Compliance for television and online

Complete and up to date information for short-form (clip) and linear TV content including forms and contacts.

Television compliance

Independent production companies should refer all compliance queries to the BBC executive.

There are two formal compliance transactions for television content: 

  • A compliance conversation with the BBC executive producer at the outset .
  • Completion of a compliance form at the end of production so that the BBC can check the programme complies with the guidelines and is suitable for the proposed slot.

Download the BBC Content compliance policy (PDF).

 

TV: compliance conversation 

There must be a formal compliance conversation between the BBC executive producer and the independent executive producer at the moment of commission for all projects. This 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. Below is a checklist of areas that may be covered. However, not all of them will apply to all programmes.

Who is responsible?

Identify and name the independent executive producer and the BBC executive producer for the project. These individuals shouldn’t be changed by either side without notification and agreement.

What are the risks/considerations?
  • Legal, fair trading, bribery act and health and safety risks
  • If children are involved as contributors or performers (please see the Working with children page for more information. Courses are available from the BBC Academy, please speak to your business affairs contact for access)
  • Other vulnerable contributors
  • Complex or unusual consent or access issues
  • Secret filming
  • Public interest justifications which may lapse over the passage of time (especially when depicting illegal or anti-social behaviour)
  • Taste and standards issues. Agree parameters of tone and content for channel and slot. If a programme is moving channel consider any implications
  • Conflicts of interest including on-screen talent commercial links
  • Any risks produced by co-production or distribution arrangements
  • Any additional steps that should be taken when content is re-used, distributed or otherwise made available, in whole or part
What are the rules?

Identify relevant sections of BBC Editorial guidelines and any other codes (eg interactivity, secret filming, fair portrayal). Ensure key production staff have read the relevant guidelines.

Managed risk programme list

The BBC executive producer is responsible for putting programmes on the list. The independent’s executive producer has an ongoing responsibility to keep the BBC executive producer informed of any reason to include the programme on the list. If things change The independent’s executive producer has a commitment to let us know of any new risks or changes in status of a project, including on multiplatform output or external promotion and advertising.

Competitions votes and awards

Discuss any competitions, votes or awards in the programme and the sign-off process to TX with specific reference to the relevant forms, codes and guidelines. Programmes with such interactivity may need to be reviewed/re-edited after the interactive elements have expired.

Editorial policy and legal referrals

Referrals to editorial policy and BBC programme legal advice should be made, at least in the first instance, through the BBC executive producer. When a programme has legal risk the independent is responsible for seeking appropriate legal advice themselves - consultation with BBC PLA gives them no protection. Contacts made directly between an independent and BBC PLA in the first instance also forfeit legal privilege.

Marketing, promotions and press

Run through responsibilities for marketing, promotional and off-air materials. Sign off for these materials remains with the BBC executive producer, although the independent’s executive producer is responsible for ensuring compliance in all press and promotional material submitted to BBC MC&A. Discuss any book, newspaper serialisation or any spin off associated with the commission. Clearly establish the rights position and discuss publicity/promotion arrangements.

Digital

Discuss multiplatform output connected to the production and any issues raised. Establish clear lines of responsibility and sign off for any non-linear output.

Learning campaigns, open university and third-party funding

Discuss any editorial or financial input and any issues this raises. Establish clear lines of responsibility and sign off for all connected output.

Talent or agent owned / co-owned /managed indies

Identify whether this is the case, discuss any potential conflicts of interest raised and steps to mitigate these risks. In exceptional cases where it is agreed that an on-screen talent can also be an executive producer, agree and name second executive producer responsible for compliance. Identify whether the talent’s agent is being proposed as executive producer and if necessary agree steps, as with talent execs, to mitigate conflicts of interest and safeguard compliance.

 

TV: compliance form

Useful links:

The compliance form should be submitted on the programme delivery date.

  • Production companies should complete the compliance form using the PTK Compliance system and inform the BBC contact when the form has been submitted.
  • Independent production companies commissioned via the nations should check requirements with their commissioning executive.

For independent production companies the online compliance form must be signed by both the independent executive producer and the BBC executive producer and should only be completed and signed by them after viewing the final edit. It is mandatory that the independent executive producer is responsible for signing the compliance form after the final viewing and is named in the editorial specification.

In the rare cases where on-screen talent or their agents are the executive producer for a programme in which they appear another executive producer must be responsible for compliance and signing the compliance form at delivery.

All questions on the compliance form reflect key aspects of the editorial guidelines. These incorporate the relevant areas of the Ofcom Broadcasting Code with which the BBC must comply. Please note that all audience interactivity questions must be completed before the form can be submitted.

