Consultation Paper 1:

Blogging: A consultation paper for ABC staff

July 2007

Advise. Verify. Review

ABC Editorial Policies

Editorial Policies

The Editorial Policies of the ABC are its leading standards and a day-to-day reference for makers of ABC content. The Editorial Policies -

• give practical shape to statutory obligations in the ABC Act; • set out the ABC’s self-regulatory standards and how to enforce them; and • describe and explain to staff and the community the editorial and ethical principles fundamental to the ABC.

The role of Director Editorial Policies was established in 2007 and comprises three main functions: to advise, verify and review.

The review function principally involves a focus on the text of the Editorial Policies to ensure the standards stay up to date in light of technological and other change. Instead of periodic reviews every few years, the Editorial Policies are to be kept under constant review, with the Director identifying areas that may require amendment, consulting and making recommendations to the Managing Director and Board.

The ABC Editorial Policies Division welcomes your comments on this consultation paper and seeks your response to the issues raised. These should be forwarded by email to [email protected] by 28 August 2007.

Acknowledgements

Director Editorial Policies acknowledges the contribution of Michelle Fisher, Manager Research (Editorial Policies) in the preparation of this Consultation Paper.

This report is published by the Australian Broadcasting Corporation © 2007 ABC

For information about the report, please contact: Director Editorial Policies ABC Southbank Centre GPO Box 9994 Melbourne VIC 3001 Phone: +61 3 9626 1631 Email: [email protected]

ABC Editorial Policies

Consultation Paper 1 Blogging: A Consultation Paper for ABC Staff July 2007

Table of contents

I. What this Consultation Paper is about ...... 1

II. Why the ABC is thinking more about UGC and Editorial Policies ...... 3

III. Why blogging is in focus...... 4 A. Focus on blogging by ABC staff and blogging by our audiences...... 4 1. ABC-hosted blogs on ABC internet sites ...... 5 2. Proposed audience-hosted blogs on ABC internet sites ...... 5 3. Audience blogging and engagement ...... 5 4. Public broadcaster affiliations with independent bloggers...... 5

IV. Legal context ...... 7 A. General legal obligations ...... 7 B. ACMA regulation of online content...... 7 C. Limited immunity for civil and criminal liability ...... 7

V. Editorial policies...... 9

VI. List of issues, and an invitation to comment ...... 10 A. Issues for consideration...... 10 1. Question 1: What aspects of our experience with audience interaction in other contexts can be usefully applied to blogging?...... 10 2. Question 2: What Editorial Policies should apply to users’ comments and UGC? ...... 11 3. Question 3: Do audience expectations and standards relating to online content differ from those relating to broadcasts? ...... 11 4. Question 4: Assuming we should moderate, how?...... 13 5. Question 5: How should we (and our audience) facilitate access to the best of the comments and foster productive discussions on our blogs?...... 16 6. Question 6: If we invite audience members to help us handle blogs, how do we best support them? Should we look at partnering with independent bloggers instead? ...... 17 7. Question 7: Should we more readily allow linking to external sites? ...... 18 8. Question 8: Is sufficient guidance already provided for staff who have personal blogs or who contribute to independent (non-ABC) blogs? ...... 20 B. How you can make a submission...... 22

Endnotes ...... 23

ABC Editorial Policies

I. What this Consultation Paper is about

This paper informs and consults ABC staff, seeking the views of the people who comprise the national public broadcaster about the issue of blogging.

Blogging is one item among several usually grouped under the label User Generated Content (UGC).

Unlike most jargon terms, this one means precisely what it says: content generated by the users of a media organisation and submitted to that organisation for it to disseminate. It is not new. Talkback radio is a form of UGC. But new information and communications technologies are facilitating more UGC, of greater variety, and all of it arriving faster than traditional media organisations have received it in the past.

A blog (short for “web log”) has been described by Dan Gillmor as:

an online journal comprised of links and postings in reverse chronological order, meaning the most recent posting appears at the top of the page. …[W]eblogs are “post-centric”—the posting is the key unit—rather than “page- centric,” as with more traditional web sites. Weblogs typically link to other web sites and blog postings, and many allow readers to comment on the original post, thereby allowing audience discussions.1

Common features of a blog include the informal tone adopted, the use of links to external sites, and the enabling and encouragement of interaction with audiences through the posting of user comments and other content.

The paper is structured like this:

Part 2 gives the wider context, demonstrating why blogging is worth thinking about, on its own and as part of a changing media environment to which the ABC must adapt if it is to thrive.

Next, blogging is examined more closely and the main distinction is made between blogs by ABC staff and blogging by audience members on or in affiliation with ABC sites (Part 3).

In Part 4, the legal framework relating to blogging and UGC is outlined and some questions raised (but not solved; in many ways the law is a long way behind developments in media and the way people are using new communications technologies).

Part 5 describes how the current Editorial Policies are relevant to blogging. The feedback to this paper will form part of a broader revision of Section 9 of the 2007 Editorial Policies, “Links and Interactivity”, which dates from 1995.

The need to revisit such areas of policy should be evident from this excerpt from a recent BBC Trust report:

Even in the short period since the publication of the [BBC’s] Editorial Guidelines (June 2005), the meaning of UGC has changed. It then was applied to message boards and public contributions to other online sites. Now, two years later, it is more often understood to mean amateur stills and video sent to newsrooms from mobile phones. This reflects the way such UGC has mushroomed in that period – along with video news releases (VNRs) from those with causes to promote. Before that, amateur stills and video were available to news networks – but for a long time were not given either the credence or the value of their professional equivalents. Now that has changed. Sometimes they themselves become the story, as with the pictures of prisoner abuse in the Abu Ghraib jail in Iraq.

Amateur digital pictures are different only in the speed with which they can now be transmitted around the world, between individuals or via broadcasters. BBC News first used such pictures in quantity after the bombings of July 2005 (300 were sent in), and then again after the Buncefield oil depot fire (when, only five months later, 15,000 images were received). Now the mobile phone operator 3 is planning a direct channel to broadcasters, by which its subscribers may feed images of a news event straight into newsrooms, so that citizen journalists become, in effect, news agency . There are also pictures circulating on web portals such as YouTube whose provenance and authenticity may be unverifiable.2

In Part 6, the paper lists some key issues, asks lots of sub-questions, and invites staff to give their views. You are encouraged to read, reflect, discuss and respond.

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ABC Editorial Policies

This is part of a larger process. The editorial policies specialists will be involved. Options must be distilled. Decisions will have to be made by persons properly authorised, and only the Board can change the Editorial Policies. But in this fascinating area, decisions are likely to be better for the ABC and its audiences if they are informed by the knowledge, experience and involvement of the many and varied people who together make the ABC work.

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ABC Editorial Policies

II. Why the ABC is thinking more about UGC and Editorial Policies

The media environment is changing. Old models are being shaken. The ABC is part of this change, adapting and innovating as it has since its inception 75 years ago.

The internet has changed the world of traditional media outlets, and they are in the process of working out what to do in response. A big part of the power and influence of mass media publications and broadcasters – let’s call them Old Media for convenience – was their combined role as collectors, interpreters and disseminators of the news and opinion that most people absorbed. The few spoke to the many. Some among the many got a word in if the few chose to allow it (e.g., letters to the Editor).

Online, the many can speak back to the few. Or speak to each other, bypassing the few. Or create new audiences, large and small, who do not necessarily see the Old Media as important. Enabled by technology, people are testing the assumptions on which traditional media organisations have based their self-image and their view of their audience. In the 19th and 20th centuries, courts and policy makers evolved ways of dealing with mass media that were also based on Old Media assumptions. The technologies and the public’s inventive ways of using them are forcing change there too.3

It is a time of transition. Familiar forms of media will continue in the midst of the new. The skills acquired and honed in Old Media will remain relevant in the New. Old Media entities like the ABC, but also commercial broadcasters and newspapers, have to continue their traditional role, under the old models of law and policy, but at the same time embrace the new media and develop in order to maintain relevance. Constant adaptation can be unsettling. Tensions are inevitable. The many and diverse references given in this paper show that one major source of tension for Old Media, especially public broadcasters, is meeting standards that were established in the era of few-to-many while simultaneously opening themselves to the potential of the many. Old Media, in this time of transition, can use their prominence and well-known brands to act as hosts to the many-to-few and many-to-many interactions that the online world allows.

Blogging is part of that process. ABC staff blog to established and perhaps to new audiences. And audience members blog to, through and about the ABC.

Many of the standards of the Editorial Policies were devised and matured in a passing era. It is necessary to adapt those standards to the new environment because those standards, when reached but also when striven towards in good faith, helped to build the ABC into a trusted source and a well-regarded host.

As media evolve into what the few and the many experience more equally, the ABC wants to be the leading public space. Its distinguished past augurs well, but it does not guarantee such a future. To secure it, the first imperative is to encourage the best thinking. This paper seeks your contribution.

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ABC Editorial Policies

III. Why blogging is in focus

The ABC has been blogging since at least 20014 and is now in the process of rolling out additional blogs about a range of topics across various Divisions.

As the ABC continues to embrace this particular form of audience interaction, we need to be mindful of the difficulties faced by other media organisations who have experimented with blogging, and some of the challenges greater user participation presents in exercising editorial control. Australian newspaper organisations’ blogs and their moderation policies were recently the subject of scrutiny by the ABC’s Media Watch program,5 which then itself received scrutiny.6

In some overseas cases, blogs have had to be suspended or removed as a result of inappropriate postings from some users.7 In other cases, the credibility and integrity of journalists have been questioned when they engage in the more informal and open style associated with blogging, particularly where staff have personal blogs.8 Blogging by journalists has also raised concerns about the blurring of news, analysis, opinion and commentary.9

The ABC is acutely conscious that, as a public broadcaster, we have statutory obligations and public expectations that may preclude use of approaches adopted elsewhere.10 Yet, audience expectations cannot be presumed to be static. The revolutionary changes in digital communications are affecting the way content is produced, delivered and consumed. Audiences can no longer be treated as passive listeners in the New Media environment involving convergence, media mobility, availability of on-demand content, and greater user participation.

The challenge for the ABC is to navigate through these trends, maintaining relevance, innovating and continuing to fulfil our statutory commitments to independence, integrity, accuracy, and impartiality.

