How to complain to the BBC

YOU CAN COMPLAIN NO MATTER WHERE YOU ARE AND HOW YOU WATCHED THE SHOW. THE FACT HOLBY CITY AIRS ON THE BBC IS SUFFICIENT TO GIVE ANYONE THE RIGHT TO COMPLAIN

Time Limits

The deadlines for complaining about particular episodes in December have now passed. (You have 30 working days from the date of first broadcast to complain.) You may be able to make a case for them considering a late complaint, especially if it is not about a particular episode. You can also send feedback to the BBC (this will not be directed to the complaints team).

If you are proceeding with your complaint through the BBC Complaints structure (i.e. if you remain dissatisfied with the BBC’s response and are asking them to reconsider), here is some useful information on context, which the BBC has been using to justify the offence caused:

Rule 2.3 of the Code requires that potentially offensive material is justified by the context. Context is assessed by reference to a range of factors including: the editorial content of the programme, the service on which the material was broadcast, the degree of harm or offence likely to be caused, and likely audience expectations. Offensive Material is “justified” by the context.

Contextincludes (but is not limited to):

  • the editorial content of the programme, programmes or series;
  • the service on which the material is broadcast;
  • the time of broadcast;
  • what other programmes are scheduled before and after the programme or programmes concerned;
  • the degree of harm or offence likely to be caused by the inclusion of any particular sort of material in programmes generally or programmes of a particular description;
  • the likely size and composition of the potential audience and likely expectation of the audience;
  • the extent to which the nature of the content can be brought to the attention of the potential audience for example by giving information; and the effect of the material on viewers or listeners who may come across it unawares.

The pivotal words are “includes but is not limited to”.  This means other scenarios can define “context”. Ofcom looks at the totality of the statement.  In the case of Berena, the totality, it can be argued, includes more than the episode at issue. This speaks to the “use of stereotypes and caricatures”.  For example:

  • The historical portrayal of wlw on TV soaps/dramas
  • The public statements of Holby personnel
  • The fact that Holby could have achieved the same outcome, a “mature” breakup in June rather than December without the drastic changes in Serena’s character, especially the cheating and harassment.

Sporadic representation of a particular minority group adds to the harm when misrepresented by stereotypes and caricatures. Not only is there an element of personal harm and offence but a more far reaching harm to an individual viewer or licensee .  That is, Holby’s actions could have reasonably been interpreted by a viewer as promoting and condoning certain negative stereotypes based on sexual orientation.

In Ofcom 2017 Guidance Notes, context was also defined as:

Discriminatory treatment or language (for example, matters relating to age, disability, gender, race, religion and sexual orientation) 

  1. There is a relationship between representation – the presence and inclusion of a diverse range of people on screen – and portrayal – the roles involved and the way that minority groups are presented in programmes. In standards regulation, the latter is assessed by context (as defined in the Code). 
  2.  Research (from Ofcom) suggests that viewers and listeners appreciate programmes that are representative of the diverse society in which they live. If there is an underrepresentation, the use of stereotypes and caricatures or the discussion of difficult or controversial issues involving that communitymay be seen as offensive in that it is viewed as creating a false impression of that minority.

We have looked at a couple of previous Ofcom investigations to see how they have applied Rule 2.3. You can view this information here.

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The information about making complaints is preserved below, for reference.

Your complaint should include the following:

-the name/title of the broadcast or published item you are complaining about;
– the date and time of the broadcast or (where possible) publication;
the channel or service on which it was broadcast, or the web address at which it can be accessed;
– the nature of the complaint (giving reasons why you are dissatisfied with the BBC) and (where possible) the particular parts of the programme or publication you are complaining about;
– your name and contact details (anonymous complaints will not normally be considered);
– whether (and if so, when) you have submitted a first-party complaint to an outside authority (e.g. Ofcom).

A couple of grounds for complaint:

A. Editorial Complaint – Stereotyping and representation

Editorial guidelines on this can be found here: https://www.bbc.co.uk/editorialguidelines/guidelines

5.4.38
Reflect fully and fairly all the UK people and cultures. The BBC may reflect prejudice but not perpetuate it. The BBC must avoid careless or offensive stereotypical assumptions.


