UK – Broadcasting Standards Commission Code on Standards

Code on Standards Broadcasting Standards Commission. (The BSC was replaced by Ofcom in 2003)

Introduction
1. Broadcasting is a dynamic cultural force in which broadcasters interact with their many audiences in a relationship of healthy respect. That is what makes audiences willing for them to experiment and to challenge conventions by presenting controversial work. At the same time, broadcasters must also be wary of causing unjustified offence. It is part of the broadcasters’ duty to find ways of striking a balance between their creative freedom and their responsibility to their diverse audiences. Furthermore, the Human Rights Act 1998 ensures that broadcasters have a right to impart creative material, information and ideas, and that viewers have a corresponding right to receive these.

2. The purpose of this Code is to provide guidance on how to strike that balance: this guidance is based on extensive independent research by the Broadcasting Standards Commission into audience views and expectations, and the ways in which these shift over time. Broadcasters should take account of current research when transmitting programmes, as will the Commission when considering complaints. The Code applies to programmes, advertisements and text broadcast on all forms of television services and radio, including satellite and cable channels.

3. The Code aims to give broadcasters, their regulators and the public an understanding of the factors which should be taken into account when making editorial judgments. Editorial responsibility lies with the broadcasters themselves, although on occasion the Code draws attention to specific issues and offers clear advice. Broadcasters and their regulators must reflect the general effect of this Code in their own codes or guidelines.

4. It is the responsibility of the programme-makers and broadcasters to explain their policies clearly for the audience. The most frequent reason for viewers or listeners finding a particular item offensive is that it flouts their expectations – expectations about what sort of material should be broadcast at a certain time of day, on a particular channel and within a certain type of programme, or indeed whether it should be broadcast at all; and whether the intentions of the programme are signalled in advance. The Commission recognises that audience expectations do vary according to whether a channel is a general entertainment channel or specialist, and whether it is mainstream, open access or available only by subscription.

5. The Commission also supports the general principle that improved levels of media literacy lead to greater reciprocal understanding. Media literacy exists when the user not only has access to a full range of electronic media, but also is able to comprehend the choices available and to evaluate them.

6. The Code is intended as a set of principles to inform the Commission’s consideration of standards complaints alongside the individual context, audience expectations and platform of the programme in question.

Scheduling
7. The composition of audiences of open access channels changes throughout the day, and the content of broadcasts reflects this. At certain times, parents will want to be confident that their children can watch or listen to programmes without the risk of being exposed to disturbing material. At other times, there will be more challenging material. The majority of parents accept that they are expected to take greater control over the choice of their children’s viewing after
the Watershed.

8. Some events have such a strong impact on the public that broadcasters have to alter their schedules in order to be responsive to the public mood. Therefore careful consideration should be given to the broadcast and scheduling of programmes after such events.

9. Special consideration is given to the child audience in other sections of the Code.

The Watershed
10. The television Watershed, which starts at 2100 and lasts until 0530, is well established as a scheduling marker to distinguish clearly between programmes intended to be suitable for family viewing and those intended primarily for adults.

11. Broadcasters have a clear duty to give sufficient information about the nature and content of programmes to allow parents to make an informed judgment on a programme’s suitability for their children to see or hear. (See also INFORMING AND WARNING)

12. The majority of adults are aware of the Watershed and its significance. Parents need also to be aware that some programming during the day might not be suitable for unaccompanied viewing by all children, particularly from 1900 until 2100. The child audience covers a wide age range, from very young children to adolescents, and even some children’s programmes or news programmes may be unsuitable for younger child audiences.

13. Broadcasters should bear in mind that children may well continue to watch programmes which start before 2100 and run through the Watershed.

14. There should not be an abrupt change from family viewing to adult programming at 2100.

15. Cable and licensed satellite services operate with the standard 2100 Watershed for all channels, except for specially encrypted services with restricted availability to children. These have two Watersheds: one at 2000 (equivalent to the 2100 change on other channels) and the second at 2200, when material of a more adult nature can be shown. Other cable and licensed satellite services are expected to follow similar standards to the terrestrial channels. The programmes and the versions of the films they broadcast should be suitable for the time of day.

16. Pay Per View services give subscribers greater choice over what they choose to watch. Given their stricter access systems, the Watershed does not apply in the same way. The expectation is, however, that the films or programmes shown will conform to the same wider principles set out in this Code.