A. Focus on blogging by ABC staff and blogging by our audiences

This paper is concerned with blogging as it relates to the ABC. This may involve the ABC taking various roles:

• the ABC may own or control the internet site on which a blog operates, irrespective of who is engaged to facilitate or “host”11 the blog;

• the ABC may employ one or more of its staff to host a blog, where the ABC staff member is the primary author of postings and audience members are invited to contribute comments;

• the ABC may invite an audience member to act as the host of a blog that is maintained on an ABC- owned or controlled internet site;

• ABC staff might participate as users or bloggers – contributing comments to ABC blogs or to external blogs;

• ABC staff may set up their own personal blog with no formal connection to the ABC other than the fact that the individual is stated or generally known to be associated with the ABC; and

• the ABC may have some affiliation, whether as aggregator or as partner, with one or more independently-operated blogs.

Illustrations of these various scenarios follow, using the ABC and other public broadcasters and media organisations.

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ABC Editorial Policies

1. ABC-hosted blogs on ABC internet sites

Examples of ABC-operated blogs that are hosted by ABC staff members include:

• personality and presenter blogs, like Triple J’s Zan Rowe’s Run with the Hunted (http://www.abc.net.au/triplej/zan/blog/) and Scott Dooley’s Dools Gold (http://www.abc.net.au/triplej/dools/blog/); and the staff blog at ABC Rural Radio Victoria, Victorian Country Hour Blog (http://www2b.abc.net.au/rural/vic/blog/about.shtm);

• blogs designed for children, such as those available on RollerCoaster, covering the topics of arts, music, science & nature, computers, sports and games (http://www.abc.net.au/rollercoaster/chatter/blog/);

• sporting blogs, like Sports Desk (http://abc.net.au/sport/thesportsdesk/default.htm) and the now archived blogs for the Commonwealth Games Melbourne 2006 (http://www.abc.net.au/commonwealthgames/2006/), the 2006 Der Blog (http://www.abc.net.au/worldcup/2006/blog/default.htm), and the 2005 The Ashes (http://www.abc.net.au/cricket/ashes/2005/);

• arts & entertainment news blogs, like Articulate (http://www.abc.net.au/news/arts/articulate/) and The Shallow End (http://www.abc.net.au/news/arts/theshallowend/); and

• election blogs, like the Poll Vault (http://www.abc.net.au/elections/nsw/2007/weblog/).

2. Proposed audience-hosted blogs on ABC internet sites

The ABC may soon offer audience members the opportunity to host a blog on ABC-controlled sites. This may involve engaging parents from across Australia to blog for the ABC Parenting site, or engaging bloggers for some foreign language sites (http://nmwiki.abc.net.au/editorial//index.php/Allocation_of_blogs).

3. Audience blogging and engagement

Other public broadcasters and media organisations have established sites where users are invited to engage in social commentary and “citizen journalism”,12 and where they are encouraged to blog or submit story ideas and images – see BBC’s (http://www.bbc.co.uk/blogs/worldhaveyoursay/2006/10/what_is_world_have_your_say.html), The Guardian’s Comment Is Free (http://commentisfree.guardian.co.uk/index.html, including guest commentators from the community: http://commentisfree.guardian.co.uk/about.html), the Denver Newspaper Agency’s Your Hub (http://www.yourhub.com/), and Minnesota Public Radio’s Public Insight Journalism http://minnesota.publicradio.org/publicinsightjournalism/).

The BBC has also established blogs in support of sites where users are encouraged to take part in community activism and civic engagement – see the BBC’s blog (http://www.bbc.co.uk/blogs/actionnetwork/) originally set up in support of the BBC’s Action Network13 (http://www.bbc.co.uk/dna/actionnetwork/) but since closed due, in part, to infrequent use.14

4. Public broadcaster affiliations with independent bloggers

The BBC’s Manchester Blog Project is an example of how a public broadcaster might engage with community bloggers and cope with some of the legal and resourcing issues that arise in relation to blogs that are set up on the broadcaster’s .

The BBC’s Richard Fair and Robin Hamman explain the motivation and intent of the project:

In the past, whenever the BBC has sought to do something with user generated content we've built new platforms, taken on the role of managing all the content that floods in, asserted some rights over that content (although not ownership in the vast majority of cases) and, some would argue, exposed the BBC to legal and moral risks.

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ABC Editorial Policies

Furthermore, doing things in the old way had a bit of a sting in the tail - if a service really took off, and sometimes they did, the BBC would actually face increased costs because our services often don't scale well.

This project is an experiment in doing things a bit differently. Rather than building platforms, we want to help people create their own stuff on existing third party (non-BBC) platforms. Instead of contributors sending us content [and] members of staff here at the BBC sifting through that content in a bid to find the good bits, we're simply going to ask contributors to tell us where they're publishing their content online and we'll keep an eye on it. The BBC won't claim any rights over the content and won't own anything.15

The project involves creating partnerships with local bloggers across the Manchester area. The BBC Manchester Blog (http://www.bbc.co.uk/blogs/manchester/) keeps in touch with local bloggers by subscribing to RSS feeds of each participant and by sourcing and quoting interesting content across a range of subject areas. While local bloggers undertake to abide by the BBC’s editorial guidelines, the BBC does not manage that content. The BBC offers participants workshops to provide practical training on creating and sharing content on existing third-party platforms (e.g. Flickr, YouTube, blogger.com).16

The Canadian Broadcasting Corporation (CBC) has also been involved in encouraging blogging and social networking through the use of partnerships with third party platforms. See the CBC’s wish blog ((http://www.cbc.ca/wish/) supporting its recent partnership with to create the Great Canadian Wish List (http://www.facebook.com/group.php?gid=2392827649, registration required), where users were encouraged to register with Facebook and create their wish in the lead up to Canada Day, with the best wishes being broadcast and discussed on CBC platforms (TV, radio and online).17 CBC has also recently partnered with Technorati, an internet search engine which can be used to search blogs and find out which blogs are linking to a website address (e.g., see the blogs who have recently linked to stories on the ABC site: http://www.technorati.com/search/www.abc.net.au). Under the arrangement, instead of relying solely on users posting to CBC blogs, CBC blogs incorporate Technorati’s technology to include direct links to independent sites who are blogging about CBC’s online stories18 -- see CBCNews.ca blog watch (http://www.cbc.ca/news/blogwatch/).

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ABC Editorial Policies

IV. Legal context

The legal framework governing audience contributions and blogs naturally affects how the ABC develops policy guidance and procedures for blogging.

A. General legal obligations

Any blog hosted by the ABC must be established and managed in accordance with the ABC’s legal obligations set out in the Australian Broadcasting Corporation Act 1983 (Cth).

Like other media entities, we must also abide by other laws relating to liability for publishing illegal or infringing content, such as the Broadcasting Services Act 1992 (Cth) and laws dealing with copyright and trademarks, defamation, privacy, surveillance devices, racial vilification, publication of judicial or Parliamentary proceedings, and duties of confidentiality.

The ABC is responsible for content it produces itself, co-produces with others, commissions from others, acquires already made by others, and licences others to make and disseminate under the ABC brand. While the Editorial Policies suggest we are also responsible for audience contributions (Section 13.1.1), the law is not clear. Some of the issues giving rise to this uncertainty are noted in the next two sections.

B. ACMA regulation of online content

The Broadcasting Services Act expressly regulates online content,19 including postings to newsgroups. If offensive or illegal material is posted, the Australian Communications and Media Authority (ACMA) can order the website operator to remove (or “take down”) that content provided it is stored on a device (e.g., a server) located in Australia.

Recent amendments to the Broadcasting Services Act will alter ACMA’s regulatory role. Once the amendments come into operation, ACMA will not only be able to order the take down of stored content that is prohibited. It will also be able to deal with content that is “live” (e.g., streamed), including content made available on convergent devices (such as mobile phones). If prohibited, ACMA can order the provider to stop making the content accessible. The take-down provisions will not, however, apply to “national broadcasting services” such as those provided by the ABC.20

ACMA’s role in dealing with prohibited content is acknowledged in the ABC’s 2007 Editorial Policies. Section 13.8.6 notes that complaints can be made to ACMA about prohibited online content, and that ACMA must investigate such complaints.

The precise extent of ACMA’s role to deal with complaints about online content is not clear. Blog postings that are alleged to be in breach of the ABC’s Code of Practice 2007 may not be reviewable by ACMA, despite the Code being drafted to apply to content made available on ABC Online or through emerging media devices. The ABC’s code-making authority is limited to programming matters and any datacasting service.21 There is no express or clear authority to make codes relating to online content. To date, ACMA’s investigations of Code breaches have been confined to ABC radio and television broadcasts.

C. Limited immunity for civil and criminal liability

The Broadcasting Services Act gives website operators some protection from civil and criminal liability under State and Territory laws and the common law arising in respect of third party content disseminated on a website, provided the operator was not aware of the nature of that content. That Act also makes clear that State and Territory laws, and the common law, cannot require a website operator to monitor or make inquiries about the content it hosts.22

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ABC Editorial Policies

Recently codified State and Territory uniform defamation laws provide some protection for innocent dissemination of unlawful content, but not where the distributor of that content has some capacity to exercise editorial control over the material prior to publication.

The application of the immunity under the Broadcasting Services Act has not yet been tested in the courts. The practical extent of immunity from legal liability for website operators is uncertain. So it is as yet unclear how the federal law made for website operators will interact in practice with State and Territory laws dealing more broadly with responsibility for disseminating infringing content.

The issue of legal liability for users’ comments is relevant to determining how the ABC moderates blogs. Legal risk must be faced and managed. As always, good communication and cooperation between ABC content makers, editorial decision-makers and ABC legal advisers will be a large part of successfully managing risk in this area as the environment changes and the ABC adapts.

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ABC Editorial Policies

V. Editorial policies

Blogging at the ABC is also guided by our commitment in the Editorial Policies to act with honesty, fairness, independence and respect. Our approach to blogging is also legitimately guided by our role as a public broadcaster to provide the diverse and dispersed Australian community with comprehensive and innovative services of a high standard that inform, entertain and educate. The ABC can enrich Australia in ways the commercial and community sectors alone cannot or will not.

Although blogging is not specifically mentioned in the ABC’s 2007 Editorial Policies, online interactivity is addressed in Section 9. This section deals primarily with linking to commercial and other external sites, moderation, and registration of users with ABC Online. (These issues are discussed in greater detail in Part 6 of this paper.) Reference is also made to related documents, such as the ABC’s Conditions of Use statement and the ABC’s Online Privacy Policy:

• The Conditions of Use (http://www.abc.net.au/conditions.htm) set out the terms and conditions users are expected to abide by when contributing content to any platform the ABC hosts or facilitates. Topics covered include parental supervision over children’s contributions to ABC Online, user liability for content submitted to the ABC, discretion to publish or edit user submissions, archiving and reuse of user submissions, copyright, complaints procedures, and user registration.

