBC Editorial Guidelines.
Introduction and Principles
Compliance ensures that the BBCs values are adequately reflected in all content. The BBCs key core values are impartiality, accuracy, fairness and editorial integrity. Maintaining trust with audiences by embodying these values is of vital importance and ensuring those values are not ignored or reflected inadequately is, in essence, what compliance is about.
Under the industry’s standard terms of trade the BBC expects independent Producers to deliver fully compliant output, including all promotional material. This means specifically that it conforms to BBC guidelines and particularly the Editorial Guidelines which are accessible online and available as hard copies to all independent producers.
There are two formal compliance transactions in the lifetime of a production:
During production it is the independent Producer’s responsibility to work in accordance with Editorial Guidelines and to inform the BBC Executive Producer of any new risks or issues that could affect the reputation of the BBC.
Independent Producers have access to Editorial Policy teams and to the BBC Programme Legal Advice Team but referrals should be made, at least in the first instance, through the BBC Executive Producer. The BBC Executive Producer is the BBC’s editorial safeguard and the final judgement about what is and is not permissible rests with them.
PDFs and useful links:
There must be a formal compliance conversation between the BBC Executive Producer and the independent Executive Producer at the moment of commission for all independent projects. These conversations should identify the specific problems and risks and discuss and draw up a plan for compliance accordingly. A written record must be kept by both parties. The Managed Risk Programme List will be discussed at this stage.
You can download a checklist of areas that might need to be covered in the compliance conversation and an additional checklist for areas to be discussed when children are to be present or otherwise involved in the production.
The Managed Risk Programme List (MRPL) is an early warning list that highlights specific editorial, legal, commercial or reputational risks. If the BBC Executive Producer puts a programme on the MRPL it does not mean the project is being managed badly but that extra care might be needed when handling the programme. The independent Executive will be informed if a project is included on the MRPL and should inform the BBC Executive if, in their view, a change in circumstances requires subsequent inclusion.
Fill in the programme information at the top of the form. The form cannot be saved without a minimum of Programme Title, Programme UID and the ‘Commissioned for pre/post-watershed’ question being completed.
The programme UID will be an eight character combination of letters and numbers. Ignore any prefixes (60 or 61). The first transmission version of a new programme is now usually given the suffix 01 with subsequent edits given 02, 03 etc. If in doubt, please refer to your BBC delivery contact.
This should be a short summary rather than a full synopsis, indicating the programme genre.
This section is usually only filled in after transmission if the programme is subject to a major complaint which may affect its compliance status if repeated. Please do not write anything other than complaints history information in this box (e.g. N/A or similar should not be entered).
N.B. It is the Production Division's responsibility (or for independents productions, the BBC Executive Producer) to complete an updated compliance form whenever a serious complaint is being entertained which may affect the programme's future compliance status. If the programme is subject to a Red Flag complaint, always give the BBC complaints reference number. Once the complaint has been resolved a further updated compliance form must be completed to record the finding.
Numbered sub-titles in this section will guide you through specific questions on the form. There are also links to the relevant Editorial Guidelines.
You must give a YES/NO answer to all questions, completing notes where necessary. Any detail you can supply - including time-codes - will save time and effort and reference back. In some cases it is essential to add a note to your answer.
The link will take you through to the relevant sections of the BBC Editorial Guidelines.
If you have sought legal advice, but there are no outstanding issues that TV should be aware of, then tick NO. Tick the YES box where there are continuing issues. In the notes indicate the subject of the legal issue (e.g. contempt, privacy etc) but do not detail the advice given.
The use of strong language must be editorially justified and appropriately signposted to ensure it meets audience expectations, wherever it appears. Attention should be given to musical lyrics used in soundtrack or performance, as well as spoken language and gestures. Section 5 Harm and Offence: Language
Tick YES, if the programme includes language that must not be transmitted before 9pm. Detail in notes the precise words used, with time-code references for first usage.
Please indicate if strong language/gestures occur near the start of the programme.