Independent production companies 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.

After submission the form will be valid for one month after first transmission. It will cover all transmissions within that period unless a new version is created or needed for any reason, in which case a new compliance form may be required

The BBC executive producer will be contacted before any repeat to establish whether the programme can still be transmitted as first aired. In some cases the independent executive producer may also be contacted, especially where there are legal or other important concerns.

 

TV: compliance form step-by-step

Useful links:

A compliance form is required for all pre-recorded programmes on BBC Red Button (also referred to as BBCi). Live programming should be dealt with under the Editorial Policy Live Compliance Guidelines (as above) and subsequent repeats of such programming also as above.

Red Button Editorial should be alerted to any content requiring guidance labelling.

Programme UID

See the technical requirements page for information about programme UIDs.

Programme summary

A short summary (not a full synopsis) indicating the programme genre.

Red flag case (complaint)

Usually filled in after transmission against that particular transmission if a major complaint has been made which may affect the compliance status if repeated

If no complaint is existing do not enter information in this field.

For independents productions it is the BBC executive producer’s responsibility 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, give the BBC complaints reference number. Once the complaint has been resolved a further updated compliance form must be completed to record the finding.

Compliance questions section

You must answer all questions on the ‘compliance events’ tab, adding accompanying notes where necessary. Any extra detail you can supply, including timecodes, will aid understanding of the compliance issues noted, and save time and effort.

Issues are listed below with the relevant section in the BBC Editorial guidelines and with links to any other guidance or supporting information.

Some issues require referrals up the editorial chain, including mandatory referrals. In the Nations and regions the relevant director or controller must be informed of any issue that is a ‘mandatory referral’ to Director, Editorial Policy and Standards.

 

1. Legal issues

Any decision to proceed with content despite legal advice must be referred to the most senior divisional editorial figure and to the Director, Editorial Policy and Standards

Editorial guidelines: Section 18 The law – mandatory referral 18.2.1

YES: where there are continuing issues. In the Referrals section, indicate the subject/s of the legal issue/s (eg contempt, privacy etc) with dates but do not detail the advice given.

NO: if you have sought legal advice but there are no outstanding issues.

Editorial guidelines: Section 18: The law

2 – 3 Strong language / gestures

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 spoken and written language and gestures, even if in a foreign language and / or captioned, as well as music lyrics (even if background).

Editorial guidelines: Section 5 Harm and offence: language

Editorial guidelines: Section 5 Harm and offence: abusive or derogatory treatment

2. Strong, most offensive

YES: if there is language that shouldn’t be transmitted pre-watershed (before 9pm), or falls into the ‘most offensive’ category. Detail in notes the precise words used with time-coded references.

Indicate if strong language/gestures occur near the start of the programme or in episode recaps (and so would be transmitted close to the 2100 television watershed).

Strong language/gestures are allowed only in consultation with the BBC Executive Producer. Use of any of the most offensive words or phrases e.g. fuck, motherfucker, 'Jesus fucking Christ' and cunt require the advance approval of Controllers and/or the Director, BBC Content. (See the BBC Content Compliance policy appendix 2 for more details)

The strongest language should not be included in content online, or in social media content, likely to appeal to a significant proportion of children. (Guideline 5.3.22)

3. Any other which may offend

YES: if there is any other offensive language (eg bloody, shit, arse, bollocks, bugger, wank etc).

If intended for pre-watershed transmission, detail in notes the precise words used with time-code references.

Strong language should not be included in content online, or social media content, likely to appeal to a significant proportion of children, unless it is justified by the context. Even then, frequent use must be avoided. (Guideline 5.3.24) 

There are a range of discriminatory words (eg yid, poof, tranny, mong, spastic) which would be offensive to particular groups of viewers as well as more widely. Racist abuse is increasingly seen as offensive to all sections of the audience (eg nigger, paki, chinkie). Detail in notes the precise words used and the context with time-code references. See also Question 15-16 Portrayal.

4 – 5 Sex
4. Sexual content

YES: if there is any kind of sexual activity depicted. Give enough detail in notes for scheduling judgements. Some disturbing scenes eg of sexual violence (including rape) should also be flagged in the Violence section (Q10), and should be used only after consultation with the BBC Executive Producer.

Editorial guidelines: Section 5 Harm and offence: sex

5. Sexual innuendo/reference

YES: for comedy and comic situations, and broad sexual discussion, language, material or themes, especially if the main topic or focus of the content, or occurring across several contributions.

Detail whether verbal or visual. It may not be necessary to give precise details if the comic innuendo is relatively mild, depending on the scheduled slot or intended platform/audience.