• The Online Privacy Policy (http://www.abc.net.au/privacy.htm) includes a section on “interacting with ABC Online” warning users to be cautious about posting their personal details on public forums, and encouraging the use of pseudonyms.

Audience contributions are also discussed elsewhere in the Editorial Polices:

• audience contributions are expressly excluded from content licensing agreements (Section 4.5.3);

• the requirements for opinion content expressly do not apply to audience contributions (Section 6.4); and

• parental supervision of children’s contributions to ABC Online is addressed, along with further guidance on use of links on sites designed to appeal to children (Section 11.14.5).

Other areas in the Editorial Policies will also be relevant. For example, conflict of interest guidelines apply to staff blogs. Upward referral for contentious postings and UGC apply as upward referral applies to all other content.

The BBC has produced extensive guidance material on blogging, staff blogs, interactive forums and user- generated content. See for instance their Editorial Guidelines on “Interacting with our Audience” (http://www.bbc.co.uk/guidelines/editorialguidelines/edguide/interacting/); supplemental guidance for its online and interactive services, Online Services Guidelines (http://www.bbc.co.uk/guidelines/editorialguidelines/onguide/), and Guidelines on Employees Personal Weblogs and (http://www.bbc.co.uk/guidelines/editorialguidelines/advice/weblogswebsites/).

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ABC Editorial Policies

VI. List of issues, and an invitation to comment

A. Issues for consideration

Staff are invited to respond to the issues raised, and to raise any other relevant considerations.

1. Question 1: What aspects of our experience with audience interaction in other contexts can be usefully applied to blogging?

Blogging shares some characteristics with other forms of audience participation:

• talkback radio, in which listeners, mediated by the broadcaster’s staff, can air their views to the broadcasters’ staff and to other listeners;

• audience participation and reactions from those who form part of a studio audience, such as occurs in A Difference of Opinion, or are selected as part of a comedy sketch or “field experiment”,23 as in The Chaser’s War on Everything;

• letters-to-the-editor pages, where readers’ comments can be sought, sifted and published to other readers – TV equivalents have included the ABC’s program Backchat;

• other forms of live broadcasts, including interviews and rolling news broadcasts; and

• online participation through message boards and guestbooks.

The ABC utilises various mechanisms to deal with unexpected, potentially controversial, or inappropriate content that may be generated by users in these contexts. The level of editorial control will depend on a number of factors, including:

• foreseeability that unlawful or otherwise inappropriate content might be generated;

• the amount of users’ comments that would require reading and editing prior to publication or broadcast;

• whether the content is published or broadcast some time after it is submitted, or whether it is instead made available in real time;

• the sensibilities and expectations of the target audience; and

• the effect different degrees of editorial intervention might have on free discourse.

So, for instance, when in receipt of a relatively small number of readers’, listener’s or viewers’ comments, detailed editorial control over which are published or read on air may be practicable. Similarly, pre-recorded interactions with studio audiences and others can be readily edited before going to air. Editorial control over live radio and TV broadcasts may be exercised through a delay mechanism, when the need is anticipated and the moderator is vigilant. Postings to message boards and guestbooks are most comparable to blog postings, yet differences remain. The number, nature, and accessibility of postings may differ in ways that affect the need for, and exercise of, editorial control. Delayed publication may not be the applicable model for all blogs, such as in the case of blogs like the one about to be trialled by the BBC featuring a real-time editors blog from their News 24 studio gallery.24

Standards and mechanisms such as those listed above have been developed over many years. Those standards are likely to be relevant to developing blogging guidelines. But they are not necessarily determinative. Aspects of blogging seem novel and may require novel responses. For instance, blogs can contain links, and the “threads” of comments on a given issue can be far more complex and longlasting in

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ABC Editorial Policies blogs than in, say, letters pages or on talkback, where the limitations of space and time are more constraining. The sheer volume of user comments may be impracticable to vet in advance of publication, particularly where excessive delay may mean the debate goes cold and the audience becomes uninterested.

What lessons learned from other forms of audience participation can be applied to blogging? What mechanisms and considerations are relevant to determining the appropriate level of editorial control that should be exercised over users’ comments?

2. Question 2: What Editorial Policies should apply to users’ comments and UGC?

The Editorial Policies state (at Section 9.2.4) that the ABC does not publish any user contribution where the ABC moderator believes it to be, among other things, inconsistent with ABC Editorial Policies.

To what extent, and in what way, do we expect audience members to abide by the Editorial Policies, including the requirements for three of the four content categories, that is, news and current affairs, factual and topical, performance (audience contributions are excluded from opinion content: Section 6.4)? How are the Editorial Policies obligations relating to accuracy, impartiality, objectivity, fairness, independence, balance, and respect best applied to audience contributions?

How, as a U.S. media ethicist asks, “do you balance the values of giving readers conversational, spontaneous and timely blogs that engage them versus serving readers with the journalistic values of accuracy, fairness, balance and editing that insures those values are upheld?”25

What can we usefully apply from our experience with talkback and other forms of interaction? Is it useful to separate out the responsibilities of the host from those of the audience? For instance, will our obligations of impartiality and accuracy be reasonably likely to be met by starting from the following basic expectations:

• users are expected to state their honest views, act lawfully and show others the respect they would expect from others; and

• the ABC is expected to propose topics, encourage diversity of perspectives (bearing in mind that participating online audiences are not necessarily representative of the whole spectrum of views in the community), challenge inaccuracy, and exercise final editorial control about what is published and what is not, or what is removed.

Does compliance with the Editorial Policies depend upon the use that is made of users’ contributions? For example, if comments or other user-generated content is accepted and used for news and current affairs, then should the obligations for meeting the standards in Section 5 of the Editorial Policies apply to that content? And if UGC is accepted and used in, say, a topical and factual program or site, should less stringent standards apply than would apply in a news context? Or is there an ever-present obligation to check the provenance and accuracy of users’ contributions prior to use (recall, in this context, the BBC Trust’s observation in paragraph 11 above)?

Should the Editorial Policies treat user comments and UGC as a distinct content category, alongside the other content categories in Sections 5-8 so that the ABC in effect develops standards expressly for UGC?

3. Question 3: Do audience expectations and standards relating to online content differ from those relating to broadcasts?

The online environment, and the conventions of the people who engage regularly with it, differ in many ways from the technology and viewers’ and listeners’ experience of television and radio. The differences may have an on how audiences engage with traditional content providers like the ABC. The internet makes available an enormous diversity, and quantity, of content – far beyond what is possible through radio and television services. Unlike broadcast (“push”) content transmitted to a passive audience, online users can actively choose what to access (or “pull”) and when. Availability of programs is no longer limited by time or place. Online content is accessible to a global audience on a “24/7” basis. Online audiences

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ABC Editorial Policies seeking to interact need not wait for a talkback program to begin, or for a studio audience to be assembled. Anyone equipped with a computer and the internet can participate online, at any time of day or night.

Blogging and other participatory technologies26 are readily available to enable users not only to publish their own content online, but also to engage and interact with other individuals and content providers. Users (or “the people formerly known as the audience”27) can participate more readily online as the technologies become increasingly easy, simple and cheap to use. It seems to take little effort to submit comments and feedback when all that is required are a few strokes of the keyboard, rather than having to put pen to paper, stamp to envelope, and envelope to postbox.

Participants contributing comments to blogs can also become quite impassioned about particular topics in ways that are perhaps evident in other areas of audience interaction (such as talkback radio). Unlike talkback though, bloggers can engage with and debate other audience members in discussions that can persist for lengthy periods of time. At times, user contributions can degenerate into personal attacks, but then others may enter the fray and lift it to a more civil and considered discourse. For an amusing illustration of the way blogs can ebb and flow in this way, see Paula Scher’s Op-Art in , “Diagram of a Blog” (http://www.nytimes.com/imagepages/2007/04/04/opinion/05opart.html).

What do these changes mean for editorial decision-making, as the ABC operates increasingly in the “blogsophere”?

If we take it for granted that user comments that threaten, vilify, defame or are otherwise unlawful can be recognised and will not be published knowingly by the ABC, questions still remain.

How should we treat other types of challenging content – strong language or other content that may disturb, distress or offend? Do online audiences have a higher level of tolerance for challenging language and images that they can choose to access than audiences used to the traditional “push” model of broadcasting?

Given the “always on” nature of the internet, how can we identify a “target audience” whose sensibilities are relevant to determining suitability and any need for editing or warnings? Should we instead be guided by the “likely audience” – that is, the audience that is likely to view the material, rather than the audience that the material is designed to attract? If so, how do we reliably tell them apart?

Should we assume all online content is potentially viewed by children?

Will the nature and extent of editorial decision-making depend on the nature of the blog – the personality of the host, the topics selected, and the aim or purpose of the blog?

Do participants in online discussions expect their comments to be speedily posted, to ensure a timely debate can ensue while the topic is still pertinent? Is it essential, or even practicable, to review all comments prior to posting – including when hundreds or thousands of emails are received in a short period of time?

Is the ABC expected to provide a high standard of discourse across all its platforms, encompassing all content whether created by the ABC or contributed by its users? How selective should the ABC be when assessing which audience comments will be posted? Should user comments be edited to allow for greater readability or relevance to the topic under discussion?

Are expectations of blogs maintained by the ABC different from those maintained by others within or outside of the media?

Recent audience research carried out by the BBC found that, while teens prefer less strictly controlled user- generated spaces (e.g., YouTube), there was a general view that the BBC was expected to strictly moderate all content before making it available on the BBC website. The BBC was expected to “set the standard in this area and lead by example”, and was recognised as having high standards in contrast to other UGC sites (such as MySpace). Do Australians expect the same of the ABC?

Do audiences expect the ABC to be fully responsible for the comments of its audience members? Or does the public accept that audience members are speaking for themselves and instead judge the ABC on how it

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ABC Editorial Policies reacts to published comments? For example, do they judge the ABC on how swiftly it removes comments that may be, say, hate speech, and, where appropriate in the circumstances, takes steps such as excluding the individual responsible from participation in the particular ABC hosted site?

How should we deal with the diversity of perspectives across our online audience? What does impartiality require in this new media space?

The BBC Trust recently suggested28 that some space should be allowed on its platforms for polemical and controversial views, provided they are honestly and rationally held.

