Due Impartiality, Due Weight and Diversity of Opinion
2.4.1 Impartiality itself means not favouring one side over another. 'Due' means 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 does not mean an equal division of time has to be given to every view, or that every argument and every facet of every argument has to be represented on every occasion. Context is important, as is the output genre and platform.
2.4.2 The BBC must be inclusive, reflecting a breadth and diversity of opinion, across the output as a whole.
Breadth and diversity of opinion may require not just a political and cultural range, but also consideration of other variations, such as between older and younger, poorer and wealthier, urban and rural, the innovative and the status quo. It may involve exploration of perspectives in different communities, interest groups and geographic areas. At times, it will require the inclusion of opinions which some of those communities or groups may argue ought not to be included, because they find them unpalatable or offensive.
2.4.3 Impartiality does not necessarily require all perspectives or opinions to be covered in equal proportions either across the output as a whole, or within a single programme, webpage or item. Instead, content makers should seek to achieve 'due weight'. For example, minority views or those less supported by evidence, should not necessarily be given similar prominence or weight to those with more support, to the prevailing consensus, or to those better evidenced.[4]
(See 2.4.22)
2.4.4 There may be occasions when the omission of views or other material could jeopardise impartiality or accuracy. There is no view on any subject which must be excluded as a matter of principle; content producers should make reasoned decisions and apply consistent editorial judgement about whether to include or omit such perspectives.
(See 2.4.16)
Controversial Subjects, Current Public Policy and Political Issues
2.4.5 The BBC applies due impartiality to all subjects; however, there are particular requirements regarding matters of 'political or industrial controversy and matters relating to current public policy', including where they occur in any output outside news, current affairs and factual journalism, such as in sport, drama, entertainment, comedy and elsewhere.[5]
Controversial subjects will arise in areas of public policy, such as health, education or world events, and with regard to politics, social or economic issues or industrial matters. As well as matters that are the subject of current public policy discussion, any other area may include controversial subjects, such as religion, science, culture, identity or ethics. Historical issues, subjects which may previously have seemed settled or those that have been legislated upon may also become controversial again.
2.4.6 When content makers are determining whether subjects are controversial, in the UK or internationally, they should take account of:
- the level of public and political contention and debate
- whether the subject is a matter of substantive debate or importance in a particular nation, region, community or discrete area which may resonate with a particular or substantial part of the audience
- how topical the subject is
- the sensitivities of relevant audiences' beliefs and cultures
- a reasonable view on whether the subject is serious
- the distinction between matters grounded in fact and those which are a matter of opinion.
Advice on whether a subject is 'controversial' is available from Editorial Policy.
2.4.7 When dealing with 'controversial subjects', current public policy or political issues, the BBC 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.
(See 2.4.28-2.4.30)
2.4.8 Particular care must be taken to achieve due impartiality when a 'controversial subject' may be considered to be a major matter.[6] 'Major matters' are generally matters of current 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, an appropriately wide range of significant views must be included and given due weight in each programme or web item or in clearly linked and timely programmes or items. Views and facts must not be misrepresented.
2.4.9 Due impartiality normally allows for output to explore or report on a specific aspect of an issue, to provide an opportunity for a single view to be expressed or for scrutiny to be focussed on a particular position. This should be clearly signposted when dealing with 'controversial subjects' or current public policy or political issues. The existence of a range of views and their respective weights should be acknowledged, and neither those views nor their respective weights should be misrepresented.
(See 2.4.3-2.4.4)
Consideration should be given to the appropriate timeframe for reflecting other perspectives and whether or not they need to be included in other connected output. It may be necessary to 'signpost' to audiences where separated elements of output are clearly linked, for instance across a series of interviews over time, or to another programme on the same service, so that impartiality is being achieved overall. Where appropriate, signposting should point back to previous output, as well as forwards to planned output; the link should normally be stated explicitly.
(See 2.4.27-2.4.29)
If such output contains serious allegations a response may be required, either as part of the same output, or in a linked and clearly signposted alternative.
(See Section 6 Fairness: 6.4.43-6.4.46)
2.4.10 Where a BBC online site covering 'controversial subjects' offers links to external sites, it should try to ensure that the information on those external sites, taken together, represents a reasonable range of views about the subject.
(See Section 15 Independence from Commercial and Other External Interests: 15.4.22)
(See guidance: Links and Feeds)
Impartiality for News, Current Affairs and Factual Journalism Output
2.4.11 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 the BBC's editorial values, including its commitment to impartiality.
