Privacy Guidelines

OVERVIEW

The purpose of these Editorial Policies is to assist Elite TV1 International to provide content which fulfils its functions towards a high standard.

The Principles set out Elite TV1 International’s approach to each of the main issues to be addressed by an independent public broadcaster that regulates itself. The Standards which follow each statement of principle are enforceable under internal management processes and under Elite TV1 International Complaints Handling Procedures. The Principles are intended to assist the interpretation and application of the Standards. More detailed advice is available in non-binding Guidance Notes.

The Editorial Policies are intended to be applied with due regard for the nature of the content under consideration in particular cases. Elite TV1 International is conscious that its dual obligations – for accountability and for high quality – can in practice interact in complex ways. It can be a sign of strength not weakness that journalism enrages or art shocks.

The Standards are to be applied in ways that maintain independence and integrity preserve trust and do not unduly constrain journalistic enquiry or artistic expression. However, all who are involved with content for Elite TV1 International are required to act with integrity and take account of likely harms in exercising their power and responsibility. 

1. INDEPENDENCE, INTEGRITY AND RESPONSIBILITY

The trust and respect of the community depend on Elite TV1 International’s editorial independence and integrity. Independence and responsibility are inseparable. The Managing Director is the Editor-in-Chief who has ultimate editorial power and responsibility.

 a.       Maintain the independence and integrity of Elite TV1 International.

b.       Exercise Elite TV1 International editorial control over the content Elite TV1 International broadcasts or publishes.

c.        Ensure that editorial decisions are not improperly influenced by political, sectional, commercial or personal interests.

d.       External activities of individuals undertaking work for the ABC must not undermine the independence and integrity of Elite TV1 International’s editorial content.

e.       Exercise editorial independence as authorised and accept responsibility for it.

f.        When in doubt about an editorial matter, refer it up to the next most senior person for advice or decision.

g.       When any editorial matter, including an editorial matter not being referred up for advice or decision, is likely to cause controversy or have an extraordinary impact, give proper notice of it to the most appropriate senior manager.

2. ACCURACY

Elite TV1 International has a statutory duty to ensure that the gathering and presentation of news and information is accurate according to the recognised standards of objective journalism.

Credibility depends heavily on factual accuracy.

Types of fact-based content include news and analysis of current events, documentaries, factual dramas and lifestyle programs. Elite TV1 International requires that reasonable efforts must be made to ensure accuracy in all fact-based content. Elite TV1 International  gauges those efforts by reference to:

  • the type, subject and nature of the content;
  • the likely audience expectations of the content;
  • the likely impact of reliance by the audience on the accuracy of the content; and
  • the circumstances in which the content was made and presented.

Elite TV1 International accuracy standard applies to assertions of fact, not to expressions of opinion.

An opinion, being a value judgement or conclusion, cannot be found to be accurate or inaccurate in the way facts can. The accuracy standard requires that opinions be conveyed accurately, in the sense that quotes should be accurate and any editing should not distort the meaning of the opinion expressed.

The efforts reasonably required to ensure accuracy will depend on the circumstances. Sources with relevant expertise may be relied on more heavily than those without.

Eyewitness testimony usually carries more weight than second-hand accounts. The passage of time or the inaccessibility of locations or sources can affect the standard of verification reasonably required.

Elite TV1 International should make reasonable efforts, appropriate in the context, to signal to audiences gradations in accuracy, for example by querying interviewees, qualifying bald assertions, supplementing the partly right and correcting the plainly wrong.

 a.       Make reasonable efforts to ensure that material facts are accurate and present in context.

b.       Do not present factual content in a way that will materially mislead the audience.

In some cases, this may require appropriate labels or other explanatory information.

3. CORRECTIONS AND CLARIFICATIONS

A commitment to accuracy includes a willingness to correct errors and clarify ambiguous or otherwise misleading information. Swift correction can reduce harmful reliance on inaccurate information, especially given content can be quickly, widely and permanently disseminated.

Corrections and clarifications can contribute to achieving fairness and impartiality.

Acknowledge and correct or clarify, in an appropriate manner as soon as reasonably practicable:

a.       significant material errors that are readily apparent or have been demonstrated; or

b.       information that is likely to significantly and materially mislead.

4. IMPARTIALITY AND DIVERSITY OF PERSPECTIVES

Impartiality lies at the heart of public service and is the core of Elite TV1 International’s commitment to its audiences.  It applies to all our output and services – television, online, and in our international and commercial services.  We must be inclusive, considering the broad perspective and ensuring the existence of a range of views is appropriately reflected.

Elite TV1 International’s vision requires us to do all we can to ensure that controversial subjects are treated with due impartiality in our news and other output dealing with matters of public policy or political or industrial controversy.  But we go further than that, applying due impartiality to all subjects.  However, its requirements will vary.

The meaning of the term ‘due’ is that the impartiality must be adequate and appropriate to the output, taking account of the subject and nature of the content, the likely audience expectation and any signposting that may influence that expectation.

Due impartiality is often more than a simple matter of balance between opposing viewpoints.  Equally, it does not require absolute neutrality on every issue or detachment from fundamental democratic principles.

Elite TV1 International’s vision forbids our output from expressing the opinion of Elite TV1 International on the current matters of public policy, other than broadcasting or the provision of online services.

The external activities of staff, presenters and others who contribute to our output can also affect Elite TV1 International’s reputation for impartiality.  Consequently, this part should be referred in conjunction with conflicts of interest.

4.1 Principles

We must do all we can to ensure that controversial subjects are treated with due impartiality in all our output.

News in whatever form must be treated with due impartiality, giving due weight to events, opinion and main strands of argument.

We seek to provide a broad range of subject matter and perspectives over an appropriate timeframe across our output as a whole.

We are committed to reflecting a wide range of opinion across our output as a whole and over an appropriate timeframe so that no significant strand of thought is knowingly un-reflected or under-represented.

We exercise our editorial freedom to produce content about any subject, at any point on the spectrum of debate, as long as there are good editorial reasons for doing so.

4.2 Referrals to Editorial Policy

Any approach by a government department to relay official messages or information films which involve a degree of public policy or political controversy must be referred to Programs Director and Political Adviser.

Any Elite TV1 International public service initiative involving any element of fundraising must be referred to Editorial Policy Adviser.

Any proposal to invite a politician to be a guest on a programme or area of content where to do so is the exception rather than the rules, must be referred to Programs Director and Political Adviser. 

4.3 Breadth and Diversity of Opinion

Across our output as a whole, we must be inclusive, reflecting a breadth and diversity of opinion.  We must be fair and open-minded when examining the evidence and weighing material facts.  We must give due weight to the many and diverse areas of an argument.

Breadth and diversity of opinion may require not just a political and cultural range, but, on occasions, reflection of the variations between urban and rural, older and younger, poorer and wealthier, the innovative and the status quo, etc.  It may involve exploration of perspectives in different communities, interest groups and geographic areas.

