Ofcom Watch

Ofcom has welcomed two new members to its board, after the Secretary of State for Digital, Culture, Media and Sport (DCMS) confirmed the appointment of Maggie Carver and Dr Angela Dean.

Maggie is currently Chairman of the British Board of Film Classification and the Racecourse Association. Starting her career in investment banking, Maggie has held a number of roles within the media industry - including sitting on the boards of ITN, Channel 5 and other organisations across the public, private and not-for-profit sectors. She was previously Managing Director of Channel 4 Racing, and worked on establishing the ITV franchise Meridian Broadcasting.

Dr Angela Dean was a financial analyst of European communications and technology companies for almost 20 years.?She was a managing director at investment bank Morgan Stanley, heading up its global technology research team; and also its Director for Socially Responsible Investment. She was previously a trustee of the Heritage Lottery Fund and a former member of the Museums, Archives and Libraries Council.

Ofcom has published a prospectus angling for a role as the UK internet censor. It writes:

Ofcom has published a discussion document examining the area of harmful online content.

In the UK and around the world, a debate is underway about whether regulation is needed to address a range of problems that originate online, affecting people, businesses and markets.

The discussion document is intended as a contribution to that debate, drawing on Ofcom's experience of regulating the UK's communications sector, and broadcasting in particular. It draws out the key lessons from the regulation of content standards 203 for broadcast and on-demand video services 203 and the insights that these might provide to policy makers into the principles that could underpin any new models for addressing harmful online content.

The UK Government intends to legislate to improve online safety, and to publish a White Paper this winter. Any new legislation is a matter for Government and Parliament, and Ofcom has no view about the institutional arrangements that might follow.

Alongside the discussion paper, Ofcom has published joint research with the Information Commissioner's Office on people's perception, understanding and experience of online harm. The survey of 1,686 adult internet users finds that 79% have concerns about aspects of going online, and 45% have experienced some form of online harm. The study shows that protection of children is a primary concern, and reveals mixed levels of understanding around what types of media are regulated.

The sales pitch is more or less that Ofcom's TV censorship has 'benefited' viewers so would be a good basis for internet censorship.

Ofcom particularly makes a point of pushing the results of a survey of internet users and their 'concerns'. The survey is very dubious and ends up suggesting thet 79% of users have concerns about going on line.

And maybe this claim is actually true. After all, the Melon Farmers are amongst the 79% have concerns about going online: The Melon Farmers are concerned that:

• There are vast amounts of scams and viruses waiting to be filtered out from Melon Farmers email inbox every day.
• The authorities never seem interested in doing anything whatsoever about protecting people from being scammed out of their life savings. Have you EVER heard of the police investigating a phishing scam?
• On the other hand the police devote vast resources to prosecuting internet insults and jokes, whilst never investigating scams that see old folks lose their life savings.

So yes, there is concern about the internet. BUT, it would be a lie to infer that these concerns mean support for Ofcom's proposals to censor websites along the lines of TV.

In fact looking at the figures, some of the larger categories of 'concern's are more about fears of real crime rather than concerns about issues like fake news.

Interestingly Ofcom has published how the 'concerns' were hyped up by prompting the surveyed a bit. For instance, Ofcom reports that 12% of internet users say they are 'concerned' about fake news without being prompted. With a little prompting by the interviewer, the number of people reporting being concerned about fake news magically increases to 29%.

It also has to be noted that there are NO reports in the survey of internet users concerned about a lack news balancing opinions, a lack of algorithm transparency, a lack of trust ratings for news sources, or indeed for most of the other suggestions that Ofcom addresses.

I've seen more fake inferences in the Ofcom discussion document than I have seen fake news items on the internet in the last ten years.

See also an article from vpncompare.co.uk which concurs with some of these concerns about the Ofcom survey.

Following an investigation, Ofcom has revoked the broadcast licence held by Ausaf UK Limited for Ausaf TV, a channel which was intended to serve the Pakistani community in the UK, but had not started broadcasting at the time of Ofcom's decision.

In line with our ongoing duty under the Broadcasting Act 1990, Ofcom opened an investigation into the licensee about whether those in control were 'fit and proper' to hold the licence.

