Working with children
Independent production companies have a responsibility to safeguard the welfare of children and young people engaged in a BBC production and must ensure they are compliant with the relevant legislation and are aware of the obligations of involving children in a programme.
The guidance below is designed to provide information on the expectations of the BBC when an independent production company has been commissioned.
The policies, regulation and guidance relevant to child protection at the BBC are:
- The BBC Child protection policy available from the Inside the BBC website
- The editorial guidance on working with children on the BBC Editorial Guidelines website
The format and the child related editorial aspects of a programme should be fully discussed with the BBC commissioning executive during the course of the commissioning discussions.
The production should be familiar with the relevant and applicable laws when working with children. It may also be necessary to consider the variances in child performance laws in Northern Ireland, Scotland and Wales and relevant overseas laws.
Note: On this website the term 'children and young people' (often shortened to just 'children') means anyone under the age of 18 years.
The Child protection policy applies to BBC Studios and all independent companies engaged on any commissioned production for the BBC involving children. It applies to all children up to 18 years of age. It is essential that all staff members are familiar with the BBC Child protection policy and how to keep the welfare of the child central to their work.
The Child protection code of conduct is ten golden rules to follow when interacting with children and young people in any capacity on behalf of the BBC.
Follow these ten golden rules when interacting directly with children and young people in any capacity on behalf of the BBC:
- Always prioritise the safety and wellbeing of the child at all times.
- Always act within professional boundaries - ensure all contact with children is essential to the programme / project / activity you are working on. You must always use BBC equipment when interacting with children as the use of personal phones or cameras is not permitted.
- Remember they are children first, and contributors or participants second.
- Never give out your personal contact details, do not 'friend' or 'follow' children you are working with on social networking sites.
- Do not assume sole responsibility for a child and only take on practical caring responsibilities such as taking a child to the toilet in an emergency. If a child needs care alert the parent or chaperone.
- Never lose sight of the fact that you are with children - behave appropriately and use appropriate language at all times.
- Listen to and respect children at all times, don't patronise them and avoid favouritism.
- Treat children and young people fairly and without prejudice or discrimination.
- If you observe children engaging in bullying behaviour or other behaviour that may put them at risk, you must report it to the Working with Children Adviser
- Ultimately, if you have any concerns about the welfare of a child or feel someone is behaving inappropriately around children, you have a duty to report your concern to your Working with Children Adviser.
The Child protection safeguarding framework has been developed to support safeguarding discussions between the commissioning executive and independent production company. It provides a guide to the minimum levels of safeguarding on any production involving children and enables the independent production to consider the steps they need to take in order to fulfil these requirements.
Further support and guidance can be obtained by contacting the Child Protection and Safeguarding team.
If anyone’s behaviour towards a child causes an individual involved in a production any concern it is important that they report it using the Incident report form.
Where children are contributors to programmes, as well as the child’s own informed consent, productions will normally need to seek signed consent from the child’s parent or legal guardian using the standard Child consent form.
A Consent form covering letter is designed to give an in-depth knowledge of which project a child is working on. This should be filled out at the same time as the BBC Child Consent form. If on location it is a good idea to print a few spare covering letters and consent forms to have on hand.
Young people aged 16–17 years-old can sometimes self-consent and in those circumstances productions should use the standard Contributor consent form which can be found on the BBC Editorial Policy website. Self-consent from young people is only acceptable if the programme or project is not sensitive or contentious.
Full information about informed consent for children can be found in the Working with Children and young people section of the BBC Editorial Guidelines website.
A risk assessment is a way of identifying and thinking about some of the issues faced when planning a production, event or project involving children. It is an important step in helping safeguard children.
Download the Risk assessment form from the BBC Safety website.
Remember that children are generally:
- Less able to recognise danger
- Likely to be in an environment which is unfamiliar to them
- Inquisitive, which can mean they are more likely to take risks
- Likely to be more prone to tiredness, anxiety and stress in response to pressure and long hours
Plan how to militate against these risks and record this in the risk assessment. For more general information about risk management in the workplace see the Health and Safety Executive website.
When planning a production, event, activity or project involving children productions and individuals must take steps to ensure that everyone who will (or might) interact directly with children is suitable for this role.
It may be necessary to request a criminal background check: Disclosure and Barring check (DBS check) for England, Wales and Northern Ireland and Protection of Vulnerable Groups check (PVG check) for Scotland.
The BBC is permitted by law to only request DBS/PVG checks for people undertaking specific activities or positions where they care for a child as part of their normal duties, provide a service as a registered professional, or manage someone who meets these requirements.
A person whose role is defined as requiring a DBS/PVG check MUST be placed on Enhanced Restrictions, which means they must not work with children until the point at which they have had their ID check. At this point they may move to Standard Restricted Duties which means they can work with children but under direct supervision.
Updating DBS/PVG check
At the BBC the DBS check is valid for three years as long as the individual remains at the BBC. If they have a break in service of more than three months they will require a new DBS check to be undertaken.
Where they are a member of the DBS Update Service this is a simple check that can be done online, otherwise they will have to complete the usual application form. For those who have a PVG check, this differs from the DBS check as it is constantly updated by Disclosure Scotland, so doesn’t need to be renewed.
