Channel 4 Online Competitions & Online Votes Good Practice Guidelines
A competition is any service or arrangement where a prize is awarded. The basic principles underpinning any Channel 4 competition are:-
Fairness – all entrants must be treated fairly and equally. For example, winners must be picked after the closing of the competition and not before. Winners should not be selected on the basis of any criteria apart from those specified in the competition rules as the basis for selection, or randomly if that is the basis for selection of the winner.
Transparency – competition rules must be clear. Entrants need to be given as much information as possible to enable them to decide whether or not to enter a competition and to understand the basis upon which the winner of the competition will be decided. For example, if the prize is a holiday abroad and travel insurance is not included but must be purchased by the winner, then this must be made clear in the competition rules.
These guidelines apply to the following types of competitions ("Competitions"):
- multiple choice question, prize draw or where entry is by providing a name and/or contact details and response is sent to Channel 4 ("Simple Competition");
- submission of creative entries and the selection of winning entries is open to subjective interpretation as to their quality or other attributes ("Editorially Judged Competition");
- via an instant win mechanic (“Instant Win Competition”); and
- where a purchase is needed in order to enter (“On-Pack Promotion”).
These guidelines also apply to votes which are conducted online only ("Votes") and reference in the guidelines to "entries" includes "votes", and "entrants" includes anyone voting. All Votes (particularly where these may affect the content of on-air programmes) must be approved in advance by Holly Fairweather, Audience Interaction Manager (‘AIM’).
The guidelines apply to Competitions and Votes promoted on air and/or online. Where a guideline only applies to one type of Competition or Vote, this is made clear below.
All Competitions and Votes must be conducted in a manner that ensures (i) fair and equal treatment of all eligible entries; and (ii) no disadvantage to members of the public. The guidelines assume (i) entry is free (); and (ii) no prizes are awarded for or in connection with casting a Vote (if prizes are awarded to anyone who casts a Vote, the Vote should be dealt with as a Simple Competition). For all Competitions requiring payment to enter, please contact the AIM immediately as Channel 4 does not presently run any premium rate competitions and there are a number of compliance implications if that is the ambition for your competition.
All Competitions and Votes must be carried out by Channel 4, and Channel 4 should retain and exercise editorial control at all times (including of any copy or questions submitted by a third party). In all circumstances Channel 4 must approve competition and vote copy before it goes live on a website or on air. No Competition or Vote should commence and/or be uploaded onto the Channel 4 website or promoted on air without Channel 4’s prior approval.
Additional provisions apply to Competitions run by Channel 4 on behalf of or in conjunction with a third-party advertiser ("Advertiser Competitions") (see point 37 below). These will be most relevant for Competitions run by the Advertising Sales/Partnerships teams and where the Competition is designed to drive sales of a particular product or service, but if you are unsure please contact the AIM.
The guidelines refer to contacting members of various Channel 4 departments. The main contact details for these departments are: (a) Audience Interaction – Holly Fairweather; (b) Legal and Compliance – Diana Izzard; and (c) Corporate Legal – please use the “#Competitions Legal” email group.
Before setting up any Competition/Vote
- A Channel 4 person must send either an advance notification email to firstname.lastname@example.org (this will go to the AIM) with the following information (the AIM will log the details on a database and no service can be set up until you have sent a notification email) or alternatively send the competition terms & conditions that have been drafted for the competition:
- type of service e.g. vote, competition;
- where the service will be promoted e.g. channel4.com/4viewers/community;
- competition mechanic e.g. multiple choice, prize draw, editorial judgement;
- name of Channel 4 person responsible for the service;
- dates and times the service will be run from and to;
- date the winner will be picked;
- prize details;
- confirmation that database details will be controlled by Channel 4; and
- any way in which you wish to depart from Channel 4’s Standard Competition Terms & Conditions.
You will need to re-send this notification email if any dates or details of the Competition/Vote change.
Please note that if you send the notification email you will still need to send your terms and conditions in a word document to the AIM for approval prior to the competition going live.
- If the Competition or Vote involves activity on social networks or other third-party sites, e.g. Twitter, Facebook etc., you must speak to the AIM who may involve the Legal & Compliance, Corporate Legal and/or Business Assurance departments as appropriate. Please note that it may be necessary to take these projects to the Project Assurance Meeting and it will be required to complete a third-party questionnaire for review by the Data Protection and Information Security teams if data is being collected by a third party that has previously not been through this process or it has been some time since they went through the process. Thorough end-to-end testing will also be required and any off-site competition that does not pass this testing will not be allowed to go ahead.
