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Church opposes on-air appeals to fund TV

16 June 2006

 

The Church of England has opposed any relaxation of the rules against on-air appeals to fund television programmes in its submission to an Ofcom consultation on lifting the ban.

The submission, made by The Rt Revd Nigel McCulloch, Bishop of Manchester, senior spokesman for the Church of England on communications policy, explains that there remains "some discomfort within the Church" over a change which it sees as potentially detrimental to broadcasting in the UK.

The ban applies to television but not radio and the Church argues that different rules for the two media are justified.

Television appeals using emotive or misleading language and images have a clear potential for exploiting viewers' sensitivities, the submission argues. This is particularly the case with religious programming.

The submission advocates proven alternative fundraising methods, such as raising money through subscription, websites or literature. These, it contends, are less likely to exploit viewers or damage editorial independence.

The Church also voices concern that any safeguards introduced with on-air appeals would be very complex to oversee. "Audience susceptibility and editorial independence both need to be protected. It is difficult to see how Ofcom could introduce cost-effective and sufficiently strong safeguards consistent with Ofcom's light-touch role," it says.

On the possible financial benefits of lifting the ban, it adds: "At best there is only a marginal case that the ban should be lifted for financial reasons based on Ofcom's conclusion that on-air appeals would raise relatively little money."

 

 

The full submission appears below:

 

Television Appeals for Donations to Make Programmes or Fund Services

Consultation Response from The Rt Revd Nigel McCulloch, Bishop of Manchester

Senior Spokesman for the Church of England on Communications Policy

 

There is some discomfort within the Church of England over any relaxation of the rules about on-air fundraising. This has potential to be detrimental for broadcasting in the UK:

• There is clear potential for exploiting viewers’ sensitivities through appeals using emotive or misleading language and images. This is particularly the case with religious programming.
• Images on television have greater emotional impact than radio transmissions, confirming the need for regulating on-screen appeals. Although radio and television can now be received through the same platform, (e.g. Freeview TV or PC) they remain distinct media and should be treated as such.
• Editorial independence can be compromised if a specific programme is paid for by on-air fundraising. This linkage may not always be clear to viewers.
• The financial benefits of taking this controversial step have yet to be proved.
• Alternatives, such as fundraising through subscription, websites or literature are preferable. They are less likely to exploit viewers or damage editorial independence.
• Viewers should be allowed to make considered and informed decisions to give money, away from the urgent influence of images on television.

If the ban were lifted:

• Extra regulation would be needed to safeguard editorial independence and to protect viewers from exploitation. This is likely to be both complex to draft and administer and would require significant resourcing from Ofcom.
• Ofcom may have powers to introduce appropriate safeguards, but the scope of the possible provisions would not be consistent with its light-touch role.
• The cost of safeguards would fall on broadcasters and regulators and therefore ultimately on the viewer, who pays twice.

[Q1. broadcasters only] 

Q2. Do you agree with the assessment of the role of television appeals in terms of a source of funding? If not, it would be helpful to have your own assessment with as much supporting information as possible.

Q3. Do you agree with the assessment of competition issues?

At best there is only a marginal case that the ban should be lifted for financial reasons based on Ofcom’s conclusion that on-air appeals would raise relatively little money (para 4.5). The case is further weakened by para 4.14’s suggestion that on-air appeals might well not provide a channel’s main source of income. Channels would have to raise funds from multiple sources, and on-air appeals would bring extra costs for broadcasters and regulators. For example, a religious channel that currently raises money through building relationship with its audience would probably be better off continuing to raise money through subscriptions, websites and offering literature.

On mainstream channels, allowing on-air appeals would devalue public service broadcasting, particularly if fundraising is aimed at particular programmes or services. This could create two tiers of programmes, those which receive funding as a right, and those which only get to air if they are funded. This would be divisive for public service broadcasting.

The key market distortion risk is that it would be the programmes with the best TV fundraisers that would get on-air – not necessarily the best programmes.

 

Q4. What are your views on the possible safeguards to protect viewers and maintain editorial independence outlined? Do you think that some or all of these should be applied if the ban is lifted? Are there other safeguards which you would like to see?

Ofcom’s rejection of the option to lift the ban without introducing any new safeguards is welcome. So is Ofcom’s recognition that television viewers need stronger protection from the greater impact of televised images.

Audience susceptibility and editorial independence both need to be protected. It is difficult to see how Ofcom could introduce cost-effective and sufficiently strong safeguards consistent with Ofcom’s light-touch role.

To be effective, safeguards would need to reduce the risk of harm to viewers while allowing fundraising. They would need to limit harm before transmission rather than merely being reactive. They must be sufficiently flexible to still be viable in the future when an increasing number of channels may wish to broadcast on-air appeals.

The consultation document suggests that the safeguards that are sufficiently strong are too onerous and those that are light-touch are not particularly strong. Strong measures will also be expensive to run. Further costs for Ofcom or broadcasters are likely to fall ultimately on viewers - effectively taxing their donations.

Safeguards examined in detail

• Section 10.16 of the Broadcasting Code (para 5.4) is about the purpose, amount and treatment of donations, but it does not control what is done to raise money.
• If the ban is to be lifted, appeals should be restricted to registered charities as they also come under the regulation of the Charity Commissioners.
• Self-regulation through a code of practice would need significant monitoring and enforcement. Many abuses could continue unreported.
• Cross-referring s 10.15 of the Broadcasting Code, about the exploitation of audience susceptibilities would be a preferable solution to self-regulation. Susceptibilities are not solely religious. This provision, if deployed, ought to extend to all channels.
• Where religious susceptibilities are concerned, it is right to exclude claims that making a donation will yield a miracle cure. But a programme made by an organisation that appealed for funds because it believed miracles did sometimes happen might be harder to exclude without denying its adherents the right to manifest their religious beliefs.
• Editorial independence is compromised in the mind of the viewer once payment for specific programmes or services is accepted
• The partial lifting of the ban for local, religious and niche channels would be preferable to a general lifting on all channels. Vulnerable viewers are open to exploitation from wherever the appeal comes.

Annex 5 - Q5. Taking the above into account, are you in favour of the ban on appeals being lifted with certain safeguards or would you prefer that it remained in place?

 

There is still discomfort in the Church of England with the idea of the ban being lifted. The benefits are few, the risks are many. Levelling the playing field with overseas unregulated broadcasters would be detrimental to UK broadcasting.

 

 

 

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