6. Nudity

YES: if nudity is featured, whether in a sexual or non-sexual context. Nudity before the watershed or online in content likely to appeal to a significant proportion of children must be justified by context which should be indicated in the notes.

Editorial guidelines:  Section 5 Harm and offence: nudity

7 – 10 Violence

All scenes containing violence must be noted.

Provide time-coded references if possible but it is essential to indicate whether scenes occur near the start of the programme or in episode recaps (and so would be transmitted close to the 2100 television watershed).

This section has relevance not just to factual and drama content, but may also apply to other genres like entertainment (e.g. spoof violence may be especially offensive should real life violence be in the news eg. terrorist beheading).

Editorial guidelines: Section 5 Harm and offence: violence

Please note that this should include significant violence to, or mistreatment of, animals as well as people.

Editorial guidelines: Section 5 Harm and offence: violence against animals and animal welfare

Editorial guidelines: Section 8 Crime other referrals (mandatory referral 8.2.13)

7. Real life

This section may apply to genres like entertainment (eg spoof violence may be become offensive in the light of a real life news event, for example terrorist acts such as bombings or beheadings). It does not apply purely to fictitious characters.

Further guidance: Harm and offence - television scheduling and the watershed

8. Fictional

Guidance: Harm and offence - television scheduling and the watershed

9. Involving children

YES: for scenes involving children, whether in scripted or unscripted content, where they appear to be or are present during verbal or physical violence. Content should adhere to the BBC’s Child protection policy (PDF) and and further working with children guidance including a code of conduct, various safeguarding procedures and child licensing issues.

Editorial guidelines: Section 9 Safeguarding the welfare of children and young people

Further guidance: Working with children and young people as contributors

10. Sexual violence

Any scenes eg of sexual violence (including rape). These should be used only after consultation with the BBC Executive Producer.

11 – 14 Imitative behaviour

The possibility of audiences, especially children, imitating dangerous, life-threatening, anti-social or criminal behaviour. This may have already been referred to in the previous section, if so, tick YES, but do not repeat detail in notes.

11. Drug/solvent abuse

Editorial guidelines: Section 5 Harm and offence: alcohol, smoking, solvent abuse and illegal drugs

12. Suicide, eating disorders, self-harm, hanging

Editorial guidelines: Section 5 Harm and offence: suicide, attempted suicide, self-harm and eating disorders

13. Other potentially dangerous behaviour

This could include dangers around the house such as a child getting into a fridge or the use of domestic objects (knives, scissors etc) in harmful acts.

Editorial guidelines: Section 5 Harm and offence: imitative behaviour

14. Use of alcohol/smoking

YES: if the activity is particularly prominent eg a contributor smoking* or the context is unusual eg in children's programming.

NO: if the content is for a general audience where the activity is not prominent and is justified by context eg scenes set in pubs or restaurants.

*This may include vaping (use of electronic or ‘e’ cigarettes).

Editorial guidelines: Section 5 Harm and offence: alcohol, smoking, solvent abuse and illegal drugs

15 – 16 Portrayal

Offensive or stereotypical assumptions must be avoided and people should only be described in terms of their disability, age, sexual orientation etc when clearly editorially justified. (See also Q3 Language). This can be a complex area where advice should be taken.

Editorial guidelines: Section 5 Harm and offence: portrayal

Editorial guidelines: Section 5 Harm and offence: religion

15. Disabilities, religious, minorities, vulnerable contributors

YES: if there are significant and potentially controversial references to people of a particular faith, race, nationality or a minority including ethnic, gay lesbian and bisexual, and transgender people, or those with disabilities.

NO: the fact that people from such groups are featured is unremarkable and would only need noting for issues which might give rise to offence.

The welfare of children and young people under 18 is of paramount concern. This means their interest and safety must take priority over any editorial requirement.

Material may require an additional assessment of the contribution of vulnerable people (including children), or those in a vulnerable state, when taking into account the nature of their contribution and the passage of time since originally broadcast or made available.

Editorial guidelines: Section 9 Children and young people: impact of a contribution

Editorial guidelines: Section 7 Privacy: children, young people and vulnerable contributors

Editorial guidelines: Section 8 Crime: dealing with witnesses and victims – children andyoung people

Further guidance: Working with vulnerable contributors or contributors at risk of vulnerability

16. Cultural sensitivities

YES: 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 ie a scene associating a person perceived to be a Muslim with tobacco or alcohol.

YES: Also if there are scenes which may be culturally acceptable in other countries (eg ritual slaughter or other scenes with animals) but which might raise concerns for the domestic audience.