2.4.12 Presenters, reporters, correspondents and on-air editors are the public face and voice of the BBC; they can have a significant impact on perceptions of whether due impartiality has been achieved. Audiences should not be able to tell from BBC output – or anywhere else – the personal opinions of its journalists or presenters in news and current affairs or factual journalism on matters of current public policy, political or industrial controversy, or on 'controversial subjects' in any other area.
They may provide professional judgements, rooted in evidence and professional experience, but may not express personal views on such matters publicly, including in any BBC-branded output or on personal blogs and social media.
2.4.13 Achieving due impartiality requires awareness that unintended biases can result from the use of loaded language, from subconscious assumptions and from choices about prominence. For example, a phrase like 'the burden of taxation' might imply a view of taxation that is biased. Advice is available from Editorial Policy.
Public Expressions of Opinion
2.4.14 All individuals for whom impartiality in their role is paramount will need to assess risk and take personal responsibility in terms of what constitutes the 'public' expression of an opinion, for instance, within closed social media groups, private meetings (online or in person) or other circumstances they may consider, normally, to be confidential.
Mandatory Referral: Any individual in a role requiring impartiality who is intending to express opinions publicly on matters of current public policy, politics or any controversial issue, or taking part in political activity, must inform their line manager in advance, who should consult Chief Adviser Politics if there is a risk to impartiality, or the perception of impartiality.
(See Section 4 Conflicts of Interest: 4.4.14-4.4.18)
(See guidance: Personal Use of Social Media)
Mandatory Referral: Any individual who intends to seek nomination as a party candidate for election at national or local level, or intends declaring publicly their independent candidacy, must notify their line manager in advance, who should then consult Chief Adviser Politics before the intention is made public.
Where the BBC, or its Content or Presenters are the Story
2.4.15 When dealing with issues concerning the BBC itself, the BBC's reporting must remain duly impartial, as well as accurate and fair.
There should be clear editorial separation between those reporting the story and those responsible for presenting the BBC's corporate position. Presenters and reporters should take care to avoid any potential conflicts of interest. When reporting about the BBC, it will normally be inappropriate to refer to the BBC as either 'we' or the content as 'ours'.
(See Section 4 Conflicts of Interest: 4.4.16)
The personal experience of reporters and presenters – for instance, in relation to their identity – can be a relevant part of storytelling; the context of any such reporting should be appropriate, generally signposted in advance to the audience and must not compromise their impartiality or the BBC's.
Mandatory Referral: Unless it is a professional responsibility, any individuals commenting publicly – such as on social media – on BBC matters, stories about the BBC, or issues concerning other broadcasters or broadcasting policy, must consult their line manager in advance.
Contentious Views and Possible Offence
2.4.16 Freedom of expression is crucial for the BBC; at times, this will mean the inclusion of views or statements which some parts of the audience may find offensive or unacceptable.
Contributors expressing contentious views, either through an interview or other means, must be challenged while being given a fair chance to set out their response to appropriate scrutiny; alternative perspectives should normally be offered as part of the same output, over time if necessary. Minority views should be given appropriate space in output.
Coverage should acknowledge the possibility of offence, and be appropriately robust, but it should also be fair and dispassionate.
(See Section 5 Harm and Offence: 5.4.43-5.4.44 and Section 8 Crime and Anti-Social Behaviour: 8.4.3)
If there are plans in any output to include content, such as language or views, which may cause serious offence, that must be weighed alongside the public interest.
Mandatory Referral: There are some views and language which may cause serious offence, but a failure to reflect them could have implications for the BBC's impartiality; if there is a risk either of causing serious offence or jeopardising impartiality, referral must be made to a senior editorial figure, who should consult Editorial Policy.
(See Section 5 Harm and Offence: 5.4.24-5.4.36)
The public expression by staff and presenters of their own personal reactions to a statement or issue – such as personal offence or indignation; or agreement or approval – may jeopardise perceptions of the BBC's impartiality and might give an impression of bias. Similar perceptions may result from the tone or attitude with which an item or programme is presented.
Contributors' Affiliations and Supplied News Material
2.4.17 It should not be assumed that contributors to BBC output are unbiased or impartial. For those from organisations such as charities, think-tanks or universities, it may be necessary, when relevant, to give appropriate information about affiliations, funding or particular viewpoints. The same applies to individual researchers, journalists, scientists or other experts and, on occasion, to contributors who may be relating their own experiences. The key test is to consider whether the audience would be misled if such information was not made available. It may also be necessary to consider whether such affiliations might risk undermining trust in the contributor’s professional credentials or in the perceived authenticity of their experiences.
