Marketing (including media planning and continuity teams), 4Creative, Network Presentation Programme Management and Channel Management
There are separate Presentation Guidelines which govern the procedures to be followed in respect of:
- On-air Programme trails – production and sign off;
- Off-air marketing – production and sign off;
- Other off-air promotions and launch tapes for external events;
- Editing/reversioning of programmes;
- Presentation announcements, warnings and flaggings;
- Legal apologies and corrections;
- Ofcom adjudication summaries;
- Programme support material;
- Appeals and viewer solicitation;
- Competitions; and
- Phone line details e.g. for voting or solicits for programme contributors.
Warnings, Flaggings, Tweesers and Twidents
Each day the announcer for C4, More4, E4, and 4Seven must run all warnings, flaggings and potentially problematic or sensitive announcements for that day past the duty lawyer from the legal & compliance department and record this in the daily 'warnings and flaggings log'.
The Duty Lawyer's details are circulated in the weekly Duty Rota by the Facilities Management Helpdesk.
Press and Publicity
Material published by the press office (e.g. press tapes for review purposes and press launch clip tapes) are not regulated by Ofcom but can be the subject of legal action. Channel 4 is potentially liable for what newspapers publish on the basis of press statements, billings and preview/review copies of our programmes issued to them. Programmes may have a range of issues which make pre-broadcast publicity potentially problematic. It is vital therefore that any press strategy for potentially contentious or sensitive programmes is discussed and agreed in advance with the commissioning editor and programme lawyer.
All billings and press releases must be seen in advance by the programme-makers and the commissioning editor to ensure they are accurate and to identify any potential problems. Normally billings and press releases should also be cleared by the programme lawyer before publication, however this is mandatory where the programme is contentious. In such cases, the programme lawyer must also be consulted, along with the commissioning editor, before pre-transmission copies are made available to the press in advance of broadcast.
Other departments in Channel 4, such as corporate relations, marketing, 4creative and partnerships, may also put together clip tapes of Channel 4's programming for external audiences. This material must also be cleared by the commissioning editor, the programme-makers where appropriate, and the legal & compliance department before being shown.
Marketing and 4Creative
All trails must be viewed and approved by a programme lawyer (or in some cases a compliance adviser), who will advise on any edits required, when the trail can be scheduled and whether, in exceptional cases, a warning is required. Programme lawyers will complete the trail certification spread sheet recording the scheduling advice.
The commissioning editor must also be consulted, and they must also view the trail for their programme before broadcast. Normally, for programmes with factual elements the programme-maker should also see the trail in advance to identify any problems relating to viewer trust, accuracy or contributors. Marketing for all programmes of a sensitive or contentious nature must be discussed at an early stage with the commissioning editor and the relevant programme lawyer who must approve the final version.
Where a particularly contentious programme is to be broadcast, the commissioning editor responsible should give appropriate advance notice to the Viewer Enquiries department and, on the advice of the relevant programme lawyer, draft appropriate wording to assist the Viewer Enquiries department in dealing with calls and emails.
Where a programme is likely to or does give rise to a significant number of complaints, the commissioning editor, in consultation with the legal & compliance department, should draft a response to assist the viewer enquiries department in dealing with callers, emails and letters.
A text alert system is in place as an early warning to alert selected senior staff across Channel 4 to a possible escalating programme issue. This is in response to complaints received overnight via Viewer Enquiries.
This is sent early the following morning, when a programme has received 60+ complaints about one issue only. The commissioning team responsible for the programme are also alerted via e-mail/phone at this time. E-mail/phone updates are provided throughout the day.
Viewer Enquiries also provide an escalated text alert, should a programme receive over 500 complaints overnight.
E4, More4, Film4 and 4Seven have their own channel-specific editorial & compliance procedures which are based on the Channel 4 procedures and are set out in the Digital Channels Protocol. Each Channel Head is responsible for reference-up to the Director of Programmes. The Editorial and VOD Compliance Manager plays a key role in the editorial & compliance process, including organising the re-versioning of post-watershed shows which are repeated pre-watershed, identifying potential problems with archive programmes in the schedule and arranging edits and warnings as required.
Acquisitions and Film 4
All acquired programming and feature films are first viewed by a panel of compliance viewers who prepare a detailed compliance report. This is then submitted to the relevant editor or programme executives in the acquisitions and Film4 departments and where appropriate to the Editorial and VOD Compliance Manager, to review and undertake any appropriate edits. Advice is also provided from the Film 4 editorial consultant and from the legal & compliance department as appropriate.
All online content is governed by Channel 4's Social Media Guidelines. The protocol covers all content published by Channel 4 on non-linear digital platforms including all video content created exclusively for non-linear platforms; full length programmes; clips and trailers; text, images, games, quizzes and polls; applications and other interactive elements; competitions; advertising; advertising-funded campaigns; content and sponsorship; and user-generated content.
VOD is regulated by Ofcom and its statutory rules and guidance, which must be followed. The Editorial and VOD Compliance Manager overseas the VOD compliance team who deal with all day to day VOD compliance issues. In the event of a complaint to Ofcom, the editorial manager liaises with the legal & compliance department. Compliance issues dealt with by the VOD compliance team include systems for the protection of under-18s, the suitability of programmes for availability on VOD (catch-up and archive), the need for carefully-worded guidance and warnings, and procedures for the take-down of programmes where required. There are special considerations concerning promotional material and clips for the VOD services.
Channel 4's Competition Guidelines set out detailed guidance and processes for the conduct of competitions, whether they are entered for free on the channels' websites or involve a premium rate service. Similarly, all online and premium rate voting is governed by detailed rules and guidance designed to ensure the integrity of processes involved. Early advice must always be sought from the audience interaction team who are part of the legal & compliance department.
Sponsorship and Product Placement
Partnerships (which encompass sponsorship, ad funding and product placement) should liaise regularly with the legal & compliance department regarding the suitability of sponsors for particular programmes, as well as the nature and content of proposed sponsor credits. Where appropriate, this process must also involve the commissioning editors for the programmes concerned. Commissioning editors must be made aware by Partnerships of the sponsorship of, or the inclusion of product placement in, any programmes for which they are editorially responsible. Any issues should be referred to the legal & compliance department at the earliest appropriate stage, so that scripts can be considered, and potentially problematic material dealt with before filming takes place.
Advertising Sales should liaise with legal & compliance regarding potential issues concerning the content of advertisements, the duration and pattern of advertising breaks, as well as the scheduling of advertisements which are restricted. Any significant issues must be referred up to a senior level within Advertising Sales and discussed as necessary with legal & compliance.
Channel 4 News
ITN has its own Compliance Manual, Hostile Environment Protocols and Policy, and reference-up procedures. There is also a pre-broadcast protocol for reference-up by the Editor of Channel 4 News to the Head of News and Current Affairs. ITN’s Head of Compliance also regularly liaises and refers-up to the Controller of Legal & Compliance on legal and compliance issues affecting the programme.