4.4 Due Weight

Impartiality does not necessarily require the range of perspectives or opinions to be covered in equal proportions either across our output as a whole, or within a single programme, web page or item.  Instead, we should seek to achieve ‘due weight’.  For example, minority views should not necessarily be given equal weight to the prevailing consensus.

Nevertheless, the omission of an important perspective, in a particular context, may jeopardise perceptions of the Elite TV1 International’s impartiality.  Decisions over whether to include or omit perspectives should be reasonable and carefully reached, with consistently applied editorial judgement across an appropriate range of output.

4.5 Reporting in the UK and Worldwide

We should also take account of the different political cultures and structures in different parts of the UK and the rest of the world, for instance, in ensuring that differing main strands of argument in one or more of the nations receive due weight and prominence in UK-wide output.

 4.6 Impartiality and Audiences

Listening to and engaging with audiences is central to Elite TV1 International’s output, from our studios to user generated content online.  But responses should not be given a wider significance than they merit and we should take care not to misrepresent the relative weight of opinions expressed.  We should also be prepared to apply appropriate scrutiny to audience opinions and ensure that the debate does not appear closed to members of the audience who support a minority view when they have not already made contact.

4.7 Controversial Subjects

We must apply due impartiality to all our subject matter.  However, there are particular requirements for controversial subjects, whenever they occur in any output, including drama, entertainment and sport.

A ‘controversial subject’ may be a matter of public policy or political or industrial controversy.  It may also be a controversy within religion, science, finance, culture, ethics and other matters entirely.

In determining whether subjects are controversial, we should take account of: the level of public and political contention and debate how topical the subjects are sensitivity in terms of relevant audiences’ beliefs and culture whether the subjects are matters of intense debate or importance in a particular nation, region or discrete area likely to comprise at least a significant part of the audience a reasonable view on whether the subjects are serious the distinction between matters grounded in fact and those which are a matter of opinion.

Advice on whether subjects are ‘controversial’ is available from Editorial Policy.

 When dealing with ‘controversial subjects’, we must ensure a wide range of significant views and perspectives are given due weight and prominence, particularly when the controversy is active.  Opinion should be clearly distinguished from fact. 

Due impartiality normally allows for programmes and other output to explore or report on a specific aspect of an issue or provide an opportunity for a single view to be expressed.  When dealing with controversial subjects this should be clearly signposted, should acknowledge that a range of views exists and the weight of those views, and should not misrepresent them.

Consideration should be given to the appropriate timeframe for reflecting other perspectives and whether or not they need to be included in connected and signposted output.

If such output contains serious allegations, a right of reply may be required, either as part of the same output, or in a connected and clearly signposted alternative.

In addition, we must take particular care and achieve due impartiality when a ‘controversial subject’ may be considered to be a major matter.  Major matters are usually matters of public policy or political or industrial controversy that are of national or international importance, or of a similar significance within a smaller coverage area.  When dealing with ‘major matters’, or when the issues involved are highly controversial and/or a decisive moment in the controversy is expected, it will normally be necessary to ensure that an appropriately wide range of significant views are reflected in a clearly linked series of programmes, a single programme or sometimes even a single item.

4.8 Controversial Subjects and Linking

Where Elite TV1 International online sites covering controversial subjects offer links to external sites, we should ensure that the information on those external sites, taken together, represents a reasonable range of views about the subject.  We should normally try to ensure the external sites do not give strong grounds for concern that they breach the law or the Elite TV1 International Editorial Guidelines on harm and offence.

4.9 Government Information

Any approach by a government department to relay official messages or information films which involve a degree of public policy or political controversy must be referred to our Political Adviser.

a) News, Current Affairs and Factual Output

News in whatever form must be treated with due impartiality, giving due weight to events, opinion and main strands of argument.  The approach and tone of news stories must always reflect our editorial values, including our commitment to impartiality.

Presenters, reporters and correspondents are the public face and voice of the Elite TV1 International, they can have a significant impact on perceptions of whether due impartiality has been achieved.  Our audiences should not be able to tell from Elite TV1 International output the personal prejudices of our journalists or news and current affairs presenters on matters of public policy, political or industrial controversy, or on ‘controversial subjects’ in any other area.  They may provide professional judgements, rooted in evidence, but may not express personal views in Elite TV1 International output, including online, on such matters.

We should not automatically assume that contributors from other organisations (such as academics, journalists, researchers and representatives of charities) are unbiased and we may need to make it clear to the audience when contributors are associated with a particular viewpoint, if it is not apparent from their contribution or from the context in which their contribution is made.

b) Elite TV1 International Content or Story

When dealing with controversial subjects concerning Elite TV1 International, our reporting must remain duly impartial, as well as accurate and fair.  We need to ensure Elite TV1 International’s impartiality is not brought into question and presenters or reporters are not exposed to potential conflicts of interest.  It will be inappropriate to refer to either Elite TV1 International as “we or the content as our”.  There should also be clear editorial separation between those reporting the story and those responsible for presenting Elite TV1 International’s case.

c) Entertainment and Culture

The audience expects artists, writers and entertainers to have scope for individual expression in drama, entertainment and culture.  Elite TV1 International is committed to offering it.  Where this covers matters of public policy, political or industrial controversy, or other controversial subjects, services should normally aim to reflect a broad range of the available perspectives over time.  Consideration should be given to the appropriate timeframe for reflecting those other perspectives and whether or not they need to be included in connected and signposted output taking account of the nature of the controversy and the subject matter.

A drama where a view of controversial subjects is central to its purpose, must be clearly signposted to our audience.  Its excellence and insights must justify the platform offered.  It may be appropriate to offer alternative views in other connected and signposted output.  Advice is available from Editorial Policy.

4.10 Contentious Views and Possible Offence

Contributors expressing contentious views, either through an interview or other means, must be rigorously tested while being given a fair chance to set out their full response to questions. Minority views should be given appropriate space in our output; it is not for Elite TV1 International to suppress discussion.

Consequently, we will sometimes need to report on, or interview, people whose views may cause serious offence to many in our audiences. On such occasions, referral should be made to a Programs Director and Editorial Adviser who may wish to consult Editorial Policy. The potential for offence must be weighed against the public interest6 and any risk to Elite TV1 International’s impartiality. Coverage should acknowledge the possibility of offence, and be appropriately robust, but it should also be fair and dispassionate.

The public expression by staff and presenters of personal offence or indignation risks jeopardising Elite TV1 International’s impartiality. 

4.11Consensus, Campaigns and Scrutiny 

a) Consensus

There are some issues which may seem to be without controversy, appearing to be backed by a broad or even unanimous consensus of opinion.

Nevertheless, they may present a significant risk to Elite TV1 International’s impartiality. In such cases, we should continue to report where the consensus lies and give it due weight. However, even if it may be neither necessary nor appropriate to seek out voices of opposition, our reporting should resist the temptation to use language and tone which appear to accept consensus or received wisdom as fact or self-evident.