Editorial guidelines: Section 5 Harm and offence: violence against animals and animal welfare

17 – 19 Disturbing content

Scenes which are inherently disturbing to sections of the audience or which could be relatively innocuous but take on impact at a particular time or within a particular context ie. after a train or air crash.

A soundtrack can enhance the sense of menace or terror and should be considered. 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.

18. Disasters, accidents, kidnappings, terrorist acts

YES: for any news coverage of recent or past events (especially on significant anniversaries)

YES: where there are fictional instances with deliberate echoes of real-life events, or where those instances have gained such overtones.

Any significant landmarks or locations should be noted.

Editorial guidelines: Section 5 Harm and offence - tragic events

19. Exorcism, occult, paranormal, horror

Editorial guidelines : Section 5 Harm and offence: hypnotism, exorcism, the occult and the paranormal

20 – 22  Impartiality and diversity of opinion

Editorial guidelines: Section 4 Impartiality

Editorial guidelines: Section 4 Impartiality: diversity of opinion

20. Personal view/authored

Content which may be regarded as giving a personal view about controversial subjects, particularly those that are matters of public policy, or political or industrial controversy.

Such personal view content must be clearly signposted to audiences in advance.

If YES: please indicate the name of author in the notes (if not clear from the programme or content title), the subject matter and whether this is intended as part of a series or is a one-off. Balancing across the schedule / platform may be needed to ensure a full range of views is heard.

Editorial guidelines: Section 4 Impartiality: personal view content

21. Controversial subjects/issues

If YES: indicate in notes the subject matter and whether there is due impartiality or whether it is part of a series which will carry a full range of views.

Multiple genres may touch on major subjects/issues of public or political controversy. It is particularly important to flag issues in content which may be less likely to deal with controversial matters.

For a definition of ‘controversial’, see:

Editorial guidelines: Section 4 Impartiality: controversial subjects

22. Does it require additional programming?

If YES: provide details of any additional programming which has been commissioned/scheduled to represent alternative points of view.

Editorial guidelines: Section 4 Impartiality: impartiality in series and over time

Editorial guidelines: Section 4 Impartiality: drama, entertainment and culture

23 – 24 Accuracy

Editorial guidelines: Section 3 Accuracy

For questions of accuracy and acceptable/misleading production techniques, including for natural history content, see:

Further guidance: Recording the natural world

For reporting and using statistics:

Editorial guidelines Section 3 Accuracy: reporting statistics

Further guidance: Reporting statistics

For opinion polls, surveys, focus groups, online voting and other forms of ‘straw’ polls, see Q34 Politics.

23. Reconstructions

YES: give notes to indicate what the reconstruction is and any issues which may arise with re-use such as if the reconstruction mirrors or comes to mirror recent real word events. This includes both factual and drama-documentary genres.

Editorial guidelines: Section 3 Accuracy: avoiding misleading audiences

Editorial guidelines: Section 8 Reporting crime and anti-social behaviour: reporting crime – reconstructions

24. Anonymity issues

YES: if either a source or contributor has been promised anonymity. Please note the level of anonymity agreed ie picture, voice, non-identifiable to the general public / non-identifiable to close friends and family.

Editorial guidelines: Section 18 The law: legal rights to anonymity

Editorial guidelines: Section 3 Accuracy: mandatory referral 3.2.1

Further guidance: Anonymity

Editorial guidelines: Section 3 Accuracy: avoiding misleading audiences – sources

Editorial guidelines: Section 6 Fairness: contributors and consent – anonymity

Editorial guidelines: Section 8 Reporting crime and anti-social behaviour: children and young people

Editorial guidelines: Section 8 Reporting crime and anti-social behaviour: mandatory referrals 8.2.9

Editorial guidelines: Section 8 Reporting crime and anti-social behaviour: disguising identities

25 Fairness and accuracy in drama

When a drama portrays real people or events it is inevitable that some dramatic elements may be fictional. However, the portrayal should be based on a substantial and well-sourced body of evidence whenever practicable and should not unduly distort the known facts, including chronology.

It is important to explain the drama's factual basis (or use of dramatic licence) with clear signposting. Portrayal of living people will often be particularly sensitive. Particular care should be taken to achieve due accuracy. There may also be issues with people who are no longer alive but have living relatives. Note names and issues which may arise with reuse ie. relatives to be informed.