2.4.18 Video and audio news releases or other material (for example, voice notes being used as pre-recorded rights of reply) supplied by outside organisations, such as companies, emergency services, government agencies, interest groups, sports clubs, campaigners, charities or other organisations seeking a platform, may sometimes be offered as a way of avoiding appropriate scrutiny. Such use may jeopardise impartiality or the perception of impartiality; the BBC should normally only use extracts from such material when it is not itself able to gather it and its use is justified by its editorial significance.
Any use of video and audio news releases, or other material supplied by outside organisations, should be clearly labelled, stating who supplied it and explaining any relevant circumstances in which it was produced.
(See Section 3 Accuracy: 3.4.14)
Use of Technology
2.4.19 The increasing use of technologies, such as automation or artificial intelligence, may impact the perception or reality of the BBC's impartiality. New technologies may provide editorial or operational benefits, but content makers should also consider the editorial risks presented by any use of AI in the direct creation of content, in supporting editorial production or research, or in the distribution and curation of content. Other issues, including legal, rights, data protection and information security should also be taken into account.
Mandatory Referral: A senior editorial figure must be responsible and accountable for overseeing the deployment and continuing use of any AI. They should seek advice from Editorial Policy, who may consult the AI Risk Advisory Group, before any decision to deploy the AI.
For independent production companies any proposed use of AI, where there may be a material impact on audience-facing content, should be discussed as part of the commissioning process. A senior editorial figure, who is responsible for compliance within the production team, should be responsible and accountable for its use of AI.
Any product that uses AI to distribute or curate content is considered to be an editorial experience and is therefore subject to editorial approval and human oversight.
(See guidance: The Use of Artificial Intelligence)
Impartiality and Audiences
2.4.20 Listening to and engaging with audiences and including their perspectives is central to the BBC's output. But responses should not be given a wider significance than they merit and care should be taken not to misrepresent the relative weight of opinions expressed. Appropriate scrutiny may also need to be applied to audience opinions and ensure that debate does not appear to discount members of the audience who support a minority view.
(See 2.4.16)
(See Section 11 Statistics, Data, Polls and Surveys: 11.4.25-11.4.46)
(See guidance: User-Generated Contributions)
Protests and Demonstrations
2.4.21 Protests and demonstrations are an important part of the democratic process and they are routinely covered as part of the BBC's news output. Interviews with organisers, protesters and demonstrators should be impartial, rigorous and challenging; the output should include alternative perspectives.
In addition, it is important that content makers:
- assess the risk that previewing protests and demonstrations might encourage people to take part and therefore change the nature of the event; however, this should not prevent advance discussion about the issues that underpin the protest
- should withdraw immediately if a peaceful protest or demonstration becomes violent and they believe their presence is inflaming the situation and/or contributing to the nature of the event changing
- take particular care when considering using material posted by protesters to publicise and justify their actions on social media.
(See Section 3 Accuracy: 3.4.12, Section 7 Privacy: 7.4.10, Section 12 War, Terror and Extreme Violence, Disaster and Disorder: 12.4.10, Section 17 Competitions, Votes and Interactivity: 17.4.68)
Scrutiny, Campaigns and Consensus
Scrutiny
2.4.22 The BBC's journalism should scrutinise arguments, question consensus and hold power to account with consistency and due impartiality. Assessing levels of appropriate scrutiny should be based on the degree of power, responsibility and accountability of the contributor.
Appropriate levels of scrutiny should be applied to those who are in government, as well as other bodies or organisations holding power and responsibility; but appropriate scrutiny should also be applied to those who oppose or seek to influence, including opposition parties, campaigners, experts and academics. On occasion, views expressed by members of the public may also require scrutiny.
BBC content makers should question, check and, where appropriate, test facts and challenge opinions put forward by contributors, when relevant. They should be careful to source and attribute alternative or contradictory information and data where appropriate, so it is clear the scrutiny is not based on beliefs or opinion held by the BBC, its journalists or presenters.
When interviewers use 'devil's advocate' questions it should be clear to the audience that they are not expressing their own opinions or those of the BBC.
Campaigns, Initiatives and Social Action
2.4.23 Where BBC content highlights issues on which others campaign, it should not endorse those campaigns, or allow itself to be used to campaign to change public policy. But this should not prevent the BBC highlighting issues and offering audiences information and choices about how to understand and relate to them.
