Chapter 2: The BBC’s accountability framework
19.This chapter considers the BBC’s current accountability framework (of which the Public Purposes are a part). We examine how this framework was developed, its merits and weaknesses; and we make suggestions for fundamental change.
Importance of an independent regulator
20.Whatever accountability framework is put in place for the BBC, it can only be effective if the regulatory body of the BBC is independent and strong. Although we have excluded governance from the scope of our inquiry, the evidence we heard indicates that it is widely expected that a new independent regulator for the BBC will be appointed and a reformed system of governance established. The recommendations we make in this chapter assume that the next Charter delivers satisfactory governance and regulatory arrangements for the BBC.
How was the current accountability framework developed?
21.The BBC’s first Charter (effective from January 1927) was simple: it tasked the BBC to entertain and educate by the means of broadcast. This work was to be overseen by a Board of Governors with the licence fee in place to provide funding. The next Charter added “inform” and this simple imperative—inform, educate and entertain—became the BBC’s mission. This system continued until the 2006 Charter, which suggested that “the objects, constitution and organisation of the BBC would be reformed so as to enable the BBC still better to serve the interests of Our People.”20
22.At this point, the notion of generally ‘serving the public interest’ was seen as too vague and was replaced with a requirement to deliver ‘single public value’ and be rigorously held to account for that delivery. This led to the creation of a new accountability framework with a set of six Public Purposes at its heart.
23.The BBC’s 2006 Royal Charter and Agreement set out the six Public Purposes of the BBC, listed in Box 1. The Charter states that the BBC’s main object is the promotion of its Public Purposes. These outline the values the BBC holds when striving to achieve its mission to “inform, educate and entertain.” The Charter sets out the activities the BBC should undertake to deliver its Public Purposes in broad terms.
Box 1: Six Public Purposes of the BBC
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1.Sustaining citizenship and civil society; 2.Promoting education and learning; 3.Stimulating creativity and cultural excellence; 4.Representing the UK, its nations, regions and communities; 5.Bringing the UK to the world and the world to the UK; 6.In promoting its other purposes, helping to deliver to the public the benefit of emerging communications technologies and services and, in addition, taking a leading role in the switchover to digital television. |
Source: Department for Culture, Media and Sport, Royal Charter for the continuance of the British Broadcasting Corporation21
24.The Public Purposes sit atop a framework of measures designed by the BBC Trust to best assess how the BBC’s activities contribute to public value: Public Purposes, Purpose Remits, public value tests, service licences and annual remit reviews. The diagram below shows the relationship between each level of the current framework. The framework embodies a set of measures of the BBC’s own performance as well as a system for measuring the BBC’s impact on the broader media sector.
Figure 1: BBC’s accountability framework
25.In developing a framework of measures in this way, the BBC positioned itself at the cutting edge of a relatively new approach to public sector management—that of public value: a mix of economics and management theory developed by Professor Mark Moore of Harvard University with the express aim of providing a “structure of practical reasoning to guide managers of public enterprises.”22
26.This early academic work was transmitted to the UK via the Cabinet Office’s Strategy Unit, whose 2002 report, Creating Public Value23 suggested that the creation of public value was via provision of high quality services of which users approved; clear outcomes (such as public health, security); and trust between citizens and public authority.
27.The concept of accountability and trying to optimise outcomes that are in the public interest forms the basis of a public value approach. The BBC—led by the BBC Trust—is regarded as a pioneer of the practical implementation of this concept since the last Charter.
28.The BBC Trust set about designing a set of public purposes—against which contribution to public value could be measured. At the same time and in parallel, Ofcom was developing a way of expressing the public purposes for the whole sector. It was agreed that they needed to be different from the BBC’s. Ofcom’s, for example, had to reflect the differences within the sector—such as Channel 4’s specific commitment to innovation—whereas the BBC’s had to acknowledge its specific responsibilities around international news and nations and regions. The underlying drive was to renew the traditional Public Service Broadcasting (PSB) mission for a digital age.
29.Both Ofcom and the BBC have been running a PSB ‘tracker’ for ten years, measuring output (using data on revenue, hours etc.) viewing (using Barb24) and audience satisfaction (surveys) annually. These show that people’s expectations of PSB have remained remarkably consistent over time.