17. Although there is no Watershed for radio, caution should be exercised at the times that children tend to listen, especially during breakfast programmes and during the ‘school run’.

18. Care should also be taken in the scheduling of daytime programmes on both television and radio both in and out of term-time.

Programme Repeats, Trails and Advertisements
19. Broadcasters should assess the suitability of material for its time slot.

20. When repeats are rescheduled from evening to daytime, editorial consideration should be given to their suitability for that particular slot. This also applies to material repeated during the school holidays.

21. Trails come upon audiences without warning, so that people cannot make informed choices about whether or not to be exposed to them. Special care needs to be taken to ensure that trails which are in themselves unsuitable for children are not broadcast before the Watershed.

22. Similarly, advertisements also appear without warning and can have the power to surprise and shock an audience which cannot selectively screen them out. Broadcasters should be alert to surrounding programmes and any juxtaposition that might cause offence – especially in relation to programmes which appeal to children. They should ensure that the content and style of an advertisement is suitable for the time of its transmission and likely audience.

Informing and Warning
23. Broadcasters have a clear duty to give accurate information about the nature and content of programmes in order to allow the audience to make an informed choice.

24. Broadcasters have to fulfil the conflicting objectives of attracting audiences while simultaneously warning viewers or listeners that they may find a programme offensive. Providing as much clear information as possible in advance about the nature of programmes can often fulfil both of these objectives.

Respect and Dignity
25. Broadcasting touches the lives of its audiences in many ways and from time to time involves them in programme-making. Whatever the relationship, programme-makers have a responsibility to preserve, as far as possible, the dignity of the individual.

26. Challenging or deliberately flouting the boundaries of taste in drama and comedy is a time-honoured tradition. Although these programmes have a special freedom, this does not give them unlimited licence to be cruel or to humiliate individuals or groups gratuitously.

27. Tastes change over time and vary from one individual and social group to another. They often relate to subjects which can cause embarrassment or upset. Matters of decency, however, are based on deeper, more fundamental values and emotions: the respect owed to the bereaved at funerals is one example. Offence to decency has the potential to cause more significant hurt and should thus be given the highest priority when considering the suitability of items for broadcast.

28. Individuals, particularly vulnerable members of the community, should not be exploited or caused distress, nor should the audience be made to feel like voyeurs of others’ distress or humiliation, particularly if consent has only been given by a third party. Unless a clear public interest justification exists, or unless the broadcast is live, the consent of the individual(s) concerned should be obtained before transmission.

29. People taking part in programmes, particularly children, callers to radio programmes and the ‘victims’ of wind-up calls and set-ups, should not be treated unreasonably, nor should they appear to have been so to the audience at large.

Broadcasters should exercise extreme caution when including children in programmes, even if they and their families have been fully briefed and given consent beforehand. Nor is it justified to broadcast intrusive material about children simply because of what someone related to them has agreed to or done.

30. The line between the public’s right to receive information and the citizen’s right to privacy can be fine and difficult to draw – the public accept that people have legitimate expectations of privacy that can, at times, be overridden by the wider public interest. There is a strong sense that certain information is publicly owned because it relates to publicly funded bodies or because of its potential impact on the public in general. There is considerable distaste for invasive media behaviour that can have harmful consequences for the people reported on. (See also the Fairness and Privacy Code, para 14 et seq.)

Occasions of Grief and Bereavement
31. Viewers and listeners can easily be offended if they consider that a broadcaster has failed to observe basic decencies or to demonstrate due sensitivity on such occasions.

32. Technology enables the programme-maker and the reporter to bring the starkness of grief and bereavement to the audience immediately. Intimate details can be available to everyone within minutes, if not seconds, before those affected can be shielded. Not every community, nor every family – nor indeed every individual – deals with this in the same way. Some are more willing than others to articulate their emotions. However, broadcasters must be careful not to take advantage of people in deep shock, for example, or persuade them into an expression of their emotions or views which they may later regret. Such approaches must be made with discretion and sensitivity, and approved at a senior level.

33. The broadcast of calls to the emergency services and amateur footage of incidents must be treated with extreme caution and approved at a senior level. Care should be taken to avoid sensationalism and undue repetition.

34. If the consent of the bereaved is obtained, the significance of funerals as a turning point in the story of an individual tragedy or a major disaster can justify the presence of reporters and their equipment. There should, however, be an accompanying readiness not to exploit such situations.

