Viewer trust

Rules and procedures for best practice and compliance

The executive producer (or series/programme producer where there is no Executive Producer) for each piece of Channel 4 content is responsible for ensuring that this document is brought to the attention of every member of the production team and that every team member follows the procedures and guidance it contains.

These guidelines apply to all factual content or items or portrayals of factual matters across all genres.

We hope these guidelines are helpful, but they are only a general guide which cannot foresee every scenario – each case will depend on its individual facts.

If you are in any doubt or if you have any concerns, please seek advice from your Channel 4 commissioning editor or content lawyer/compliance advisor.

Introduction

Channel 4 has faith in the honesty and integrity of our content creators and, in the overwhelming majority of cases, that faith is justified.

Channel 4 has a bond of trust with its audience across all its platforms and a duty to ensure that viewers are not deceived or misled by our content. This bond must not be broken and, if it is, the most serious consequences will follow across all its platforms. Channel 4 will not hesitate to take appropriate action against content creators who deceive our viewers and/or Channel 4.

Content creators must never stage, construct, reconstruct, re-enact or otherwise fake any scenes of actuality and pass them off to viewers or to Channel 4 as the reality.

Channel 4 has a duty to ensure that viewers are not materially misled by our content, including portrayals of factual matters, trails and other promotional/press materials. Content must be truthful, accurate and fair and must not mislead the audience.

The importance of viewer trust is not limited to current affairs, documentaries or conventional factual content. It also applies to factual entertainment series and content. Simply because factual content is primarily designed to entertain or is 'formatted' does not mean that there is a licence to mislead the audience.

Commissioners and content creators must collaborate honestly and openly on the basis of mutual trust. If a project is not working and content creators are struggling to deliver content, this must be shared with Channel 4's commissioning staff. It is vitally important that everyone involved in the content, whether at the content creator or at Channel 4, avoids even inadvertently making anyone involved in the production feel they are under pressure to deliver 'results' or to 'hype' the story at the expense of the truth. On rare occasions, halting a project which is not working out (perhaps because the story does not stand up) is the right course of action. Inventing the story is never an option. This applies equally to footage obtained from a third party and to footage shot by Channel 4-commissioned content-makers.

Other areas where authenticity issues can arise:

• Use of secret filming

• Use of disguised or anonymous interview

• Drawing on anonymous sources

• Reliance on uncorroborated claims

• Advertising for contributors

• Payments to participants, especially criminals

Channel 4 takes the issue of viewer trust very seriously. Viewers are entitled to expect that content is accurate and true, and the audience is not being misled.

This obligation applies to all types of content – including entertainment – with factual elements. Portraying real events, whether in documentary, features, factual entertainment, drama or any other content, which the viewer is entitled to take at face value, must respect truth and accuracy.

Content creating is a creative rather than literal medium and has always been more sophisticated than the simple recording of action in real time. However, though the editing process will inevitably condense events which have occurred over a period of time, this must not be at the expense of distorting reality and misleading viewers.

The accuracy and truthfulness of content has been the subject of significant media and legal and regulatory scrutiny and raises issues of the utmost importance. If it is claimed or suggested that footage is actuality, then that is what it should be; if it is not, then that should be made clear to viewers.

In non-fictional content, it is never acceptable to represent as having happened something that did not. It is the responsibility of Channel 4 and the content creators to ensure that viewers are not misled. Ofcom can impose the most serious sanctions for content that materially mislead audiences and it can also lead to legal action. 

Accuracy in relation to all aspects of factual content is vital to ensure we maintain viewers' trust. For example, in addition to scrupulous fact checking and labelling, where necessary, the qualifications, experience and other credentials of contributors, presenters and experts who appear in factual content must be checked and properly verified. Potential contributors should not be taken at face value. If they claim to have particular qualifications or expertise this must be corroborated.

The responsibilities of Channel 4 and content creators

The importance of viewer trust is not limited to current affairs, documentaries and conventional factual content. These guidelines apply equally across all genres where there is a factual element, for example, to an entertainment show with factual elements. Our viewers must feel confident that they can take what they see or are told in content at face value.