30.We note that it is expected that there will be a new and independent regulator of the BBC. We recommend that the BBC’s independent regulator should oversee a root and branch reform of the BBC’s accountability framework to deliver a simpler, more transparent framework that both encourages creativity and allows all stakeholders to analyse the BBC’s performance. There are many forms that this new framework could take. To aid the regulator in its work, we set out in this chapter our suggestions for change based on the evidence we have received.
The ‘Reithian Principles’: Inform, Educate and Entertain
31.The BBC’s mission, “to inform, educate and entertain” was propounded by Lord Reith, the first Director-General of the BBC. They are sometimes termed the ‘Reithian Principles’.25
32.The National Union of Journalists (NUJ) said that this mission statement was more widely understood by the public than the more detailed Public Purposes.26 The BBC Trust told us that the Public Purposes are “a more detailed articulation of the BBC’s enduring mission to Inform, Educate and Entertain.”27 Professor Robert Beveridge agreed with this view: “The public purposes constitute a reasonable attempt to define—in more detail than inform, educate and entertain—a framework and indicators/bench marks by which the BBC’s performance can be assessed.”28
33.The ‘Reithian principles’—to inform, educate and entertain—are widely understood and recognised as a distillation of the BBC’s mission and as such are embedded in the BBC Royal Charter. We therefore recommend that the status of the ‘Reithian Principles’ as the mission of the BBC should be reaffirmed and, within the BBC itself, given greater prominence.
What are the merits of an accountability framework?
Positives
34.Many witnesses said that the Public Purposes and associated accountability mechanisms were a useful tool to judge the BBC’s performance as a public service broadcaster. Meadhanan Gàidhlig Alba (MG ALBA) told us “the public purposes … set out the broader objectives sought by public service broadcasting … [They] are a means by which metrics can be established for the measurement of these broad, public service objectives.”29
35.The Children’s Media Foundation pointed out the importance of the Public Purposes in “assessing the Corporation’s effectiveness in serving diverse audiences with a range of content they value and which provide broad societal and cultural benefits.”30 The Institute of Economic Affairs (IEA) agreed that they “act as both a broad guide for what the BBC should be doing and something against which those who want to continue the current arrangements can judge the BBC’s performance.”31
36.Professor Diane Coyle, former vice-chairman of the BBC Trust, said they were “setting a framework at a high level for all the measurement tools or management tools that are used to deliver them.”32 She stressed the importance of viewing them as high level rather than at programme level.33
Negatives
37.The Freedom Association said that the Public Purposes “should be removed … The BBC managed for many decades without these public purposes, and I am sure it can manage without them now.”34
38.We received evidence that the current Public Purposes were too broad. The Guardian Media Group (GMG) told us “they are so broad as to effectively provide the BBC with the authority to act as it chooses, acting more as a mission statement than metrics for analysis.”35
39.Luke Johnson, former Chairman of Channel 4, said it could be argued that the language was “phoney” and that the BBC was: “desperately trying to protect itself through various remit definitions so that it can tick all the boxes and prove to the stakeholders, politicians, critics and so forth that it has fulfilled its obligations.”36
40.We support the principle of an accountability framework. However, we conclude that the current accountability system of mission statement, unique Public Purposes, Purpose Remits, Purpose Priorities and very detailed service licences is far too complex. This complexity makes the practical interpretation and assessment of delivery difficult. We recommend a much simpler and more transparent approach.
Public Service Broadcasting Purposes
41.In the Communications Act 2003 Parliament defined the broad purposes of public service broadcasting as the provision of TV programmes dealing with a wide range of subjects, of a high standard and catering for as many different audiences as possible. The legislation aims to ensure that broadcast content is for the public benefit, rather than for purely commercial purposes.
42.Ofcom was created by the Act and, as part of its responsibilities, was tasked with ensuring the availability throughout the United Kingdom of a wide range of television and radio services which (taken as a whole) are both of high quality and calculated to appeal to a variety of tastes and interests.