After carefully considering all available evidence, including oral representations made by the licensee, our investigation concluded that:

• the individual in control of Ausaf UK Limited had close links to the Pakistan and UK editions of the Daily Ausaf newspaper, in which articles were published which we considered amounted to hate speech and incitement to crime/terrorist actions;

• the licensee provided misleading or false information about the links between the Daily Ausaf and Ausaf UK Limited during the course of our investigation; and

• there is a material risk that the licensee could breach our broadcasting rules; for example, by airing similar content to that published in the Daily Ausaf on Ausaf TV, which would be harmful to viewers if the licensee were permitted to broadcast; and

• this brings into question public confidence in the regulatory activity if Ofcom were to remain satisfied that the licensee was fit and proper to broadcast.

In light of these serious findings, we are no longer satisfied that that those in control of Ausaf UK Limited are fit and proper to hold a broadcast licence. We have therefore revoked the licence.

The channel had not started broadcasting, and it will now be prevented from doing so.

Bob's Breakfast
Bob FM, 4 May 2018, 08:40

Bob FM is a local commercial radio service for Hertford and its surrounding areas. The station's output consists of music and information aimed at listeners aged between 25 and 54.

We received a complaint about a segment broadcast during the station's daily breakfast programme, during which the presenter took call from a listener who identified the location of a vehicle with a mobile speed camera.

The listener described the person conducting the speed checks as a scumbag and said he was sat there like a little maggot. The presenter then said that this person was:

In the back of a van, catching hard-working, tax-paying people who are on their way to work206to earn their living, to take their place in society, to make a bit of a difference, to you know, help the economy of this country so they can earn a living to put a roof over their head and pay taxes. Those are the people that this maggot

Ofcom consider Rule 2.3 of the Code:

In applying generally accepted standards, broadcasters must ensure that material which may cause offence is justified by the context... Such material may include offensive language...[or] discriminatory treatment or language

The Licensee said that the language used was provocative and designed to be entertaining while empathising with listeners' frustration. It added that there was no assertion that the person in the speed camera van was a police officer or whether the van was unmanned.

Ofcom Decision

This two-minute segment called into question the actions of speed camera operators and their motivation for carrying out this function. The item contained six uses of the word maggot, two uses of the word maggotwatch and one use of the word scumbag to describe people who operate mobile speed cameras. The presenter and caller criticised their work, saying that its purpose was to generate revenue and that it caught innocent people.

In Ofcom's view, the language used in this segment was critical and derogatory and had the potential to cause offence. We took into account the Licensee's argument that there was no assertion that the people operating the speed cameras were police officers. However, in our view, listeners were likely to have understood the criticism as being directed at police officers in speed camera vehicles. We considered that this heightened the potential for offence. We also took into account the Licensee's submission that children were unlikely to be in the audience. However, our concern in this case was the potential offence to the audience generally rather than just children

Our Decision is that the offence caused by this segment was not justified by the context and in breach of Rule 2.3.

On Sex and violence, Ofcom writes:

The incidence of people finding something offensive on television has remained stable at 19% year on year, although over-64s are significantly more likely than all adults to say they have seen something offensive (28% vs. 19%).

Offensive language, sex/sexual content, discrimination and violence are cited as causing the most offence by more than a third of respondents. This is followed by nakedness and anti-social behaviour, both mentioned by almost a quarter of respondents.

Although a third of adults aged 16+ feel there is too much violence (34%) and too much swearing (33%) on TV, this has declined over time (from 43% and 40% in 2014 respectively). Adults aged 65+ are more likely to feel that there is too much of both. Around a quarter (26%) feel there is too much sex (down from 28% in 2014).

Ofcom have presented some long discussions when censuring several broadcasters. Here is just the most brief summary of each

 

The Healing School
Loveworld Television Network, 10 November 2017, 06:30 and 10:00

Loveworld Television Network is a religious channel. During routine monitoring, Ofcom identified two episodes of the series The Healing School. These programmes outlined the experiences of several people who had attended events at The Healing School, which, according to its website1, is a healing ministry of Rev. Chris Oyakhilome (Ph.D) which takes divine healing to the nations.

Ofcom have little faith in faith healers and censured the channel for not suggesting that the people would be better advised to consult a doctor rather than a faith healer:

In its representations the Licensee stated that faith based healing/miracles is a fundamental principle of the Bible which many practising Christians of various denominations believe in and the Bible is not classified as an offensive or harmful material therefore the practice or expression of faith as taught by Jesus Christ who Himself performed many miracles and healings as taught by the Bible in our view is not harmful or offensive. It is not Ofcom's role to question viewers' religious beliefs, nor caution against any particular religious teaching. However, all broadcasters are subject to the Code, regardless of their religious stance. Ofcom's duty is to ensure all members of the public watching television (whether people of faith or not) are provided with adequate protection from potentially harmful material. The nature of faith and the right to freedom of religion does not mean that religious broadcasters are at liberty to broadcast content that poses a potential risk to viewers, especially viewers who are potentially vulnerable (for example, because of their own health or medical circumstances), without adequate protection.