- You should also refer to the competition checklist and follow the checklist when setting up your Competition/Vote.
Information needed on all Competition/Vote pages
- You must ensure the page on which answers/votes are submitted by entrants sets out the following details:
- EITHER the question(s) to be answered (Simple Competitions) OR details of the creative entry each entrant is required to submit including clear details of any requirements (the failure to address which will render entries ineligible) (Editorially Judged Competitions) OR how an instant win works (Instant Win competitions) OR details of the purchase necessary to enter (On-Pack Promotion) OR how to cast a vote (Votes);
- accurate details of the prize(s);
- accurate details of how the winner will be selected. This will be a random draw for all Competitions except (1) in the case of Votes, where the winner will be the contestant who has received the most number of votes; and (2) where you decide to pick a winner of an Editorially Judged Competition by judging entries (rather than picking a winner at random), the page must set out accurate details of the criteria on which the entries will be judged and the winner will be selected;
- if relevant, details of the panel of judges (if this information is available) or a notice that the full names of the members of the panel of judges are available on request (Editorially Judged Competitions only);
- time and date on which the Competition/Vote closes;
- any time periods within which winners have to respond to a notification from Channel 4 (whether by telephone or email) to claim their prize (and if they do not respond in this time, an alternative winner may be selected). The time/contact method needs to be reasonable and will depend on the type of Competition/Vote. If you have goods that can be sent directly to the winner, you may do so only if you specify on the competition notice that the prize will be sent to the address provided on entry and also send an email to them letting them know that their prize is on its way;
- in addition, for Editorially Judged Competitions only, that by submitting an entry the entrant accepts that Channel 4 may use and/or exploit the entrant's submission as set out in the terms & conditions (although Channel 4 is under no obligation to do this) and details of any intended use;
- any minimum age requirement together with other eligibility criteria not already set out in the Competition/Vote terms & conditions (e.g. if the Competition is only open to UK residents or if there is a limit on the number of entries that differs from the standard Terms & Conditions). Please note that there would need to be an exceptional editorial reason for opening up your competition to under-16s and this must be discussed in advance with the AIM. At a minimum anyone who handles the data must have been DBS checked where appropriate.
Capturing entrants’ details
- All entries and entrant details must be captured by Channel 4 instantaneously and automatically in a secure file (CSV file for Simple Competitions and Votes, and appropriate secure storage for Editorially Judged Competitions) and you must make sure the file only contains details of entries submitted while the Competition/Vote is open (you should use the time/date stamp functionality for CSV files). A Channel 4 person must be responsible for downloading the competition CSV file in order to select winners. For competitions hosted by third parties they may need to download the data themselves and securely pass it to Channel 4 via Channel 4’s SFTP for winner selection.
- The file should only be accessible by those people within Channel 4 who are responsible for running the Competition/Vote. Processes should be in place to deal with submissions for creative Competitions that are in physical form.
- If there is a problem when an entrant is submitting an entry or after the entrant has submitted an entry (e.g. the entry may be lost), the entrant should receive an error message so they know their entry may not have been submitted properly and can try again.
- The systems used for Competitions/Votes must be robust so you can be confident they will not crash (e.g. part way through answering questions). You should also be able to check, so far as is reasonably possible, that entrants are complying with Competition/Vote rules (e.g. people have not used hacks to submit multiple entries for votes or competitions). Where enabled, the use of CAPTCHA (Completely Automated Public Turing Test To Tell Computers and Humans Apart) when setting up your competition will prevent spam entries by asking all entrants to input the code/distorted text that they see on-screen.
- Appropriate back-up systems should be in place to enable Channel 4 to access the entries and entrant details in the event that the "master" file becomes inaccessible or corrupted. To the extent the back-up service is being undertaken by Channel 4’s online technical support providers for Form-To-Text Competitions, you should ensure the relevant back-up provisions have been implemented.
Opening and closing dates
- No person should be able to submit an entry after the time/date it is stated to close. Should any such entries be submitted, these should not be included in either the file from which winners will be chosen or the number of votes counted towards the final totals (as applicable). As soon as the Competition/Vote closes, either: (a) the mechanism which allows a person to submit an entry (e.g. the "submit" button) should be removed from the page and a notice put up that the Competition/Vote has closed; or (b) the relevant entry page should be removed entirely. Please note the Competition page template has an expiry date and time functionality that must be used here.