43.In its first PSB Review Ofcom developed a range of PSB purposes and characteristics to provide a detailed description of public service broadcasting. These were based on the public service purposes presented in the Communications Act 2003 and as such are a codification of Parliament’s expectations and ambitions for public service broadcasting. These are set out in Box 2.37 Enders Analysis raised the possibility that the BBC Public Purposes could be aligned with these.38
Box 2: Ofcom PSB purposes and characteristics
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Purpose 1: Informing our understanding of the world—To inform ourselves and others and to increase our understanding of the world through news, information and analysis of current events and ideas. Purpose 2: Stimulating knowledge and learning—To stimulate our interest in and knowledge of arts, science, history and other topics, through content that is accessible and can encourage informal learning. Purpose 3: Reflecting UK cultural identity—To reflect and strengthen our cultural identity through original programming at UK, national and regional level; on occasion, bringing audiences together for shared experiences. Purpose 4: Representing diversity and alternative viewpoints—To make us aware of different cultures and alternative viewpoints, through programmes that reflect the lives of other people and other communities, both within the UK and elsewhere. |
Source: Ofcom, Public Service Broadcasting in the Internet Age: Ofcom’s Third Review of Public Service Broadcasting
Mission statement and purposes to be underpinned by a set of values?
44.The BBC Trust has proposed that the BBC should be given the following set of values or duties: “Independence, Impartiality, Value for money and the highest editorial and creative standards.”39 The BBC already publishes a set of six values, which are set out in Box 3.40
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Trust is the foundation of the BBC: we are independent, impartial and honest. Audiences are at the heart of everything we do. We take pride in delivering quality and value for money. Creativity is the lifeblood of our organisation. We respect each other and celebrate our diversity so that everyone can give their best. We are one BBC: great things happen when we work together. |
Source: BBC, Inside the BBC41
45.Professor Des Freedman, Professor of Media and Communications, Goldsmiths, University of London, pointed to key principles which were at the heart of Building Public Value42 but are not in the Royal Charter—universality, fairness, equity and accountability. He said that they were “arguably more important than the public purposes in that these ought to be values inscribed into everything the BBC does … they may provide a more robust means with which to protect the BBC as an outward-looking, independent and confident public service broadcaster.”43
46.The Voice of the Listener and Viewer (VLV) suggested a set of values which should be included in the next Charter to “help the BBC regulator assess whether the BBC is performing as well as it should, give clearer guidance to BBC staff about the behaviours expected of them and reinforce the principle of BBC independence.”44
47.S4C, the Welsh-language public-service broadcaster, generally agreed that the BBC Trust’s proposals could be appropriate in reflecting the core values of any PSB service.45 The International Broadcasting Trust (IBT) told us that “a creation of a set of values explicitly stated in the Charter could help the BBC regulator assess whether the BBC is performing as it should and could reinforce the principle of BBC independence.”46 However, to avoid overloading staff with compliancy work it recommended that “any set of values should be used cautiously as a regulatory tool … without being imposed on content makers.”47
Our proposal for reform of the accountability framework
48.There is considerable overlap between the BBC’s Public Purposes and the Ofcom PSB purposes. The latter already capture our general expectations of public service broadcasting. We therefore recommend that the current six Public Purposes should be scrapped. As the starting point for a new accountability framework, the BBC should adopt the four general PSB purposes—informing our understanding of the world, stimulating knowledge and learning, reflecting UK cultural identity and representing diversity and alternative viewpoints.
49.But audiences have higher expectations of the BBC than we do of other Public Sector Broadcasters. The BBC has a special status: it is “one of this nation’s most treasured institutions,”48 it is established by Royal Charter and its principal source of funding is a universal licence fee. This status imposes on the BBC unique obligations to its audience. We therefore expect the BBC to set the gold standard amongst the PSBs in its fulfilment of the PSB purposes. We expect the BBC to make a particular commitment to reflecting the different opinions, lifestyles, beliefs and values of the nations, regions and diverse communities of the UK. We therefore dare to suggest that a fourth dimension be added to the BBC’s mission so that it becomes, “to inform, educate, entertain and reflect.”
50.We welcome the suggestion made by the BBC Trust that the BBC should have a new set of values or duties. These underlying values should permeate through the BBC and be apparent in all the content it produces. These new values will help to assess whether the BBC is performing as is required, give clearer guidance to BBC staff about the behaviours expected of them and reinforce the principle of BBC independence. The BBC’s executive body, in consultation with the independent regulator, should have the responsibility, in the next Charter period, to establish these values or duties.
51.The BBC’s performance is measured annually by the BBC Trust in the Purpose Remit Survey.49 This is a useful tool in terms of assessing public attitudes to and views on the BBC. The independent regulator of the BBC should ensure in the next Charter period and beyond that the public’s views are similarly canvassed and captured.
52.This new accountability framework, taken together with the ‘Reithian Principles’, should provide a concise exposition of what the BBC is for.