Refer to:

Editorial guidelines: Section 6 Fairness to contributors and consent: portrayal of real people in drama

Editorial guidelines: Section 3 Accuracy

Editorial guidelines: Section 6 Fairness to contributors and consent: mandatory referrals: 6.3.1 – 6.2.3

26 – 28 Privacy

Editorial guidelines: Section 7 Privacy

Further guidance: Secret recording

We must balance the public interest in freedom of expression with the legitimate expectation of privacy by individuals.

Editorial guidelines: Section 7 Privacy – legitimate expectations of privacy

26. Secret Recordings/webcam/CCTV – including body worn and drone cameras

Editorial guidelines: Section 7 Privacy - secret recording

All proposals to record secretly must be referred to Editorial Policy prior to approval by the BBC Executive. These should also be notified to the relevant figure in each Division responsible for record keeping.

Editorial guidelines: Section 7 Privacy - mandatory referrals 78.2.8 - 7.2.11

Further guidance: Secret recording

For all Mandatory referrals, you MUST provide dates and specify if approval has been given for both recording and transmission.

Forms available from the Editorial guidelines website

Note use of live streaming (webcam/CCTV footage).

Editorial guidelines: Section 7 Privacy secret recording - live streaming

Inconspicuous recording - body-worn cameras

Note that in some circumstances open filming with small, body worn digital cameras (such as ‘GoPros’) may be construed as secret recording.

Any proposal to equip third parties with body-worn cameras and microphones where to do so might infringe the privacy of an individual or where the third party is entering private premises without permission must be referred in advance to Director Editorial Policy and Standards (mandatory referral 7.2.4).

Editorial guidelines: Section 7 Privacy: tag-along raids

Further guidance: Body-worn cameras ('go-pros') and microphones

Any proposal to use a tracking device where it would infringe the privacy of an individual must be referred to Director Editorial Policy and Standards (mandatory referral 7.2.6)

Inconspicuous Recording - Drones

Drones are subject to Civil Aviation Authority regulation and safety considerations.

Any proposal to gather material using a drone must be referred to a senior editorial figure or, for independent production companies, the commissioning editor (mandatory referral 7.2.13)

Legal issues (including data protection) concerning filming with drones (also known as remote controlled aircraft or UAV) – such as where identifiable individuals will be filmed without consent and their privacy would be infringed - should be discussed with Programme Legal Advice.

Further guidance: Use of drones

Editorial guidelines: Section 7 Privacy: secret recording - privacy and consent

Editorial guidelines: Section 7 Privacy: secret recording - approval

Editorial guidelines: Section 7 Privacy: secret recording - news and factual investigations

Editorial guidelines: Section 7 Privacy: secret recording - comedy and entertainment

Editorial guidelines: Section 7 Privacy: secret recording - outside sources third parties

Editorial guidelines: Section 7 Privacy: secret recording – electronic note taking 

27. Footage of death, suffering and distress

This applies to both contemporaneous and archive footage. If YES please detail the nature of the material.

Editorial guidelines: Section 7 Privacy – reporting death, suffering and distress

Editorial guidelines: Section 7 Privacy – reporting death, suffering and distress – revisiting past events

Editorial guidelines: Section 13 Re-use and reversioning – fairness, consent and privacy issues

28. Door-stepping

If YES, overall details of the referrals, with dates, must be given in the referrals section.

Editorial guidelines: Section 7 Privacy – doorstopping

Editorial guidelines: Section 7 Privacy – mandatory referrals 7.2.8/7.2.16 - 7.2.18

29 – 30 Reporting crime and anti-social behaviour

Material likely to encourage or incite the commission of crime, or lead to disorder, must not be included in our services. Any proposal to broadcast content which risks inciting crime or disorder must be referred to Director Editorial Policy and Standards (mandatory referral 8.2.1).

Editorial guidelines: Section 8 Reporting crime and anti-social behaviour

Repeating content depicting illegal or anti-social behaviour, particularly more than a year after first shown, is not straightforward and can throw up problematic editorial issues. Any public interest justification may diminish with the passage of time and may require discussions between a senior editorial figure in the TMO unit, production, and Editorial Policy. Additional blurring or editing may be required.

Also see:

Editorial guidelines: Introduction - our editorial values

Editorial guidelines: Introduction - the public interest

Further guidance: Re-use of factual content featuring illegal or anti-social behaviour

29. Interviews with criminals

If YES: detail name and the nature of crime. Attention should be brought to any restrictions on re-use (as above).

Editorial guidelines: Section 8 Reporting crime and anti-social behaviour – reporting crime

Editorial guidelines: Section 8 Reporting crime and anti-social behaviour – dealing with criminals and perpetrators of anti-social behaviour

Editorial guidelines: Section 8 Reporting crime and anti-social behaviour – mandatory referrals 8.2.1 - 8.2.12

30. Demonstration of illegal activity

This applies to both demonstration and witnessing of illegal activity.