- Sufficient time must be allowed between closing the Competition/Vote and choosing the winning entry or announcing the result, to allow all valid entries to be received, included on the file and, for Votes, counted towards the final totals. Winners should not be chosen or calculated until after the Competition/Vote has closed and all entries have been included on the file. In no circumstances must any steps be taken to select a winner before the closing time (including starting to create a shortlist) or from an incomplete list of entries. Timing is particularly critical where winners will be announced on air and adequate arrangements must be put in place in the event the file cannot be accessed and/or winners cannot be chosen in time for the on air announcement in accordance with these guidelines. In no circumstances must any references be made on air or elsewhere to anyone other than the actual person selected or the actual contestant who received the highest number of votes (as applicable) in accordance with the properly functioning process set out in these guidelines.
Choosing Winners (Competitions)
- All entries must be included in the draw and the winner chosen using the Automated Winner Selector Tool (AWST). The AWST will automatically remove invalid entries before a winner can be selected. You will need to complete an IS request in order for this Tool to be installed on your PC. Where this tool is not appropriate, Excel contains a function which should be used for this purpose. Winners must not simply be chosen from the list of entries by any individual. For Instant Win Competitions, the algorithm used must be reviewed by Channel 4 to ensure that it is fair.
- The selection of the winning entry should be overseen by one person from Channel 4 under the independent supervision of the AIM (or, if they are not available, a member of Legal & Compliance or Corporate Legal). In no circumstances should the list of winning entries be passed to a producer or advertiser for them to select the winner. You must select the winner in accordance with these guidelines and pass this information onto the advertiser or producer (if relevant).
- Once a winner has been selected you must check whether they appear to have used software or other automated methods to submit bulk entries (speak to the AIM if you have any queries). If this is the case, they should be disqualified, and an alternative winner may be selected in accordance with these guidelines. See use of CAPTCHA at point 8 above.
Choosing winners (Editorially Judged Competitions)
- Where the Editorially Judged Competition is being judged, a panel of judges should be appointed and made up of at least the following: (i) the person running the Competition; (ii) an independent judge (see point 16 below); and (iii) the AIM as independent supervisor. The full names of the panel should be made available on request if not already provided to entrants on the website or mobile portal. It is advised you have a minimum of three judges and an odd number where possible to avoid a tie.
- The independent judge should be someone who has no direct or indirect involvement with the competition's promoters and intermediaries or the running of the promotion, who is demonstrably independent of the awarding of any prizes or the prize-winners and who is competent to judge the subject matter of the Competition. They cannot be an employee of Channel 4.
- The judges should choose the winner on the basis of the advertised criteria. Each member of the panel should have an equal say in choosing the winner and a record should be kept of all the judges and any notes made by the judges should be retained. In no circumstances should entries be passed to a producer or advertiser for them to select the winner (although they may form part of the panel). You must select the winner in accordance with these guidelines and pass this information onto the advertiser or producer (if relevant).
- If any entries are to be used in a TV programme these entrants may need to sign a release form (please contact a member of Legal & Compliance or Corporate Legal).
Choosing Winners (votes)
- Unless otherwise agreed with the AIM and Legal & Compliance, the winners of any Vote will be the contestant(s) who received the greatest number of eligible votes during the voting period. You must discuss in advance of any vote going live how you will resolve any tied votes and this must be detailed in the Terms & Conditions.
Prizes (all Competitions and Votes)
- Where the prize is only suitable for people over a certain age you should follow the steps below to contact the entrant to verify that they are not under age. You should request physical age verification when the prize is:
- A film or game rated 18;
- A trip/holiday in the UK/abroad;
- Significant amount of money (exceeds £100)
- Any other prize where it would be illegal to be sold to a minor, e.g. knives, solvents etc.;
For any prizes that are tickets to an event you can rely on the DOB provided at entry (or request their DOB if not captured) only if the venue of a gig, cinema or screening will be performing age verification on those who appear underage. You need to check this with the venue in advance and this should be covered off in your prize agreement or their standard terms of purchase/entry.
- Physical age verification should be either a scan of a passport or driving licence or other suitable age verification documentation.
Step 1 - Email the winner/runner-up advising them that they are a winner/runner-up and in order to claim the prize they need to reply to the email by X date and time.
Step 2 – Once you have received this confirmation email back from them you should advise them that they need to send in proof of age, and in order to do so they should use the secure upload at https://winners.channel4.com/.
You should remind them of the file size and type that is acceptable (png, jpeg, jpg and up to 5mb) and when they need to have sent this documentation in by. They can also redact any information that is not required as part of this verification e.g. passport number.
Step 3 – Any documentation that is uploaded will be sent to the AIM and in turn this will be sent to the Competition Manager for approval. If you have not received the documentation by the deadline date that you gave the winner/runner-up, please let us know as you may need to chase your winner/runner-up for this.
