Open Broadcasting Strategy Race Equality Impact Assessment

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Open Broadcasting Unit
Full Race Equality
Impact Assessment
for the
Broadcast Commissioning
Strategy
October 2008
Contents
1.
Introduction
3
2.
Background to the Broadcast Commissioning Strategy
4
3.
Equality Relevance
5
4.
Data, Evidence and Feedback Used
4.1 External benchmarking data
4.2 Internal benchmarking data
5
5
6
5.
Assessment of Impact on Race Equality
6
6.
Promotion of Equality
9
7.
Consideration of Alternatives
10
8.
Formal Consultation
10
9.
Decisions and Actions
11
10.
Monitoring Arrangements
12
11.
Publishing
13
12.
Next Review
13
Appendix 1: Analysis of OU Series in Relation to the Ethnicity of their Viewers
14
Appendix 2: British Broadcasting Corporation Race Equality Scheme
18
We welcome feedback on this report. We are interested to know of any possible or actual adverse
impact that the Broadcast Commissioning Strategy may have on any groups in respect of age,
disability, gender or marital status, race, religion or belief, sexual orientation or any other
distinguishing characteristics.
Queries about this report or the impact of the strategy should be directed to:
Liz Toone
Manager, Broadcast Project (Impact)
Open Broadcasting Unit
Room B075
Wilson Building
Walton Hall
Milton Keynes
MK7 6AA
l.toone@open.ac.uk
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1. Introduction
The University’s broadcast strategy is intended to be flexible and audience focused, with
respect to the different needs of each audience segment. The partnership with the BBC
and other emerging broadcast platforms is expected to take advantage of new learning
technologies and new delivery methods, including digital channels and interactive and
online approaches.
For the purposes of this report the policy being screened is the Broadcast
Commissioning Strategy and up to this point in time the strategy is wholly connected to
the BBC partnership.
In steering each broadcast project through from its initial proposal to its transmission on
television, radio or broadband, the Open Broadcasting Unit, (OBU) strives to deliver
broadcast and learning materials that will:



Build public awareness of the University
Widen participation in education, in particular the harder to reach audiences
Help people make the transition from being a passive viewer/listener to becoming
active learners
The Open University has used its academic expertise to work with the BBC’s expertise in
audio and visual production and create educational programmes since the charter was
granted in 1969 and the first students came on board in January 1971. This has evolved
more recently into the commissioning of peak time programmes for BBC1, BBC2 and
BBC4 along with Radio 3 and Radio 4.
Every TV, radio and broadband programme is supported by learning materials on the
BBC/OU website (Open2.net) which meets strict BBC editorial guidelines and is regularly
assessed to meet OU, BBC and industry accessibility standards. On occasion the OU
also offers free printed learning materials to further engage the audience. These are not
available for all programmes, are not reprinted once stocks run out (unless the
programme is still transmitting) and therefore only provide a limited proportion of
observable data on broadcast related enquiries to the OU.
Via the 5th Agreement the OU has access to the BBC television and sound archives
where material can be used by Open University course teams and commissioned
programme makers.
The BBC's commitment
The BBC is committed to reflecting the diversity of the UK audience in its workforce, as
well as in its output on TV, on radio and online. It aims to reflect the population of modern
Britain - through gender, age, ethnicity and cultural diversity, disability, faith and social
background, and sexual orientation.
The BBC is a member of the major industry networks on disability and ethnicity, as well
as of the main UK employer forums which bring together organisations committed to
driving progress on diversity.
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2. Background to the Broadcast Commissioning Strategy
The Broadcast Commissioning Strategy provides a strategy and plan for decisions on the
commissioning of TV and Radio programmes for broadcast on BBC channels and other
broadband platforms. It identifies a range of targets and other factors which influence
commissioning decisions over programmes, content of programmes, channels, timings
and subsequent usage of content.
Purpose and direction of the Open Broadcasting Unit
The OBU manages the University's relationship with the BBC and its broadcast projects
including web and print related elements. These projects increase OU brand awareness
in the UK and internationally via the sale of OU commissioned programmes to a
worldwide audience and promote knowledge transfer and public awareness of learning
opportunities. The Unit also contributes to a number of University strategies.
