大象传媒

Editorial Guidelines issues

This Guidance Note applies to all children and young people we work with - contributors and actors. It relates to the following Editorial Guidelines:

• Children and Young People as Contributors
  See Editorial Guidelines Section 9 Children and Young People as Contributors
• Harm and Offence
  See Editorial Guidelines Section 5 Harm and Offence: 5.3.49 鈥� 5.3.51

The Editorial Policy Guidance Note on Interacting with Children and Young People Online contains further advice on user contributions.  See Guidance online: Interacting with Children and Young People Online

This Guidance should be read in conjunction with the Editorial Policy Guidance on Working with Vulnerable Contributors or Contributors at Risk of Vulnerability.

Key Points

• In the course of our work if we suspect a person under 18 may be at risk, or we are alerted to a child welfare issue, the situation must be referred promptly to the divisional Working with Children Adviser [1] or, for independent production companies, to the commissioning editor. If we are concerned about an adult, including a member of staff, working with a child the situation must be referred promptly to the 大象传媒 Safeguarding Lead/Head of Safeguarding [2] or Head of Corporate Investigations [3] or, for independent production companies, to the commissioning editor.
• If a child is in immediate danger or requires medical attention dial emergency services, (999 in the UK), and ask for the appropriate emergency service. The 大象传媒 Safeguarding Lead/Head of Safeguarding or, for independent production companies, the commissioning editor should be informed urgently.
• Any online safeguarding concerns, whether related to online grooming or child abuse images, must be referred to the Head of Editorial Standards Children鈥檚 and Education (whose previous job title was Head of Safeguarding, Policy and Compliance) [4] immediately.
• We should apply the principles of the 大象传媒 Child Protection Policy in our dealings with children and young people. [5]
• We should consider whether a contributor/contestant/child actor might be regarded as being at risk of significant harm as a result of taking part in 大象传媒 content. We should conduct a 鈥渃ontributor due care鈥� risk assessment to identify any risk of significant harm to the contributor, unless it is justified in the public interest not to do so.
• The decisions about whether and how to identify a child in our output require editorial judgement. Considerations include balancing the freedom of expression of the child with the requirement to safeguard the welfare of those who contribute to our content. The requirement to obtain informed consent is a key principle of the Editorial Guidelines. In addition to parental consent, when establishing the willingness to participate of a child or young person, all the information should be given in a way they can understand.
• For all genres, where risks to a child contributor/contestant/child actor have been identified in relation to their contribution to 大象传媒 content, the parent/guardian should be provided with relevant information about those risks and any steps that will be taken to mitigate them. It is helpful to keep written records of discussions with the parent/guardians of contributors before filming, in addition to informed consent in writing.
• We should not request more personal information from children and young people than is necessary. To help keep children safe, consider carefully how much information we plan to give out on air/online and think about all the points at which children鈥檚 data needs to be kept securely. 
• Wherever possible liaise with the parents/school for contact information and use a 大象传媒/independent company contact address, email or phone number, especially for any contact with children.
• Behaviour with a child should be appropriate. Follow the 大象传媒 Code of Conduct for working with children and young people at the 大象传媒.[6]
• Consider carefully the impact and possible consequences of any involvement by a child or young person in our content, both during the production process and once it has been broadcast. Potential contributors may sometimes be psychologically assessed by an independent expert before final decisions are taken as part of the pre-production process for choosing contributors. An assessment after recording and ongoing support after transmission may also be appropriate.
• With sensitive material, in addition to any expert opinion, it can be advisable to speak to the head teacher of the child鈥檚 school for an opinion, or to someone who knows them well, about the child鈥檚 participation.
• Consider the impact on young actors and contributors of witnessing or participating in activities that might have a negative psychological effect on them and of being asked to take part in activities that are not appropriate for their age, for example, wielding a weapon or smoking a cigarette.
• Aftercare is important. Any aftercare needs to be proportionate to the ongoing risks identified and have clear boundaries and time frames.

It may be appropriate for a member of the team, preferably the main contact, to keep in touch with the child and their family to monitor any specific after-effects that might have resulted from the child鈥檚 participation. In some cases, providing access to sources of professional help or support may be advisable.

• There may be some very sensitive content where it could be appropriate for the 大象传媒 to limit the period of time that the programme should be repeated for.