Our guidance suggests that one approach commonly used by broadcasters with a view to protecting audiences against potentially harmful material is to include a warning, for example advising viewers or listeners to consult a qualified medical practitioner before making decisions based on the programme. No such warning or advice appeared in these programmes.

The Alex Salmond Show
RT, 16 November 2017, 07:30

The Alex Salmond Show is a political and current affairs series hosted by the former First Minister of Scotland, Alex Salmond and produced by his own production company.

Ofcom received a complaint about the first episode of the new series alleging that the programme invented tweets presented as real from viewers of the show to direct the debate on his views and terms. The complainant suggested that this enabled Alex Salmond to pretend that he was merely answering questions from concerned viewers about Brexit rather than trying to control the debate....

Ofcom decided that this was a fair cop and censured Salmond accordingly.

Bible ki Nabouat: The Prophecy of the Bible
Glory TV, 10 January 2018, 16:00

Glory TV is a religious, digital television channel serving Indian and Pakistani Christian communities in the UK. The licence for Glory TV is held by Glory TV Limited (Glory TV or the Licensee).

During routine monitoring, Ofcom identified the one-hour programme, Bible ki Nabouat 203 The Prophecy of the Bible. As the programme was broadcast mainly in Urdu, Ofcom translated the content into English.

In this programme, which was originally broadcast in 2014, two presenters interpreted the Biblical books of Daniel, Ezekiel, Zechariah and Matthew. They said:

The prophecy we are looking at today is based on a period of seven years. When will this period start and what will be the signs? That is what we will look at today. There are many who know that Lord Jesus will return, that there will be war, that there will be a need to call the 666 number of the devil, that we will have 1,000 years with Lord Jesus, that Iblis [meaning Satan] will be thrown into the fire. They know there will be a fake prophet. However, what will be the system or method?""

The presenters then proceeded to assert that the Israel/Palestine conflict fulfils the pre-requisites for the war of the prophecy. However in arguing that the conflict fit the bill, the presenters managed to offend the sensitive souls on both sides of the conflict.

While the comments in this programme were made through the prism of Biblical prophecy, in our view, they portrayed the Arab world and all Arab people as susceptible to the influence of the Antichrist. They also portrayed all Arab people as hating Jewish people to the extent that they would be prepared to persecute them. The comments also portrayed a negative future for Israel, in which the Antichrist would stand in the new Jewish Temple and in which Jewish people would suffer another holocaust. Ofcom recognised the primary audience for this channel is Indian and Pakistani Christian communities in the UK. However, in our view the discriminatory and potentially offensive nature of these comments was likely to have exceeded audience expectations. Further, the wider audience of British Muslim people, who share the same faith as many people in the Arab world was likely, in our view, to have been highly offended by the comments about and characterisation of the Arab world and people in this programme.

Jago Pakistan Jago
HUM Europe, 15 March 2018, 10:00

HUM Europe is a general entertainment channel that serves the Pakistani community in the UK, broadcasting in Urdu.

Ofcom received three complaints about racially offensive material.

We identified a section of the programme where make-up artists taking part in a competition were set the task of applying make-up to models live on the programme. The first part of the task required the contestants to make the models’ skin tone appear darker.

Ofcom considered that specific terms used to refer to the darker skin tone had the potential to offend. These included three uses of the word negro: This stick is called Negro; make sure that you use the Negro skin tone; and it gave him a real Makrani [black] colour or Negro skin tone -- whatever you call it.

Ofcom were offended by the word 'negro' and noted:

We acknowledged that in the first two instances in this broadcast, the word was likely to be the manufacturer's name for the particular shade of make-up being used. However, this was not obviously the case in the third instance.

Ofcom censured the channel accordingly but it rather sounds that the offending word is a practical term used in the make up industry.

Free Jaggi Now
KTV, 6 January 2018, 21:30

KTV is a religious and cultural channel aimed at the Sikh community in the UK and Europe, broadcasting in Punjabi and English.