It is important to note that a Broadcast Strategy Review has been underway during 2007
and it is likely that the final outcomes will affect the way ‘broadcasting’ is delivered and
will require the unit to revise plans and expectations. The final outcomes of this review
are beginning to emerge as this report is being finalised.
Why the relationship with the BBC?
The relationship with the BBC provides the best means of reaching large numbers of
people and meets the OU’s Charter obligation ‘to promote the educational well-being of
the community generally and to do so by a diversity of means including broadcasting’.
The future of broadcasting
The work of the OBU is very heavily focussed on the BBC relationship. It has been
agreed that the 5th Agreement between the OU and the BBC will be extended to 2011.
The BBC itself faces challenges and is changing in order to meet them. Restructuring in
the BBC, developments in broadcasting and associated technologies, government
initiatives and an increasing emphasis on the need to work in partnership all have an
influence on OBU activities and plans.
Measuring progress
To support the institution’s need for students the OBU analyses audience share,
audience demographics and brand awareness of each broadcast series and with OU
Marketing, monitors the patterns of registration and retention behaviour from broadcastled enquiries. Since August 2007 the unit has also made use of a website analytics
package, to analyse web traffic into, through and out of Open2.net web pages and into
OU sites, particularly for on-line print/prospectus requests and resultant registrations.
It is important to note that registrations following broadcasts can only be monitored if a
print item was available for the series and that resultant registrations typically take place
up to 2 years after the initial enquiry for the broadcast print item.
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3. Equality relevance
The policy is considered to be highly equality relevant and this reflects the decision that
was made resulting from the race equality screening exercise completed in 2005/06.
The OU Broadcast Strategy and Commission Plan for 2005 – 2010 formal written policy
sets out:
“To contribute to the University’s widening participation strategy. It is vital to our core
purpose that we continue actively to encourage and support the successful participation
of all those who wish to take up opportunities for higher education, especially those from
disadvantaged backgrounds or from under-represented groups.
 Black and ethnic minority students
 Students from low socio-economic groups
 Disabled students
 Students from isolated or rural areas
Programmes commissioned and presenters used need to acknowledge and reflect social
diversity.”
The Broadcast Strategy Review, concluded that current broadcast activities do not
enable us to target specific communities, particularly the harder to reach ones.
This, coupled with the demographic structure of the BBC audiences represents an area
that needs to evolve to meet the public engagement mission. This means evolving
broadcasting to target and support specific learning communities in a more focussed
way. This will, however, reduce the general reach of broadcasting activity.
4. Data, Evidence and Feedback Used
Historically, no systematic evaluation of the impact of Broadcasting on different ethnic
groups has taken place. Audience demographics, including ethnicity, are measured
following each OU/BBC series but current OU management information systems do not
support the collection and monitoring of subsequent enquiries or registrations resulting
from broadcasting.
It is considered unreasonable to collect ethnicity or other information of this nature at
point of enquiry, because the enquirer may just be requesting information and have not
reached the decision to enter into a relationship with the University at this point –
therefore it is not proportionate to our duty to promote equality to do this.
To assess the impact of the Broadcast Commissioning Strategy a number of sources
were used.
4.1 External benchmarking data
The BBC Marketing Communications & Audiences (MC&A) division regularly
produce various lifestyle reports on ethic minority audiences. The reports focus on how
lifestyle influences use of television, radio and new media and are available on the
intranet for productions houses to consider when commissioning programmes. This
information is not in the public domain, but available to the University via the partnership.
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Omnibus Research TNS Global, (Taylor Nelson Sofres)
TNS Global conduct omnibus surveys for the University by commissioning face-to-face
surveys with large sample sizes of around two to three thousand people per
series. Ethnicity is recorded within the survey results.
Audience Response Reports – Broadcast Audience Response Board (BARB)
All peak-time audience figures are researched to help deepen our understanding of
audience behaviours and feed into the Broadcast Commissioning Strategy process.
4.2 Internal benchmarking data
Enquiry Generation Data (CIRCE )
The OBU monitors the number of enquiries that have approached the Open University
for a print item relating to the OU/BBC programmes. Not all programmes are supported
with print items and to date (Aug 08) enquirers have not been given the option to ‘opt-in’
to the University.
5. Assessment of Impact
Stage One
For the first stage of the impact assessment the OBU analysed its audience demographic
data against the national statistics 1from the Census 2001 that shows that 7.9% of the
UK population was from a black and ethnic minority group. Open University broadcasts
currently average 4.7% (2006/7).