Guidance in full

• Safeguarding the Welfare of Children and Young People 
  -  Identifying children in our output
  -  Personal Information
• Informed Consent for Children and Young People
• The Impact of a Contribution
• Appropriate Behaviour with Children and Young People
• Aftercare

Safeguarding the welfare of children and young people

Children and young people contribute and interact with us in many different ways including as contributors, actors, presenters and via our interactive services. They have a right to speak out and to participate, as enshrined in the United Nations Convention on the Rights of the Child but we must safeguard the welfare of those who contribute to our content, wherever in the world we operate.

Safeguarding is a preventative approach to working with children and young people. It also protects the 大象传媒 because, if we have considered the safety and welfare of our contributors throughout the production process, we are less likely to, inadvertently, have acted inappropriately, or to be accused of acting inappropriately.

We must take due care over the physical and emotional welfare and the dignity of under-18s who take part or are otherwise involved in our editorial content, irrespective of any consent given by them or by a parent, guardian or other person acting in loco parentis. Their welfare must take priority over any editorial requirements.

This guidance note gives advice to help us take due care of our young contributors and actors and to make other editorial decisions relating to them that should be considered on a case by case basis in line with the Editorial Guidelines. Further advice about children and young people as contributors and actors is available from Editorial Policy. (See below for the areas that the 大象传媒 Safeguarding team advise on.)

We should apply the principles of the 大象传媒 Child Protection Policy in our dealings with children and young people.

(See Editorial Guidelines Section 9 Working with Children and Young People as Contributors: 9.3.1- 9.3.5) 

Each 大象传媒 division has a nominated Working with Children Adviser who has responsibility for implementing the policy in their area. A list of 大象传媒 nominated advisers can be found on the Safeguarding site.[7]

The 大象传媒 Safeguarding team, part of the Safety, Security and Resilience department, advises on safeguarding children including:

• In practice what the legal requirements are for working with children and young people
• Chaperoning
• Licensing of child performers in the UK
• Responding to safeguarding issues regarding children

Editorial Policy advises on

Working with children and young people as contributors such as:

• Informed consent to take part, ranging from brief vox pops, to potentially distressing content in News output and to major contributions in factual or dramatic output
• Considering whether scripts we want children to say, or content we want them involved with, are appropriate
• Impact of a contribution (including child actors) before, during and after transmission and putting in place appropriate procedures

Considering children as part of our audience:

• what content is appropriate when children and young people are likely to be in the audience, whether it is designed for children or adults, and on all platforms

There is detailed advice about the risks from online and electronic communication and how to escalate it in the Guidance Note on Interacting with Children and Young People Online.

(See Guidance: Interacting with Children and Young People Online)

Identifying children in our output

(NB Full names of child actors and performers are normally listed in programme credits, unless there are safety concerns.)

The decisions about whether and how to identify a child in our output require editorial judgement. Considerations include balancing the freedom of expression of the child with the requirement to safeguard the welfare of those who contribute to our content.

Identification can include their name, their school or other location, or their age. The more identifying information that is given about them, the more likely a child could be located by someone wishing them harm. The platform is important too 鈥� there is likely to be more risk with permanent content with the possibility of reverse image searches, than in a one off TV bulletin. Safety considerations are particularly pertinent if we are producing content for social media as clips identifying children and young people are likely to be shared and accessible beyond 大象传媒 platforms.

Think about what information to put in press photos and billings, which may have wider reach than the programme itself.

Consent should be sought from a parent or person acting in loco parentis, about the amount of identifying information to include about a child.

For child safety reasons, we should consider referring to a child by first name and large town only. (Take into account whether the child has an exceptionally distinctive name which could make them more identifiable). However, there may also be instances when it is appropriate to give the full name of a child or young person. (See below).

Conversely there may be occasions when we would not identify the child at all or further limit the amount of information that could identify a child.

An example could be where the 大象传媒 is recording in a school and one child should not be recorded because they and a parent have fled from an abusive partner. If the child were recorded, their location could be revealed to the ex-partner. It is good practice to check this with a school when seeking consent from a head teacher. Advice is available from Editorial Policy.