4. Question 4: Assuming we should moderate, how?

One feature of blogs, and a prevalent expectation of participants to blogs, is immediacy. They want comments posted live or close to it. This of course raises issues about liability for content and presumptions of trust. Three models of moderation are commonly considered. Pre-moderation means everything is assessed before it is posted. This takes time. A post-moderation model, involving review of users’ comments after they are published, allows quicker posting and assumes a higher level of trust than a pre-moderation model. A reactive moderation model, often used in conjunction with post-moderation, relies on readers reacting to inappropriate comments by sending an alert or complaint to the host organisation.

The manner in which audience contributions to blogs are monitored and the penalties imposed (in the case of inappropriate comments) can have a serious impact on the entire community’s willingness to engage in blogs. If the host’s response is seen as being heavy handed or an attempt to stifle comment or contributions, users have been known to revolt.29 In some cases, newspaper blogs have had to be suspended30 or shut down31 because a group of users refused to behave. Media organisations have faced criticism for removing comments.32 So organisations have exercised greater control over their blogs, some by requiring registration,33 or banning users34, or re-publishing only those comments that complied with their standards,35 or revising their guidelines, or a combination of such measures.36

The ABC’s current Editorial Policies indicate the preferred model is pre-moderation, although approval can be sought for post-moderation (Section 9.2.2). The ABC provides moderation training and has developed a “Community Content Management and Moderation Policy”, which is available on the ABC intranet (http://nm/moderation/) along with other support material. This Moderation Policy (http://nm/moderation/1.Community%20Content%20Policy.doc) states that, while the moderators can edit contributions to remove identifying information (e.g., email addresses) or links from posts, editing the body of a message is discouraged.

The ABC’s escalation of response to inappropriate user contributions is set out in our procedures document, “Online Moderation of Audience Contributed Content” (http://nm/moderation/4.Online%20Moderation.doc). Disciplinary measures include:

• sending an email to users alerting them (or reminding them) to the ABC’s Conditions of Use;

• holding users’ posts in the moderation queue for increasing periods of time (“for seconds, minutes, days, weeks, months, years and forever”);

• locking or deleting the registration of persistent offenders; and

• in the case of repeated breaches or serious offenders, contacting the user’s Internet Service Provider and/or instigating legal action.

What are the pros and cons of maintaining strict control over users’ comments? How does the ABC avoid the collision of “two important journalism values – free, unfettered comment and civil, intelligent discourse”37?

Dr Roy Peter Clark, Vice-President of the Poynter Institute, a leading U.S. media ethics centre, suggests a number of frameworks that might assist in developing standards that align with an organisation’s values:

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ABC Editorial Policies

Frame #1. The Freedom Frame: Those who see the problem through this frame value freedom of expression as a primary value. They sometimes cite the First Amendment, an argument that may confuse the right to speak with the duty to publish. Democracy is messy and impolite, they argue. Over time civility has been used as a weapon of oppression against words or ideas at the margins of acceptability or antagonistic to the status quo. Our ability to tolerate even obnoxious expression is a sign of our strength. While traditional newspapers provided few opportunities for public comment and expression, the Internet has democratized expression as never before. The examples of crude extremism should be interpreted not as a vice of new media, but as a virtue. Obnoxious speech can be tolerated, even if it's not encouraged.

Frame #2. The Responsibility Frame: Those who see through this frame argue that with all freedoms come responsibilities, not just for news organizations, but for any person who chooses a public platform for expression. Responsible restraint includes not publishing certain military secrets, or directions for building bombs, or promoting the abuse of children, or threatening someone's life. In our day, it also includes taking special care with language that insults a person on the basis of race, gender and other familiar categories of identity. Through this frame, words like community, dialogue and conversation are valued -- sometimes at the expense of unfettered speech. The worry is that crude or hateful speech crowds out responsible speech and chases away many who might want to be included. Obnoxious speech, they argue, crowds out reasonable speech.

Frame #3. The Business Frame: Those who see through the business frame invoke a duty to create healthy, profitable news enterprises. They argue that we are in the midst of a technological and media revolution in which news Web sites will soon become the first place most people turn for breaking news. While newspapers experience drops in circulation and advertising revenue, more money is being made on the Web -- but, right now, not enough to offset the losses experienced in traditional media. Who will pay for good journalism? What does a viable new business model look like? What we need, they argue, is more and more business on the Web, more and more eyeballs on the page. On the Internet, readers demand interactivity. Unbridled comment sections are central to the culture of new media. Some controls are necessary and desirable, but current budgets cannot afford the manpower necessary to preview hundreds of comments in advance of publication. Nor do they want to assume the legal responsibilities that come with the decision to preview and edit public commentary.

Frame #4: The Journalism Frame: Those who see through this frame argue that, while journalism changes all the time, some values in the practice of journalism should endure -- even when challenged by social, political and technological shifts. One traditional value requires journalists to check things out before publication. Journalists also value the process of editing, protocols of judgment based on experience and buttressed by sets of standards and practices. To support their arguments, they would cite cases in which people's lives and reputations were damaged by lies, fabrications, misrepresentations, identity piracy or threats online. They would likely argue that -- at least within journalism Web sites -- a culture of civil discourse must be encouraged and enforced, that new- media owners must provide the resources necessary to make this work.

Frame #5: The Self-Policing Frame: Those who see through this frame argue that there is wisdom in the collective, that truth can be achieved over time, and that the best online communities of interest are self-regulating. They cite evolving practices that have helped shape, in a short period of time, the cultures, communities and markets expressed via the Internet. These practices, they argue, help correct the record; hold traditional journalists' feet to the fire; marginalize the worst offenders; give authority to the most reliable commentators; and democratize a process that in the hands of traditional journalists has become something of a self-anointed priesthood. 38

The approach adopted by other organisations may also prove instructive. The Poynter Institute recently asked news organisations how they deal with users’ comments, receiving responses from the Wall Street Journal, the New York Times and , among others.39 Some review users’ comments prior to posting (pre-moderation), while some do so after publication (post-moderation). Many enlist the assistance of readers to identify objectionable comments (reactive moderation). Users are not always required to register before submitting comments. Some are fairly strict about which comments they post, and whether they will edit these.

The Wall Street Journal moderates their blogs (http://blogs.wsj.com/) differently from the way they moderate their forums (http://forums.wsj.com/). Users can post comments onto their blogs without having to first register, and they are free to comment on any item they wish. Forums require registration, and they are generally attached to questions of the day or particular columns published online or in print. Comments posted on blogs and forums are all checked for profanity and other “nasty stuff”, but a fairly tolerant approach is taken to erring on the side of allowing discussion rather than inhibiting it. Spelling and grammar are not edited. Not all news stories are open for comments.

The New York Times pre-moderates its blogs (http://www.nytimes.com/ref/topnews/blog-index.html), reviewing “every single comment readers send in”.40 This approach is viewed as a service to their readership, who are “well-informed, passionate and more often than not highly articulate”. Moderation aims

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ABC Editorial Policies to “weed out the tenacious few who would try to derail the conversation”. It is acknowledged that there are some costs to this effort,41 and that they are still experimenting with various formats, “but our standards and commitment to civility are unwavering”. The vast majority of comments are published, and (unlike traditional letters to the editor) are not edited. Personal attacks, profanity and vulgarity are not tolerated. Moderators’ assessment of offensiveness may differ, but they “lean on the side of good taste and respectfulness”. Users seeking to post a comment must provide a name (preferably a real one42) and email address, although the email address is not published. Moderating comments prior publication, even when done quickly, is still seen as “not fast enough for some used to instant gratification”.

The Washington Post post-moderates its blogs (http://www.washingtonpost.com/wp- dyn/content/opinions/columnsandblogs/index.html). They acknowledge that they’re still working on how to deal with “the very serious and very real issues created by bad actors in our commenting areas”. A profanity filter is used, but otherwise issues are picked up after publication. Readers are invited to report offensive comments, using an email link that is included with all comments. Some areas are closely watched by moderators, such as stories that run off of the home page and subject areas such as politics and local crime. Users posting comment are required to provide a name.

The Guardian Unlimited requires user registration for its blogs (http://blogs.guardian.co.uk/index.html). The Guardian outlines its approach to user comments in its recently revised43 “Talk Policy” (http://www.guardian.co.uk/talkpolicy/0,,210609,00.html). The aim is to encourage discussions that are “lively, entertaining and, above all, intelligent” and to foster a community that “is inclusive and safe, as well as being a platform for vibrant discussion”. Comments are moderated after publication, as the volume of comments makes it impractical to pre-moderate without the discussion “grind[ing] to a halt”.44 A combination of post- and reactive moderation is used, where moderators patrol discussions and respond to user complaints about offensive or unsuitable comments. Each user comment includes an email link for complaints to be made. Postings will be removed when they are racist, sexist, homophobic, potentially defamatory or in breach of copyright of another law, or are obviously commercial or spam-like. While encouraging a diversity of views, content may be removed where other users find it extremely offensive or threatening. The Guardian “actively discourages obscenity and mindless abuse”. Comments that are not relevant to the discussion may be removed. Long-running discussions may be diverted into new threads, closed and/or deleted. Comments that are not in English may be removed. Greater emphasis is given to user moderation than under the previous Talk Policy. The Guardian revised its approach to moderation, in recognition that a “different kinds of user interaction mean that a one-size-fits-all system of moderation would not be the best solution…. Some discussion threads will need more attention than others.”45 The new Talk Policy also details the various responses the Guardian may take to manage user interaction, including editing some or all of a posting or discussion thread, warning and banning users, or simply joining the discussion to focus or refocus the conversation.

CBS News also requires user registration for its blogs (http://www.cbsnews.com/stories/2007/01/03/blogs/main2327516.shtml), where both a name and a real email address must be provided . CBS News sets out its approach in its Rules of Engagement (http://www.cbsnews.com/stories/2005/10/20/utility/main959709.shtml), the tone (but not the substance) of which is slightly varied across some of its blogs.46 While “heated, robust debate” is encouraged, users are expected to be polite and civil:

Here’s the plain English: no libel, slander, no lying, no fabricating, no swearing at all, no words that teenagers use a lot that some people think aren't swearing but we do, no insulting groups or individuals, no ethnic slurs and/or epithets, no religious bigotry, no threats of any kind, no bathroom humor, no comparing anyone to Hitler, Stalin or Pol Pot.

A combination of post- and reactive moderation is adopted. Language filtering programs are used to block certain words. CBS News will remove any comment that they believe breaks the letter or spirit of its rules. Users are invited to on a “report abuse” button which is located under each comment.