Walk-ons and supporting artists
The BBC requires all walk-ons and supporting artists, when engaged on programmes commissioned by the BBC and which will involve children at ANY stage of the production, to be in possession of a Basic disclosure certificate from either Disclosure Scotland or AccessNI which confirms that they have no unspent convictions for offences contained within the Sexual Offences Act 2003.
If a Basic Disclosure is not possible i.e. Supporting Artists from abroad then you must put in place extra safeguards. For more information please see the International Supporting Artists Flowchart (PDF).
Answers to frequently asked questions can be found in the Walk-ons and supporting artists and basic disclosure checks Q&A document (PDF).
The contribution of children and young people to our content is much valued by the BBC. BBC practice is therefore to employ licensed chaperones in a professional capacity to act in loco parentis and to ensure the wellbeing of any child or young person under the age of 18 who is performing in, or taking part in, a production as a contributor.
Where children are working under a performance license, a professional chaperone must be engaged at all times. The policy at the BBC is that parents will not be engaged as a chaperone to their child. In some circumstances where a child is very young or has particular medical or developmental needs, it may be beneficial to have a parent present while the child is working on the production. However, a licensed chaperone should still be engaged.
Where a child’s contribution to a production does not come under the Performance regulations, for example, observational documentaries or news output, and where their contribution is very short term ie of no more than a day, it may be appropriate to invite the parent to chaperone their child during filming. However, if the parent is also actively engaged as a contributor and depending on the nature of the production, it may be sensible to engage a licensed chaperone as well.
When children under 18 years of age are attending BBC events, or are members of the audience for BBC shows, they must be accompanied by a responsible adult. Any variance to this must be discussed with the Child Protection and Safeguarding team.
It is particularly important to consider the role of social media and the internet in young people’s lives when setting out to work with children and young people, especially as contributors.
Productions must make sure that young people understand the impact of appearing in BBC content, and what the implications can be for anyone active on social media.
Productions should have a conversation with the young people about how to keep themselves safe and mitigate any risks and it’s a good idea to have a chat with parents too.
Children also need to be given information about what to do if they experience difficulties online after the content is published or broadcast. This can include blocking and reporting to the social networking site but, in more serious cases they can also contact the Child Protection and Safeguarding team.
Productions and individuals should bear in mind that the lower age limit for the majority of social networking sites is 13 years of age and productions must not set out to target children younger than this on social media.
Adult presenters and performers should also be briefed to ensure that their social media activity doesn’t breach any BBC safeguarding standards towards young audiences, particularly those who are working on productions likely to attract a family audience.
Find more help and information about this in the Interacting with Children and Young People Online section of the BBC Editorial Guidelines website.
Visit the policies and guidelines page to download the BBC Policy around social media activity around programmes.
If an individual or an independent production company is concerned that a child's safety or wellbeing is at risk they must follow the BBC Child protection policy, including taking whatever action is necessary to safeguard the child. They must then notify the BBC commissioning executive within 48 hours.
Individuals or productions should not worry that they may make a situation worse or suffer any personal detriment by reporting concerns. Not only do individuals and productions have a duty of care, they are also required by the BBC Child protection policy to raise any concerns they have and can therefore be confident that they will be listened to and supported as required.
If an individual or production is sent something that they have reason to believe may be child abuse images or video it should be reported immediately to CEOP. NEVER open any attachments or click on any links that could be child abuse images and do not forward them to anyone unless asked to do so by the Child Exploitation and Online Protection service (CEOP), the Internet Watch Foundation (IWF) or the police.
If an individual or production has reason to think a child is being groomed online (remember that the child may not realise it themselves) this is a mandatory referral in the Editorial Guidelines and must be reported by the production to the Child Protection and Safeguarding team. In addition to this referral, it can also be reported to CEOP via their website.
All children who are under official school leaving age and who perform in BBC programmes need to be licensed unless certain exceptions apply. The process of obtaining Child Performance Licences may differ between countries. Licences are granted by the local authority for the area where the child lives and are a legal requirement under the Children and Young Persons Act 1963.
A Child Performance Licence will be required if a child is appearing in:
- Any performance for which a charge is made, whether for admission or otherwise
- Any performance on premises licensed to sell alcohol eg in a hotel, a pub, a theatre
- Any live broadcast performance, for example a television or radio broadcast, internet streaming
- Any performance recorded (by whatever means) for use in a broadcast or in a film intended for public exhibition eg a live stage performance recorded for a cinema screening, a feature film, a video or sound recording of a performance on a website
- The child is being paid. However, a performance licence may be required whether or not the child is paid
Children of different ages are permitted different working hours and the production may be required to complete a working hour’s document. See below.
For more information, please visit the National Network for Child Employment and Entertainment website.
Any member of a production staff or crew working directly with children or who come into contact with children on an ad hoc basis, it is mandatory to complete the Working with Children Online training module via the BBC Academy myDevelopment website before they begin.
Login details are issued by BBC HR on returning a new user request form by a production supervisor/co-ordinator. Please email the Commissioning Executive to obtain a new user request form.
Contact the BBC Child Protection and Safeguarding team: firstname.lastname@example.org
Copies of the Child protection policy can be provided by the Child Protection and Safeguarding team on request.
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