Naming the contributor鈥檚 school can make a child easy to be located by those who might wish to cause them harm. It is not usually advisable to name the school unless it is part of the story, for example where the school has done something interesting and so is the main focus of the piece. Where a school is named, consider limiting other information that is given out.

Think carefully about when to film children in school uniform. Even if the name on a school jumper is not legible on screen, a distinctively-coloured uniform may identify the school to that area鈥檚 inhabitants.

It is also important that children and young people have the right of self-expression and have their achievements and life history recorded. There may be some instances when it is appropriate to give the full name of a child or young person, and other details such as school or club, for example, where they have won an award and deserve recognition for their achievements or where they are already publicly known (a sports star for instance).

Personal Information

Remember to consider all points at which children鈥檚 data needs to be kept securely. For example think about what information goes into a script and who might have access to that script, or if user generated content or correspondence is being physically taken to a studio or public area, mask the contact details. 

(See Editorial Guidelines Section 9 Working with Children and Young People as Contributors: 9.3.11)

Informed consent for Children and Young People

The requirement to obtain informed consent is a key principle of the Editorial Guidelines.

(See Editorial Guidelines Section 9 Children and Young People as Contributors: 9.3.12-9.3.20)

In addition to parental consent, when establishing the willingness to participate of a child or young person, all the information should be given in a way they can understand. An appropriately-pitched explanation of the proposed contribution should be given. Sometimes it can be helpful to ask a child to say back what he/she understands his/her participation would involve, to check they have understood. Make sure the child does not feel pressurised to agree 鈥� let them know it is okay to accept or decline. (Children often see adults as authority figures with whom they cannot disagree.) Also look for non-verbal signals that may express what a child is really feeling about participating.

Some children may have vulnerabilities, such as mental health issues, learning difficulties or physical health conditions. In order to establish their willingness to participate it is important to find out in advance from their parent and/or an expert how to communicate with the child or young person appropriately.

For all genres, where risks to a child contributor/contestant/child actor have been identified in relation to their contribution to 大象传媒 content, the parent/guardian should be provided with relevant information about those risks and any steps that will be taken to mitigate them. It is helpful to keep written records of discussions with the parent/guardians of contributors before filming, in addition to informed consent in writing.

(See Guidance: Interacting with Children and Young People Online)

It is important to explain any possible consequences to the child or young person too - including the potential negative impact of social media - and how these would be managed. Remember to make sure that parental consent is explicitly sought for social media use. There are social media guidelines templates for parents and young contributors on the Safeguarding site.[8] It may be relevant to give the programme title too, especially if it is contentious.

An easy to understand briefing/covering letter could be addressed to both the child and parent, along with the parental consent form. Or two briefing documents could be written鈥� one for the child, one for the parent. This will be necessary if there are any surprises planned for the child, as parents should be made aware of these. Any likely consequences of the contribution 鈥� both negative and positive - should also be made clear to both parties.

Briefing documents/covering letters to parents could also include:

• Practical details;
• Health and safety details;
• Inform parents that there is a child protection policy which staff should be compliant with. Staff should not ask for children鈥檚 personal details or offer their own details. 大象传媒/independent company contact details should be provided by staff. (For example programme email addresses or phone numbers, not individual email addresses. ) It should also be made clear that staff should not be placed in a caring or supervisory position. 

The standard child contributor release form is available on the Production Toolkit site.[9] There is more information on parental consents for different types of user contributions online in the Guidance Note on Interacting with Children and Young People Online.

(See Guidance online: Interacting with Children and Young People Online)

As part of our due care requirements, (See Editorial Guidelines Section 9 Working with Children and Young People: 9.1) for example where the nature of the content could be challenging or where the child/young person might have vulnerabilities, it is sometimes advisable to assess potential child or young people contributors psychologically as part of the pre-production/ selection process and sometimes to put in place expert psychological support throughout.

This assessment should be carried out by appropriately registered and qualified health professionals, for example psychologists, psychiatrists or psychotherapists, who, if possible, also understand how the media works, have experience of working with specific genres and child contributors and understand the potential impact on them. They should be contracted with a clear commitment to provide advice which is in the best interests of the child irrespective of whom they are contracted to. They can advise both the content-makers and the parent or guardian about the impact 鈥� if any 鈥� of taking part. They can advise on specific risks and, where relevant, how to support the child/young person and minimise any negative impact on them.

