91Èȱ¬

Editorial Guidelines issues

• Accuracy
  See Editorial Guidelines Section 3 Accuracy
• Fairness to Contributors and Consent
  See Editorial Guidelines Section 6 Fairness to Contributors and Consent
• Privacy
  See Editorial Guidelines Section 7 Privacy
• Children and Young People
  See Editorial Guidelines Section 9 Children and Young People

Summary of main points

• Don’t assume UGC is what it claims to be. Always verify content before using it
• Seek consent before using any significant UGC particularly in a breaking news situation and always credit the rights holder
• Be aware of privacy issues. Just because content has been posted to the social web and is available to billions it doesn’t mean that we can ignore legitimate privacy concerns
• We should never encourage individuals to break the law or put themselves in danger in filming material

Guidance in full

• Introduction
• Verification
• Consent and credit
• Privacy
• Duty of care
• Children and young people

Introduction

User generated content has become an essential part of our storytelling across our entire output. It plays a central role in most breaking news stories, but it is equally important in many other non News output – including Children’s.

It can be still pictures, video or comment; it can be sent to us directly as a result of specific calls to action or be found by searching for it on social media platforms and the wider web.

Whatever we use and however we use it requires particular consideration.

Verification

We should not assume that any content we use – whether we have found it on the web or have received it directly from the audience – is always what it claims to be. It may be fake, it may be genuine footage but of a different incident, it may be just part of the incident or taken from one perspective.

In News, in particular, where UGC can play an important part in our output, we must always authenticate any content before we use it. This might include anything from speaking to the individual who filmed the content to using a range of more sophisticated techniques such as geo-location and cross referencing satellite imagery to interrogate the image itself.

The more important the image is, the more important it is to ensure that we establish its authenticity – although our responsibility for due accuracy remains regardless. Advice on verifying any UGC can be obtained from the UGC Hub.

In a non-News environment we might ask audience members to send in videos of themselves undertaking particular activities, or we might source similar content from the social web. We still have a responsibility to ensure the accuracy of that content before we use it, but that might be ascertained in a simple conversation.

Consent and credit

Where we are considering using significant content found on social media – such as video of a breaking news event – we should always seek to secure the consent of the owner of the material, even if we might argue a Fair Dealing use.

We would not normally pay for the use of such material, other than in exceptional circumstances but we should be aware of copyright or other legal issues and take appropriate advice when necessary.

We should always credit the owner of the material wherever and whenever we use it – unless to do so might put the contributor at risk.

We may not always need consent to use material where there is a public interest in using it.  But we should always consider carefully the wider editorial justification and impact of using user generated content on our own platforms that is already being shared extensively on social media.

Comment, tweets or posts to 91Èȱ¬ channels or otherwise open spaces may be used without the explicit consent of the individual authors. That is particularly the case when individuals are taking part in a public debate or it is clear they understand and are participating in the open nature of social media.

Similarly it is reasonable to use appropriate pictures of individuals taken from their open social media profiles without explicit consent when it is in the public interest. However, we should take due consideration of potential distress to family and friends where we use pictures of individuals who have died.

Privacy

Even though content may have been posted to social media platforms that have a potential global audience of billions, we must still consider whether our own use of the material respects the privacy of those featured.

If the content is filmed openly in a public or even semi-public space then the presumption would generally be that it would be reasonable for us to use. This may still be the case even where the subject is not aware they are being filmed provided there is a public interest. For example, it could be video of vehicle drivers using their mobile phones or other examples of anti-social or illegal behaviour. 

However, if the content features individuals who might otherwise have a legitimate expectation of privacy, for example if they are receiving medical treatment, or where they are in a private space or the content was clearly not intended for public consumption we should continue to respect that – unless there is a public interest in bringing that material to our audiences.

We may consider anonymising individuals featured where there remains a public interest in using the material.

Where we have asked for contributions from our audiences we should ensure we act in accordance with data protection laws in handling their personal information and take appropriate advice.

Duty of care

We should never encourage individuals to break the law or put themselves in danger. We should not normally use material sourced from social media where it is clear individuals have put themselves at unnecessary risk.

We should make it clear that contributors should continue to act in the way they would normally do regardless of the fact that they may be creating content that we might use. They should never be encouraged or even ‘given permission’ to undertake activities they would not normally undertake. This is particularly the case when we are working with contributors producing longer form personal view or eye witness content.

In breaking news stories we should be co-ordinated and considerate in approaching individuals on social media for both their consent to use their material and to request any further contribution to our output. It may be they are still caught up in the incident or dealing with the consequences of it.

Children and Young People

We should not routinely ask children to act as newsgatherers for the 91Èȱ¬, but we may want to ask them to submit content for creative projects or competitions on C91Èȱ¬ or other appropriate outlets.

Where we have asked for content to be sent directly to us by children under 13 we should use our own uploader, where parents have already given permissions for their child to upload content and will notify them every time content is submitted. Where content submitted to us features other children under 13 we must seek parental consent.

Where children are featured in content found on social media that we are considering using, we should take into account the impact on the child or young person of doing so.

Any online safeguarding concerns that we discover, whether related to online grooming or child abuse images, must be referred to the Head of Safeguarding and Child Protection immediately. 

Last updated July 2019

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