Editorial guidelines: Section 8 Reporting crime and anti-social behaviour – reporting crime

Editorial guidelines: Section 8 Reporting crime and anti-social behaviour – mandatory referrals 8.3.2 

Editorial guidelines: Section 11 War, terror and emergencies - mandatory referrals 11.2.1 - 11.2.5

We must ensure that material which contains hate speech is not included in our output unless it is justified by the context. Broadcasting hate speech can constitute a criminal offence if it is intended or likely to stir up hatred relating to race, religious belief or lack of religious belief or sexual orientation.

Editorial guidelines: Section 8 Reporting crime and anti-social behaviour: hate speech

31 – 33 Independence from external interests

Editorial guidelines: Section 14 Independence from external interests

31. Commercial, sponsor or brand references

The BBC must not commission, produce or co-produce output for its UK Public Services which contains product placement. For a definition see

Editorial guidelines: Section 14: Independence from external interests – meanings

Any proposal to carry output on UK Public Services which requires signalling for product placement must be approved by the Director-General (mandatory referral 14.2.4)

Editorial guidelines: Section 14 Editorial integrity mandatory referral 14.2.1

Editorial guidelines: Section 14 Independence from external interest – public service references to BBC commercial services and products

Detail commercial references including branded goods, trade names or names of products such as books, CDs, DVDs etc and the nature of references. Also note when 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 which are being referenced with or by guests.

Editorial guidelines: Section 14 Editorial integrity and independence from external interests – product prominence

Editorial guidelines: Section 14 Editorial integrity and independence from external interests – public service references to BBC commercial services and products and other material related to editorial content

32. Branded products featured

List any products featured or visually or verbally prominent.

33. Conflicts of interest: Presenters/guests/production team

YES: for 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.

Editorial guidelines: Section 15 Conflicts of interest

Editorial guidelines: Section 10 Politics, public policy and polls

Potential conflicts of interest can also arise where an independent production company is owned / co-owned by an on-air presenter or performer or their agent, or where they are part of the senior management of an independent production company. 

In exceptional circumstances, where there is clear editorial justification and where the programme or content and its subject cannot be commissioned unless it is produced with the associated agent or talent-owned independent, the proposal should be referred to the Director, Editorial Policy and Standards (mandatory referral).

Further guidance: Section 15: Conflicts of interest - mandatory referral 15.2.2

34 – 36 Politics

The BBC is committed to achieving due impartiality in all its output. This commitment is fundamental to our reputation, our values and the trust of audiences. Due impartiality usually involves more than a simple matter of ‘balance’ between opposing viewpoints. It does not require absolute neutrality on every issue or detachment from fundamental democratic principles, such as the right to vote, freedom of expression and the rule of law. 

Editorial guidelines: Section 10 Politics: reporting opinion polls 10.3.30

34. Opinion polls/surveys (also see Q36)

Both for commissioning and reporting polls or surveys. If YES: please note the subject of the poll or survey and whether it was commissioned by the BBC.

Editorial guidelines: Section 10 Politics, public policy and polls – opinion polls, surveys and votes

Further guidance: Opinion polls, surveys, questionnaires, votes and 'straw polls'

See also Q23-24 Accuracy.

35. Interview/appearance of party leaders (also see Q36)

If YES: detail the name and party of leader.

Editorial guidelines: Section 10 Politics, public policy and polls – political interviews and contributions

36. If yes to 34 or 35, referred to Chief Political Adviser?

Any proposal to commission an opinion poll (or use other methods, such as data analysis) with the intention of sampling party political support or voting intentions must be referred in advance to Chief Adviser Politics for approval (mandatory referral 10.2.6).

Any proposal to commission an opinion poll or BBC survey or conduct a vote on matters of public policy, political or industrial controversy, or on ‘controversial subjects’ in any other area, must be referred to Chief Adviser Politics (mandatory referrals 10.2.7, 10.2.9 and 10.2.10).

Chief Adviser Politics must be consulted in advance about proposed bids or offers of interviews (or other active participation) for the Prime Minister and Leader of the Opposition at Westminster, the First Ministers of Scotland and Wales and the First Minister and Deputy First Minister in Northern Ireland. In the nations of the UK, the respective Heads of News must also be consulted (mandatory referral 10.2.2).