In October 2005, BBC News took the “revolutionary” step of relaxing its approach to content moderation by allowing some users to post directly to its site without prior review. The comments would instead be reactively moderated, where readers are asked to report inappropriate content and material that breaches house rules. The change was prompted by the volume of comments received, the inability to look at them all and consequently the arbitrariness and unpredictability of selecting what was published, and the desire to provide a better and more diverse experience for users. At the time, the BBC received an average of

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ABC Editorial Policies

6000 comments a day, and up to 20,000 on a busy news day, but only about 10% of those were published.47

The BBC’s policy on moderation is set out in its Online Services Guidelines (http://www.bbc.co.uk/guidelines/editorialguidelines/onguide/interacting/moderation.shtml), which allow for a range of moderation techniques to be used, including pre-, post- and reactive moderation. Sites may move in and out of the various forms of moderation for limited periods of time. Generally, pre-moderation is used for sites dealing with particularly sensitive areas (e.g., health issues) or which are designed to appeal to children. Post-moderation is seen as suitable for sites which attract robust debate about current affairs. This form of moderation is seen as providing a sufficient degree of scrutiny for sites where there has been “a history of controversy or polarised debate, personal or racist abuse or potentially defamatory comments”. Generally, comments that are post-moderated must be checked within an agreed time period, which can be varied to take into account the expectations of the audience and sensitivity of the site. Moderation by the audience (reactive moderation) is used for topics that are not likely to attract polarised or extreme responses (e.g., gardening), where greater self-regulation is seen as appropriate, such as in the case of an “active, mature online community where few messages have to be removed”.

It may be that the ABC’s preference for pre-moderation in the current Section 9 of the Editorial Policies may not be sustainable in the long-term, and may not be the desirable starting point for all blogs. Should post- and reactive moderation models be encouraged? Should we allow some blogs to be moderated primarily by our audience?

What criteria are relevant to determining which model of moderation we adopt for a particular blog? Relevant factors might include:

• the contentiousness of the topic;

• whether vigorous debate and diverse perspectives are sought;

• the general tone and civility of the discussion that has occurred in the past, or is expected to occur;

• the sensibilities and expectations of the target (or likely) audience;

• any risk of legal liability;

• whether contributors are already known to, or registered with, the ABC;

• potential impact, good or bad, on the ABC’s brand;

• the volume of user comments;

• the effect delay in posting might have on discussion; and

• the availability and resourcing of trained moderators.

If we are able to post-moderate, what circumstances should that be allowed, and under what conditions? Should we require user registration? Would this assist in promoting at atmosphere of civility and respect amongst users? How should disruptive users be handled? Are there additional or alternative approaches to those set out in our Online Moderation procedures?

5. Question 5: How should we (and our audience) facilitate access to the best of the comments and foster productive discussions on our blogs?

When the BBC began using reactive moderation, it also equipped its Have Your Say audience with the ability to recommend postings that audience members thought were useful or interesting. Recognising that typical readers might only scan a handful of comments, the recommendation system was seen as a way to enable the audience to more efficiently browse the best content and also become more involved in the discussion by flagging comments of interest.48 Registered users are invited to click a “recommend” button

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ABC Editorial Policies

below each comment in the Have Your Say forum. The most recommended comments rise to the top of the “Readers Recommended” list.49 The Have Your Say site also shows the “debate status”, which indicates how many comments a particular topic attracted, how many were published, how many rejected, and how many are awaiting moderation.50 (An example of the “Readers Recommended” list and Debate Status is available at http://newsforums.bbc.co.uk/nol/thread.jspa?sortBy=2&threadID=6686&edition=2&ttl=20070711064736&.)

Other models for audience moderation and ratings systems used elsewhere include:

• The Slate Magazine’s The Fray (http://fray.slate.com/discuss/) categorises audience discussions according to three criteria: most read, editor’s picks, and highest rated. This system has been regarded as “extremely valuable for a forum where topics and threads are voluminous and diverse…. In particular, highlighting editors' picks appears to be a pretty effective positive incentive for constructive, insightful posts.”51 The audience rating system allows users to recommend interesting and thoughtful topics and recommend against ones that are irrelevant or abusive. Each user can rate a topic only once. A net rating is given which, if above a certain value, places the topic in the recommended posts filter.52

• Slashdot (http://slashdot.org/) developed its audience moderation system as it became more popular. The increasing volume of comments (thousands a day) was accompanied by an increasing number of users posting abusive and annoying comments. Realising they could not resource the number of moderators needed to keep up with the volume, Slashdot decide to enlist a randomly chosen selection of moderators from the group of long-time, regular users. Moderators are given a certain number of points to use within a limited time and can rate comments on a scale of -1 to 5. Slashdot editors also moderate, but they constitute only about 3% of all moderation and they tend to focus on the more extreme cases which require a more focused and immediate response.53

In weighing the virtues of methods like these, it is important not to assume that popularity will necessarily be a definitive test of value. As can happen in other media contexts, interest groups may organise to try to ensure that their favored message is falsely given the appearance of having widespread support. Since these tactics can never be eradicated (and democracy is in any event an untidy business), a mix of methods may be the wisest.

Should we think about moderation not only in the sense of what should not be published, but also in the sense of raising the visibility of useful or insightful comments? How can the ABC encourage the best of audience contributions to rise to the surface? If users’ comments are to be promoted (or demoted) on the ABC site, is this an endeavour that we can share with our readers? Or is something for which ABC editors alone should be responsible? Is it helpful to categorise comments by popularity, irrespective of tone or quality?

6. Question 6: If we invite audience members to help us handle blogs, how do we best support them? Should we look at partnering with independent bloggers instead?

Blogging requires resources, including any set-up costs, time spent by ABC staff authoring blog postings as hosts or overseeing invited non-ABC hosts, and time spent reviewing links to external sites and moderating comments. And, as discussed in Part 4, a degree of legal risk may attach to content that we publish or include on ABC sites.

To what extent are community members or groups going to be invited to host a blog for the ABC? Are they expected to be familiar with the ABC’s Editorial Policies and other obligations? If so, how is this achieved? What challenges (if any) arise from using non-ABC staff as hosts for blogs operated by the ABC?

Should we consider engaging our audience through partnerships with third-party blogging and other social media platforms, such as those listed at the end of Part 3 of this paper? In what circumstances should this approach be considered? Would it be a preferred option for blogs hosted by invited commentators in the community (such as parents or students)?

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ABC Editorial Policies

While distancing the ABC from its commentators through the use of third-party platforms may minimise some of the resourcing and liability issues, are there some costs too? Al Jazeera English is currently utilising YouTube (http://www.youtube.com/aljazeeraenglish) to invite individuals to post video comments about their channel and programs, with the intention of broadcasting some of these on television. It has been suggested that this kind of “outsourcing of interactivity” creates the risk of inviting, and being unable to control, incivility to the detriment of those who wish to respectfully contribute to the discussion initiated by Al Jazeera.54

CBC’s “Great Canadian Wish” partnership with Facebook has also been criticised. Initially set up as a forum for Canadians to express their hopes and dreams for a future Canada in anticipation of the country’s 140th birthday,55 the conversation became “dominated by political causes usually associated with Christian conservative or right-wing groups”.56 While some saw this as a “perversion of populism”,57 others saw it as an interesting experiment that provided an opportunity for people with something to say to do so – “including people with unpleasant views, or those whose opinions we disagree with.”58

Should we consider models like the BBC’s Manchester Blogs Project, which facilitate links with bloggers who publish on externally-hosted blog networks, and requires the bloggers to abide by the BBC’s editorial guidelines in return for accessing workshops on content development and gaining access to the BBC’s audience?

7. Question 7: Should we more readily allow linking to external sites?

One of the features of blogs is the use (by the host and users alike) of links to external websites and sources of information. While the ABC’s Editorial Policies suggest a willingness to publish links to external sites after careful consideration, the ABC’s Conditions of Use actively discourage audiences from doing the same.

Links are addressed in Section 9.1 of the Editorial Policies. External links may be published where:

• there is a clear editorial context for doing so;

• the links have been regularly reviewed to ensure they remain appropriate and relevant;

• linking to a range of views is aimed for;

• suitable warnings are included where the content may be offensive or otherwise challenging;

• special care has been taken in relation to ABC children’s sites and the use of commercial links; and

• viewers are alerted that they are about to leave the ABC site for an external commercial site.

The ABC’s Conditions of Use (http://www.abc.net.au/conditions.htm) indicate a presumption against publication of such links when submitted by participants to interactive forums:

2.3 If you wish to refer to material on someone else's website we recommend you include an attribution in your message. The ABC publishes links to other websites at its sole discretion. Unless otherwise advised the ABC will not publish external links in its guestbooks or forums.

Most ABC interactive features (guestbooks, forums and message boards) will delete references to external sites before posting user comments. The reason for caution is the perceived risk that the external site will change. The site may change ownership or be revised so that the original content linked to is replaced with inappropriate content.

The inclusion of links has also been seen as potentially creating misperceptions in that, in the words of an online reporter for a U.S. media organisation, it “might give readers the impression that we're somehow associated with that linked Web site, or that we were giving free advertising.”59

However, some see the inclusion of external links more as a service for readers. Failing to include a direct link to something mentioned in a story frustrates and alienates the audience. Sending readers to other sites

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ABC Editorial Policies may give reciprocal value: “in online media, you only get what you give. If you don't give many relevant links, it's unlikely you'll get many in return.”60

Should some aspects of the Editorial Policies be revised to acknowledge that users tend to be more savvy about the way the internet operates these days? For instance, is it still necessary to alert viewers to the fact that, when they click on a link, they are about to leave the ABC site for an external one? How regularly should we review external sites to ensure they continue to be relevant and appropriate? Should we do it at all, after the initial check? Can we take for granted that audiences understand that the ABC is not responsible for the content on a site that is linked to, and use appropriate disclaimers to that effect?

Would it assist if there were more specific criteria to guide decision-makers in assessing when external links should be permitted? See, for instance, the BBC’s criteria for linking to external sites or content (http://www.bbc.co.uk/guidelines/editorialguidelines/onguide/editorial/criteriaforlink.shtml)61:

Criteria for linking to third party sites will vary to some extent depending on the reason for offering the link. In general terms, the external site should: • be relevant to the BBC content from which a link is envisaged • meet the needs of a UK-based audience • meet the expectations of the likely audience. For example, a link from a BBC site which is likely to appeal to a high proportion of children should contain content which is suitable for children. It should not contain content which is clearly unsuitable for children • be regularly reviewed and refreshed where necessary • normally be free to access.