The BBC (and relevant staff individually) 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 the BBC's impartiality are maintained when content is scheduled topically and coincides with a third party's campaign or initiative. Advice is available from Editorial Policy.
(See Section 15 Independence from Commercial and Other External Interests: 15.4.22)
2.4.24 Some issues, when relating to matters of current public policy, may lend themselves to sympathetic case studies or may be more likely to be approached from the perspective of an individual, such as someone affected by poverty or a particular illness. Where such an approach may jeopardise perceptions of the BBC’s impartiality (for instance, if the individual may have relevant affiliations), consideration will need to be given to the inclusion of wider context or different perspectives whether within the item or over time.
Where due impartiality requirements may be met within such an item, consideration may still need to be given to a possible cumulative effect if a similar approach is taken repeatedly across the same service. Relevant output controllers may also need to take account of such a cumulative effect across different services to ensure there is no impression of bias.
2.4.25 Social action output can form an important part of the BBC's public service. However, care is required to ensure the BBC sets its own social action agenda and decides its own priorities. Content makers should ensure that:
- output does not simply embrace the agenda of any particular campaign groups or charities (except for BBC charitable appeals) and that groups are treated objectively, not favouring one above another
- if BBC social action programmes coincide with a government campaign or lobbying initiative, an arm's-length position is retained
- the BBC does not lobby on matters of public policy when raising awareness of important social issues
- news reporting of BBC social action campaigns is duly impartial.
Social action initiatives must not involve any element of on-air fund raising except for BBC charitable appeals.
(See Section 16 External Relationships, including Commercial Relationships and Financing: 16.4.11-16.4.15)
Consensus
2.4.26 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, these issues may present a significant risk to the BBC’s impartiality; for instance, where opinion may change over time, or where a minority holds a view it is either reluctant to express or its opportunity to do so is limited. In such cases, the BBC should continue to report where the consensus lies and give it due weight. However, even if it may not be necessary or appropriate to seek out voices of opposition, reporting should not use language and tone which appear to accept consensus or received wisdom as fact or self-evident.
Content makers must challenge their own assumptions and experiences and also those which may be commonly held by parts of the audience. BBC 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. Care should be taken to treat areas of apparent consensus with appropriate rigour; advice is available from Editorial Policy.
Elections and Referendums
2.4.27 There is no area of broadcasting where the BBC's commitment to due impartiality is more closely scrutinised than during election and referendum campaigns, in the UK and around the world. Special considerations apply during election and referendum periods (ie when content is being directly consumed by those about to vote), but may also be relevant in the run-up to those formal campaign periods, in some cases for several months before. This is likely to involve greater sensitivity with regard to due impartiality in all output genres. Specific advice is available from Chief Adviser Politics, who, for the UK, will publish separate guidelines for each campaign.[7]
(See Section 10 Politics and Public Policy: 10.4.21-10.4.23)
Impartiality in Series and Over Time
2.4.28 In achieving due impartiality, a 'series of programmes may be considered as a whole.[8]
The term 'series of programmes' applies to the following:
- multiple pieces of content on the same service, editorially linked, dealing with the same or related issues, within an appropriate period and aimed at a like audience.
This may include different types of linked programmes (such as a drama with a following debate); a clearly identified season or cluster of programmes or items on the same subjects; or a set of linked webpages or social media posts. Such content, items or webpages need to achieve due impartiality across the series, and should include appropriate links or signposting.
The intention to achieve due impartiality in this way should be planned in advance and made clear by signposting as part of the output.
- programmes dealing with widely disparate issues from one edition to the next, but also clearly linked as a continuing strand with a common title and a particular remit. In such 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.
2.4.29 On long-running or continuous output (such as general daily news programmes, the BBC News channel, the BBC News website and social channels) due impartiality may be achieved over time by the consistent application of editorial judgement in relevant subject areas; for instance, an appearance by a politician, or other contributor with partial views, does not normally have to be followed by someone taking a contrary view, although it may sometimes be necessary to offer the opportunity to respond.
However, editors of long-running or continuous output should ensure that:
- it reflects a broad range of individuals and views, including, where editorially appropriate, all main strands of argument
- differing views are given due weight and treated fairly, including in terms of prominence, treatment and time of day
- there is an appropriate timeframe for assessing that due impartiality has been achieved.