The use of a dramatic reconstruction, sometimes involving real people rather than actors, is a perfectly acceptable technique, provided viewers are not misled and clearly understand or are informed, for instance, by labelling on screen or in voice-over, the true nature of what they are seeing. Reconstructions must not, however, distort the known facts.

At the heart of the commissioning system, which is central to Channel 4's remit, is the relationship between the commissioning team and content creators. To be effective, and to achieve the highest quality content, the relationship must operate with honesty, openness and trust. It is important that the commissioning process does not act as a disincentive to content-makers at any level, inhibiting them from telling Channel 4 if a project is not working.

If anyone on the production team at the content creator has any concerns about a viewer trust issue, they should refer this up immediately to a senior person at the content creator and if the concerns are justified Channel 4 must be promptly informed.

Channel 4 will have far more respect for and trust in any member of a production team at the content creator who is prepared to openly identify problems in the production or development stages of content than in an individual who conceals such problems. More often than not, problems or issues brought to Channel 4's attention can be resolved and the commission can proceed, albeit possibly in a different direction to that originally envisaged. On many occasions, it may be simply a case of labelling material and explaining to the viewer that there is an element of legitimate artifice. This could include a pre-publication announcement, a line of commentary or an on-screen caption.

On rare occasions, halting a project which is not working out (perhaps because the story does not stand up) is the right course of action; inventing the story is never an option.

Editing and representation of facts

Since the early days of factual film-making, the making of content has always been more sophisticated than the simple recording of action in real time. It is a creative, rather than literal, medium, often reflecting the style of the film-maker in a similar way to a writer. The structuring and compression of experience is inherent in the making of content. However, although the editing process will inevitably condense events which have occurred over a period of time, this process must not distort reality and mislead viewers. The truth must not be sacrificed for the sake of a more entertaining piece of content if the effect is to cheat the viewer. Similarly, viewers must not be misled about the nature of material they are watching. If it is claimed or suggested that footage is actuality, then that is what it should be; if it is not, then that must be made clear to viewers.

Simulated news

Sometimes entertainment shows and dramas, even documentaries, include fake news items within them which can seem authentic. Channel 4 must ensure that there is no reasonable possibility of viewers being misled into believing they are watching real news items in such circumstances.

Ofcom and guidance on viewer trust

Compliance of content must be a shared and collaborative process between Channel 4 and the content creator, although Channel 4 is ultimately accountable to Ofcom for compliance of its broadcasts with the Ofcom Broadcasting Code ("the Ofcom Code") and all our content creators (from the most junior to the most senior) have a contractual responsibility to have read and to comply with its provisions and with all the guidelines and procedures set out on the 4Compliance website. Ofcom will not hesitate to impose the most serious sanctions, including substantial fines, for failure to ensure that content is accurate and truthful or where viewer trust is breached.

Rule 2.2 of the Ofcom Code states that "Factual programmes or items or portrayals of factual matters must not materially mislead the audience."

This rule is designed to deal with content that materially misleads the audience so as to cause them harm or offence. Whether content is ‘materially’ misleading depends on a number of factors such as the context, the editorial approach, the nature of the misleading material and, above all, either what the potential effect could be or what actual harm or offence has occurred.

Content-makers should also refer to Rules 2.13–2.16 and associated Ofcom guidance to ensure that audiences are not materially misled when invited on air to participate in broadcast competitions and voting schemes.

Like all best-practice documents, these Viewer Trust Guidelines identify important areas but do not replace the Ofcom Code and guidance.

The remainder of this page sets out further practical steps and guidance concerning viewer trust.

Practical steps to ensure truth and accuracy in content

i. The production team

It is the responsibility of the executive producer (or most senior production executive at the content creator) on every piece of content to ensure that:

• The entire production team is adequately staffed and resourced to deal with the demands of the content concerned – including training, experience and supervision. Any trainees or interns must be closely monitored, especially if they are dealing directly with any members of the public, including contributors.
• The production team is aware of the importance of compliance with these guidelines, the Ofcom Code and the 4Compliance website.
• The production team is adequately supervised at a senior level in the content creator.
• The content creator has in place effective procedures to ensure that any concerns about viewer trust, content veracity or any other important issue is escalated swiftly within the team to the executive producer and then to Channel 4 as expeditiously as possible and that these are communicated to and understood by the team.
• When a decision is made on a viewer trust issue it is clearly communicated to and understood by the production team.

ii. What is acceptable practice?