The BBC also commonly uses disclaimers on its blogs to make clear that the BBC is not responsible for the content on external sites (http://www.bbc.co.uk/guidelines/editorialguidelines/onguide/editorial/disclaimers.shtml).

The CBC similarly uses disclaimers for external links and its links policy (http://www.cbc.radio- canada.ca/accountability/journalistic/links.shtml) strongly acknowledges their utility by stating:

Hypertext links are fundamental to the presentation of online information and can provide opportunities for enhancing stories, providing users with context, perspective, additional information and a diversity of views.

Following the Poynter Institute’s Critical Issues Conference in August 2006, 62 an ad hoc group of conference attendees (Thomas Brew from MSNBC.com, Lea Donosky from The Atlanta Journal- Constitution, Robert Cox from the Media Bloggers Association, and Eric Deggans from the St Petersburg (Florida) Times) set up a wiki to draft guidelines and protocols on linking.63 These were later incorporated into Poynter’s Online Ethics Guidelines wiki (http://poynter.editme.com/ethicsonline). Their approach to the issues already discussed is instructive and worth quoting in full:

Linking is at the core of the Web experience, tying together content that allows readers to discover unexpected treasures and contextual information that can't comfortably fit into print and broadcast paradigms. But linking also comes with challenges for media organizations. Until now, content was easily classified -- it was in the paper or it wasn't; it was broadcast on the air or it wasn't. Linking has created a netherworld in which media companies can point to sites without assuming responsibility for their veracity or standards. It has also provided media sites with ways to expose their readers to content that falls outside of their own standards -- such as with the Nick Berg beheading and the Muslim cartoons run by Jyllands-Posten -- while still claiming that they didn't "run" the content themselves. So how do media sites embrace linking without compromising their core values?

Principles & Values

• A link to an external site does not signify and [sic] endorsement of that site or its point of view. It is merely a signal to the reader that there may be content of interest on the destination site.

• Despite this, media sites should make it clear to their readers -- in the user agreement, site guidelines or via some other method -- that there's a difference in standards between the content that resides on their own site and the content they link to.

• Because of the spider-like nature of the Web, media sites can't be expected to apply even these relaxed standards to the content of sites that are linked to from sites we link to (the two-click rule).

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ABC Editorial Policies

• When readers put their own links to content in message boards, blog posts, etc., those links should be considered user-generated content and subject to the same controls.

• We encourage all media sites to link to external sites. Linking off-site is an extension of your site's user experience and fosters a feeling of openness that's conducive to repeat visits. Trying to keep readers within just your site is a losing proposition.

• When linking, sites should not be forced into including links that support all sides of an issue. While news articles themselves should adhere to the traditional standards of fairness and accuracy, assuring balance in links run counters [sic] to the concept of providing only useful links to the reader.

Protocols

When deciding whether to links [sic] to other parts of your own site, ask yourself the following questions:

• Is this content being linked to relevant to someone who would be reading/viewing this content?

When choosing whether to include a link to another site, ask yourself the following questions:

• Is the linked content relevant for someone who would be reading/viewing this content?

• Does the content being linked include content that could potentially fall within the realm of libel or slander?

• If the content being linked to falls outside the standards of your site, should you include notification of that fact (i.e., notify users of profanity, nudity, etc.)?

Assuming more linking than the current Section 9 of the Editorial Policies and ABC’s Conditions of Use envisage, what risks are foreseeable? How might they be mitigated?

8. Question 8: Is sufficient guidance already provided for staff who have personal blogs or who contribute to independent (non-ABC) blogs?

A number of ABC staff write and publish their own blogs or contribute as users to non-ABC blogs.

The ABC recognises that staff, as members of the community, have a right to make public comment on matters that affect them (ABC Workplace Values and Code of Conduct, Section 6). The potential for personal blogs to affect the work of staff, the editorial integrity of ABC programs, or the reputation of the ABC is addressed by the Editorial Policies (Section 4.4) and Workplace Values and Code of Conduct (Section 9).

Employees of Dow Jones & Co., owner of the Wall Street Journal, are similarly required to abide by a Code of Conduct that addresses the issue of public comment in the context of “Political and Civic Activities”:

All news employees and members of senior management with any responsibility for news should refrain from partisan political activity judged newsworthy by their senior editor or in the case of senior management, the Chief Executive Officer. Other political activities (including "issue oriented" activity) are permitted, but should not be inconsistent with this code.

On the other hand, it is not the intention of Dow Jones, or of this code, to dissuade employees from participating actively in civic, charitable, religious, public, social or residential organizations. Such activities are permitted, and even encouraged, to the extent that they:

• Do not detract from performance or effectiveness at work; • Do not, by their extensiveness, cause the Company to subsidize or appear to subsidize the activity; and • Do not otherwise violate this code. In the event that a conflict arises or may arise between an outside organization with which an employee is affiliated and the interests of Dow Jones, the employee should refrain from participating in the conflicting or potentially conflicting activity.

No Dow Jones employee should permit his or her Dow Jones affiliation to be noted in any outside organization's materials or activities without the express written approval of a member of senior management or unless of course the employee serves as a representative of Dow Jones or unless the affiliation is noted as part of a broader description of the employee’s identity.64

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ABC Editorial Policies

Personal blogs have also been set up by staff at both the BBC and CBC. In many of these, the bloggers identify themselves as working at the public broadcaster. See, for instance, blogs run by BBC journalists and other staff including Robin Hamman’s cybersoc (http://www.cybersoc.com/), Jem Stone’s Common User (http://commonusers.blogspot.com/), and Martin Asser’s Blog (http://martinasser.blogspot.com/). See also Planet CBC (http://peterjanes.homeip.net/cbc/), an automated digest of a number of CBC employee blogs.

Although the CBC does not provide specific guidance about personal blogs, the BBC does. In 2005, a set of guidelines on employee blogs and websites was developed by the BBC in consultation with its staff (through the use of a “wiki”).65 These guidelines (http://www.bbc.co.uk/guidelines/editorialguidelines/advice/weblogswebsites/) acknowledge that BBC staff may want to take part in blogs as a form of public conversation, and they state that staff are expected to behave in accordance with the BBC’s editorial values and policies if they clearly identify themselves as working for the BBC and/or discuss their work. The guidelines are intended to complement the BBC’s editorial policies dealing with conflict of interest.

In Canada, a lack of specific guidance in the CBC’s Journalistic Standards and Practices (http://cbc.radio- canada.ca/accountability/journalistic/index.shtml) prompted a number of CBC bloggers to collaborate in 2006 to draft what they called the “CBC Blogging Manifesto”. The Blogging Manifesto came about in part because some staff viewed the Journalistic Standards as too restrictive and not sufficiently tailored to deal adequately with this form of new media.66

The New York Times Company’s Policy on Ethics in Journalism (http://www.nytco.com/press/ethics.html) provides extensive guidance about activities engaged by staff in their own time. A specific section is included on “Web Pages and Web Logs”, which states (at paras 126-131):

Web pages and Web logs (the online personal journals known as blogs) present imaginative opportunities for personal expression and exciting new journalism. When created by our staff or published on our Web sites, they also require cautions, magnified by the Web's unlimited reach.

Personal journals that appear on our official Web sites are subject to the newsroom's standards of fairness, taste and legal propriety. Nothing may be published under the name of our company or any of our units unless it has gone through an editing or moderating process.

If a staff member publishes a personal Web page or blog on a site outside our company's control, the staff member has a duty to make sure that the content is purely that: personal. Staff members who write blogs should generally avoid topics they cover professionally; failure to do so would invite a confusion of roles. No personal Web activity should imply the participation or endorsement of the Times Company or any of its units. No one may post text, audio or video created for a Times Company unit without obtaining appropriate permission.

Given the ease of Web searching, even a private journal by a staff member is likely to become associated in the audience's mind with the company's reputation. Thus blogs and Web pages created outside our facilities must nevertheless be temperate in tone, reflecting taste, decency and respect for the dignity and privacy of others. In such a forum, our staff members may chronicle their daily lives and may be irreverent, but should not defame or humiliate others. Their prose may be highly informal, even daring, but not shrill or intolerant. They may include photos or video but not offensive images. They may incorporate reflections on journalism, but they should not divulge private or confidential information obtained through their inside access to our newsroom or our Company.

Bloggers may write lively commentary on their preferences in food, music, sports or other avocations, but as journalists they must avoid taking stands on divisive public issues. A staff member's Web page that was outspoken on the abortion issue would violate our policy in exactly the same way as participation in a march or rally on the subject. A blog that takes a political stand is as far out of bounds as a letter to the editor supporting or opposing a candidate. The definition of a divisive public issue will vary from one community to another; in case of doubt, staff members should consult local newsroom management.

A staff member's private Web page or blog must be independently produced. It should be free of advertising or sponsorship support from individuals or organizations whose coverage the staff member is likely to provide, prepare or supervise during working hours. Care should be taken in linking to any subject matter that would be off limits on the Web page itself.

To the extent that ABC staff write and publish their own blogs, in which they identify themselves (or are readily identified) as an employee of the ABC, or submit comments to independent blogs about their work at the ABC, do the current Editorial Policies and Workplace Values and Code of Practice adequately deal with the issues that arise? If not, what would improve the guidance?

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B. How you can make a submission

The aim of this Consultation Paper is to tap into the experience and insight of ABC staff and seek your views about the challenges and issues raised by blogging. Some of these issues are identified in this paper. You are encouraged to suggest more. Your feedback will contribute to the development of editorial policy guidance in this area. The outcome of this consultation may also highlight other areas of interactivity and UGC that may require or benefit from more guidance.

Comments should be sent by email to [email protected] by 28 August 2007.