How might you word your complaint?

– That the lesbian community is often unfairly portrayed as promiscuous and the storyline perpetuated this.
– That lesbian relationships are always ended by some horrid event, a death, typically, here with Holby a career decision. Unfair portrayal, they can endure and so endure IRL.
– That LGBT representation is skewed towards men. We have Dofty and yet Berena has been kicked into touch.
– Any other stereotypical rubbish, i.e., (1) Lesbians cheat; (2) Lesbians have this “undeniable sexual attraction” and then it dies within six months to a year. (3) Lesbian relationships are angst filled after consummation. (4) Lesbians should not fall in love with our best friend. As friends, Serena and Bernie had each other’s back. As lovers, they did not; and (5) Lesbians act as if their relationships are disposable.
– Quote the Ofcom review at them from October 2018 which is “the baseline for assessing the BBC’s future performance”. It must “lead by example and produce distinctive content that accurately represents and authentically portrays the whole of the UK.
– Use comments made by Simon Harper, Catherine Russell, and Holby PR that misrepresented their intentions as to the Berena Storyline. They used the terms “representation matters,” visibility, “continue the fight”, “hurl out the bunting & shout ‘Hoorah’”. Use whatever statements made on YouTube, Twitter, or the press.
– Try and focus on establishing unfair treatment especially in relation to other minorities.

The BBC has already responded to some complaints by saying that characters on Holby City are not intended to represent anybody. Feel free to use our rebuttal by including the url in your complaint.

B. Editorial Complaint – Harm to audiences

5.2.1
The BBC must apply generally accepted standards so as to provide adequate protection for members of the public from the inclusion of offensive and harmful material.


How might you word your complaint?

– The prevalence of mental health issues amongst the lesbian community is a known factor. The insidious use of spoilers on twitter caused unnecessary harm. (Share your individual response Berena storyline, including how inspiring it was “to be brave” and how devastating it was how It ended.)
– Promotional material released hinted at a Berena wedding, but they were cruelly kicked into touch in an episode touted as celebrating love in all its diverse forms.

C. Editorial Complaint – Publicity (stills and by implication video?)

Editorial Guidelines on publicity can be found here: https://www.bbc.co.uk/editorialguidelines/guidance/stills/guidance-full

Care should be taken not to use images to mislead the audience.

Images that reinforce prejudicial perspectives or depict groups in stereotypical ways should be selected with special care and with editorial justification.

Images that could be seen as offensive to ethnic, religious or minority groups should be selected with special care and with editorial justification.


How might you word your complaint?

– The promotional material, particularly pictures captured with comments about Bernie staying on the BBC Holby City feed Twitter feed were misleading. Reference how #1 & #2 effected your reaction to the promotional materials.
– Pictures of Serena kissing Leah in promotional material were unnecessarily distressing to the fandom.

What happens After I Complain?

If you complain in writing or by email you should hope to hear from the BBC within 2 weeks. If there are a lot of similar complaints this may take longer.

What If I Am Not Happy With The BBC’s Response?

Contact the BBC in writing either by letter or by email within 20 working days of the response quoting your complaint case number. The BBC will respond usually within 20 working days. In returning to the BBC explain why you are not satisfied. You cannot raise NEW points at this stage, unless exceptionally, it is necessary to do so in the interests of fairness. The word limit is again 1000 words.

If you remain unhappy you can escalate the matter to the BBC’s Executive Complaints Unit (ECU). The procedure is similar with a 20 working day time limit and restrictions on new matters which can be raised. Again 1000 words maximum. You should include the points raised at the earlier stage. Your complaint will be acknowledged within 5 working days and the ECU aim to respond within 20 working days.

If you are still dissatisfied you can refer the matter to OFCOM to investigate.

Full details of the BBC’s complaints procedures can be found in the Complaints Framework which can be found here.

https://ssl.bbc.co.uk/complaints/forms/assets/complaintsnew/resources/BBC_Complaints_Framework.pdf

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