Where a single programme is unable to reflect important elements of debate on a particular issue, but is achieving impartiality by reference to another programme (for instance, relying on the same programme the next day, or a different daily programme on the same service), then that should normally be made clear to the audience. If the issue is a 'major matter', achieving due impartiality may require an explicit reference to a clearly linked and timely programme.[9]
In all instances where the aim is to achieve due impartiality regarding politics or current public policy over a series or over time, particular care and additional consideration is required in the approach to and during election and referendum periods; advice is available from Chief Adviser Politics.
2.4.30 Mandatory Referral: Exceptionally, there may be circumstances where an individual programme or other BBC content, such as a personal view documentary or a drama, which is not part of a series or long-running or continuous output, may include the expression of a particular or singular view on a 'controversial subject', current public policy or a political issue. Any such proposal must be referred to Chief Adviser Politics to ensure it still meets the requirements of due impartiality.
(See 2.4.9 and 2.4.34-2.4.35)
Politicians and Political Content in Non-Political Output
2.4.31 Some output which covers normally non-controversial areas (such as favourite music or books, sporting allegiances or personal biography) may seek, on an occasional basis, to include contributors who are otherwise known for their partiality, for example politicians, campaigners or others who are identified with particular views. Over time, an appropriate range of such contributors should be considered. There will be different considerations during the run-up to election and referendum periods.
Mandatory Referral: Chief Adviser Politics must be consulted in advance of any proposal to invite a politician to take part in output which would not normally include politicians, political opinions or 'controversial issues', irrespective of whether the proposed contribution is itself 'political'. Any offer from a politician to take part in such output must also be referred before it is either accepted or declined.
Where there is a proposal to involve others in such output who may have taken a prominent political stance, advice is available from Editorial Policy.
2.4.32 Where content would not normally include political opinions, current public policy or 'controversial issues' (for example in sport, music, quiz/panel shows, factual entertainment, lifestyle output), it is advisable to consult Editorial Policy in advance before doing so.
(See 2.4.5)
(See Section 10 Politics and Public Policy: 10.4.3-10.4.9)
Drama, Entertainment and Culture
2.4.33 Audiences will expect artists, writers and entertainers to have freedom to explore subjects from a particular perspective, to create content that reflects their own distinctive voice and gives them scope for individual expression in drama, entertainment and cultural output. The BBC is committed to offering such content.
Consideration should be given by commissioners and heads of relevant genres to the range of perspectives represented over time. On occasion, it may be necessary to signpost other connected output to achieve due impartiality.
Mandatory Referral: When commissioning drama, entertainment or cultural output covering matters of current public policy, political or industrial controversy, or other 'controversial subjects', Editorial Policy must be consulted in advance.
Particular consideration is needed during the run-up to election and referendum periods. Advice is available from Chief Adviser Politics.
Potential conflicts of interest may also need to be considered.
(See Section 3 Accuracy: 3.4.31 and Section 4 Conflicts of Interest)
Personal View Content
2.4.34 The BBC has a tradition of enabling 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 audiences. All of these can add to the public understanding and quality of debate, especially when they allow audiences to hear fresh and original perspectives on familiar issues.
The nature of such personal view content must be made clear to audiences in advance.
2.4.35 Additionally, when personal view content covers 'controversial subjects', especially those concerning matters of current public policy or political or industrial controversy, they should:
- maintain factual accuracy
- fairly represent opposing viewpoints when included
- provide an opportunity for response or alternative perspectives when appropriate, for example in a pre-arranged and signposted discussion programme.
(See 2.4.30)
(See Section 6 Fairness: 6.4.43-6.4.46)
2.4.36 BBC staff and regular BBC presenters or reporters associated with news or public policy-related output may offer professional judgements rooted in evidence and professional experience. However, it is not normally appropriate for them to present or write personal view content on current public policy, matters of political or industrial controversy, or 'controversial subjects' in any area.
(See 2.4.15)
Footnotes
- [4] For information about impartiality during referendums and elections, see Section 10: Politics and Public Policy ↩
- [5] See Ofcom Code Section 5 for Meaning of 'matters of political or industrial controversy and matters relating to current public policy' ↩
- [6] See Ofcom Code Section 5.11 for Meaning of 'matters of major political or industrial controversy and major matters relating to current public policy' ↩
- [7] In the run-up and during the election period, see the Editorial Policy website for Election Guidelines ↩
- [8] See Ofcom Code Section 5 for Meaning of 'series of programmes taken as a whole' ↩
- [9] See Ofcom Code Section 5.11 and 5.12 including Meaning of 'major matters'. ↩