37 – 40 Other issues

Editorial guidelines: Section 5 Harm and offence:intimidation and humiliation (guideline 5.3.32)

37. Public figures - as contributors

Contributors and potential contributors must be treated with respect. The BBC must not be unduly intimidating, humiliating, intrusive or aggressive to contributors, either to obtain their consent or during their participation in output.

Editorial guidelines: Section 5 Harm and offence: intimidation and humiliation

‘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.’ (Guideline 5.4.32)

Editorial guidelines: Fairness, contributors and content, section 6.4.24

38. Public figures - reference to

YES: if any royal figure, well-known person or prominent figure in politics, entertainment, sport etc either takes part in the content or is referred to. In particular, any person involved in significant news stories during production or leading up, or expected to lead up to, broadcast or publication.

Full detail should be provided if possible but if this would be overly burdensome (ie if there are multiple references and / or delivery is close to transmission or publication), then simply tick YES. Please note that this section may be particularly valuable if unexpected events occur eg. sudden death or illness between delivery and availability that would make significant news.

NO: Historical figures

39. Sensitive content issues

Covers a range of potential problems, primarily in the event of a repeat. For example, references to currently seriously ill or recently dead people, interviews with children etc.

Religious sensitivity around holy days should also be considered.

Editorial guidelines: Section 12 Religious content

40. Any restriction on re-use?

Including any contributor sensitivities or legal reasons which would affect the partial or whole re-use/repeat of the content. If YES: give full details.

Editorial guidelines Section 13 Re-use, reversioning and permanent availability - mandatory referral 13.2.2

For Accuracy issues see: Editorial guidelines: Section 13: Re-Use - accuracy

For fairness consent and privacy issues see: 

Editorial guidelines: Section 13 Re-use – fairness consent and privacy issues

Consider any additional steps that should be taken when content is re-used, distributed or otherwise made available, in whole or part, in ways that may not have been contemplated at the time of production.

For help with questions where the public interest justification in depicting illegal or anti-social behaviour may have diminished over time, see Crime (Q 29-30) above.

Editorial guidelines: Section 7 Privacy – Reporting suffering and distress - past events

Editorial guidelines: Section 8 Reporting crime and anti-social behaviour – impact on victims

Editorial guidelines: Section 8 Reporting crime and anti-social behaviour – disguising identities

Editorial guidelines: Section 8 Reporting crime and anti-social behaviour – disguising identities of witnesses and victims

For Harm and Offence Issues see:

Editorial guidelines: Section 13 Re-Use – harm and offence issues

For Interactivity issues see:

Editorial guidelines: Section 17 Competitions votes and interactivity

Further guidance: Re-use of factual content featuring illegal or anti-social behaviour

41. Flashing lights/flash photography/strobing/lighting effects which have failed technical review

YES: If content features flashing lights or strobing that has failed technical review, cannot be fixed, and where there is editorial justification.

Where a programme which failed, is then fixed and passes, this might not be enough to answer NO, particularly if the pass is a narrow one and has only been achieved by multiple attempts. Further advice should be sought from the Channel Compliance Managers.

Approval to go ahead on the basis of a YES must be sought from the relevant Controller.  Where approval is given, please note in the referral section. The programme must then be preceded by a clear continuity warning or given clear guidance labelling online.

Editorial guidelines: Section 5 Harm and offence: flashing images, strobing and images of very brief duration

42 – 46 Competitions, votes and interactivity

Anyone proposing to carry out a phone, text or online vote or competition which involves audience interaction must refer to the BBC’s Interactivity Technical Advice and Contacts Unit (ITACU) and complete the appropriate approval process (mandatory referrals 17.2.7 and 17.2.12).

Any proposal for the BBC to accept a donated career or life-changing opportunity for contestants or participants must be referred to Editorial Policy (mandatory referral 17.2.17)

Votes on matters of public policy, political or industrial controversy or any other ‘controversial’ subject must be referred to Chief Adviser Politics (also see Q36 Opinion polls/surveys)

Detailed information on all forms of interactivity is also available here:

Further guidance: Part A - detailed guidance on competitions

Most interactivity requires approval forms which can be found on the Editorial guidelines website.

Editorial guidelines: Section 17: Competitions, votes and interactivity

Programmes with interactive elements (competitions, phone votes, other calls to action) may need to be reviewed/re-edited for availability on iPlayer after the interactive elements have expired.

Editorial guidelines: Section 17: Competitions, votes and interactivit - content that is pre-recorded, repeated, or available on catch-up services

47. Interactivity approval form authorisation

If YES to questions 42 - 46 confirm the mandatory Interactivity Approval Form has been authorised by the relevant controller.  