Step 4 – Once received you should email your winner/runner-up and confirm that their documentation has been reviewed and that they are the winner/runner-up.
Step 5 - For audit purposes please save this documentation as evidence in the S-drive. Do not save it to your personal drives or in your email inbox.
- If the winner is reluctant to provide this information for data security reasons, please speak to the AIM.
- If the winner is not the appropriate age, an alternative winner should be selected in accordance with these guidelines.
- For competitions where the prize is suitable for all ages, we can rely on the fact that an entrant has accepted the Terms and Conditions upon entry and by doing so have declared they are the requisite age of 16 years of age or older. In this circumstance you may post prizes directly if you have captured an entrant’s address in the entry form, however you must ensure you email them to tell them that you are posting their prize and this email must be retained for audit purposes.
- Where the prize is being provided by a third party you should do one of the following (a copy of the email or signed contract should be saved in the relevant folder in the shared drive - see point 34 below – and the original signed contract given to Corporate Legal who should retain the fully executed copy):
- Prizes worth up to £500 (and where a replacement could be provided by Channel 4) – unless you have been given the prize before the Competition/Vote starts, you must obtain email confirmation from the provider that they will supply the prize.
- Prizes worth £500 and above or any “one-off” prizes – the third party must sign a competition contract (a blank draft of which can be obtained by emailing the AIM). Please complete the details in square brackets and update with all necessary information and send the contract back to the AIM. This will then be allocated to an appropriate lawyer to check before the draft is sent to the provider and signed, once agreed this should then be sent back to the appropriate lawyer for signature. Once countersigned the lawyer will send back to the competition manager and retain a fully executed copy centrally. It is the competition manager’s responsibility to send the fully executed copy to the prize provider.
- Please note if you fail to get any of the above you are accepting responsibility for the prize, and should the prize provider fail to deliver the prize an alternative will need to be purchased out of your department’s budget.
- If you are transferring data to a third party and you do not require a prize agreement please see point 40 below for further details.
- Winners should be notified as soon as reasonably possible by telephone/email after the closing date. If winners are notified by telephone then this must be followed up with email confirmation. Third parties can notify winners and provide prizes but someone from Channel 4 must be fully aware of the process being followed (see point 29 below). Channel 4 Viewer Enquiries contact details and/or details of the Help section on the Channel 4 website must also be given to the winners (so they can contact us if there are any problems). These are as follows: Channel 4 Viewer Enquiries can be contacted on 0345 076 0191 or alternatively go to www.channel4.com/help.
- Where there is no winner (either because there were no entries or no eligible entries, or for Editorially Judged Competitions where entries were of a low standard and none of them could reasonably be awarded the prize) a message should be posted on the Channel 4 website explaining that this is the case. The public should not be led to believe there was a winner if there was not.
- If no response is received from the winner within the stated time or if the winner proves to be ineligible, then an alternate winner may, in the case of Competitions, be chosen in accordance with the competition terms & conditions and these guidelines or, in the case of Votes, the contestant with the next highest total number of eligible votes received during the voting period will be the winner.
- If a third party is contacting winners and/or providing prizes directly to winners (see point 34 below) then the Channel 4 person responsible for the Competition/Vote should be copied in on the email notifying the winner (if entrants are notified by phone then the Channel 4 person must be copied into the written follow-up confirmation). The winner(s) must be given the Channel 4 contact details (see point 25 above) so they can contact us if they do not receive their prize or if there is any problem with their prize.
- Prizes must be delivered in a timely manner and within 28 days of contacting the winner. If there is a delay in sending out a prize this must communicated to the winner and you must remain in regular contact until the prize is delivered.
Records to be kept
- Competitions – a record must be kept of: (i) the winning entry; (ii) the method by which the winner was chosen; (iii) the terms & conditions (if these were not the Channel 4 standard terms - see point 38 below); and (iv) for Editorially Judged Competitions, the reasons for choosing that submission (as against the specified criteria). This should be done by completing and signing the Competition Record Form.
- Votes - a record must be kept of: (i) the winner of the vote; (ii) the number of votes received by each candidate; and (iii) the terms & conditions.
- the following records/documents should be given to the AIM: (a) a screen shot of the live competition page on the website; (b) the email confirming agreement to provide a prize; and (c) a copy of the email or letter notifying each winner that they have won a prize and their email confirmation that they accept the prize (where you subsequently enter into email correspondence with a winner you only need to provide the last email in the chain). All signed competition contracts should be retained by a member of Corporate Legal.