Differences in relation to individual series can be seen in the extended piece of research
conducted on a sample of 32 OU peak-time programmes where ethnicity of respondents
was recorded during the survey process. See Appendix 1 on p13
The key findings from the research revealed:
• Over the 4 years we have collected data on ethnic origin for OU series: on
average 4.7% of viewers to OU series are drawn from black and ethnic minority
groups.
•
Greater differences exist in relation to the series subject. Often, however, only
one series has been broadcast on any subject and this makes it difficult to draw
conclusions with any certainty. Compared to the OU’s average reach of 4.7%
amongst those from black and ethnic minority groups, Ever Wondered About
Food Series 4 attracted 9.3% and Sport Relief Goes All Out For India attracted
8.0%. The two series of The Money Programme averaged 5.9%.
•
Due to the audience size for BBC1 programmes, this channel has the highest
proportion of viewers from minority ethnic groups.
The unit also analysed the BBC Viewer/Listener complaints service which revealed that
there has been no reported correspondence of a racial nature during the last 5 years
regarding OU peak time programmes.
1
National Statistics are published online at http://www.statistics.gov.uk/.
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Questions were drawn up to establish the OBU’s current position re Race Equality and
broadcasting.
1.
2.
3.
4.
5.
Are we producing print on programmes likely to attract a diverse audience?
Are the programmes reaching a diverse audience?
Are we satisfied that contractors are legally compliant?
Are presenters and programmes participants sufficiently diverse?
What proportion of students from ethnic minorities register for a course after
seeing a broadcast?
Monitoring Data
1. Are we producing print on programmes likely to attract a diverse audience?
 2007 data currently being generated by AACS systems for analysis in second
half of 2008.
2. Are the programmes reaching a diverse audience?
 Viewer demographics were checked using Omnibus Research data by series.
Samples of two to three thousand adults are asked seven questions about
OU/BBC programmes following transmission and the interviewer (since start
of 2007) also provides the demographic profile and ethnic make-up of those
who watched any programmes in the series. Data is fed back to the OBU on a
half yearly basis and targets are measured annually against the Unit Business
Plan.
3. Are we satisfied that contractors are legally compliant?
 The BBC’s broader diversity strategy2 reflects the core principles that serve
the diverse communities which it endeavours to reach. There is a clear
understanding that, in order for programmes to have wide appeal, the creative
teams themselves must be representative of a broad range of ethnic, cultural,
religious and regional backgrounds (as well as reflecting other communities of
interest).
4. Are presenters and programmes participants sufficiently diverse?
 Presenters are employed according to BBC Equal Opportunity Policy3.
5. What proportion of students from ethnic minorities register for a course after
seeing a broadcast?
 Student Services will provide annual data using the Mosaic Profiling system.
The first analysis will be conducted in the second half of 2008. It is not
compulsory to answer a question on ethnicity at the point of enquiry to the OU
for print material related to an OU/BBC broadcast and only a small proportion
of enquirers to the OU answer this question.
Stage Two
The second stage of the impact assessment looked at one BBC/OU series, Child of Our
Time, because the series long running history provided us with data over an extended
period.
Information about the BBC’s commitment to diversity is published online at
http://www.bbc.co.uk/info/policies/diversity.shtml#commitments.
3 Information about the BBC’s Equal Opportunities policy is published online at
http://www.bbc.co.uk/info/policies/diversity.shtml#equal.
2
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Average Ethnic Make-up of Enquiries and Students resulting from OU
Programmes.
As very little data is collected at point of requesting a brochure/leaflet, it is virtually
impossible to find an accurate measure of ethnic origin. However, we were able to
establish that of 95,000 respondents for the print item, only 6% of respondents left details
about their ethnic origin.
At the stage of reserving a course it was found that approximately 53% of respondents
left details about their ethnic origin (of which 83% were in one category). This highlights
the difficulty in determining student numbers by ethnic origin resulting from BBC/OU
programming via current student records. A more reliable measure would be to monitor
registrations arising from enquiries (where ethnicity data is more complete) and
comparing these to the Census population data.