There is more information on this from 大象传媒 Safety Security and Resilience in the Guidance on the use of External Psychological Specialists for 大象传媒 Programmes; and Psychological Well-Being: Guidance for Protecting Contributors.[10] An assessment after recording, and ongoing support after transmission may also be appropriate and should be proportionate with clear timescales and commitments. 

However, even after seeking professional advice, it remains the 大象传媒鈥檚 responsibility to choose whether to go ahead with a particular contributor.

The Impact of a Contribution

We should consider whether a contributor/contestant/child actor might be regarded as being at risk of significant harm as a result of taking part in 大象传媒 content. We should conduct a 鈥渃ontributor due care鈥� risk assessment to identify any risk of significant harm to the contributor, unless it is justified in the public interest not to do so. 

(See Guidance online: Working with Vulnerable Contributors or Contributors at Risk of Vulnerability) 

Remember, the welfare of under-18s must take priority over any editorial requirement. 

(See Editorial Guidelines Section 9 Working with Children and Young People as Contributors: 9.1) 

Even when we have secured parental consent, we must consider carefully the impact and possible consequences of any content that involves a child or young person, at all stages of the production process, including the period after transmission and any availability online, and must put appropriate measures in place where necessary. 

(See Editorial Guidelines Section 9 Working with Children and Young People as Contributors: 9.3.21-9.23)

We should think about the story we want to tell and how to do it in a way that is not detrimental to the child, either at the time, or afterwards. Think about what is appropriate to put into the public domain.

When children feature in our output in a way that potentially infringes their legitimate expectation of privacy, we should normally gain the child鈥檚 assent wherever possible as well as the informed consent or parent, legal guardian or other person of 18 or over acting in loco parentis.

(See Editorial Guidelines Section 7 Privacy: 7.3.7)

In some circumstances it may be appropriate throughout the production to retain an expert for assessment and support.

(See Informed Consent above for more on psychological assessments)

Where a child or young person has a vulnerability or may be at risk of vulnerability, any additional needs should be identified at the planning stage and appropriate measures embedded, such as adjustments and support, to ensure an inclusive approach is taken. Advice can be sought from the family of the contributor and relevant experts and organisations.

There is more on working with vulnerable contributors or contributors at risk of vulnerability in the relevant editorial policy guidance note.

(See Guidance: Working with Vulnerable Contributors or Contributors at Risk of Vulnerability)

With sensitive content, in addition to any expert opinion, it can be advisable to speak to the head teacher of the child鈥檚 school for an opinion from someone who knows the child well as to whether it could harm the child if they become involved or are identified in the project. If the child does take part and the head teacher knows about it, the head can also keep an eye out in case there are any issues post-transmission in the school environment.

Different genres and formats present different challenges regarding due care to children and young people. Children and young people with vulnerabilities may face additional challenges.

Where a child is portrayed negatively in a factual or entertainment piece we need to think about filming their redemptive journey - if there is one. There may be some cases with no positive story to tell and we should consider whether it is in the interests of the child to broadcast them at all. The more constructed the format, the greater the responsibility we have to give a child the chance to redeem themselves in the story.

Clearly we must not mislead the audience 鈥� we should tell true stories - but we must not do this at the expense of the child.

Where conflict or highly emotional situations may be involved, big surprises could cause harm or distress, especially in live or as live programmes. (An example might be where a child is unexpectedly reunited with an absent parent, live on air.) The impact on children and young people of pranking for entertainment purposes must also be considered.

In scripted output it may be appropriate to create a redacted script and for the child or young person not to be present at read-throughs. It is important to consider what details should be given to the child about the full nature of the drama and what language should be used to describe it, in order not to cause distress, yet allow them to give their assent. The age of the child and nature of the content must be considered. Make sure parents are fully aware of the content and have seen a script before agreeing to the child鈥檚 participation.

Consider the impact on young actors and contributors of witnessing or participating in activities that could have a negative psychological effect on them and of being asked to take part in activities that are not appropriate for their age, for example, wielding a weapon or smoking a cigarette. Young children have difficulty understanding what is 鈥渁cting鈥� and what is real.