Archive Material
35. When using archive material, programme-makers should bear in mind the distress that can be caused to survivors or the relatives of victims when coverage of previous disasters or serious incidents is used to illustrate other programmes.

Swearing and Offensive Language
36. Language is never static; words acquire new meanings and interpretations, and levels of offence undergo constant change. The impact of particular words can differ between generations, as well as between different tones of voice. The repeated use of expletives can cause significantly greater offence than isolated incidents which are justified by the context. A study of the relevant research will clearly indicate where the areas of concern lie.

37. Racist terms and terms mocking disability and mental illness have come to be regarded as deeply offensive, overtaking some traditional terms of abuse. Broadcasters should also be alert to the use of derogatory terms originating from religious affiliation and sexual orientation. Broadcasters should be sensitive to the offence caused to the majority by these words, as well as to the minorities directly affected.

38. Where the language can be justified, the majority of the audience favours the use of a later transmission time rather than editing, particularly for films.

39. The paramount concern of most adults is for children. In research conducted by the Commission, most respondents said that all programmes shown before the Watershed should contain language suitable for a family audience. Respondents were also concerned about the use of swearing by those whom children take as role models, for example, footballers or pop stars. Particular vigilance should be exercised in the hour before the Watershed.

40. The most senior levels of broadcasting management should approve the use of the strongest swearwords at any time. There is rarely ever any justification for the use on television of offensive language before the Watershed. Most people also believe that advertisements should not contain strong language at any time.

41. While no radio Watershed exists, the use of words that give particular offence should be overseen at senior levels within the broadcasting organisations.

42. Broadcasters must be alert to, and guard against, the use of such language in live programmes.

Offences against Religious Sensibilities
43. Religion is a contentious topic, mainly because it is the source of deeply held convictions on the part of believers that are not easily understood by nonbelievers. Although religions should not be exempt from the critical scrutiny that is an important aspect of the culture of our diverse society, particular care should be taken when referring to religion in entertainment.

44. Programme-makers should be aware that the casual use of names, words or symbols regarded as sacred by believers can cause unnecessary offence. Moreover, while many people may not themselves be offended by the casual use of holy names as expletives, the majority would not wish to cause offence to others by this usage.

45. Particular offence is given by the linking of the holy names with the strongest swearwords.

Occult and Psychic Practices
46. Many people are concerned about the inclusion of material relating to psychic practices, especially pre-Watershed and on open access channels. Content relating to the occult gives rise to even greater levels of disquiet.

47. Broadcasters should be aware that such content has the potential to have an adverse influence on vulnerable members of the audience.

Imitative and Anti-social Behavior
Suicide/Self-Harm
Factual Programmes
48. The reporting of suicide and self-harm requires particular care. Programmes should avoid being precise about the means of suicide/self-harm, especially when that method is readily available or contains some novel aspect. Broadcasters are reminded that the Samaritans are available to offer help and advice in this area, and they may wish to consider publicising helplines when appropriate.

49. Factual reports should not suggest that there is a simple explanation or conversely that the suicide/self-harm was inexplicable. The action should not be conveyed as an understandable response to difficulties encountered in life or perceived failures. Reports should refrain from making the news overly prominent or using it repetitively, especially when a possible role model is involved.

50. There is evidence that leaving details as to method or location imprecise can discourage both imitative suicide attempts and the presence of curious spectators. It should be borne in mind that late evening, early morning and public holidays are periods when loneliness and isolation can be at their most intense.

Fiction
51. In addition to the guidelines noted under paragraphs 48-50, broadcasters should exercise particular care over fictional suicides/self-harm involving attractive role models, especially in soap operas. It is also important to depict the realities and the consequences of their actions for others. Explicit hanging scenes, however, should never be shown before or close to the Watershed, and storylines involving the details of suicide/self- harm should be considered at senior levels within the broadcasting organisation.

Drugs
52. While it is entirely right for programme-makers to explore the style and prevalence of the drugs culture in our society in both factual and fictional programmes, no individual programme, taken in its entirety, should promote or encourage the use of illegal drugs.

53. There is particular danger in showing in any detail how to administer drugs and in failing to illustrate the adverse consequences that drug abuse can bring about, especially in programmes that appeal to young people. Similar considerations apply to any other drug-related substance abuse. Broadcasters may wish to consider publicising helplines when appropriate.