The Ward Deprivation Index will be used in the second half of 2008 to establish if this
method of data collection provides more robust results. The OU has carried out its own
mapping analysis which shows that there is a high correlation between the locations of
the lower quintiles in the Index of Multiple Deprivation in England and the locations where
ethnic minority people are most likely to live. This is linked to the higher likelihood of
ethnic minority people living in urban rather than rural areas. Therefore we are using the
IMD as a proxy indicator, but we recognise that this is far from adequate and any findings
will need to be interpreted with caution.
The following data will serve as a preliminary benchmark: 15% of respondents
requesting print items came from the low bands in the Deprivation Index and 16% of
respondents that subsequently went on to reserve a course came from the same band.
Currently OU programmes show that 40% of respondents are drawn from 0 to 50% in the
Deprivation Index and 60% drawn from the higher end of the Index.
(0-25% bands match OU Widening Participation areas)
Stage Three
The third stage of the impact assessment looked at the specific demographics of the
platforms used to broadcast OU commissioned series.
BBC Television Profile
BBC ONE has the highest reach to ethnic minorities both in all hours and peak hours,
followed by ITV1. BBC TWO has a higher reach than Channel 4, FIVE or cable and
satellite due to volume. BBC ONE is voted to be the channel which represents ethnic
minorities the best by all audiences (source MC&A - ethnic minority project, Ipsos-UK,
BBC Marketing Communications, Strategy & Distribution, April 2003).
BBC Radio Profile
Overall radio appeals slightly less to Black listeners – this is driven by the lower than
average approval to BBC local radio, especially when compared with commercial local
radio. BBC National radio has high approval, particularly amongst Asian listeners.
However, ethnic minority audiences prefer local commercial stations – the weekly reach
to all independent local radio is far higher than to BBC local or regional radio. Many of
the commercial radio stations, even the mainstream stations such as 95.8 Capital FM
over-perform amongst ethnic minorities. Both Black and Asian adults are less likely to
listen to the radio during the day compared to White adults and more likely to listen in the
evening. 62% of Black and Asian adults have no contact with BBC Network Radio, rising
to over 70% in London; Radio 1 attracts the highest numbers, over half a million Black
and Asian people. (Source Rajar/IPSOS-RSL Q4 02 - based on 12 months).
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5.4 Stage Four
The fourth stage of the impact assessment looked at the risks around failure to effectively
meet the diverse needs of the various communities that the institution is trying to serve.
Internal Risks
The most significant internal risk facing the Unit is around the failure to effectively meet
the diverse needs of the various communities in the institution, supporting recruitment
from target groups, supporting the teaching and learning strategy and delivering
commercially attractive materials, (source OBU Risk Register).
External Risks
The major external risks lie around the need to develop the broadcast strategy and take
advantage of new opportunities (e.g. around emerging technologies and use of new
technologies) without losing the current benefits of the BBC partnership. The current
Broadcast Strategy Review is considering this area.
6. Promotion of Equality
The relationship with the BBC provides the best means of reaching large numbers of
people and meets the OU’s Charter obligation ‘to promote the educational well-being of
the community generally and to do so by a diversity of means including broadcasting’. As
the broadcast commissioning process develops to include new technology and multiplatform delivery then a more targeted approach may be possible to include all
population demographics including ethnicity.
The BBC, the OU’s main partner in the Broadcast Commissioning Strategy, has its own
Race Equality Scheme (RES)4 that forms a part of the BBC's overall commitment to
equality and diversity. It outlines a framework for how the BBC, in relation to its public
functions, will now develop, implement, monitor and review its work towards achieving
equality for people who belong to different ethnic and/or cultural groups. (See Appendix
2 for a foreword by BBC Chairman Sir Michael Lyons p17)
The BBC Charter Obligation
The BBC will, when planning or developing future access services, consider the
potentially differing impact or needs requirements of people from diverse ethnic and
cultural backgrounds.
Cultural Diversity Network
The BBC is a member of the Cultural Diversity Network (CDN)5 alongside Sky, Five,
Channel 4, GMTV, SMG, ITN, ITV and Pact. CDN is a network of broadcasters
promoting cultural diversity both on and off screen. The network aims to facilitate real
change and to liaise with both talent and decision makers to keep diversity at the top of
the agenda.
4
The BBC Race Equality Scheme is published online at
http://www.bbc.co.uk/info/policies/diversity.shtml#schemes.