We must challenge our own assumptions and experiences and also those which may be commonly held by parts of our audience. Elite TV1 International output should avoid reinforcing generalisations which lack relevant evidence, especially when applying them to specific circumstances. This might occur in the fields of politics, race, charity, science, technology, medicine or elsewhere. These can

present some of the most difficult challenges to asserting that Elite TV1 International does not hold its own opinion. Care should be taken to treat areas of apparent consensus with proper rigour. Where necessary, consult Editorial Policy. 

b) Campaigns

Similarly, Elite TV1 International must remain independent and distanced from government initiatives, campaigners, charities and their agendas, no matter how apparently worthy the cause or how much their message appears to be accepted or uncontroversial.

Careful thought will be necessary to ensure perceptions of Elite TV1 International’s impartiality are maintained when content is scheduled topically and coincides with a third party’s campaign. It is advisable to contact Editorial Policy.

           Social Action

Social action output can form an important part of Elite TV1 International’s public service. However, care is required to ensure Elite TV1 International sets its own social action agenda and decides its own priorities:

  • We must ensure that our output does not simply embrace the agenda of any particular campaign groups and that we treat groups objectively and do not favour one above another.
  • If our social action programmes or campaigns coincide with a government campaign or lobbying initiative, it is important we retain an arm’s length position.
  • We must not lobby on matters of public policy when raising awareness of important social issues
  • News reporting of Elite TV1 International social action campaigns must be duly impartial.
  • Any Elite TV1 International public service initiative involving any element of fundraising must be referred to our Department of Finance and Human Resources.

c) Scrutiny

 We should ensure that appropriate scrutiny is not limited just to those who are in government, or hold power and responsibility, but is also applied to those who oppose them, campaigns, lobbyists, opposition groups and others, including views expressed interactively by the audience.

  • Elections and Referendums

Special considerations apply during the campaigns for elections and referendums and, in some cases, the period running up to campaigns will involve greater sensitivity with regard to due impartiality in all output genres.

Programs Director will issue specific advice and, for the UK or international, will publish separate Guidelines for each campaign period.

  • Impartiality in Series and Over Time

In achieving due impartiality, a series of programmes may be considered as a whole.

The term ‘series of programmes’ applies to the following:

Content that deals with the same or related issues, within an appropriate period, and are clearly linked.

This may include a strand with a common title; different types of linked programmes (such as a drama with a  following debate); a clearly identified season of programmes or items on the same or similar subjects; or a set of interlinked web pages. Such programmes, items or web pages need to achieve due impartiality across the series, and online content should include links or signposts to the other online elements.

The intention to achieve due impartiality in this way should be planned in advance. For programmes, the dates and times of other programmes in the series should be announced at the time of the first relevant programme. Where that is not practicable, advance notice of subsequent programmes in the series should be given in other ways.

Programmes dealing with widely disparate issues from one edition to the next, but also clearly linked as a strand with a common title and a particular remit.

In strands, due impartiality should normally be achieved within individual programmes, or across a specific number of explicitly editorially linked programmes. However, across a whole series or over time these strands will also need to demonstrate due impartiality, for example through a consistent application of editorial judgement.

On long-running or continuous output (such as the News Channel, Online, etc.) due impartiality may be achieved over time by the consistent application of editorial judgement in relevant subject areas. For instance, it is not usually required for an appearance by a politician, or other contributor with partial views, to be balanced on each occasion by those taking a contrary view, although it may sometimes be necessary to offer a right of reply.

It reflects a broad range of individuals and views, including all main strands of argument differing views are given due weight and treated fairly in terms of prominence, treatment and time of day there is an appropriate timeframe for assessing that due impartiality has been achieved. Particular care is required approaching elections.

When dealing with ‘major matters’, due impartiality cannot normally be achieved over time or by a breadth of views available across our online services.

Some output which covers normally non-controversial areas (such as favourite music, sporting allegiances or personal biography) may seek, on an occasional basis, to include contributors or presenters who are otherwise

known for their partiality, for example politicians, campaigners or others who are identified with particular views. On these occasions, an appropriate breadth and diversity should be achieved over time by a consistent application of editorial judgement which might mean ensuring that, for example, potentially

favourable content includes other individuals with differing views. The appropriate timeframe for achieving the necessary breadth and diversity will vary according to context, but it will not normally be greater than a programme series or a year. There will be different considerations during periods approaching elections.

Any proposal to invite a politician to be a guest on a programme or area of content where to do so is the exception rather than the rule, must be referred to the Managing Director or his deputy.

In all instances where the aim is to achieve due impartiality regarding politics or public policy over a series or over time, periods approaching elections and referendums must be given special consideration.

On occasion, an individual programme or other content, which is not part of a series or long-running or continuous output, includes the expression of a view on a ‘controversial subject’ and still meets the requirements of due impartiality for that individual programme or content. On such occasions, referral should be made to the relevant output controller, so that consideration can be given to due impartiality across the relevant service if necessary.

  • Personal View Content

Elite TV1 International has a tradition of allowing a wide range of individuals, groups or organisations to offer a personal view or opinion, express a belief, or advance a contentious argument in its output. This can range from the outright expression of highly partial views by a campaigner, to the opinion of a specialist or professional including an academic or scientist, to views expressed through contributions from our audiences. All of these can add to the public understanding and debate, especially when they allow our audience to hear

fresh and original perspectives on familiar issues. Such personal view content must be clearly signposted to audiences in advance.

Additionally, when personal view programmes and websites (for example, blogs) cover controversial subjects, especially those concerning matters of public policy or political or industrial controversy, we should:

  • retain a respect for factual accuracy
  • fairly represent opposing viewpoints when included
  • provide an opportunity to respond when appropriate, for example in a prearranged

             discussion programme

  • ensure that a sufficiently broad range of views and perspectives is included in output of a similar type and weight and in an appropriate timeframe.

Elite TV1 International staff and regular Elite TV1 International presenters or reporters associated with news or public policy-related output may offer professional judgements rooted in evidence. However, it is not normally appropriate for them to present or write personal view programmes and content on public policy, on matters of political or industrial controversy, or on controversial subjects in any area.

5. FAIR AND HONEST DEALING

Fair and honest dealing is essential to maintaining trust with audiences and with those who participate in or are otherwise directly affected by Elite TV1 International content. In rare circumstances, deception or a breach of an undertaking may be justified. Because of the potential damage to trust, deception or breach of an undertaking must be explained openly afterwards unless there are compelling reasons not to do so.

Dealing with participants

  • Participants in Elite TV1 International content should normally be informed of the general nature of their participation.
  • A refusal to participate will not be overridden without good cause.

Opportunity to respond

  • Where allegations are made about a person or organisation, make reasonable efforts in the circumstances to provide a fair opportunity to respond.