54. Research carried out for the Commission suggested that, while some programmes were considered to have portrayed drugs in an unrealistic manner, other programmes were perceived to have glamorised those discovered to be drug abusers – this was particularly the case with celebrity coverage illustrated by library or archive footage.

55. Neither smoking nor the abuse of alcohol should be promoted, particularly in programmes directed mainly towards young people.

Lyrics and Music Videos
56. Broadcasters should be alert to content which glamorises crime and drug-taking, encourages aggressive behaviour or debases human relationships. Music videos should observe the appropriate scheduling considerations and limits applied to other broadcasts.

Portrayal
Race and Diversity
57. Care should be taken to foster tolerance and respect for difference and avoid the lazy adoption of stereotypes covering race, gender, age, religion or sexual orientation.

58. There are times when racial or national stereotypes, whether physical or behavioural, may be used without offence in programmes, but their use and likely effect should always be from an informed stance and be considered well in advance. This also applies to stereotypes of people from places, regions or nations within the United Kingdom. Research also points to the desire for positive role models from British ethnic minorities.

People with Disabilities or Mental Health Problems
59. Programmes should avoid anything encouraging prejudice or patronizing attitudes towards people with disabilities or mental health problems.

60. Colloquial abusive terms may cause great offence, and care should be taken neither to propagate myths nor to stigmatise. Programme-makers should seek to avoid stereotypes by consulting those with disabilities or mental health problems when appropriate.

61. It is also important when portraying acts of criminal violence not to associate them uncritically with questions about the mental health of their perpetrators.

Crime
62. Although there are programmes that can legitimately be built around real-life crimes or criminals, broadcasters should avoid glamorising or condoning crime.

63. The retelling by criminals or their relatives of their stories of criminal or anti-social behaviour should not result in their personal gain, unless there is an overriding public interest both in the telling of the story and in the making of payments. It is also important for the media not to glamorise the lives of offenders or their families.

64. It is possible to arrange interviews with named criminals – sometimes with the legitimate aim of drawing attention to injustice or with the declared intention of helping the audience to understand the criminal mind. Both are proper ambitions for broadcasters with a purpose of serving the public interest, but each is capable of being exploited for sensational ends. Programme-makers should be clear about the purpose of such an interview and ensure that its presentation is consistent with that goal. In such cases, broadcasters should also, where practicable, inform victims or their families. Consideration of the portrayal of an offender and their
offences should also include that of the possible effect on his/her victim(s).

65.Care should also be taken not to give details which could lead to emulation.

Portrayal of Violence
66. Violence is a fact of life. As long as it exists in society, television and radio programmes will portray it and report it. There are some significant concerns, however, about the portrayal of violence which broadcasters need to take into consideration. These include the concern that repeated exposure to violence desensitises audiences, making them apathetic towards increases in actual violence or indifferent to the plight of victims; the concern that viewers might identify violence on the screen with the reality of their own lives and become unreasonably fearful; and the concern that it could also encourage the view that violence or aggressive attitudes are acceptable as responses to difficult situations or as the means of resolving disputes.

67. Particular attention should be paid to avoiding the overly detailed portrayal of criminal or violent techniques and the glamorisation of weapons. This also applies to any action which could promote illegal or anti-social behaviour in real life.

68. In scheduling a programme containing violence, especially where it is violence with
which viewers may identify closely, broadcasters should consider the programmes
placed either side of it and their likely audiences, as well as the time of transmission.

Violence in News, Current Affairs and Documentary Programmes
69. Images and music shown on television can have an overwhelming impact. While broadcasters should not shy away from showing the consequences of violence, they must also take care in the choice of accompanying words to ensure that they put the scenes into the right perspective. Senior editorial judgment must be exercised in assessing the impact such material may have on the audience.

70. News and factual programmes play an important part in informing citizens about their society and the state of the world. The immediacy and speed with which images and reports can be relayed into people’s homes means that decisions about the suitability of items for different time slots sometimes have to be made swiftly, with little time for consultation. News channels or services relying on a rotating sequence of items, some repeated many times in succeeding cycles, need to consider issues of suitability and likely audience composition as they pass through various phases of the day.

71. The increasing availability of amateur and CCTV videos and webcam footage provides another source of material where careful editorial decisions at a senior level are called for, balancing the immediacy of the material with its impact and suitability for transmission at one time of the day or another. Broadcasters will have to make difficult decisions about how much detail of shocking material is necessary or acceptable, and to what degree material must be edited before
it can be shown at all.