5 For more information about CDN visit their website at http://www.culturaldiversitynetwork.co.uk/.
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The Radio Industry Diversity Group
The BBC was instrumental, with BECTU6, in setting up the Radio Industry Diversity
Group in December 2006. This is the first such group in the radio industry and it covers
all aspects of diversity ranging from race to disability. The BBC also has its own internal
Radio Diversity Group.
The BBC Trust
The Trust works to make sure that people from a wide range of cultural and ethnic
communities and the many different groups that make up those communities are listened
to and heard. It must make sure that it engages with the widest possible audiences and
in the ways that best suit them. The BBC is committed to the principle of ‘race equality’
in relation to all its activities and in respect of its public functions in particular, and the
Trust will continue to consult the public in order to maintain and review this work.
7. Consideration of Alternatives
The possibilities where adverse impacts are identified are;
a) Do not have a policy
b) Change the policy in some way
c) Keep it as it is, but have some mitigating actions to compensate – the Broadcast
Commissioning Strategy is an organic strategy that is continually evolving following
audience and university priorities
8. Formal Consultation
Consultation between the OBU and the following took place to aid the publication
of this report:

With the UK general public via TNS Omnibus surveys following transmissions of each
OU series.

Analysis of BBC viewer/listener enquiries and complaints

Viewing habits from the Broadcast Audience Research Board. BARB provides inhome TV viewing measurement for the UK. This is obtained from a panel of 5,100
homes. The panel design is representative of the whole of the UK and people are
recruited from all sectors of the population.
With additional data from:

BBC Marketing & Sales, Campaign Planning & Data for information on viewer/listener
responses to OU/BBC broadcasts.
6
Broadcasting Entertainment Cinematograph and Theatre Union is the independent union for
those working in broadcasting, film, theatre, entertainment, leisure, interactive media and allied
areas, for more information see http://www.bectu.org.uk/.
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
The BBC Diversity Centre highlighted relevant research ‘Connecting with Ethnic
Minority Audiences’ which was conducted in 2003. Networks have been set up along
side other broadcast companies which aim to facilitate real change to liaise with both
talent and decision makers to keep diversity top of the agenda.

The BBC's Race Equality Scheme (RES) Published 12 June 2007, outlines a
framework for how the BBC will develop, implement, monitor and review its work
towards achieving equality for people from diverse ethnic and/or cultural
backgrounds. It includes:
a. an overview of the constitutional position of the BBC
b. a detailed explanation of the key elements which make up the scheme
c. action plans for the first year of the scheme for each of the public
functions
d. a list of the public functions of the BBC
The BBC Race Equality Scheme is now available at: http://www.bbc.co.uk/info/policies/
Between May and August of 2007 the BBC Trust will be publicly consulting on how it
should engage with its diverse audiences, with particular effort to ensure that those
communities which are traditionally hardest to reach are properly included. This will
ensure that the part of the OU Broadcast Commissioning Strategy that relates to
programmes on the BBC will be able to take advantage of the BBC’s own plans to reach
as diverse an audience as possible.
9. Decisions and Actions
There are some moves to change the policy now following the Broadcast Strategy
Review with the likelihood that we will be able to broadcast to smaller markets using new
technologies such as YouTube and itunesU – this has huge potential for the promotion
of equality and reaching targeted sections of the market.
A set of monitoring arrangements have been put in place that measure the audience
profile of OU broadcasting activities. During 2008 this data will be analysed to gain a
greater understanding of the demographics of the broadcasting audience that contacts
the OU.
Working with OU Marketing, data sets for 2005, 2006 and 2007 will be analysed and
where possible benchmarks drawn up for target setting in 2008 and 2009.
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10. Monitoring Arrangements
This data will be analysed by the OBU with input from OU Marketing, BBC Marketing and
audience research data. Where any adverse impact is found, this will be reported unit
wide and remedial action will be noted within the OBU Unit Plan.
Questions
Monitoring arrangements
Are we
producing
print on
programmes
likely to attract
a diverse
audience?
Check profile of respondents
requesting print resulting from
broadcasts using Mosaic
Profile System
Timescale: 6 monthly basis
starting 2008.
Omnibus demographics
research BBC1/2 –profiled by
ethnic origin per series.
Timescale: 6 monthly
basis.