The inclusion of strong language/gestures in a programme should only be made in consultation with the BBC Executive Producer. Use of the most offensive words or phrases e.g. fuck, motherfucker, 'Jesus fucking Christ' and cunt require the advance approval of Channel Controllers and, in the case of the latter, the Director of BBC Vision.
Tick YES if there is any other offensive language (e.g. bloody, shit, arse, bollocks, bugger, wank etc).
If intended for pre-watershed transmission, detail in notes the precise words used, with time-code references.
There are a range of words (e.g. mong, spastic) which may be offensive to particular groups of viewers, for example, members of faith groups and people with disabilities. Racist abuse is offensive to all sections of the audience (e.g. nigger, paki, chinkie). Detail in notes the precise words used and the context with time-code references.
Tick YES if there is any kind of sexual activity depicted in the programme. Please give enough detail in notes to allow TV to make sensitive judgements about scheduling. Some disturbing scenes, e.g. of sexual violence against women (or men) should also be flagged up in the Violence section, and should be used only after consultation with BBC Executive Producers, Heads of Department and with Controllers.
Detail in notes whether verbal or visual. It may not be necessary to give precise details if the innuendo is relatively mild.
You should answer YES if nudity is featured in the programme, whether in a sexual or non-sexual context. Please indicate the context in notes. Nudity before the watershed must be justified by context.
All scenes containing violence must be noted.
Provide time-code references if possible but it is essential to indicate whether scenes occur near the start of the programme.
This section has relevance not just to factual and drama programmes, but may also apply to other genres like entertainment (e.g. spoof violence may be especially offensive when real life violence is in the news e.g. terrorist beheading).
Please note that this should include significant violence involving animals as well as people.
This section has relevance not just to factual programmes but may also apply to other genres like entertainment (e.g. spoof violence may be especially offensive when real life violence is in the news, for example terrorist acts such as bombings or beheadings). It does not apply purely to fictitious characters.
This section deals with the possibility of audiences, especially children, imitating anti-social, life-threatening or criminal behaviour e.g. hanging scenes. In some cases you may have already referred to them in the previous section. If so, tick YES, but do not repeat detail in notes.
This could include dangers around the house such as a child getting into a fridge or the use of domestic objects in violent acts.
Only tick YES if the activity is particularly prominent e.g. a contributor smoking or the context is unusual e.g. in children's programming.
You do not need to tick YES if the programme is for a general audience where the activity is not prominent and is justified by context e.g. scenes set in pubs or restaurants.
Offensive or stereotypical assumptions must be avoided and people should only be described in terms of their disability, age, sexual orientation and so on when clearly editorially justified. This can be a complex area where producers should take advice. It is an area of increasing sensitivity and complaint by viewers.
Indicate YES if there are significant and potentially controversial references to people of a particular faith, race, nationality or a minority including ethnic, gay and lesbian or people with disabilities. The fact that people from such groups are featured is hardly remarkable in itself and should only be flagged if there are issues which might give rise to offence.
Tick YES to cultural sensitivities if there are scenes or subject-matter which may be generally acceptable to domestic audiences, but which could be an issue to specific ethnic or religious groups, particularly if transmitted outside the UK e.g. a scene associating a person perceived to be a Muslim with tobacco or alcohol.
This section covers scenes which may be inherently disturbing to sections of the audience, as well as scenes which could be relatively innocuous but which may take on significant impact at a particular time or within a particular context, e.g. after a train or air crash.
In some programmes, a soundtrack can enhance the sense of menace or terror and should be noted. Repeating factual material involving emotional trauma and death may cause particular distress. Given the wide-ranging nature of this section, it is particularly important to provide full details in notes.
This concerns programmes which may be regarded as Personal View programmes about controversial subjects, particularly those that are matters of public policy or political or industrial controversy.
If you tick YES please indicate in the notes, the name of author (if not clear from the programme title), the subject matter, and whether the programme is intended as part of a series or is a one-off. These may need balancing out in the schedule to ensure a full range of views is heard.
If you tick YES, please indicate in notes the subject matter and whether there is due impartiality within the programme or whether it is part of a series where the series will carry a full range of views.