Free Jaggi Now was a current affairs programme covering the arrest of Jagtar Singh Johal (“Jaggi”)1, a UK citizen arrested in India on 4 November 2017, and detained in the State of Punjab.

We received a complaint that the programme included statements promoting “separatism” in India.

This 55-minute programme focussed on support for the ‘Free Jaggi now’ campaign. It included a discussion about the alleged torture of Jaggi by India’s National Intelligence Agency (“NIA”) during his interrogation and detention, the alleged restriction on Jaggi receiving consular assistance and an independent medical report following allegation of torture, and allegations about corruption in the Indian judiciary.

The long winded censure by Ofcom revolved around a lack of balance in the programme.

We took into account that the programmes broadcast on KTV were mostly of interest to the Sikh community in UK. Ofcom also acknowledged that the target audience for this programme consisted of members of the UK South Asian community, who may have already been aware of Jaggi's arrest and detention in India. However, we considered that these contextual factors did not mitigate the need to ensure that due impartiality was preserved in the absence of sufficient alternative viewpoints and/or challenge to the critical views expressed about the policies and actions of the Indian authorities.

Sharon White, the CEO of Ofcom has put her case to be the British internet news censor, disgracefully from behind the paywalled website of the The Times.

White says Ofcom has done research showing how little users trust what they read on social media. She said that only 39% consider social media to be a trustworthy news source, compared with 63% for newspapers, and 70% for TV.

But then again many people don't much trust the biased moralising from the politically correct mainstream media, including the likes of Ofcom.

White claims social media platforms need to be more accountable in how they curate and police content on their platforms, or face regulation.

In reality, Facebook's algorithm seems pretty straightforward, it just gives readers more of what they have liked in the past. But of course the powers that be don't like people choosing their own media sources, they would much prefer that the BBC, or the Guardian , or Ofcom do the choosing.

Sharon White, wrote in the Times:

The argument for independent regulatory oversight of [large online players] has never been stronger.

In practice, this would place much greater scrutiny on how effectively the online platforms respond to harmful content to protect consumers, with powers for a regulator to enforce standards, and act if these are not met.

She continued, disgracefully revealing her complete contempt of the British people:

Many people admit they simply don't have the time or inclination to think critically when engaging with news, which has important implications for our democracy.

White joins a growing number of the establishment elite arguing that social media needs cenorship. The government has frequently suggested as much, with Matt Hancock, then digital, culture, media and sport secretary, telling Facebook in April:

Social media companies are not above the law and will not be allowed to shirk their responsibilities to our citizens.

Update: The whole pitch to offer Ofcom's services as a news censor

15th July 2018. See Sunday Times article republished by Ofcom from ofcom.org.uk

Ofcom has published Sharon White's pitch for Ofcom to become the internet news censor.

White is nominally commenting on two research reports:

• Scrolling news: The changing face of online news consumption A report for Ofcom [pdf] (It's actually very interesting and well presented)
• The changing world of news: Qualitative research [pdf]

There seems to be 4 whinges about modern news reading via smart phones and all of them are just characteristics of the medium that will never change regardless of whether we have news censors or not.

1. Fake News: mostly only exists in the minds of politicians. No one else can find hardly any. So internet news readers are not much bothered by trying to detect it.
2. Passive news reading. Its far too much trouble typing in stuff on a smart phone to be bothered to go out and find stuff for yourself. So the next best thing is to use apps that do the best job in feeding you articles that are of interest.
3. Skimming and shallow reading of news feeds. Well there's so much news out there and the news feed algorithm isn't too hot anyway so if anything isn't quite 100% interesting, then just scroll on. This isn't going to change any time soon.
4. Echo chambers. This is just a put-down phrase for phone users choosing to read the news that they like. If a news censor thinks that more worthy news should be force fed into people's news readers than they will just suffer the indignity of being rapidly swiped into touch.

Anyway this is Sharon White's take:

Picking up a newspaper with a morning coffee. Settling down to watch TV news after a day's work. Reading the sections of the Sunday papers in your favourite order.

For decades, habit and routine have helped to define our relationship with the news. In the past, people consumed news at set times of day, but heard little in between. But for many people, those habits, and the news landscape that shapes them, have now changed fundamentally.

Vast numbers of news stories are now available 24/7, through a wide range of online platforms and devices, with social media now the most popular way of accessing news on the internet. Today's readers and viewers face the challenge to keep up. So too, importantly, does regulation.