Systems to monitor adverse
impact
Monitor OU broadcast
respondents profile for ethnic
make-up against population
averages (AACS)
Responsibility
Manager Broadcast
Project Impact
(M-BPI)
2007 research will be
assessed to provide
benchmarks/targets for 2008
Viewer/Listener enquiries &
complaints to be logged as
appropriate.
Omnibus Marketing Research
by series
Timescale: 6 monthly basis
Appropriate action taken to
remedy the enquiry/complaint
Proportion of viewers drawn
from Ethnic Minorities
grouped by subject, financial
year and channel
Timescale: annually (end
2008)
BBC contractual process
Monitor programmes by
subject using Omnibus
Review BBC contractual
process and BBC Trust
Guidelines annually.
M-BPI
Are presenters
and
programmes
participants
sufficiently
diverse?
Currently employed
according to BBC equal
opportunities and editorial
policy.
Annual analysis of
presenter/contributor ethnic
make up for 2008.
M-BPI
Proportion of
students from
ethnic
minorities who
register for a
course after
seeing a
broadcast?
Check profile of registered
students resulting from
OU/BBC broadcasts using
Mosaic Profile System (area
of deprivation index/profile
indicators). Will include age
and gender.
Are the
programmes
reaching a
diverse
audience?
Are we
satisfied that
contractors
are legally
compliant?
Monitor OU/BBC programmes
for ethnic profile against
population average
Monitor viewer/listener
complaints
2007 research will be
assessed to provide
benchmarks for 2008
M-BPI
Viewer/Listener
Complaints
Officer
Marketing/M-BPI
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11. Publishing
This report will be published internally as an email message to all OBU staff with a link to
its folder on both OU and BBC systems. A copy will also be available for download on
the Open Broadcasting website on the OU Intranet.
A copy of this report will be published on the University’s public facing equality and
diversity website7.
12. Next Review
The Unit will:
a. implement annual monitoring as specified earlier
b. actively consider race equality during implementation of Broadcast
Strategy Review outcomes
c. conduct a major race review, including a published report, within a
period of 3 years
This report will be published on the University’s website online at http://www.open.ac.uk/equalitydiversity/.
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Appendix 1: Analysis of OU Series in Relation to the Ethnicity of their
Viewers
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Appendix 2: British Broadcasting Corporation Race Equality Scheme
British Broadcasting Corporation Race Equality Scheme
http://www.bbc.co.uk/info/policies/text/race_equality_scheme.html
Foreword by the Chairman of the BBC Trust, Sir Michael Lyons
The publication of the BBC’s first Race Equality Scheme in 2003 was an important
milestone and one more step in the way the BBC contributes to meeting diverse needs
and expectations and to enhancing the lives of people from a wide range of different
communities and backgrounds. This is the second issue of the scheme, published in May
2007.
On 1 January 2007, the BBC’s Board of Governors was replaced by the BBC Trust. This
saw the introduction of an entirely new constitutional and governance arrangement.
Under the terms of the new Charter and Agreement, the Trust is charged with upholding
the interests of all licence fee payers. The Trust must have meaningful engagement with
those who pay the licence fee, must have a good understanding of their attitudes towards
and usage of the BBC services, and must place audiences at the heart of the Trust’s
decision-making. The Trust must also explain its decisions to audiences and report to the
public about why the Trust has chosen to act as it has. The Trust has to work hard to
make sure that people from a wide range of cultural and ethnic communities and the
many different groups that make up those communities are listened to and heard. It must
make sure that it engages with the widest possible audiences and in the ways that best
suit them. As this document explains, later in the spring of 2007 the Trust will be publicly
consulting on how it should engage with its diverse audiences, and there will be a
particular effort to ensure that those communities which are traditionally hardest to reach
are properly included. In the meantime, the Trust’s initial plans under the Scheme are set
out in this document.
Much of the BBC’s day-to-day work is delegated to the BBC Executive and is out of the
scope of the Race Equality Scheme. This does not mean that it is not vital and important.
The BBC Executive has an established track record in this area. A number of activities
have been agreed through its participation in the Cultural Diversity Network, details of
which are included in this document. Where activities are covered by the Scheme, plans
are set out.
The Trust has a duty to report to the public and explain all decisions to all audiences. The
BBC is committed to the principle of ‘race equality’ in relation to all its activities and in
respect of its public functions in particular, and the Trust will continue to consult the
public in order to maintain and review the Scheme as described in this document.
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