It is important to note that programmes in a wide range of genres may touch on major subjects/issues of public or political controversy. It may be particularly important to flag issues in programmes which may be less obviously likely to deal with controversial matters.
If YES please provide details of any additional programming which has been commissioned/scheduled to represent other points of view to those reflected in the programme.
If answered YES, notes should indicate what the reconstruction is and any issues which may arise with re-use e.g. where the reconstruction mirrors other recent events in the real world. It covers both factual and drama-documentary genres.
Tick YES if either a source or contributor has been promised anonymity. Please note the level of anonymity agreed e.g. picture, voice, non-identifiable to the general public, non-identifiable to close friends and family.
Section 3 Accuracy: Avoiding Misleading Audiences – Sources
Section 6 Fairness, Contributors and Consent – Anonymity
Section 8 Reporting Crime and Anti-Social Behaviour – Children and Young People
Section 8 Reporting Crime and Anti-Social Behaviour – Mandatory Referrals 8.3.9
There may also be issues with people who are no longer alive, but where living relatives may be affected. Please note names and issues which may arise with reuse e.g. relatives to be informed.
Section 6 Fairness, Contributors and Consent – Portrayal of Real People in Drama
Section 3 Accuracy – Factually Based Drama
Section 6 Fairness Contributors and Consent – Mandatory Referrals: 6.3.2
NB See also Editorial Guidelines: Accuracy: Factually Based Drama 3.4.19. When a drama portrays real people or events, it is inevitable that the creative realisation of some dramatic elements such as characterisation, dialogue and atmosphere may be fictional. However, the portrayal should be based on a substantial and well-sourced body of evidence whenever practicable and we should ensure it does not distort the known facts, including chronology, unduly.
It is important to explain the drama's factual basis (or use of dramatic licence) with clear signposting. Sensitivities will often be at their highest when a drama has, as its central purpose, the portrayal of living people, people with living close relatives or recent events. Particular care should be taken to achieve due accuracy.
All proposals to record secretly must be referred to Editorial Policy prior to approval by the relevant senior editorial figure in the Division or for Independents by the commissioning editor.
Also note use of footage from webcams and CCTV.
For all Mandatory referrals, you MUST give details at the bottom of the page of referral, with dates, and if approval has been given for both recording and transmission. Note that in some circumstances open filming with small digital cameras may be construed as secret recording.
Section 7 Privacy – Secret Recording - Privacy
Section 7 Privacy – Secret Recording - Approval
Section 7 Privacy – Secret Recording - News & Factual
Section 7 Privacy – Secret Recording - Comedy & Ent.
Section 7 Privacy – Secret Recording - Outside Sources
Section 7 Privacy – Secret Recording – Electronic note taking
This applies to both contemporaneous and archive footage. If YES please detail the nature of the material.
Section 7 Privacy – Reporting Suffering and Distress
Section 7 Privacy – Reporting Suffering and Distress - past events
Section 13 Re-use and Reversioning – Fairness, Consent and Privacy Issues
If you tick this box, you MUST give details at the bottom of the page of referral, with dates.
Section 7 Privacy – Doorstepping - Privacy
Section 7 Privacy – Doorstepping – News & Factual with prior approval
Section 7 Privacy - Door-stepping – News & Factual without prior approach
Section 7 Privacy Door-stepping for comedy & entertainment programmes
Section 7 Privacy – Mandatory Referrals 7.3.5, 7.3.13, 7.3.14
If YES please detail the name and the nature of the crime. It is important that attention is brought to any restrictions on re-use.
Section 8 Reporting Crime and Anti-social Behaviour – Reporting Crime
Section 8 Reporting Crime and Anti-Social Behaviour – Dealing with Criminals and Perpetrators of Anti-social Behaviour
Section 8 Reporting Crime and Anti-Social Behaviour – Mandatory referrals
This applies to both demonstration and witnessing of illegal activity.