The fluid environment of social media certainly brings benefits to news, offering more choice, real-time updates, and a platform for different voices and perspectives. But it also presents new challenges for readers and regulators alike -- something that we, as a regulator of editorial standards in TV and radio, are now giving thought for the online world.

In new Ofcom research, we asked people about their relationship with news in our always-on society, and the findings are fascinating.

People feel there is more news than ever before, which presents a challenge for their time and attention. This, combined with fear of missing out, means many feel compelled to engage with several sources of news, but only have the capacity to do so superficially.

Similarly, as many of us now read news through social media on our smartphones, we're constantly scrolling, swiping and clearing at speed. We're exposed to breaking news notifications, newsfeeds, shared news and stories mixed with other types of content. This limits our ability to process, or even recognise, the news we see. It means we often engage with it incidentally, rather than actively.

In fact, our study showed that, after being exposed to news stories online, many participants had no conscious recollection of them at all. For example, one recalled seeing nine news stories online over a week -- she had actually viewed 13 in one day alone. Others remembered reading particular articles, but couldn't recall any of the detail.

Social media's attraction as a source of news also raises questions of trust, with people much more likely to doubt what they see on these platforms. Our research shows only 39% consider social media to be a trustworthy news source, compared to 63% for newspapers, and 70% for TV.

Fake news and clickbait articles persist as common concerns among the people taking part in our research, but many struggle to check the validity of online news content. Some rely on gut instinct to tell fact from fiction, while others seek second opinions from friends and family, or look for established news logos, such as the Times. Many people admit they simply don't have the time or inclination to think critically when engaging with news, which has important implications for our democracy.

Education on how to navigate online news effectively is, of course, important. But the onus shouldn't be on the public to detect and deal with fake and harmful content. Online companies need to be much more accountable when it comes to curating and policing the content on their platforms, where this risks harm to the public.

We welcome emerging actions by the major online players, but consider that the argument for independent regulatory oversight of their activities has never been stronger. Such a regime would need to be based on transparency, and a set of clear underpinning principles.

In practice, this would place much greater scrutiny on how effectively the online platforms respond to harmful content to protect consumers, with powers for a regulator to enforce standards, and act if these are not met. We will outline further thoughts on the role independent regulation could play in the autumn.

When it comes to trust and accountability, public service broadcasters like the BBC also have a vital role to play. Their news operations provide the bedrock for much of the news content we see online, and as the broadcasting regulator, Ofcom will continue to hold them to the highest standards.

Ofcom's research can help inform the debate about how to regulate effectively in an online world. We will continue to shine a light on the behavioural trends that emerge, as people's complex and evolving relationship with the media continues to evolve.

And perhaps if you have skimmed over White's piece a bit rapidly, here is the key paragraph again:

In practice, this would place much greater scrutiny on how effectively the online platforms respond to harmful content to protect consumers, with powers for a regulator to enforce standards, and act if these are not met. We will outline further thoughts on the role independent regulation could play in the autumn.

Ofcom has received more than 2,500 complaints over Sunday night's episode of Love Island.

The complaints are directly related to a scene where Dani Dyer is shown a misleading video about the fidelity of boyfriend Jack Fincham. The couple were put in separate villas, after the boys and girls were split up as part of a plot twist.

Viewers took to Twitter to criticise the scene, with some saying the show was not considering the mental health of contestants.

A spokeswoman for Ofcom confirmed that there had been 2,525 complaints in total relating to Dani being shown the video of Jack. She added the rather disinterested comment:

We are considering these complaints against our broadcasting rules, before deciding whether or not to investigate. The number of complaints is irrelevant - Ofcom will investigate if it considers a broadcaster or service provider may have breached its codes.

Update: Final tally

16th July 2018. See article [pdf] from ofcom.org.uk

And indeed Ofcom reported that they consigned 2644 complaints about Love Island straight into the waste paper bin.

There's plenty of fine words in Ofcom's latest Annual report covering the 12 months up until March 2018.

Particularly prevalent are comments about diversity, obviously a big thing at Ofcom. They speak of programming for diverse audiences, diversity targets for employment in the TV and radio industry, and diversity targets for their own staff. It is clearly commendable that they have set themselves aggressively short time scales to sort out their own diversity, but is seems a little ironic that the only way they can achieve this is by the blatant discrimination against white men, by refusing to employ any of them for 2 or 3 years.