Other layers in the current accountability framework
Purpose Remits and Purpose Priorities
53.The current accountability framework for the BBC has been described as too complex. Alex Towers, Director of the BBC Trust, said that there was “a degree of concern inside the BBC management that there is too much that is too complicated.”50 Fujitsu agreed that the “core purposes of the BBC are complex”51 and Prof Coyle told the Committee “there is a danger of over-complexity.”52 Magnus Brooke, Director of Policy and Regulatory Affairs at ITV, said:
“ … there is massive complexity … There are purposes, there are purpose remits, there are purpose priorities and there are purpose plans. I can see how it is bewildering for the BBC genuinely to know, “What am I supposed to do? I have too many documents here purporting to tell me one thing and another.”53
54.In acknowledging this James Purnell, BBC Director of Strategy and Digital, said:
“We very much agree that there needs to be a clear framework, with purposes, service licences and effective regulation to balance public value and market impact, but … there is a bit of danger now that, if you have hundreds and hundreds of pages, it is quite hard to know what the fundamental framework is.”54
55.We recommend that the BBC’s Purpose Remits and Purpose Priorities should be scrapped. They add to the complexity of the current accountability framework without affording commensurate value.
Service Licences
56.In the current accountability framework, the service licences sit underneath the Public Purposes and the Purpose Remits. Will Harding, Chief Strategy Officer of Global Radio, told us that they “need to be a lot more specific and, frankly, a lot more demanding in terms of what the BBC delivers to licence fee payers.”55 Rona Fairhead, Chairman of the BBC Trust, felt the current system worked but “We have to be very careful about not overcomplicating, not putting so many boxes that have to be checked that you are staunching the creativity.”56
57.BBC service licences57 should be reviewed by the independent regulator of the BBC as soon as possible in the new Charter period. The licences should be simplified, strengthened and should define clearly what is expected of each service in a way that leaves no room for doubt about the contribution of each service to the BBC’s overall mission. The service licences should also encourage creativity.
58.The BBC must be held to account for any non-compliance with service licences and these should be reviewed more frequently than the current review held every five years.
20 Department for Culture, Media and Sport, Copy of Royal Charter for the continuance of the British Broadcasting Corporation, Cm6925, October 2006: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/272348/6925.pdf
21 Department for Culture, Media and Sport, Copy of Royal Charter for the continuance of the British Broadcasting Corporation, Cm6925, October 2006: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/272348/6925.pdf
22 Mark H. Moore, Creating Public Value: Strategic Management in Government (Harvard University Press, 1995)
23 Cabinet Office Strategy Unit, Creating Public Value: An analytical framework for public service reform, Gavin Kelly and Stephen Muers (October 2002): http://webarchive.nationalarchives.gov.uk
/20100416132449/http:/www.cabinetoffice.gov.uk/strategy/seminars/public_value.aspx
24 Broadcasters’ Audience Research Board
25 BBC, Inside the BBC: Mission and Values, http://www.bbc.co.uk/corporate2/insidethebbc/whoweare/mission_and_values [accessed 2 December 2015]
33 Ibid.
37 Ofcom, Public Service Broadcasting in the Internet Age: Ofcom’s Third Review of Public Service Broadcasting (2 July 2015) http://stakeholders.ofcom.org.uk/binaries/consultations/psb-review-3/statement/PSB_Review_3_Statement.pdf [accessed 2 December 2015]
40 BBC, Inside the BBC: Mission and Values http://www.bbc.co.uk/aboutthebbc/insidethebbc/whoweare/mission_and_values [accessed 8 February 2016]
41 BBC, Inside the BBC: Who we are, <http://www.bbc.co.uk/aboutthebbc/insidethebbc/whoweare/mission_and_values> [accessed 9 February]
43 Ibid.
47 Ibid.
48 Department for Culture, Media and Sport, BBC Charter Review Public Consultation 26 July – 8 October 2015, Foreword: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/445704/BBC_Charter_Review_Consultation_WEB.pdf [accessed 23 November 2015]
49 Participants in the Purpose Remit Survey are given a number of statements relating to each Public Purpose and are then asked to rate them in terms of how well the BBC performs on these measures and how important the respondents think they are.
57 A service licence is issued by the BBC Trust for every UK public service. It defines the scope, aims, objectives, headline budget and other important features of each service and states how performance is assessed by the BBC Trust. Each BBC service is reviewed against its licence at least once every five years.