Section 8 Reporting Crime and Anti-Social Behaviour – Reporting Crime
Section 8 Reporting Crime and Anti-Social Behaviour – Mandatory referrals 8.3.2
Section 14 Editorial Integrity and Independence from External Interests
You should detail commercial references, whether of branded goods, trade names or of products, such as books, CDs, DVDs etc and the nature of references. You should also note where programmes are covering sponsored events with the name of the sponsor and the type of reference, visual or verbal. Particular care must be taken with BBC products which cannot be promoted within programmes and to any products such as CDs etc which are being promoted by guests.
Section 14 Editorial Integrity and Independence from External Interests – Product Prominence
Section 14 Editorial Integrity and Independence from External Interests – Product Prominence in trails
Section 14 Editorial Integrity and Independence from External Interests – Product Prominence Undue prominence and contributors
Section 14 Editorial Integrity and Independence from External Interests – BBC Commercial Channels, Services and Products
Please list any products featured or visually prominent.
This covers any issues or perceived issues which may arise concerning guests, presenters, producers and production. Give as much information as you can. Particular attention should be paid to business interests.
This covers both commissioning and reporting polls or surveys. If YES please note the subject of the poll or survey and whether BBC commissioned.
Commissioning opinion polls: Section 10 Politics, Public Policy and Polls – Opinion Polls, Surveys and Votes
Reporting opinion polls: Section 10 Politics, Public Policy and Polls – Opinion Polls, Surveys and Votes
Reporting opinion polls at election times
Section 10 Politics, Public Policy and Polls – Opinion Polls, Surveys and Votes
If YES please detail the name and party of the leader.
It is MANDATORY to get approval from the Chief Adviser, Politics to commission a survey on any matter or an opinion poll on politics, party political support, voting intentions in the electorate at large or any other matter of public policy.
Except for brief news interviews, any proposal to interview or profile any of the party leaders in the UK for BBC network and English regional output areas must be referred in advance to Chief Adviser, Politics. In BBC Scotland, BBC Wales or BBC Northern Ireland it should be referred in advance to the respective Head of News and Current Affairs.
See Editorial Guidelines - Fairness, Contributors & Content, Section 6.4.24 - We must treat our contributors and potential contributors with respect. We must not be unduly intimidatory, humiliating, intrusive or aggressive to contributors, either to obtain their consent or during their participation in our output.
Tick YES, if any well-known person, in politics, entertainment, sport etc either takes part in the programme or if reference is made to a public figure. If possible, you should provide full detail, but if this would be overly burdensome e.g. if there are multiple references in programmes delivered close to transmission, then simply tick YES. Please note that this section may be particularly valuable to TV in the event of unexpected events between delivery and transmission e.g. death of a public figure.
NB See also Editorial Guidelines - Intimidation and Humiliation -Harm & Offence Section 5.4.32. BBC content must respect human dignity.
Intimidation, humiliation, intrusion, aggression and derogatory remarks are all aspects of human behaviour that may be discussed or included in BBC output. Some content can be cruel but unduly intimidatory, humiliating, intrusive, aggressive or derogatory remarks aimed at real people (as opposed to fictional characters or historic figures) must not be celebrated for the purposes of entertainment. Care should be taken that such comments and the tone in which they are delivered are proportionate to their target.
This covers a range of potential problems, primarily in the event of a repeat. It includes for example, references to recently dead people, people who are very ill and may subsequently have died, interviews with children etc. Try to think hard about any other potential issue which may arise.
This question refers to any contributor sensitivities or legal reasons which would affect the partial or whole re-use/repeat of the programme. If you tick ‘yes’ please give full details in the notes section.
If a pre-recorded programme fails its Technical Review or Automated QC due to flashing lights or strobing and the Producer feels strongly that the sequence must be retained for editorial/artistic reasons, approval must be sought from the relevant Channel Controller via the Genre Commissioning Editor. In the very rare occasions when approval is given in these circumstances, this must be clearly noted in the Video Comments field within the file metadata for file deliveries, the eyeball report and on the TX and Compliance forms within the notes section, giving the name of the Channel Controller, Genre Commissioning Editor and date of approval. The programme must be preceded by a clear continuity warning.