Attribution and sources

  • Aim to attribute information to its source.
  • Where a source seeks anonymity, do not agree without first considering the source’s motive and any alternative attributable sources.
  • Do not misrepresent another’s work as your own.

Undertakings

Assurances given in relation to conditions of participation, use of content, confidentiality or anonymity must be honoured except in rare cases where justified in the public interest.

Secret recording and other types of deception

 Secret recording devices, misrepresentation or other types of deception must not be used to obtain or seek information, audio, pictures or an agreement to participate except where:

  • justified in the public interest and the material cannot reasonably be obtained by any other means; or
  • consent is obtained from the subject or identities are effectively obscured; or
  • the deception is integral to an artistic work and the potential for harm is taken into consideration.

Mandatory referral

An appropriately senior Elite TV1 International person designated for the purpose must approve in advance, having consulted Elite TV1 International Legal, any proposal:

  • to use secret recording during the production of content commissioned, produced or co-produced by Elite TV1 International; or
  • to broadcast or publish material obtained by deception; or
  • to broadcast or publish without attribution information that forms the basis of a report and the Elite TV1 International is to be committed to protect the identity of the source of the information; or
  • not to honour an assurance given in relation to conditions of participation, use of content, confidentiality or anonymity. 

6. PRIVACY

Privacy is necessary to human dignity and every person reasonably expects that their privacy will be respected. But privacy is not absolute. Elite TV1 International seeks to balance the public interest in respect for privacy with the public interest in disclosure of information and freedom of expression.

Intrusion into a person’s private life without consent must be justified in the public interest and the extent of the intrusion must be limited to what is proportionate in the circumstances.

7. HARM AND OFFENCE

Elite TV1 International broadcasts and publishes comprehensive and innovative content that aims to inform, entertain and educate diverse audiences. Innovation involves a willingness to take risks, invent and experiment with new ideas. This can result in challenging content which may offend some of the audience some of the time. But it also contributes to diversity of content in the media and to fulfilling Elite TV1 International’s function to encourage and promote the musical, dramatic and other performing arts. Elite TV1 International acknowledges that a public broadcaster should never gratuitously harm or offend and accordingly any content which is likely to harm or offend must have a clear editorial purpose.

Elite TV1 International potentially reaches the whole community, so it must take into account community standards. Elite TV1 International must also be able to provide content for specific target audiences whose standards may differ from generally held community attitudes. Applying the harm and offence standard requires careful judgement. Context is an important consideration.

What may be inappropriate and unacceptable in one context may be appropriate and acceptable in another. Coarse language, disturbing images or unconventional situations may form a legitimate part of reportage, debate, documentaries or a humorous, satirical, dramatic or other artistic work. Consideration of the nature of the target audience for particular content is part of assessing harm and offence in context, as is any signposting that equips audiences to make informed choices about what they see, hear or read.

a) Content that is likely to cause harm or offence must be justified by the editorial context.

b) Where content is likely to cause harm or offence, having regard to the context, make reasonable efforts to provide information about the nature of the content through the use of classification labels or other warnings or advice.

c) Ensure all domestic television programs – with the exception of news, current affairs and sporting events – are classified and scheduled for broadcast in accordance with Elite TV1 International’s Associated Standard on Television Program Classification.

d) If inadvertent or unexpected actions, audio or images in live content are likely to cause harm or offence, take appropriate steps to mitigate.

e) The reporting or depiction of violence, tragedy or trauma must be handled with extreme sensitivity. Avoid causing undue distress to victims, witnesses or bereaved relatives. Be sensitive to significant cultural practices when depicting or reporting on recently deceased persons.

f) Where there is editorial justification for content which may lead to dangerous imitation or exacerbate serious threats to individual or public health, safety or welfare, take appropriate steps to mitigate those risks, particularly by taking care with how content is expressed or presented.

g) Avoid the unjustified use of stereotypes or discriminatory content that could reasonably be interpreted as condoning or encouraging prejudice. 

8. CHILDREN AND YOUNG PEOPLE

Elite TV1 International aims to provide children and young people (under the age of 18) with enjoyable and enriching content, as well as opportunities for them to express themselves. Children and young people participate and interact with Elite TV1 International in various ways – as actors, presenters, interviewees, subjects, content makers and audience members.

Elite TV1 International has a responsibility to protect children and young people from potential harm that might arise during their engagement with the ABC and its content. Elite TV1 International shares this responsibility with parents/guardians and with the child or young person him/herself.

In particular, Elite TV1 International recommends that parents/guardians supervise children and young people’s access to content, their participation in interactive services, and their exposure to news and current affairs. It is not always possible to avoid presenting content that may be distressing to some audience members.

a) Take due care over the dignity and physical and emotional welfare of children and young people who are involved in making, participating in and presenting content produced or commissioned by Elite TV1 International.

b) Before significant participation of a child or young person in content produced or commissioned by Elite TV1 International, or in interactive services offered by Elite TV1 International, consider whether it is appropriate to obtain the consent of both the child/young person and the parent/guardian.

c) Adopt appropriate measures wherever practicable to enable children and young people, or those who supervise them, to manage risks associated with the child/young person’s participation with, use of and exposure to Elite TV1 International content and services designed for them.

d) Take particular care to minimise risks of exposure to unsuitable content or inappropriate contact by peers or strangers.

9. PUBLIC ACCESS AND PARTICIPATION

Elite TV1 International provides opportunities for individuals and organisations to engage with Elite TV1 International, its audiences and each other consistent with Elite TV1 International’s public service purposes to inform, entertain, educate and encourage and promote the arts.

Public access and participation can take many forms, for example: musicians and artists

submit work for broadcast or online presentation; audience members question Elite TV1 International presenters and their guests by phone or through online interactive services; organisers of concerts and other activities inform local communities through event diaries; political parties are granted broadcast time to convey their policies directly to the electorate; and community service announcements support charities and other activities in the public interest.

Elite TV1 International seeks both to draw audiences to the platforms it controls and to reach audiences using suitable services that third parties control. Elite TV1 International  takes editorial responsibility in proportion to its control of the media environment in which it operates. Elite TV1 International expects those who participate also to exercise responsibility for what they can control.

In fostering engagement, Elite TV1 International seeks to maintain its independence and integrity, preserve trust and cultivate respect among participants. Elite TV1 International may establish conditions for participation with which participants are expected to comply, such as Elite TV1 International‘s Terms or Conditions of Use relating to users’ interactivity on www.elitetv1international.com. Elite TV1 International will exercise appropriate oversight over participants’ contributions, for example through appropriate moderation of its interactive services.

Elite TV1 International does not require content generated and submitted by individuals and organisations to meet the standard of accuracy required of content generated by Elite TV1 International. However, where Elite TV1 International is satisfied that it is appropriate to do so, Elite TV1 International may decline to broadcast or publish, or may edit, remove, correct or clarify content generated by public participants that contains error or is otherwise false, misleading or harmful.

