BBC Trust consults public on standards
I have never worked for the BBC (and, given what I say and write about it, I doubt I ever will). My understanding of what it's like to work for the BBC is gleaned from those who do so that I know or have spoken to or have seen speaking on public platforms. One impression that I have gained from this admittedly limited insight is - as I have blogged previously - that 'compliance' is seen as a bureacratic headache, a burden, a nuisance, something that they are grateful is the job of 'compliance people' who have to fill in or sign off the endless compliance forms that producers have to tackle.
If that is the attitude towards compliance amongst programme makers in the BBC, then that is a cultural problem as much as a procedural one. As long as compliance is seen as a chore, or an obstacle to creativity - rather than as a fundamental aspect of the broadcaster's craft, providing part of their basic professional and ethical standards - then the BBC will forever encounter compliance difficulties and, from time to time, crises.
The BBC Trust published yesterday a new draft of its Editorial Guidelines. I quite like the current Guidelines. Whenever I have had to refer to them, I have found them clearly written, in plain, but not patronising, English. Where both the current and new draft guidelines suffer is in their length. The Ofcom Broadcasting Code is already worrying long at 97 pages (when reproduced as an A4 PDF file), but the BBC Guidelines are nearly twice as long, at 190 pages. Just as I have heard some in commercial broadcasting say they can't follow the Ofcom Code because its language is too legalistic (I disagree, but I do think it is poorly written in places), so I can imagine some in the BBC looking at the sheer length of their Guidelines and wondering how they can ever be expected to know what's in it. Regulatory codes need to be concise and accessible - they need to be usable every day by programme makers of varying levels of ability.
More than that, though, regulatory codes need to be understood as only part of the compliance tool kit. They are important, undoubtedly. But your organisation's culture and attitude are likely to be more important. If you believe that compliance is an obstacle to creativity, and that a producer's judgement should be subordinate to detailed regulations, then you will have an organisation that is so unwilling to take any risks that, when it decides it wants to, it is unable to judge them accurately. An organisation that understands that risk is inevitable, but manageable, is one that will be more comfortable taking creative risks, confident in its ability to make judgements about when it has taken a risk too far.
Take offensive language as an example. Ofcom trusts broadcasters to make their own judgements about what is acceptable or not in the context of their output. Ofcom's Code essentially urges caution with strong language, and extreme caution indeed with the most offensive language. If you're a broadcaster, you know what that means - and you know what that means in the context of your station or channel, your audience, at your particular time of day.
As The Guardian reported yesterday, the BBC approach is much more detailed and less flexible. Unlike Ofcom, the BBC (draft guideline 5.3.2) stipulates the three words it considers most offensive, and requires that their use be approved by an "Output Controller". Far from reducing the amount of swearing on the BBC, I predict no change, or possibly even an increase. Some producers will simply assume that any word apart from those three must, logically, be acceptable, and so other offensive language will be used instead - some of which will, in reality, be just as offensive, if not more so, to some sections of the BBC's audience. Meanwhile, in contexts where one of those three words would normally be the most appropriate, it will not appear - as writers and producers shy away from them, unwilling to go through the bureaucratic hassle of getting permission to use them.
Compliance is about values, not just rules.
By the way, the BBC Trust is consulting the public on its new editorial guidelines, for reasons passing my understanding. (Do some proper research, by all means, but little will be gained from the submissions of a self-selecting sample of people with axes to grind). If you want to comment, you have until Christmas Eve to respond (although I'm guessing that you could leave it until 2 January and it would be opened at the same time as all the others).
If that is the attitude towards compliance amongst programme makers in the BBC, then that is a cultural problem as much as a procedural one. As long as compliance is seen as a chore, or an obstacle to creativity - rather than as a fundamental aspect of the broadcaster's craft, providing part of their basic professional and ethical standards - then the BBC will forever encounter compliance difficulties and, from time to time, crises.
The BBC Trust published yesterday a new draft of its Editorial Guidelines. I quite like the current Guidelines. Whenever I have had to refer to them, I have found them clearly written, in plain, but not patronising, English. Where both the current and new draft guidelines suffer is in their length. The Ofcom Broadcasting Code is already worrying long at 97 pages (when reproduced as an A4 PDF file), but the BBC Guidelines are nearly twice as long, at 190 pages. Just as I have heard some in commercial broadcasting say they can't follow the Ofcom Code because its language is too legalistic (I disagree, but I do think it is poorly written in places), so I can imagine some in the BBC looking at the sheer length of their Guidelines and wondering how they can ever be expected to know what's in it. Regulatory codes need to be concise and accessible - they need to be usable every day by programme makers of varying levels of ability.
More than that, though, regulatory codes need to be understood as only part of the compliance tool kit. They are important, undoubtedly. But your organisation's culture and attitude are likely to be more important. If you believe that compliance is an obstacle to creativity, and that a producer's judgement should be subordinate to detailed regulations, then you will have an organisation that is so unwilling to take any risks that, when it decides it wants to, it is unable to judge them accurately. An organisation that understands that risk is inevitable, but manageable, is one that will be more comfortable taking creative risks, confident in its ability to make judgements about when it has taken a risk too far.
Take offensive language as an example. Ofcom trusts broadcasters to make their own judgements about what is acceptable or not in the context of their output. Ofcom's Code essentially urges caution with strong language, and extreme caution indeed with the most offensive language. If you're a broadcaster, you know what that means - and you know what that means in the context of your station or channel, your audience, at your particular time of day.
As The Guardian reported yesterday, the BBC approach is much more detailed and less flexible. Unlike Ofcom, the BBC (draft guideline 5.3.2) stipulates the three words it considers most offensive, and requires that their use be approved by an "Output Controller". Far from reducing the amount of swearing on the BBC, I predict no change, or possibly even an increase. Some producers will simply assume that any word apart from those three must, logically, be acceptable, and so other offensive language will be used instead - some of which will, in reality, be just as offensive, if not more so, to some sections of the BBC's audience. Meanwhile, in contexts where one of those three words would normally be the most appropriate, it will not appear - as writers and producers shy away from them, unwilling to go through the bureaucratic hassle of getting permission to use them.
Compliance is about values, not just rules.
By the way, the BBC Trust is consulting the public on its new editorial guidelines, for reasons passing my understanding. (Do some proper research, by all means, but little will be gained from the submissions of a self-selecting sample of people with axes to grind). If you want to comment, you have until Christmas Eve to respond (although I'm guessing that you could leave it until 2 January and it would be opened at the same time as all the others).



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