This section of the compliance form was introduced in April 2008 following publication of new Editorial Guidelines regarding audience interactivity[s11] and the introduction of Interactivity Approval Forms.
You must tick 'yes' against the relevant question if your programme includes a Competition, Audience Voting, BBC Awards, Premium Rate Telephony and/or Non-Premium Rate Telephony.
If you have ticked yes to any of questions 42 - 46 you must also confirm that the correct, mandatory Interactivity Approval Form has been authorised by the relevant Controller. Divisional controller sign off arrangements for Interactivity Approval Forms are detailed in [s13]
Vision Compliance Managers, Editorial Policy and PLA can be consulted on wording for pre-TX content information. Please contact Compliance Managers for advice in order to arrange.
Where there is a programme-related interactive site, this should be indicated, but there should be a separate form submitted by the relevant Interactive Executive or TV Executive Producer for programming on Red Button interactive stream/s.
Producers may wish to make an additional recommendation about placing here for example regarding suitability for transmission during an election period, scheduling in terms of proximity to the watershed or children's programming etc.
All mandatory referrals are summarised at the start of each section of the BBC Editorial Guidelines.
You must indicate on the form whether there are any issues which require mandatory referral to the BBC's Director, Editorial Policy & Standards; click on the "Help" button at the beginning of the section on Advice / Approvals / Referrals to view the list of these mandatory referrals. If none applies, click "No".
If one or more does apply, click "Yes" and insert the issue number(s) from the list and any notes in the box. NB any referrals to Director, Editorial Policy & Standards must be through your BBC Executive Producer who will be able to advise you in detail on the full referrals process.
If you have taken additional advice or sought approval for aspects of the programme from other departments or individuals at the BBC, e.g. advisers in Editorial Policy, the Commissioning Department Head or the Channel Controller, briefly summarise the issue in the relevant section. If you have consulted Programme Legal Advice, indicate the subject of the legal issue (e.g. contempt, privacy etc) but do not detail the advice given.
If you have any doubts on any issue you should consult your BBC Executive Producer for advice.
It is mandatory that the person completing and signing the compliance form for the Independent Company has viewed the programme and is the programme's Executive Producer as identified in the Editorial Specification. The confirmation states that the programme has been made and delivered in compliance with BBC Editorial Guidelines.
You should also tick if the programme is suitable for pre-watershed viewing on all linear channels and on Video On Demand services (including broadband and the BBC i-Player) without content 'Guidance' labelling. (NB Content 'Guidance' labelling refers to additional text information given on EPGs and Programme Information web pages alerting viewers to stronger programme material). If in doubt, please contact the Vision Compliance Managers for advice.
All originated programmes must also be viewed by the BBC Executive Producer, who must give final sign off on the programme once the form has been uploaded into the BBC Compliance Manager database.
When you have completed the form please email it to the appropriate BBC Delivery Team on the delivery date.
When you submit the form you are taking responsibility for the programme being compliant with BBC Editorial Guidelines. It is therefore essential that the programme's Executive Producer completes the form after viewing the final edit. NB for independent productions the compliance form must be signed by both the independent Executive Producer and the BBC Executive Producer.
For the duration of the Simpler Editorial Compliance Pilot (from October 2011), the BBC Executive Producer can waive the need to view the final version of the programme. To indicate this – and to recognise they still retain final compliance responsibility – they should fill in the bottom right hand corner sign-off box as follows: In the field labelled ‘Position’ under their name, type ‘For this TX I have not viewed the final version’ – then complete as usual.
Once the form has been submitted it will be valid for one month from the first transmission, i.e. it will cover all transmissions within that period, unless you decide or are advised otherwise (e.g. if a news event raises a question as to the suitability of a scheduled repeat.)
If you have read the Guidance Notes and still need advice completing the form, or have a problem with the form itself, please contact the Compliance Managers in BBC Television as follows:
Specific editorial advice can also be sought from the Duty Adviser in Editorial Policy on 020 8008 1819 but this should not replace your usual editorial referral procedures - always involve your BBC Executive Producer.
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