PAUL CHADWICK Director, Editorial Policies

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Endnotes

1 Dan Gillmor, “The Read-Write Web: Technology that Makes We the Media Possible”, Chapter 2 in We the Media: Grassroots Journalism by the People, for the People, July 2004, http://www.authorama.com/we-the-media-3.html. [Note: a pdf printable version of the chapters of this eBook is available at http://www.oreilly.com/catalog/wemedia/book/index.csp.] 2 BBC Trust, From Seesaw to Wagon Wheel: Safeguarding Impartiality in the 21st Century, June 2007, pp 15-16, http://www.bbc.co.uk/bbctrust/research/impartiality.html. 3 Defamation, copyright and contempt are just three areas of law that have been affected by the internet: see the High Court of Australia defamation case of Dow Jones & Company Inc. v Gutnick [2002] HCA 56, http://www.austlii.edu.au/au/cases/cth/HCA/2002/56.html; and the UK House of Lords libel case of Jameel v. Wall Street Journal Europe Sprl [2006] UKHL 44, http://www.publications.parliament.uk/pa/ld200506/ldjudgmt/jd061011/jamee-1.htm. See also the copyright infringement, Universal Music Australia Pty Ltd v Sharman License Holdings Ltd [2005] FCA 1242, http://www.austlii.edu.au/au/cases/cth/federal_ct/2005/1242.html, which was ultimately settled in July 2006: relevant media releases and press reports are available at the Australian Copyright Council site, http://www.copyright.org.au/news/newsbytopic/musicnews/u27055/. Contempt charges were threatened in a case involving the online publication of criminal records which led to a Victorian Supreme Court murder trial being aborted: see Rebecca Carmody, “CrimeNet could face contempt charges”, 25 May 2000, ABC’s PM, transcript, http://www.abc.net.au/pm/stories/s131079.htm. Media organisations’ policies about correcting inaccuracies or acknowledging conflicts of interest are under pressure from the blogosphere: see, e.g., Katharine Q. Seelye, “L.A. Times Opinion Editor Resigns”, 23 March 2007, New York Times, http://www.nytimes.com/2007/03/23/business/23paper- web.html?ei=5088&en=81ea30c5965ea591&ex=1332302400&partner=rssnyt&emc=rss&pagewanted=p rint. 4 See ABC’sThe Poll Vault and Election Weblog covering state and federal elections since February 2001 (http://www.abc.net.au/elections/qld/2001/weblog/default.htm). Other historical and current ABC blogs are listed later in this paper. 5 Monica Attard, “Have Your Spray”, 18 June 2007, Media Watch, transcript and video, http://www.abc.net.au/mediawatch/transcripts/s1954733.htm. 6 “Media Watch fails racism test”, 25 June 2007, The Daily Telegraph, http://www.news.com.au/entertainment/story/0,23663,21959678-10388,00.html. 7 See the experiences of The Washington Post and The Guardian: Neil McIntosh (Assistant Editor, Guardian Unlimited), Our new blog will aim to stop the clowns disrupting the circus, 11 February 2006, http://technology.guardian.co.uk/online/weblogs/story/0,,1732472,00.html; Jim Brady (Executive Editor, washingtonpost.com), AskPost.com, transcript, 20 January 2006, http://www.washingtonpost.com/wp- dyn/content/discussion/2006/01/20/DI2006012000566.html; Jeff Jarvis, Jane Hamsher, Jay Rosen, Glenn Reynolds & Jim Brady, Panel: Interactivity Ethics, 25 January 2006, http://www.washingtonpost.com/wp-dyn/content/discussion/2006/01/24/DI2006012400817.html. The LA Times’ earlier experiment using “wikitorials” (editorials that users could rewrite) also ended up with the site being suspended because of inappropriate user postings: Associated Press, “Los Angeles Times suspends ‘Wikitorials’: Users flood paper’s Web site with foul language, pornography”, 21 June 2005, MSNBC, http://www.msnbc.msn.com/id/8300420/. The Washington Post continues to debate how best to handle user comments: Deborah Howell, “Online venom or vibrant speech?”, 6 May 2007, Washington Post, B06, http://www.washingtonpost.com/wp- dyn/content/article/2007/05/04/AR2007050401904_pf.html; as does The Guardian: Siobhain Butterworth , “Open door: The readers' editor on ... why we need to keep an eye on website talkboards”, 21 May 2007, The Guardian: Comment is Free, http://www.guardian.co.uk/commentisfree/story/0,,2084348,00.html. 8 See: Aly Colón, “Private and Public: What Journalists Reveal About Themselves”, posted 8 October 2004 and updated 9 October 2004, Poynter Online, http://www.poynter.org/column.asp?id=36&aid=72557; Adam L. Penenberg, “Heartaches of Journalist Bloggers”, 13 January 2005, Wired, http://www.wired.com/culture/lifestyle/news/2005/01/66251. And see the David F. Gallagher,”Reporters Find New Outlet, And Concerns, in Web Logs”, 23 September

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2002, The New York Times, http://query.nytimes.com/gst/fullpage.html?sec=technology&res=9C04E1DD1739F930A1575AC0A9649 C8B63. 9 Tony Burman (Editor-in-chief of CBC News), “News, opinion and a fuzzy shifting line”, 25 September 2006, CBC Inside Media, http://www.cbc.ca/news/inside- media/2006/09/news_opinion_and_a_fuzzy_shift.html. Also see Jeffrey Brown’s interview of Callie Crossley and Jeff Rosen at “Some Media Shifting to Add Point of View: Media experts explore the trend of media organizations including opinion when reporting the news”, 18 June 2007, PBS’ The Online News Hour, http://www.pbs.org/newshour/bb/media/jan-june07/news_06-18.html. 10 See the “ incident”. Digg (http://www.digg.com) is a user-driven social content website where users can rate what stories they like or dislike. Digg initially complied with a “cease and desist” demand to remove postings that revealed the code for an encryption key that protects HD-DVDs from being copied. This triggered a user revolt by thousands of users. Their reaction led Digg to decide it would no longer delete stories or comments containing the code and would accept whatever legal consequences that resulted: Ryan Singel, “HD DVD Battle Stakes Digg Against Futility of DRM”, 3 May 2007, Wired, http://www.wired.com/entertainment/hollywood/news/2007/05/digglegal?currentPage=all. Digg’s change of heart is illustrated in their same-day postings on their blog, Digg the Blog: Jay Adelson, “What’s Happening with HD-DVD Stories?”, 1 May 2007 at 1pm, http://blog.digg.com/?p=73, followed by , “Digg This: 09-f9-11-02-9d-74-e3-5b-d8-41-56-c5-63-56-88-c0”, 1 May 2007 at 9pm, http://blog.digg.com/?p=74. 11 In this paper, the term “host” is not used to mean “internet content host”, which is defined in internet regulation legislation as essentially meaning someone who stores information on a server or other device in order to make it accessible over the internet. Rather, the term is used here in the context of hosting a blog, a role described by Robin Hamman as “a bit like someone hosting a dinner party in their home. When you organise a dinner party you set the date and theme, invite guests, welcome guests when they arrive at your home, introduce guests who don't know each other, and get friends who might come from different walks of life started in discussions about the things they have in common. Well, that's the way a dinner party is supposed to work. When it doesn't work out well, the host might also jump in and tell someone not to drink so much, or ask one of the guests to quit talking about something that's upsetting the other guests - making a pre-emptive strike before a fight breaks out and the police have to be called! An online discussion host, sometimes called an "online facilitator", particularly in online education circles, has the same role within an online community as the person hosting a dinner party in their home: inviting guests, making people feel welcome and valued, kicking off discussions, feeding information into those discussions, and wrapping up discussions when they seem to come to a logical endpoint” (original emphasis): Robin Hamman, “Moderation and Hosting - What? Who?”, 12 April 2005, cybersoc.com, http://www.cybersoc.com/2005/04/moderation_comp.html. 12 Various forms of citizen journalism are discussed in Steve Outing, “The 11 Layers of Citizen Journalism”, 13 & 15 June 2005, Poynter Online, http://www.poynter.org/content/content_view.asp?id=83126#. These include opening up news items to public comment, soliciting news stories and photos from users, collaboration between citizens and journalists, inviting citizens to write their own blog, encouraging transparency and engagement with newsroom and editorial policy decisions, etc. 13 The BBC’s Action Network is profiled at pages 28-30 in Frontiers of Innovation in Community Engagement: News Organizations Forge New Relationships with Communities, A report from the Center for Citizen Media by Lisa Williams with Dan Gillmor and Jane MacKay, March 2007, http://citmedia.org/reports/newscommunities.pdf. The report’s launch was announced by Dan Gillmor, “New Report Shows How News Orgs Encourage Audience Involvement”, 5 March 2007, Center for Citizen Media Blog, http://citmedia.org/blog/2007/03/05/new-report-shows-how-news-orgs-encourage- audience-involvement/ and an online (html version) is available at http://citmedia.org/frontiers. 14 Ki Elwood, “Final post”, 1 February 2007, BBC’s Action Newtork blog, http://www.bbc.co.uk/blogs/actionnetwork/. 15 Richard Fair and Robin Hamman, “BBC Manchester Blog”, 23 August 2006, BBC Manchester Blog, first posting to the blog, http://www.bbc.co.uk/blogs/manchester/2006/08/bbc_manchester_blog_1.shtml. Robin Hamman is more recently interviewed about the BBC Manchester Blog by Rob Baker in “BBC über blogger has designs on the region”, 25 June 2007, How Do, http://www.how-do.co.uk/north-west- media-news/north-west-digital-media/bbc-%fcber-blogger-has-designs-on-the-region-20070625540/.