Individuals and organisations who generate and submit content are not required to be impartial. Elite TV1 International recognises that social and political activity, including robust debate, is a necessary and desirable aspect of a healthy democratic community.

a) the content is broadcast or published as a public service;

b) the content is relevant and suitable in the context in which it appears;

c) Elite TV1 International maintains editorial control; and

d) Elite TV1 International independence and integrity are maintained.

e) Opportunities to participate must be administered fairly and respectfully.

f)  Do not knowingly mislead audiences about the nature of the content.

g) Clearly distinguish content generated and submitted to Elite TV1 International from  content produced, commissioned or acquired by Elite TV1 International.

h) Do not accept money or other benefit in exchange for broadcasting or publishing the content generated through public access and participation.

10. ANNOUNCEMENTS ABOUT ELITE TV1 INTERNATIONAL PROGRAMS AND ACTIVITIES

Elite TV1 International is permitted by Elite TV1 International Act to publicise its programs, products, services, events and other activities. Elite TV1 International is conscious that its audiences value Elite TV1 International’s role as a non-commercial broadcaster and its commercial style. To that end, Elite TV1 International will ensure that announcements about Elite TV1 International activities are produced, scheduled and broadcast or published in a style consistent with the tone and approach of Elite TV1 International’s various content strands. Elite TV1 International program promotions should not misrepresent original content and should be scheduled so as to be consistent with the nature of the surrounding content.

10.1 Ensure program promotions and announcements about other Elite TV1 International activities are produced, scheduled and broadcast or published in a style consistent with the tone and approach of the surrounding content and appropriately take into consideration the likely composition of the audience.

10.2 Program promotions must not misrepresent the content they promote.

10.3 Announcements about specific Elite TV1 International commercial products, services or other activities may be broadcast or published provided that:

  • the product, service or activity is directly related to Elite TV1 International content or to content

               or services that bear an Elite TV1 International logo or trademark;

  • prior approval has been obtained from an appropriately senior person designated for the purpose within the Division(s) editorially responsible for the surrounding content or from the     Managing Director;
  • where the product, service or other activity involves sponsorship, any reference to the sponsor must be relevant to informing the audience and not simply a promotion of the sponsor; and
  • the announcement is not broadcast within news content, content designed for preschool children, or any television program.

10.4 Generic announcements about Elite TV1 International commercial products, services or other

activities may be made provided that:

  • prior approval has been obtained from an appropriately senior person designated for the purpose within the Division(s) editorially responsible for the surrounding content or from the Managing Director; and
  • the announcement is not broadcast within news content, content designed for preschool children, or any television program.

10.5 Except where permitted by law, do not accept payment or other benefit to broadcast an announcement relating to any program, product, service or other activity which has been produced, published or otherwise created or made available by Elite TV1 International in association with an external organisation. 1

11. ADVERTISING AND SPONSORSHIP

The advertisements and commercial sponsorship are one of the specific features of Elite TV1 International channel and online services. It has been defined by statute on Elite TV1 International creation. Elite TV1 International is conscious that its audiences value its connective role and style as a commercial broadcaster.

Elite TV1 International  is permitted by law to increase its private funding through advertising and sponsorship in relation to certain of its activities, for example its international television service. Elite TV1 International may also include advertisements in its commercial products and services where permitted under its internal rules.

Elite TV1 International will also accept advertising or sponsorship for online content or services offered on www.elittv1international.com.

Where permissible advertising or sponsorship occurs, Elite TV1 International is committed to maintaining  its audience in the honesty and integrity of what people see, hear and read. Advertisements and sponsored content must be readily recognisable as such. Advertisers and sponsors must have no influence over editorial content or scheduling decisions.

In all decisions relating to advertising and sponsorship, Elite TV1 International’s independence and integrity are paramount.

11.1 Elite TV1 International will accept advertising or sponsorship in relation to content or services offered on:

11.2 Can accept sponsorship for news content

11.3 Ensure advertising is following our procedures during the broadcasting within news content or others designed content. Announcements about Elite TV1 International programs and activities

11.4 Ensure sponsored content is identified as such and in a manner that informs.

11.5 References to a sponsor or a sponsor’s product or service must not be a condition of the sponsorship arrangement. Any sponsorship reference must be editorially justified.

11.6 Ensure advertising is readily distinguishable from editorial content.

11.7 Product placement and other forms of embedded or surreptitious advertising are prohibited. In exceptional cases, Elite TV1 International may use content that already contains product placement provided:

  • Elite TV1 International played no role in the production of the content;
  • the content has intrinsic editorial value;
  • the product placement is not unduly frequent or unduly prominent; and
  • Elite TV1 International’s editorial independence and integrity are not undermined.

11.8 Elite TV1 International will not enter into any advertising or sponsorship arrangement if it would be likely to undermine the its’ independence and integrity or could be reasonably perceived to do so.

12. COMMRCIAL REFERENCES

Elite TV1 International needs to be able to reflect the world as it is, and this involves referring appropriately to commercial organisations, products and services, while maintaining the Elite TV1 International’s editorial independence and integrity.

 

 12.1 References to trade names, brand names, and logos may be made provided that:

  • the references are editorially relevant in the context; and
  • Elite TV1 International’s editorial independence or integrity is not undermined.

12.2 Commercial references must not be unduly frequent or unduly prominent.

12.3 Take particular care to minimise commercial references in content designed

for children.

12.4 Do not state or imply that Elite TV1 International endorses any commercial organisation, product or service.

13. EXTERNAL FUNDING AND RELATIONSHIPS

Elite TV1 International relies on private funding from individual or organisation to fulfil its charter obligations and carry out its functions under Act. Elite TV1 International is permitted to supplement its private funding and work collaboratively with others to extend the variety and reach of content offered to the community. Elite TV1 International is permitted to accept direct external funding from private sources and can also enter into funding arrangements with other producers and publishers of content.

The production of content by independent producers, including co-production arrangements, regularly involves funding from the private sector, producer industry funding sources and other permitted sources some of which Elite TV1 International may not be able to access directly. Elite TV1 International is also able to accept free or discounted products, services or facilities to support the creation of content where that does not undermine the Elite TV1 International’s independence and integrity.

External funding sources for Elite TV1 International produced, commissioned or co-produced content must be scrutinised by Elite TV1 International to ensure its editorial independence and integrity are maintained. Contentiousness alone is not a reason to reject a proposal. Elite TV1 International policy requires innovative services of a high standard. The Editorial Policies require Elite TV1 International to present a diversity of perspectives over time on contentious matters. Innovation, high quality, diversity and contentiousness can travel together, so long as risks are properly managed.

In these Standards, “external partners” includes funders, producers, publishers and distributors.