Diversity also features prominently in Ofcom's summary of broadcasting sanctions for the year, albeit with a distinctly non-diverse commonality:

Our Broadcasting Code includes rules which prohibit the broadcast of material that is likely to encourage or incite crime or disorder. This is a critically important duty and we have taken robust enforcement action against broadcasters for serious breaches of our rules, involving hate speech and material likely to incite crime or disorder.

In the most serious case, we found that the licence holder for Iman FM was not a fit and proper licensee and we revoked its broadcast licence. This community radio station in Sheffield broadcast lectures by a radical Muslim cleric which contained material likely to incite crime, hate speech and justified in tolerance towards non-Muslim people.

We also fined Ariana International £200,000, Kanshi Radio £17,500,and Radio Dawn £2,000 for serious breaches of our rules in this area.

Ofcom does not mention other censorship issues much beyond repeatedly claiming that they are protecting people from harm (by not letting them watch what they want to watch).

Perhaps the most hopeful section of the report is that Ofcom look set to allow more adult content to be broadcast before the watershed when PIN technology is available as an alternative to waiting until bedtime. Presumably British TV companies are rather seeing their narrow post watershed time slot as a little unfair when US internet TV services, notably Netflix and Amazon Prime can sell their programmes throughout the day.

Ofcom writes:

In March 2018 we published a consultation seeking stakeholder views on a proposal to extend the mandatory daytime protection rules in the Code beyond premium subscription and pay-per-view film channels, so that programmes which can currently only be shown after the 9pm watershed could be shown on scheduled television channels at any time of day, provided that a mandatory PIN protection is in place.

To inform this work, we commissioned research on family viewing habits and audience awareness, use of and attitudes towards PIN systems. This research report was published alongside the consultation.

The consultation set out Ofcom's view that the proposed extension of the rules in this area would enable the Code to reflect the evolving viewing habits of TV audiences, and would allow adults to have increased choice in daytime viewing. Importantly, our proposal would not affect the 9pm watershed, which is a trusted and fundamental feature of broadcast regulation that continues to ensure protection for children.

We are currently considering stakeholder responses and expect to publish a statement in summer 2018.

Suddenly It's Spring
That's Oxford, 17 March 2018, 11:20

That's Oxford is a local television service for Oxford and the surrounding area.

Suddenly It's Spring was a children's cartoon made in 1944, featuring the doll Raggedy Ann setting out on a mission to ask the Sun to shine on her poorly owner. On her journey she was shown asking other weather elements, Mr Cloud, Mr Breezy and Mr Zero to assist her.

Ofcom received a complaint that the character of Mr Cloud was depicted as an offensive and outdated racial stereotype of a black person. Mr Cloud was depicted in the cartoon as a black person from the deep south of America with exaggerated facial features. In addition, he was portrayed as indolent with slow, slurred speech.

Ofcom considered:

• Rule 1.3: Children must206be protected by appropriate scheduling from material that is unsuitable for them206.

• Rule 2.3: In applying generally accepted standards broadcasters must ensure that material which may cause offence is justified by the context206Such material may include, but is not limited to, ...humiliation, distress, violation of human dignity, discriminatory treatment or language (for example on the grounds of...race....

The Licensee accepted that the cartoon contained a racial stereotype that was likely to cause offence and apologised for any offence caused.

Ofcom decision

Ofcom considered whether the characterisation of Mr Cloud in this cartoon was unsuitable for children. In Ofcom's view the exaggerated facial features and indolent nature of the character reinforced an outdated, pejorative and harmful racial stereotype of a black person which was not suitable for children to view.

Rule 2.3 states that in applying generally accepted standards broadcasters must ensure that potentially offensive material is justified by the context. Context includes, but is not limited to, editorial content of the programme, warnings given to listeners, the time of the broadcast and the likely expectation of the audience.

We first considered whether this content was potentially offensive. Given this cartoon included a negative stereotype of a black person, which reinforced racial prejudice, Ofcom was of the view that this material was also highly offensive.

We next considered whether there was sufficient context to justify any potential offence. We acknowledged this cartoon dated from 1944 when there were very different attitudes towards portrayals of race and when race discrimination was prevalent. We also accepted that with the appropriate level of context such archive material may still be broadcast. However, in our view UK audiences today would find such racial stereotyping highly unacceptable and out of step with generally accepted standards as it was broadcast in this case. Therefore, the broadcast of this offensive content without a warning or any other context was also a breach of Rule 2.3.

Breaches of Rules 1.3 and 2.3