Editorial guidelines: Section 17 Audience interactivity

Getting more advice on completing the form

If you need further advice during normal working hours, please contact the Content Division Channel Compliance Managers:

  • For BBC One and Three call 020 361 42156/0791 2583698 (office hours only)
  • For BBC Two and Four call 0791 2583696  (office hours only)

For specific editorial and/or out of hours advice at evenings and weekends you should contact Editorial Policy on 0208 008 1819.

For legal advice please call the Duty Lawyer on 020 8008 2200 or 020 8008 2220

In cases where a serious issue of editorial judgment is concerned (e.g. use of very strong language or surreptitious recording), this should not replace your usual editorial referrer.

 

TV: mandatory referrals

Referrals to David Jordan, the Director of Editorial Policy and Standards are mandatory for the inclusion of specific content in a TV programme. This includes the broadcast of secretly recorded material, interviewing a criminal or the dramatic portrayal of a real person against the wishes of the individual or their relatives.

Download a full list of mandatory referrals (PDF).

 

I&RP Ofcom compliance form

As part of the BBCs commitments to supporting the growth and strength of television production out of London, we need to ensure productions are complying with Ofcom criteria. 

For each production we require suppliers to submit an Ofcom Independent and Regional Production (I&RP) compliance form so that the BBC has a formal record of the status of that programme. 

The form must be signed by the most senior business person on the production who is responsible for the spend and be submitted by email to IRPOfcomCompliance@bbc.co.uk and the usual Business Affairs contact within two weeks of the programmes transmission.

Find out more about Ofcom regional definitions (PDF)

Download the Ofcom I&RP compliance form (Excel).

 

Online: clip compliance

A compliance form must be completed for all online clips and audio clips to confirm they comply with the BBC Editorial guidelines and to ensure that guidance labels are applied where necessary.

The completed form must be submitted to shortformvideoteam@bbc.co.uk with sign off from the independent production company executive producer.

The form will then be sent to the BBC executive producer for final sign off before the content is published.

The Online compliance form is a simplified version of the full Television compliance form. Further information on completing the full Television compliance form can be found above.

*BBC Studios can find further information on compliance on the BBC intranet compliance portal.

A single form can be used for multiple clips when there are no compliance issues that need noting and they relate to the same programme or product.

If a clip is being republished due to technical issue or with minor changes, eg spelling mistakes, a new form does not need to be submitted. A new form must be submitted if there is a significant editorial change to the content.

If, for technical or procedural reasons such as a live programme, it is not going to be possible to submit an Online compliance form before publication of a clip an alternative sign off process should be agreed in advance by the BBC executive producer.

Download the Short-form (clip) compliance form from the Publicity page

 

Online: clip compliance responsibility

The BBC executive producer is responsible for the content being compliant. The executive producer can designate a member of the production team with appropriate editorial expertise to view the content and sign the form on their behalf if they consider the online content carries a low level of risk. The executive producer must record the fact that compliance has been delegated via an email to the designated member of staff. However, overall responsibility for compliance still rests with them. Likewise, the independent executive producer can delegate sign off in the same way as the BBC executive producer.

It is essential that either the executive producer or the designated team member has viewed the video (or listened to the audio) and, if it is derived from a programme, is familiar with the programme's content.

Delegated compliance is not always advisable. Executive producers should assess the level of risk involved in online content which may include issues such as but not restricted to the following:

Is the programme on the managed risk list? Does it contain controversial or extremely sensitive material? Is there a risk that material taken out of context could lead to legal or Editorial Policy issues? Does a careful assessment need to be made regarding young or vulnerable contributors? Will the embedding of the clip cause problems for the programme or for contributors? Does the clip meet user expectations? Is the clip representative of the TV programme?

The BBC requires consistency in compliance across all BBC platforms.

Channel compliance managers can provide guidance on short-form content. If the video carries content that requires a mandatory referral, the executive producer or designated individual must contact the relevant controller and obtain authorisation. Find contacts for compliance teams.

 

Online: clip guidance labels

Some clips may require a guidance label.

Download label guidance (PDF).

 

Online: other content

Other content such as text and images do not have be individually complied but the executive must ensure that they have put in place satisfactory procedures to ensure that content is compliant with the BBC Editorial guidelines.

This includes a process for the escalation of issues or queries. The executive should also decide whether it is necessary to re-check ongoing updates based on what content is planned.

Sign off of this content can be done via email confirmation. Save a copy of the paperwork.

The clip will be a permanent record of the programme. It should be representative of the programme and the content should meet the audience expectation of the show.

Find out more on the online content page.

 

Contacts

Please visit the Contacts page to find specific compliance contacts.