13.1 Before Elite TV1 International enters into an arrangement for external funding or co-production of content, the arrangement must be scrutinised by an appropriately senior Elite TV1 International person designated for the purpose who must reject the arrangement unless satisfied that the independence and integrity of Elite TV1 International are fully protected. Factors to consider include:

  • whether the arrangement is permissible under Elite TV1 International policy;
  • whether the content is something that Elite TV1 International would consider producing for broadcast or publication without external funding;
  • the nature of the external partners’ interest in the subject matter of the content and in broadcast or publication of the content by Elite TV1 International, and how that interest – whether it be political, commercial, sectional, personal or otherwise – is likely to be perceived;
  • the extent to which the making, promotion or scheduling of the content will be influenced by any funder and how that influence is likely to be perceived;

12 Commercial

  • the reputations of the external partners, including where relevant whether they have editorial standards similar to Elite TV1 International’s;
  • the willingness of external partners to contract to comply with the Editorial Policies and to assist Elite TV1 International to comply;
  • how Elite TV1 International will exercise an appropriate level of editorial control that is commensurate with Elite TV1 International‘s contribution and consistent with its obligations under Elite TV1 International rules and Editorial Policies; and
  • the degree to which the subject matter or proposed treatment of the subject matter or scheduling of the content is likely to be contentious, and ways to manage that contentiousness consistent with obligations under Elite TV1 International rules and Editorial Policies.

13.2 A record of the reasons for acceptance or rejection of external funding proposals

must be kept.

13.3 The sources of funds obtained by external partners must be disclosed to Elite TV1 International before an external funding or co-production arrangement is formalised.

13.4 Free or discounted products, services or facilities may be accepted to support the

creation of content provided that:

  • there is no obligation imposed on or accepted by Elite TV1 International to structure or present any matter with a particular editorial perspective;
  • prior approval is obtained from an appropriately senior Elite TV1 International person designated for the purpose;
  •  the independence and integrity of Elite TV1 International are fully protected; and
  • accurate records are kept of what is accepted.

13.5 Any credits acknowledging creative, managerial and financial contributions must be editorially justified and not unduly prominent.

13.6 Ensure appropriate disclosure of any external funding arrangement, and any acceptance of free or discounted products, services or facilities, where the arrangement or

acceptance, if it were not disclosed but later became public, may reasonably be perceived to distort the editorial content or otherwise undermine Elite TV1 International’s independence or integrity.

14. RELIGION

Elite TV1 International respects the fundamental human right to exercise freedom of thought, conscience and religion. This includes an individual’s freedom to worship, teach, practise and observe. There is no longer an offence of blasphemy or blasphemous libel in any part of the UK, but religious beliefs are central to many people’s lives and arouse strong views and emotions. We should take care to avoid unjustified offence.

We aim to achieve this by ensuring our output is not used to denigrate the religious beliefs of others, while upholding the right to freedom of expression. 

Under the Ofcom Broadcasting Code, “The religious views and beliefs of those belonging to a particular religion or religious denomination must not be subject to abusive treatment”. In law, the Racial and Religious Hatred Act 2006, which applies to England and Wales, forbids a person from using threatening words or behaviour or displaying written material that is threateningif he intends thereby to stir up religious hatred”. 

Elite TV1 International also has a duty to protect the vulnerable and avoid likely harm. The Ofcom Broadcasting Code requires that religious output “must not seek to promote religious views or beliefs by stealth”, nor “improperly exploit any susceptibilities of the audience”.

For the purposes of Elite TV1 International Editorial Guidelines, religious output is defined as output dealing with the religious views and/or beliefs of a religion or religious denomination as the central subject or a significant part. This part of the Guidelines has considerations both for religious output and any other output concerning religion.

  • The beliefs and practices of religions and denominations must be described with due accuracy.

1 Rule 4.2, Ofcom Broadcasting Code

2 Rule 4.4, Ofcom Broadcasting Code

3 Rule 4.6, Ofcom Broadcasting Code

  • The religious views and beliefs of an individual, a religion or denomination must not be misrepresented or abused, as judged against generally accepted standards.
  • We must be aware of the religious sensitivity of references to, or uses of, names, images, deities, rituals, scriptures and language at the heart of the different faiths and ensure that any uses of, or verbal or visual references to, them are editorially justified within generally accepted standards. Examples include the Crucifixion, Holy Communion, the Qur’an, the Jewish Sabbath and similar.
  • We must consider the religious sensitivity surrounding the observance of holy days and the principal festivals of the great world faiths to avoid unnecessary offence from material that might be more acceptable at other times.

Any content dealing with matters of religion and likely to cause offence to those with religious views and beliefs must be editorially justified as judged against generally accepted standards and must be referred to Elite TV1 International managerial committee.

When a religion or denomination is the subject of religious output, the identity of the religion or denomination must be clear.

Religious output should not be used to recruit, for example by making direct appeals to audiences to join a particular religion. References to the positive effects of belonging to a particular religion will normally be acceptable.

We should treat any claims made in our religious output for the special powers or abilities of a living person or group with due objectivity. Such claims should not be made when significant numbers of children may be expected to be watching television or in online content likely to appeal to a high proportion of children.

Contributors to religious output should not be allowed to undermine or denigrate the religious beliefs of others. Religion and religious views may be criticised but we should ensure there is appropriate context and critical views are open to challenge.

Any content dealing with matters of religion and likely to cause offence to those with religious views and beliefs must be editorially justified as judged against generally accepted standards and must be referred to Elite TV1 International managerial committee.

All advices are available from the Religion and Ethic concerns in Elite TV1 International managerial committee.

With user generated content on religion, care is necessary to strike the right balance between freedom of expression and avoiding unnecessary offence. We are more likely to achieve this balance if:

  • the space is actively hosted
  • we select a suitable form of moderation
  • on occasion, we make a rapid intervention – unless, for example, the online community has already responded robustly and in an authoritative way to an offensive comment.

14. LEGAL POLICY

Elite TV1 International producers, whether making programmes or other content, should seek the advice of Programme Legal Advice whenever legal problems are encountered or suspected.

Elite TV1 International Legal handles legal issues affecting Elite TV1 International, with different departments

dealing with different issues.

The Programme Legal Advice department gives pre-transmission advice on the main content-related issues including defamation, privacy, contempt of court, victims of sexual offences and reporting restrictions.

Advice on other issues should be sought from Elite TV1 International management committee.

There are significant differences between the legal systems of England and Wales, Scotland and Northern Ireland which, if not observed, can cause serious problems.

For advice on our media law consult Elite TV1 International Programs Director, or our Solicitor in the UK.

In addition, Programme Legal Advice keeps a list of lawyers in various countries and may be able to assist with advice on foreign law.

In this section, children are referred to according to legal definition rather than the ages used elsewhere in the Editorial Guidelines.

Any decision to proceed with a programme despite legal advice must be referred to Managing Director, Director of Programs and Director of Finance and Human Resources.

Any proposal to break the law must be referred to Managing Director, Director of Programs, or Director of Finance and Human Resources, who may consult Programme Legal Advice and, if necessary before processing.