Many established content-making techniques are unproblematic, and viewers would not find them surprising or troubling. For example, the use of a cutaway shot, 'noddy' or a 'set up' shot to establish an interviewee. Often, a contributor might legitimately be asked to repeat an insignificant action, e.g., to walk into a room again, shake hands with the presenter or to do for the camera what they do normally or a brief 'pick up' shot of their interview to assist editing. Contributors should not however be asked to repeat or re-enact significant actions or events, e.g., to re-enact a row with their partner because the director didn't like the camera angle when it originally happened or because it wasn't being filmed, unless this is clearly sign-posted to the viewer, e.g. by calling it a 'reconstruction'.

People may behave differently when they know they are being filmed, although many will relax when they get used to the cameras. You must not, however, deliberately provoke or encourage behaviour which would not have occurred naturally without making it clear to the audience that you have done so.

The broad distinction is this: it is not acceptable to incite someone to take or recreate an action which will have a bearing on the outcome of the content's narrative and to present this action as something of significance observed as it happened on camera (even if it is something which actually happened in the past). This is an unacceptable intervention which is entirely different to the legitimate creation of a filmed sequence representing insignificant everyday activity which has no bearing on the outcome of the content's narrative.

Stylised documentaries

Inevitably, there are areas of ambiguity including occasions where the style and idiom of the film is intentionally heightened. This is often the case in deliberately light-hearted films. An obviously stylised documentary might be visually inventive, for example, filming shots of the same thing from several camera angles and intercutting them. But there is a world of difference between an imaginative film where the audience understands the nature of what it is they are seeing and methods which mislead the audience and claim evidential validation of a sequence which would not have happened without the intervention of the content creator.

The artifice of such imaginative documentaries is unproblematic, so long as it is clear that they do not seek to misrepresent contrivance as observed actuality. It is legitimate to innovate and take creative risks. There is, however, a duty to be clear about the terms on which we engage participants and its viewers and to ensure that viewers are clear about what they are watching and that they are not misled.

Chronology and the compression of time

The compression of time is a common content creating technique and will generally be unproblematic. However, where the content narrative places emphasis on the importance of a strict timescale, care needs to be taken not to mislead the audience. For example, where a contributor is shown achieving a goal within record time, when in fact it took them several attempts over a prolonged period, this should be made clear to the viewer. In addition, it may not always be necessary to reflect the actual chronology of events strictly where this is not material to the narrative, but if events appear out of sequence, e.g., to tell the story more clearly, this must not mislead viewers.

Inevitably there will be occasions when a fine judgement will need to be taken as to where the line is drawn, but the cardinal rule is that when in doubt ask the question and refer up to senior staff and Channel 4.

Viewer information

Viewers are now more media literate than ever, and they will understand many conventions of content creating, but they must be equipped, by appropriate sign-posting, to properly understand and make an informed judgement about what they are watching. Sometimes it may involve simply being upfront about the techniques used. The proposition of a piece of content and its genre will dictate what is acceptable and what the audience needs to be told. In an undercover investigation it should, for example, be clear when any footage is not shot covertly. On the other hand, a history programme will use archive and stylised reconstructions of events, at least some of which will self-evidently not be contemporaneous or real. Viewers generally expect that in entertainment content some degree of artifice is legitimate for comic effect. However, this does not mean that ‘anything goes', and audience expectations will vary for each piece of content.

Reference up

Tell your commissioning editor anything they should know about the provenance or authenticity of any footage, including techniques used to get it, so that a judgement can be made about whether to include it and, if so, whether any signposting is necessary for the viewer. Take advice as appropriate from the Legal & Compliance department. We have an equal responsibility for footage obtained from a third party as footage we shot ourselves. Your content must be truthful, accurate and fair. Use your common sense and good judgement. If you have distorted reality and the viewer has been misled, you have crossed the line of acceptability.

iii. Fact-checking and accuracy

A cornerstone of maintaining viewer trust is ensuring that content is factually accurate. You must have checked all facts and allegations in your content and be able to substantiate its accuracy as appropriate. This includes claims by interviewees which may sometimes need to be corroborated.