To help a child actor differentiate between acting and real life it is useful to explain the technical aspects of how things are done. For example in a television drama with adult themes where a child actor might witness some violence, they can be shown certain props are fake so that the actor is not hurt 鈥� anything to help them separate reality and artifice.

We should consider what repercussions there may be to a young actor in a drama with adult themes after it is broadcast. It is necessary to have protocols in place to ensure children and their peers do not view productions if they are post-watershed. Don鈥檛 forget to liaise with experts if appropriate and keep parents posted if things change materially between agreement and recording, and recording and broadcast.

With some content it may be necessary to advise young people to come off social media platforms during the period of transmission to avoid potentially negative and upsetting comments. The social media guidelines templates for parents and young contributors on the Safeguarding site [11] may be helpful.

When working with children and young people from vulnerable backgrounds or environments we should consider any potential reprisals or consequences that they or their wider family may face as a result. In these circumstances it may be advisable to contact local area experts to determine any associated risks during and after production. Examples of local area experts might be a youth offending worker, a police gang officer or a youth worker.

Another concern is where contributors or actors may emulate an activity which is controlled in a production but which in real life would be dangerous for them to participate in. For more on imitative behaviour see the Editorial Guidelines Section 5 Harm and Offence.

(See Editorial Guidelines Section 5 Harm and Offence:  5.3.49-51)

Children involved in competitions or game shows may become stressed or upset if not cared for appropriately, so we should make plans that minimise stress and support the contestants.

We should also consider how to make sure that the audience are aware that we have not been cavalier about the welfare of contributors or actors. For example, in editing entertainment programmes to give the impression of added jeopardy; it is easy to give the false impression that children have been put under extreme stress, which would be misleading to an audience.

We should put suitable measures in place to mitigate the risk of the audience being caused offence by the treatment of people who appear to be put at risk of significant harm as a result of their taking part in a programme. For example, this might involve signposting that the contributor was not put at risk of significant harm in voice over and/or caption or by other editorial inclusions which may show elements of care provisions such as a shot of a conversation with a partner, family member or a member of the welfare team offering support where this is justified editorially by the nature of the content.

It is good practice, and in some sensitive cases strongly advisable, to keep a record of procedures, risk assessments and contingencies. 

Appropriate behaviour with children and young people

We want the experience of working with the 大象传媒 to be a good one for children 鈥� to do otherwise could distress a child. We should follow the 大象传媒 Code of Conduct for working with children and young people at the 大象传媒.[12]

In all dealings with young contributors and actors, clarity is key. Always make sure the child and parents understand what is planned (see 鈥淚nformed Consent鈥� above). Make sure the potential long-term consequences of participation are explained and never make promises that cannot be kept. Being clear about intentions is especially important on a long-term project, as a working relationship is built up with a family or child, especially if any of the contributors are vulnerable.

We also need to make it clear to external organisations what we expect from them, for example that we do not expect them to leave us unsupervised in a class of children. When visiting an external organisation that works with children, it is important to take suitable identification. The organisation may request us to provide a criminal records check and complete training prior to attending their site. A line manager should be aware of the visit, so that the organisation can check authenticity, if they wish to.

We should think about appropriate behaviour with children, beginning at the research stage. Wherever possible liaise with the parents/school for contact information and use a 大象传媒/independent company contact address, email or phone number, especially for any contact with children. It is important to use an office number even if own mobiles are normally used for work calls. Do not give out personal mobile numbers to a child or young person.

If the only way to contact a child or young person is to approach them directly, we should consider the most appropriate method. The contact should be made using an official method (see above) . We should ask the child to ask their parent to get in touch and should not normally have direct contact with them at this stage. It is not normally appropriate to use social media to contact a contributor who is a child or young person under 16, or a young person who is 16 or 17, where there are due care considerations that would make this inappropriate, such as when the content is sensitive or where the contributor could be considered vulnerable.

If we are considering contacting a child who is 13 or above via social media it should be discussed in advance with a senior editorial figure, who may wish to consult Editorial Policy.

(See Guidance online: Interacting with Children and Young People Online)

We normally aim to work with children in the presence of those responsible for their supervision, although circumstances may vary.

(See Editorial Guidelines Section 9 Working with Children and Young People as Contributors: 9.3.22)

It is sensible to provide a single, consistent point of contact on the production team, someone who can also oversee the contributor or actor鈥檚 welfare throughout and with whom the participant and parents can liaise with throughout production.