Any formal requests for information or notices to stop processing under the Data Protection Act must be referred in good time to Information Policy and Compliance (IPC).

14.1 General

There may be occasions where providing accurate, impartial and fair coverage in the public interest involves possible conflict with the law. Where such cases arise we must consider:

  • what effect breaking the law might have on Elite TV1 International
  • what the effect might be on the people concerned internationally, the effect on Elite TV1 International’s future coverage of the region.

Any proposal to break the law must be referred to Managing Director, Director of Programs, or Director of Finance and Human Resources, who may consult Programme Legal Advice and, if necessary before processing.

Any decision to proceed with a programme despite legal advice must be referred to Managing Director, Director of Programs, or Director of Finance and Human Resources.

14.2 Defamation

An individual can sue for damage to their reputation caused by material broadcast to a third party, including material published online.

This area of the law is called defamation or libel. It is the biggest legal pitfall relating to Elite TV1 International’s output, with serious financial consequences if we get it wrong.

Any living individual or company can sue as long as they are reasonably identifiable from what is said and the material is defamatory of them. This means that it would tend to lower them in the estimation of right-thinking people generally.

The claimant does not need to show that they suffered any actual damage, nor that what was said was false. On the contrary, the defendant generally has to prove that it was true.

If involved in an action for defamation there are a number of possible defences but, generally, broadcasters will need to have good evidence to back up what they say.

14.3 Privacy

The Human Rights Act, which came into effect in 2000, includes a right to privacy.

Individuals can now take action to enforce that right. Often, they will ask the court to grant an injunction to stop true stories about their private lives being made public.

If there is a reasonable expectation of privacy, the court will seek to balance the individual’s right to privacy against the media’s right to freedom of expression.

When broadcasting a story which contains private information, each piece of private information will need to be considered separately. If private information is conveyed by pictures, these will be subjected to special scrutiny.

14.4 Contempt 

Contempt of court is the body of law which protects the integrity of the legal process from outside influence. Contempt can take many forms but the most serious for Elite TV1 International is publication of prejudicial material when legal proceedings are said to be active.

In most criminal cases, the active period starts with the granting of an arrest warrant, the arrest of a suspect, the issue of a summons indictment. This may be well before a person is charged.

Once a case is active, anything which creates a substantial risk that the course of justice in those proceedings will be seriously prejudiced or impeded will be a contempt of court. This is the case regardless of intent. A serious prejudice might include, for example, the publication of previous convictions.

These rules apply to all courts and tribunals exercising the judicial authority of the state. However, the risk is highest when the case is due to be heard by a lay jury (for example, in criminal trials) and particular care should be taken with coverage immediately before a jury trial. Reports of the trial itself are generally safe so long as they are fair and accurate and no reporting restrictions have been put in place.

14.5 Victims of Sexual Offences

All victims of rape and other sex crimes, including children, are automatically guaranteed anonymity for life from the moment they make a complaint that they are the victim of a sex crime. In other countries, the law is different but the practice of respecting anonymity is the same.

These restrictions only apply to identifying the person as being the victim of an alleged sexual offence. They do not prevent the identification of the person in other contexts.

Judges may, on occasion, lift the restrictions 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.

We should be always aware of the risk of ‘jigsaw identification’. 

14.6 Other Reporting Restrictions

There are a number of other situations in which reporting restrictions either apply automatically, or can be specifically ordered by a court. Automatic restrictions apply to:

  • reports of preliminary/committal proceedings in magistrates’ courts in England. We can only report certain very basic details
  • reports of proceedings in Youth Courts (see below)
  • proceedings under the Children Act. We must not broadcast anything which is likely to identify any child as being involved in such proceedings.

These restrictions can be lifted or varied by a court. 

Some of the more common reporting restrictions which may be ordered include:

  • Section 39 Orders, preventing the identification of under-18s involved in proceedings before an adult court
  • Postponement Orders, preventing publication of reports of proceedings until after the conclusion of related proceedings or until the court lifts or varies the restrictions

Anonymity Orders, where the court has allowed a person’s details to be withheld, for example in blackmail cases.

Note that any queries involving legal proceedings in any country should be referred to Elite TV1 International Solicitor, in the UK.

14.7 CHILDREN AND THE LAW

Programme Legal Advice should be consulted whenever there are queries about the law as it affects children. 

Children Involved in Criminal Cases

In United Kingdom people accused of committing offences while under 18 are usually dealt with in Youth Courts. In other countries, a young person accused of criminal behaviour is treated as an adult from the age of 16, except in children’s hearings.

In Youth Court proceedings, there is an automatic ban on anything which might lead to the identification of a witness, defendant or other party in those proceedings who is under 18.

This includes a prohibition of giving the name, address or school, as well as the use of pictures.

In other courts, there is no automatic restriction but the court can make an order preventing identification of a child involved in the proceedings.

The restrictions for Youth Courts also apply to Children’s Panel/Referral cases.

Children Involved in Civil Cases

Other court proceedings involving children may be heard in magistrates’ courts, County Courts, or the High Court. They may deal with care proceedings, adoption or guardianship.

The Children’s Hearings System 

The Children’s Hearings system deals with children in other countries including Scotland. Any child involved in a hearing before the Children’s Panel or an associated referral hearing before a Court cannot be identified. It is forbidden to broadcast anything in respect of any case about which the reporter has received information or any matter to do with a children’s hearing which is likely to identify any child concerned in any way with the case. Please note that this may include not just victims and witnesses, but children who are brothers, sisters, friends etc. Note too that contentious Children’s Panel cases can end up in the Court. If they do, they are still covered by this wide prohibition.

For children’s hearing purposes, a person remains a child until he or she turns 18.

Courts Sitting in Private 

In any courts sitting in private, it is usually a contempt to broadcast detailed accounts of child related hearings. This will include proceedings involving wardship, adoption and guardianship of an infant.

In wardship cases it is not contempt to report the court’s order or an accurate summary of it, unless the court expressly forbids this.

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 16
  • involve a child under 16 in a photograph that is itself indecent even if the child’s role is not.

14.8 Copyright and Other Intellectual Property Rights

Intellectual property rights include:

  • copyright
  • moral rights
  • performers’ rights
  • trade marks
  • patents and designs
  • rights to prevent “passing off” and breach of confidence.

Intellectual Property lawyers in the Litigation and Intellectual Property (L&IP) management give advice on the protection and exploitation of Elite TV1 International’s intellectual property rights and on the infringement risks to Elite TV1 International of using third parties’ intellectual property rights. Litigation specialists in this section give advice on the infringement of intellectual property rights.

Advice must be sought from the Talent and Rights Negotiation Group (TRNG) in Rights and Business Affairs about the commissioning or clearance of copyright works for use in Elite TV1 International programmes or the contracting of performers.

TRNG will generally provide the contracting service and contact should be made with them in good time.