72. News bulletins are now part of the day-long output of many broadcast services. At some times of the day, large numbers of children are viewing or listening, so broadcasters must continue to practise discretion over what is transmitted at different times and provide appropriate warnings. Although documentary programmes may be seen to have greater licence, similar considerations apply.

Explicitness
73. A balance needs to be struck between the demands of truth and the danger of desensitising people.

74. As general guidance in striking this balance, the following principles should be borne in mind:
• decency requires that people should be allowed to die in private. Only in the rarest circumstances should broadcasters show the moments of death;
• the dead should be treated with respect and not shown in close-up, unless there are compelling reasons for doing so;
• close-ups of the injuries suffered by victims should generally be avoided;
• care should be taken not to linger unduly on the physical consequences of violence;
• explicit scenes of hangings or other executions should not be shown before the Watershed, without overwhelming justification.

Radio News
75. Radio responds rapidly to news events and so also faces the difficulty of maintaining a perspective on the violence it reports. The choice of language is crucially important.

76. Where casualties occur, accurate reporting of the details is paramount. Natural sounds, whether on radio or television, can be as distressing as pictures. In reporting certain kinds of crime, such as sexual assaults or incidents involving children, the time of transmission must be taken into account and the degree of explicit detail matched to the probable presence of children listening. A balance needs to be struck between accurate and full news reporting and engendering unjustified fear.

Reconstruction of Violent Crimes
77. Reconstructing a crime, sometimes with fresh details of which the victims and their families are unaware, can disturb not only those directly affected, but also others in similar situations. Strenuous efforts should be made to inform the people involved wherever appropriate.

78. Where cooperation is withheld, especially in drama-documentary programmes, the programme should have some overriding public interest, such as the illumination of public policy or the disclosure of significant new facts, and be considered at the most senior levels within the broadcasting organisation. (See also the Code on Fairness and Privacy, Paragraph 31.)

79. It is important not to overemphasise the dramatic aspects of reconstructed crime by the insensitive use, for instance, of slow motion, music or other special dramatic effects. The weapons used should not be discussed in unnecessary detail. Broadcasters are reminded that Victim Support is available to offer help and advice in this area, and they may wish to consider publicising helplines when appropriate.

Violence in Drama
80. Viewers are most shocked when violence occurs in locations that are familiar to them and with which they can identify, particularly if that violence ‘erupts’ and cannot be foreseen.The context of the violence, and the audience’s ability to appreciate the conventions within which the drama is being played out, are key considerations.

81. Violence in situations which are more distant, and which are further from reality, are less likely to disturb; conversely, the apparently gratuitous intrusion of violence into locations regarded as places of safety can be deeply shocking. The impression of violence goes beyond the actual violence seen or heard, and is connected with the audience’s expectations. People are more concerned when the act of violence is personal and shown explicitly and realistically. It is the combination of pain, cruelty and viciousness in a recognisable situation that causes anxiety, as fictional violence is seen by some as more real than the actual violence of war in a far-off place.
Nevertheless, the serious consequences of violence should never be glossed over.

Rape
82. Particular care needs to be taken when portraying sexual violence. When a scene involves rape or indecent assault, consideration must always be given, while achieving the dramatic purpose, to minimising the depiction of the details and avoiding any suggestion that such crimes are erotic or endorsed.

Incest and Child Abuse
83. Where a play or film takes incest or child abuse as its theme, there should be particular awareness of the relative ease with which some people, including children, may identify characters or actions with their own circumstances. In television, material of this kind should be accompanied by clear warning of the programme’s content, while sensitive scheduling and labelling are also called for in radio.

84. The inclusion of these subjects in well-established series or single programmes may be justified as public information, even in programmes directed at older children. These programmes may also play a legitimate role in warning children of the dangers of abuse and advising them of the help available. Broadcasters may wish to consider publicising helplines when appropriate.

85. A sexual relationship between an adult and a child or between under-age young people can be a legitimate theme for programmes; it is the treatment that may make it inappropriate or unlawful. The treatment should not suggest that such behaviour is legal or is to be encouraged. Explicit portrayals of sexual acts between adults and children should not be transmitted.

86. Broadcasters should take legal advice; however, even when legal advice indicates material is on the right side of the law, it should be subjected to careful scrutiny at the highest level over the need to include the sequence in the programme. This applies even when the child is played by an older actor. (See also Portrayal of Sexual Conduct, paragraphs 95 et seq.)