Using the internet for research

The internet is a very valuable research tool and contains an enormous amount of information. However, just because information appears on the internet does not mean that its true or accurate. Some sites will be more reliable than others, for example, the sites of major broadcasters or reputable national newspapers are, on the whole, more likely to be more reliable and accurate than obscure fanzine sites. Wherever the internet is being used as a research tool (including using AI assistance), common sense is required. Any information gleaned from it must be properly evaluated and, where appropriate, corroborated before being included within content.

iv. Editing interviews

As well as not misleading the viewer, it is vital that interviews and other contributions, including observational filming, are edited fairly and that you do not distort or misrepresent the person's known views, position or experience. Much content, especially in 'lifestyle' and ‘formatted documentary' genres, are driven by the strong, sometimes colourful, characters that feature in them and the audience enjoys sharing their journey or transformation. However, in representing characters and their journey in order to tell their experience in an interesting and entertaining way, care must be taken not to distort the truth and mislead viewers or be unfair to the contributor.

v. Hoaxes

Members of the public have been the subject of hoaxes by content creators since shows like Candid Camera started. Hoaxing has become increasingly sophisticated as technology has developed, and so has the viewing audience. Sometimes the tables are turned. Look out for signs that you may have been hoaxed by a contributor. Their motive may only be to attain their 15 minutes of fame. Hoaxers can be very convincing. Don't take everything at face value – make appropriate checks to establish whether people are who they say they are and whether they have done what they claim to have done. If it seems too good to be true perhaps it is. Make further enquiries as to their authenticity to ensure that you, and consequently Channel 4 and the viewer, have not been fooled.

If you are in any doubt about any of your contributors or what they are saying you must share your concerns with your commissioning editor at the earliest possible opportunity.

vi. Filming criminals or criminal behaviour

This is an area fraught with difficulty and can lead to authenticity problems.

If people talk about their crimes openly or are prepared to let you film them carry out an apparently criminal act, you must tell your commissioning editor and content lawyer/compliance advisor straight away and get advice.

Someone admitting to or carrying out a criminal act could well be prosecuted after broadcast/publication and your footage could be obtained by the police under a court order. Ask yourself why they are doing it if they are incriminating themselves. Do they understand the consequences? Or are they trying to have you on? Remember criminals tend not to be truthful and they will have a vested interest for their own self-preservation to deny it if challenged later.

Early legal advice from Channel 4's Legal & Compliance department must be obtained before filming or as soon as reasonably practicable.

vii. Attribution of historic comments on social media

If you do not have a call to action in the programme or online content and you are planning to show historic social media comments (i.e. not made in response to a specific call to action), you should consider if it is appropriate to display the user’s social handle alongside their comment and/or whether you should seek permission from them to display their comment and handle. This should be assessed on a case-by-case basis. A few examples with the approaches to be taken are below: 

• If you are planning to show a contributor’s social media post, and you have their permission to do so (preferably written permission), it may be advisable to blur the handle/name of anyone who has commented on that post. When posting their comment, they will not have envisaged that it would be broadcast/published in your content. 
• If you would like to display a social media comment and attribute it to the person who wrote it, provided that the comment is not controversial in nature and carries no risk whatsoever AND they have used the content's hashtag you do not need to contact them for permission to use their comment or handle.
• If you would like to display a social media comment and attribute it to the person who wrote it, and the comment is or could be controversial in nature, it is advisable to contact that person to ask their permission (preferably written permission) to include it in your content. In the event that you do not have permission but would like to show the comment, it would be advisable not to display the user’s handle as they will not have an expectation that their handle would be broadcast/published in your content.
• If you would like to display a comment which has been made by a public figure, it's unlikely to be necessary to seek their permission given their public standing, but you should be mindful of the date of when they posted the comment and/or if the comment is appropriate and in context. What constitutes a public figure will vary according to the circumstances but useful indicators would be number of followers or views, whether the person has received verification from the social media platform (e.g. X, formerly Twitter blue tick) if an individual has made public comments on a particular issue in the press etc.

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