When working with children or young people, avoid entering a room where they may be changing their clothes or not fully dressed. If it is vital to speak to the child, make sure another adult is present. Do not initiate physical contact 鈥� this can obviously be innocently intended but it can easily be misunderstood. However, if a child comes to an individual , or is in distress, act responsibly and in public.

If physical contact is necessary, for example by a make-up artist or by a sound engineer attaching a radio microphone, ensure the child is accompanied by a chaperone and that doors are kept open. Where possible, this should be within the hearing of others. Any contact should also be age appropriate, the child鈥檚 permission should be asked beforehand and it should be explained what is proposed and why it is necessary.

A child should never be made to feel uncomfortable or pressurised in any way. Make sure that the child and young person continues to feel comfortable with their participation throughout and that their dignity is always maintained. Their wishes should be respected if they change their mind. If necessary put in place a system to enable them to do so, such as a hand signal. Never engage in or endorse any bullying or harassment of a child. Make sure inappropriate language is not used in front of a child.

The 大象传媒 can play a part, where appropriate, in providing positive role models of disabled children. Vulnerable children and young people may have additional welfare requirements, and not just those with obvious physical or mental health conditions. Even minor learning difficulties or non-visible health conditions may mean the child/young person requires some adjustments/ accommodation in order to participate in the programme. As mentioned above in The Impact of a Contribution, it is important to plan in advance for any additional needs. Family and relevant experts and organisations can be involved for advice including about details of relevant protocols to follow.

(See Guidance online: Working with Vulnerable Contributors or Contributors at Risk of Vulnerability)

It is also important that all production staff, crew and on screen talent are briefed appropriately so that they put any child鈥檚 welfare first. In a drama with adult themes, where there is strong language and action on set, make sure this does not spill over off set.

(See above: The Impact of a Contribution)

Training should be given to staff who have little experience of working with children. 

Aftercare

Aftercare is important. Any aftercare needs to be proportionate to the ongoing risks identified and have clear boundaries and time frames.

An agreed plan should be drawn up with an outline of how aftercare will be delivered and for what period of time it should be available. This aftercare plan may need to be adjusted if any contributor develops a vulnerability during the production. It should be signed off by production commissioning and the 大象传媒 who may consult Editorial Policy.

This plan may involve a member of the team, preferably the main contact, keeping in touch with the contributor and their family to monitor any specific after-effects that might have resulted from the child鈥檚 participation. However, we should consider the consequences of continuing a relationship or communication beyond the recording/event. A vulnerable child/family may seek a production member out for further, ongoing, support which could place them in a difficult position. In some cases, providing access to sources of professional help or support may be advisable. A psychological assessment after recording, and ongoing support after transmission may be appropriate. 

(See above: Informed Consent for more detail on psychological assessments and see Guidance online: Working with Vulnerable Contributors or Contributors at Risk of Vulnerability) 

If a child鈥檚 contribution has evolved during post-production, it may be advisable to let them and their parent know prior to transmission.

There may be some very sensitive content where it could be appropriate for the 大象传媒 to limit the period of time that the programme should be repeated for.

However, the contributor and their parents should be made aware that third party websites may reproduce our content globally without our knowledge or consent.

[1] See : available on Gateway for 大象传媒 staff or via commissioning editors for independent producers

[2] See : available on Gateway for 大象传媒 staff or via commissioning editors for independent producers 

[3] See or via commissioning editors for independent producers 

[4] See : available on Gateway for 大象传媒 staff or via commissioning editors for independent producers 

[5]   

[6]    

[7] See : available on Gateway for 大象传媒 staff or via commissioning editors for independent producers<

[8] See the : available on Gateway for 大象传媒 staff or via commissioning editors for independent producers

[9] See : available on Gateway for 大象传媒 staff or via commissioning editors for independent producers.

[10] See Guidance on the use of External Psychological Specialists for 大象传媒 Programmes And Psychological Well-Being: Guidance for Protecting Contributors from 大象传媒 Safety Security and Resilience 

[11] See the : available on Gateway for 大象传媒 staff or via commissioning editors for independent producers

[12]  

Last updated April 2022

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