Cult Movies
87. Some film genres and cartoons present highly stylised violence which would be unacceptable in other contexts.

88. It is important to schedule programmes appropriately and ensure that they are trailed so that audiences can exercise informed judgment on whether to watch. It is also important to have pre-transmission announcements where appropriate. (See Scheduling, paragraphs 7 et seq.)

Children and Drama
89. Broadcasters should be aware that some children can be disturbed by the portrayal of violence in familiar surroundings. Domestic violence is particularly distressing for children.

90. Broadcasters should alert parents both by scheduling and by providing adequate information about a programme’s content, so that they are able to make an informed choice about its suitability for their child or children. Care should be taken to in pre Watershed drama to avoid:
• suggesting that violence does not injure people or have consequences for the perpetrator as well as the victim;
• implying that violence does not cause long-term damage or psychological harm;
• showing dangerous conduct that might be copied by children;
• portraying characters, especially those likely to be children’s heroes, who resort easily to violence as the means of resolving differences, exhibit callousness to their victims or enjoy inflicting pain and humiliation.

Imitation
91. Broadcasters should avoid any material likely to encourage or facilitate imitative violent behaviour.

92. The description of ingenious methods of crime, the use of dangerous items and weapons, and the use of readily available objects for criminal purposes should be avoided. Detailed instructions on how to make explosives or other harmful substances should not be given.

Animals
93. Images of cruelty to animals are especially upsetting to many members of the audience, particularly children – even when no harm comes to the animals during production.

94. If cruelty to an animal needs to be included in a programme, it should not be dwelt on. Consideration should be given to an appropriate transmission announcement if no harm was caused to the animals.

Portrayal of Sexual Conduct
95. Audiences in Britain have generally become more liberal and relaxed about the portrayal of sex, but broadcasters cannot assume a universal climate of tolerance towards sexually explicit material. The broadcast of sexually explicit scenes before the Watershed should always be a matter for judgment at the most senior levels within the broadcasting organisations. On radio, broadcasters must take into account the likely composition of the audience before scheduling
more explicit dramatisations of sexual activity.

96. On general broadcast channels, radio and television have to meet the expectations of wide audiences with widely varying levels of tolerance of the portrayal of sexual relationships. Even those unlikely to be offended themselves may be concerned about viewing some programmes in the company of others and are likely to be mindful of the effects on children. Sensitive scheduling, especially within the hour around the Watershed, is particularly important for items involving sexual matters. Broadcasters should provide straightforward labelling in clear language and
sufficient warnings about programmes containing explicit material.

97. Broadcasters have a duty to act responsibly and reflect the fact that relationships within and between the sexes normally reflect moral choices. Audiences should not be reduced to voyeurs, nor the participants to objects. There is an important distinction between titillation and dehumanising objectification. Editorial judgment must be exercised when there is any association of sex with restraint, pain or humiliation, especially if this is nonconsensual.

98. Encrypted subscription and pay-per-view services offering explicit sexual content cater to self-selected adult audiences. However, even these operate under the general law on obscenity, and there should not normally be clear portrayal of actual intercourse in fictional, including ‘adult’, contexts.

Factual Programmes
99. When a news story involves a sexual aspect, it should be presented without exploitation.

100. The broadcaster must, in any case, measure the relative explicitness of such content against the time of day at which it is transmitted and the likely presence of children in the audience. Where factual programmes deal with a variety of sexual themes, producers should ask  themselves whether an explicit representation is justified.

Discussion and Phone-in Programmes
101. Programmes need to be scheduled with care and warnings given of their likely content.

102. There is a wide difference of attitudes, particularly between the generations, towards the open debate of sexual topics. Broadcasters should take account of the expectations of the likely audience to a particular programme.

Nudity
103. The appearance of the nude human body can be a legitimate element in a programme, provided it does not exploit the nude person and there is a clear editorial rationale.

Innuendo
104. Coarse humour and sexual innuendo may cause offence, especially if broadcast when there are children and young people in the audience.

105. This should be reflected in the scheduling of risqué material, particularly before the Watershed, and in programmes which would not normally be expected to contain material of this kind. This also applies to radio programming broadcast when a substantial number of younger listeners may be in the audience, such as at breakfast time, during the school run and during the school holidays.

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