Please note that all documentation MUST be completed and saved within 60 days of the competition closing.
- A copy of the file containing details of all entrants must be kept (together with details of the winning entry, the method by which the winner was chosen, the prize and the details set out in points 26 to 32) for at least 2 years following the closing date in the shared drive and folder, saved under the name of the competition and date. Copies of all submissions for Editorially Judged Competitions should also be kept for a reasonable period (this will depend on the type of entry). Channel 4's Corporate Legal, Legal & Compliance or Business Assurance departments may request details of all Competitions, Votes, entries and winners, including confirmation of the eligibility of winners and entrants, at any time.
Third party involvement
- Third parties (e.g. an advertiser or editorial partner) may propose ideas, source prizes, promote the Competition/Vote and/or provide prizes to winners (so long as this is all in accordance with the guidelines), but the Competition/Vote must be operated, managed and approved (i.e. entries received/winners selected and copy approved) by Channel 4. If you have any queries on this (or whether a contract is needed with the third party) please contact a member of Legal & Compliance or Corporate Legal. If there are circumstances where we commission a third party to develop a competition application on our behalf, they must complete the Third Party Competition Questionnaire which will be reviewed by the Data Protection and Information Security teams.
- We may promote third party competitions (e.g. via a link where the competition is operated by the third party and entries cannot be made on our site), but you must first check it will be run fairly and in a way that is consistent with these guidelines. You must also make it clear next to the link on our site that the competition is being run by a third party by using the following disclaimer: ‘This competition is run by X and is not administered by Channel 4’. If you have any queries on this, please contact the AIM.
- Where we plan to use a third-party site (e.g. social network) for a Channel 4 competition you must: (a) ensure the third party site allows this (check their T&Cs); (b) if necessary ensure that the project has been presented and approved at a Project Assurance Meeting; (c) speak to the AIM to get clearance for the use of the third party site – you may need to engage the services of an intermediary supplier who will be able to access all entries; and (d) follow these guidelines.
- The Committee of Advertising Practice Sales Promotion Rules ("CAP Rules") apply to Advertiser Competitions. These set out certain requirements for information to be made available to entrants. Relevant sections of the CAP Rules (as at the date of these guidelines) are in Annex 1. Most of this is or should be covered in these guidelines and the Channel 4 standard competition terms & conditions but you must check that arrangements for your Competition cover all the requirements. The full CAP Rules are here.
- If you plan to run an incentivised survey using a third party, you are free do so providing the following wording is clearly displayed on the website at the point at which the user submits their data for entry into the draw:
‘This research is carried out by [INSERT NAME OF COMPANY] on behalf of Channel 4 Television. The incentives and prize draws are administered solely by [INSERT NAME OF COMPANY] in accordance with the MRS code of conduct.’
- Please note that any third party may still need to complete the Data Protection Questionnaire and this will need to be signed off by Channel 4’s Data Protection Lawyer and Channel 4’s Information Security Officer before your survey can launch. You should also ensure that any company that you do plan to use is aware of and follows the MRS code of conduct.
- Channel 4’s standard competition terms & conditions are here. These are suitable for Simple Competitions and for Editorially Judged Competitions. To add these to your Competition page you need to use this link in the Competition template. If you need to make any changes (or are unsure whether they are appropriate) please contact the AIM or Corporate Legal. Additional or alternative terms apply to Votes, or other types of competitions. Again, please speak to the AIM or Corporate Legal.
- Depending on the type of Competition, you should think about whether there should be any "user-friendly" FAQs. Please speak to the AIM, Legal & Compliance or Corporate Legal if you are unsure whether these would be appropriate.
- In addition to informing entrants, if you are passing data to a third party (e.g. a commercial sponsor or the prize provider), you must also have a contract with the third party to ensure they only use the data for the agreed purposes. If there are up to 10 winners with name and basic contact details these may be transferred by email on password protected spreadsheet, the password must be suitably complex and passed to the recipient by phone or text message, NEVER emailed. If the data exceeds 10 records, then it should be transferred via SFTP. If you have any queries, please speak to the AIM, Corporate Legal or the Information Security Team. Details of Channel 4’s Acceptable User Policy can be found in the infosec e-learning module at https://channel4.acteonhost.com/code/default.aspx.
- If data is being transferred outside the UK or sensitive personal data is being collected (information about a person's race, ethnic origin, religious or philosophical beliefs, political opinions, trade union membership, genetic or biometric data, physical or mental health, sex life, sexual orientation or criminal offences) there are additional requirements (please speak to Corporate Legal).