There may be circumstances where a copyright work, in which rights have not been cleared, can nevertheless be included in a programme under fair dealing or other copyright exceptions. Anyone requiring advice on this from News and Current Affairs should contact the Intellectual Property lawyers in L&IP. Other departments should contact TRNG.

If negative checks cast any doubt on the use of a particular programme title or associated products, info@elitetv1international.com should be consulted.

14.9 DATA PROTECTION ACT 

This act protects individuals’ privacy by regulating how personal information, known in the act as ‘personal data’, is collected and used. The act applies to information stored electronically or in manual systems.

‘Personal data’ is any information that relates to a living individual who can be identified:

  • from that information, or
  • from that and other information in our possession or likely to come into our possession.

Personal data can include:

  • email addresses or telephone numbers, collected when people enter competitions, sign up for a newsletter or become part of a programme’s database of contributors
  • information about people we collect for use in content, including images and sound recordings.

The act requires that personal information is:

  • collected and used fairly (i.e. we make it clear to people how we intend to use their information and whether it will be given to anyone else inside or outside Elite TV1 International)
  • appropriate to the uses which have been agreed
  • not excessive (i.e. we only collect and use the data necessary for Elite TV1 International’s purposes)
  • accurate
  • stored for the minimum time relevant to the use for which it is collected
  • stored and used securely, for example, by using encrypted memory sticks or CD- ROMs and in accordance with any further applicable guidelines issued by Elite TV1 International
  • disposed of securely once the use for which it has been collected has come to an end
  • protected by a contract, if it is being given to an agent of Elite TV1 International or to a third party, to ensure the information is only used for the purpose Elite TV1 International has agreed. A contract or other special arrangements are also needed if personal information is being sent to a third party or agent of Elite TV1 International located outside the EU.

Material acquired and used for journalistic, artistic or literary purposes is exempt if compliance with the act would frustrate those purposes. For example, we do not need the consent of someone being filmed committing crime. It must be incompatible with the journalistic, artistic or literary purpose to comply with the Act – inconvenience is not enough. Note that the requirement to store and use data securely applies at all times.

People have certain rights under the act in relation to information stored about them and can make a request to Elite TV1 International to be provided with a copy of that information.

Any formal requests for information or notices to stop processing under the act must be referred in good time to the Information Policy & Compliance Department (IPC).

IPC or the Commercial and Regulatory Legal department can advise on queries about the act.

15. ACCOUNTABILITY

Elite TV1 International is accountable to its audiences. Their continuing trust in Elite TV1 International is a crucial part of our relationship with them. We will act in good faith by

dealing fairly and openly with them.

We are open in acknowledging mistakes when they are made and encourage a culture of willingness to learn from them.

We will use Elite TV1 International’s online presence to provide proper reporting to the public on complaints we have received, and actions we have taken.

15.1 OFCOM

Ofcom has certain powers to regulate Elite TV1 International’s licence fee funded television and radio services aimed at audiences in the UK, but not the World Service which is grant-in-aid funded. Ofcom’s Broadcasting Code applies in the following areas:

  • · Protection of under-18s
  • · Harm and Offence
  • · Avoidance of inciting crime or disorder
  • · Responsible approach to religious content
  • · Prohibition of use of images of very brief duration
  • · Fairness
  • · Privacy.

The Editorial Guidelines reflect the provisions of the Ofcom Broadcasting Code in these areas.In addition, Elite TV1 International’s commercial services (whether broadcasting to the UK, or from the UK to our international audiences) must comply with the whole of the Ofcom Broadcasting Code. 

Where Ofcom finds a breach of the privacy or fairness sections of its Code, it may require the BBC to broadcast a statement of its findings. Where Ofcom considers that the Code has been breached “seriously, deliberately, repeatedly, or recklessly”, it can impose sanctions, which range from a requirement to broadcast a correction or statement of finding to a fine of no more than £250,000.

15.2 FEEDBACK AND COMPLAINTS

Audiences are at the heart of everything the BBC does. Audience feedback is invaluable to us and helps to improve programme quality.

Our commitment to our audiences is to ensure that complaints and enquiry are dealt with quickly, courteously and with respect.

Elite TV1 International has created a complaints framework, which lays out practices for complaints handling:

  • Complainants should be treated politely and with respect
  • The stages of all procedures will be published on Elite TV1 International website so that information about complaints procedures is clear and readily available to the complainant and will be provided on request
  • A complainant/member of the audience who contacts Elite TV1 International at Stage one with a comment or complaint should be informed in the reply that there is a complaints process and that there may also be a way of pursuing a complaint outside Elite TV1 International
  • Any response to a complaint should inform the complainant of the next step in the process for taking the complaint further if applicable and where, if applicable, to pursue the complaint outside Elite TV1 International
  • Complaints should be responded to in a timely manner
  • Reasonable provision must be made to ensure that complaints procedures are accessible to all. Assistance will be provided to those who are unable to make their complaint in the usual format and contact details will be provided
  • There should be a presumption that Executive decisions to uphold a complaint will be reported on. Exceptions to this will be where information is provided in confidence or publication would be inappropriate, for example details of an upheld first party editorial complaint where there has been a breach of privacy or a commercially sensitive complaint. Details about complainants and complaints will be anonymous unless otherwise discussed with the complainant
  • When considering complaints on substantive matters Elite TV1 International must provide adequate reasoning for its decision, setting this reasoning within the context of any relevant Elite TV1 International’s Editorial guidelines.

In practice, the first point of contact for a complaint should be Elite TV1 International Information, although people can contact management team directly if they prefer. We are committed to responding to complaints within fourteen (14) working days of their first receipt and to keeping complainants informed of progress.

Complainant may not be satisfied by the response from Elite TV1 International’s Information or management team. If the complaint concerns a breach of the editorial standards set out in the Editorial Guidelines or relates to a particular broadcast, programme or specific web content they can appeal to the Editorial Complaints Unit to investigate the issue independently.

Elite TV1 International has a Code of Practice for complaints handling which sets out these procedures in more detail.

 15.3 Editorial Complaints Management Unit

The Editorial Complaints Management Unit deals with serious complaints about breaches of Elite TV1 International’s editorial standards in connection with specific programmes or items of content. It deals with complaints about any Elite TV1 International service or product where Elite TV1 International has editorial responsibility. This includes international, public and commercial services and Elite TV1 International branded magazines.

If complainants are not satisfied by the Editorial Complaints Management Unit finding, they can appeal to the Editorial Management Committee of Elite TV1 International.

When the Editorial Complaints Management Unit identifies a serious breach of the standards in these Guidelines, its finding will normally be published on Elite TV1 International complaints website. It may also direct Elite TV1 International to broadcast an apology or correction.

Keeping Content

Elite TV1 International is obliged by law to keep recordings of all broadcast programmes: television (including interactive content) for 90 days.

Elite TV1 International online policy is that we make best efforts to keep a record of the last 90 days of text based output.