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16 Robin Hamman, “Speaking at the european broadcasting union”, 14 March 2007, CyberSoc, http://www.cybersoc.com/2007/03/speaking_at_the.html/. 17 The Great Canadian Wish List is described by Tony Burman (Editor in Chief of CBC News), “Facebook, Student Vote and CBC News”, CBC Inside Media: A Forum about Media Issues, 31 May 2007, http://www.cbc.ca/news/inside-media/2007/05/facebook_student_vote_and_cbc.html. 18 Tod Maffin, “CBC inks deal with Technorati for blog references”, 19 June 2007, Inside the CBC, http://www.insidethecbc.com/technorati. See also Robert Andrews, “Technorati plugs bloggers into CBC”, 25 June 2007, Online Journalism News, http://www.journalism.co.uk/news/story3372.shtml. 19 Broadcasting Services Act 1992 (Cth), Schedule 5. When the Communications Legislation Amendment (Content Services) Act 2007 (Cth) comes into operation, a new Schedule 7 will also be relevantly inserted into the Broadcasting Services Act. 20 The Communications Legislation Amendment (Content Services) Act 2007 was passed by federal Parliament on 21 June 2007 and assented to on 20 July 2007. Parts of the Act came into operation on 20 July 2007, and the remainder will commence within the next 6-12 months. The legislation will, among other things, amend the Broadcasting Services Act 1992 (Cth) (the BSA) to (a) provide for the regulation of content services delivered over convergent devices, such as broadband services to mobile phones, and new types of content provided over the internet, such as live streamed video and other ephemeral content; (b) replace Schedule 5 of the BSA, which regulates stored content that is made available over the internet, to the extent that it regulates Internet content hosts (ICHs); and (c) replace the definition of ICH so as to limit the application of the online regulatory scheme to “designated content and hosting services”. National broadcasting services (including those provided by the ABC under section 6 of the Australian Broadcasting Corporation Act 1983 (Cth)) are expressly excluded from this new definition underpinning the revised regulatory regime. “Broadcasting services” include radio and television broadcasts, but are defined to exclude (i) services that provide no more than data or text; (ii) services that make programs available on demand, on a point to point basis, including through dial-up; (iii) and services exempted under a Ministerial determination. On 12 September 2000, the Minister issued a determination excluding television and radio programs that are streamed over the internet, except for those that use broadband services. 21 Australian Broadcasting Act 1983 (Cth), s. 8(1)(e). 22 Broadcasting Services Act 1992 (Cth), s. 91(1)(a) and (b). 23 “About the Chaser”, 2007, ABC TV The Chaser’s War on Everything, http://abc.net.au/tv/chaser/war/about/default.htm. 24 Simon Waldman, “Realtime blogging”, 11 July 2007, BBC’s The Editors, http://www.bbc.co.uk/blogs/theeditors/2007/07/realtime_blogging.html. 25 Bob Steele, “Helter Skelter No More: An Evolving Guidebook for Online Editors”, posted 31 January 2007 and updated 1 February 2007, Poynter Online, http://www.poynter.org/content/content_view.asp?id=117347&sid=32. 26 Other participatory technologies are available through social networking sites like Facebook (http://www.facebook.com), YouTube (http://www.youtube.com/), MySpace (http://www.myspace.com/), and Flickr (http://www.flickr.com/). 27 Jay Rosen, “The People Formerly Known as the Audience”, 27 June 2006, PressThink, http://journalism.nyu.edu/pubzone/weblogs/pressthink/2006/06/27/ppl_frmr.html, which references the use of the term “former audience” with Dan Gillmor, “The Former Audience Joins the Party”, Chapter 7 in We the Media: Grassroots Journalism by the People, for the People, eBook, 2004, http://www.authorama.com/we-the-media-8.html. [Note: a pdf printable version of the chapters of this eBook is available at http://www.oreilly.com/catalog/wemedia/book/index.csp.] 28 BBC Trust, From Seesaw to Wagon Wheel: Safeguarding Impartiality in the 21st Century, June 2007, pp 37, 42 and 80-82, http://www.bbc.co.uk/bbctrust/research/impartiality.html. 29 See the recent Digg incident, discussed in endnote 10 of this paper. 30 Jim Brady (Executive Editor), “Comments turned off”, 19 January 2006, Washington Post’s post.blog, http://blog.washingtonpost.com/washpostblog/2006/01/comments_turned_off.html.

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31 See the Guardian’s experience: Neil McIntosh (Assistant Editor, Guardian Unlimited), “Our new blog will aim to stop the clowns disrupting the circus”, 11 February 2006, Guardian Unlimited Technology: Editor’s Week, http://technology.guardian.co.uk/online/weblogs/story/0,,1732472,00.html. 32 See the Washington Post’s experience: Jeff Jarvis, Jane Hamsher, Jay Rosen, Glenn Reynolds & Jim Brady, “Panel: Interactivity Ethics”, 25 January 2006, Washington Post, http://www.washingtonpost.com/wp-dyn/content/discussion/2006/01/24/DI2006012400817.html. 33 In the case of the Guardian, see: Jane Perrone (Deputy News Editor, Guardian Unlimited), “News blog introduces comment registration”,12 April 2006, Guardian Unlimited’s News blog, http://blogs.guardian.co.uk/news/archives/2006/04/12/news_blog_introduces_comment_registration.html. 34 Ernst Poulsen, “35 Bloggers Banned from Danish News Site”, 4 July 2007, Poynter Online’s E-Media Tidbits, http://www.poynter.org/column.asp?id=31&aid=126041. 35 Liz Kelly (Editor, Interactivity & Opinions), “Some Comments Returned”, 20 January 2006, Washington Post’s post.blog, http://blog.washingtonpost.com/washpostblog/2006/01/some_comments_returned.html. See also Jim Brady (Executive Editor), “Ask post.com”, transcript, 20 January 2006, Washington Post, http://www.washingtonpost.com/wp-dyn/content/discussion/2006/01/20/DI2006012000566.html. 36 In the case of the Washington Post, see: Washington.post Editors, “Comments Welcome”, 17 February 2006, Washington Post’s post.blog, http://blog.washingtonpost.com/washpostblog/2006/02/comments_welcome_1.html (including link to full posting policy at http://www.washingtonpost.com/wp-srv/liveonline/delphi/delphirules.htm, which has since been revised, with the last update on 12 July 2007). 37 Deborah Howell, “Online Venom or Vibrant Speech?”, 6 May 2007, Washington Post, B06, http://www.washingtonpost.com/wp-dyn/content/article/2007/05/04/AR2007050401904_pf.html. 38 Five differeint frameworks used by news organisations for handling user comments are proposed by Roy Peter Clark in “The Frames of Incivility”, 17 May 2007, Poynter Online, http://www.poynter.org/column.asp?id=103&aid=123281. 39 Pat Walters, “Dealing with Comments: A Few Interesting Approaches”, 31 May 2007, Poynter Online, Dialogue or Diatribe? series, http://www.poynter.org/column.asp?id=103&aid=123155. 40 Jim Roberts, “Talk to the Newsroom: Digital News Editor Jim Roberts”, 25-29 June, 2007 New York Times, http://www.nytimes.com/2007/06/25/business/media/25asktheeditors.html?ei=5070&en=4f100d2069ed4 c0e&ex=1184126400&pagewanted=all. 41 In answer to readers’ questions, Jim Roberts (Digital News Editor) noted that there have been occasions when “bad things slip through”, and that there can be an hour or more delay before comments are approved for posting as they “don’t have a huge squad of people moderating their comments…. and even fewer people doing it at night and on weekends”: “Talk to the Newsroom: Digital News Editor Jim Roberts”, 25-29 June, 2007 New York Times, http://www.nytimes.com/2007/06/25/business/media/25asktheeditors.html?ei=5070&en=4f100d2069ed4 c0e&ex=1184126400&pagewanted=all. 42 Jim Roberts, “Talk to the Newsroom: Digital News Editor Jim Roberts”, 25-29 June, 2007 New York Times, http://www.nytimes.com/2007/06/25/business/media/25asktheeditors.html?ei=5070&en=4f100d2069ed4 c0e&ex=1184126400&pagewanted=all. 43 The revised Talk Policy was announced by Georgina Henry in the Guardian Unlimited’s blog, Comment is Free, at 4.20pm on 19 July 2007: “Rules of engagement: Guardian Unlimited has launched a new talk policy: here are the details”, http://commentisfree.guardian.co.uk/georgina_henry/2007/07/the_past_week_as_regular.html. Readers were quick to react, generating over 300 comments within 24 hours of the announcement. 44 Siobhain Butterworth (The Guardian’s readers’ editor), “Open door: The readers' editor on ... why we need to keep an eye on website talkboards”, 21 May 2007, The Guardian: Comment is Free, http://www.guardian.co.uk/commentisfree/story/0,,2084348,00.html.

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45 Siobhain Butterworth (The Guardian’s readers’ editor), “Open door: The readers' editor on ... why we need to keep an eye on website talkboards”, 21 May 2007, The Guardian: Comment is Free, http://www.guardian.co.uk/commentisfree/story/0,,2084348,00.html. 46 CBS News’ Public Eye open their “Rules of Etiquette” (http://www.cbsnews.com/stories/2005/08/30/publiceye/main805627.shtml) with statement that the rules are “pretty strict”, commit themselves to following them as well, and say that discussion should always be about “news, journalism, public affairs, and politics – public things”. Katie Couric’s blog, Couric & Co, uses softer language in their Rules of Etiquette (http://www.cbsnews.com/stories/2006/08/30/couricandco/main1953621.shtml), opening with a statement that they’re eager to hear from users, similarly committing to abide by the rules themselves, altering the language about the kind of discussion they expect (“lively debate”, rather than “heated, robust debate”), illustrating their discretion to moderate with a football analogy, and encouraging users to keep discussion focused to avoid “wandering into oncoming traffic”. 47 Jemima Kiss, “BBC site braces itself for more open user comments system”, 22 September 2005, Online Journalism News, http://www.journalism.co.uk/news/story1526.shtml. Also see Robert Andrews, “BBC News drops comment moderation”, 24 October 2005, Online Journalism News, http://www.journalism.co.uk/news/story1569.shtml. 48 Jemima Kiss, “BBC site braces itself for more open user comments system”, 22 September 2005, Online Journalism News, http://www.journalism.co.uk/news/story1526.shtml. 49 “About Have Your Say: How does Recommendation work?”, BBC News: Have Your Say, http://news.bbc.co.uk/2/hi/help/4180382.stm. 50 “About Have Your Say: Debate status explained”, BBC News: Have Your Say, http://news.bbc.co.uk/2/hi/help/6499093.stm. 51 Amy Gahran, “Slate's Fray: Making the Most of Discussion”, 19 June 2007, Poynter Online’s E-Media Tidbits, http://www.poynter.org/column.asp?id=31&aid=125042. 52 See the question on how ratings work in “The Fray: Frequently Asked Questions”, viewed 11 July 2007, Slate Magazine’s The Fray, http://fray.slate.com/discuss/help.aspx#ratings. 53 “Slashdot FAQ: Comments and moderation”, last modified 4 June 2003, Slashdot, http://slashdot.org/faq/com-mod.shtml. 54 Steve Petersen, “The Danger of Outsourcing Interactivity”, 10 July 2007, The Bivings Report, http://www.bivingsreport.com/2007/the-danger-of-outsourcing-interactivity/. 55 “The Great Canadian Wish List: Wish launch 2007!”, 28 May 2007, CBC news, http://www.cbc.ca/wish/2007/05/test_entry.html. 56 Tod Maffin (CBC’s technology columnist), “Religious and political ‘wishes’ dominate Facebook experiment”, 18 June 2007, Inside the CBC, http://www.insidethecbc.com/facebookprolife. The Wish List project has now come to an end, with a video broadcast of the outcome, “The final Wish List results”, available at the CBC’s official blog, InsideTheCBC, http://www.insidethecbc.com/wishfinal, 3 July 2007. 57 Elaine Corden, “Is CBC’s New Populism Perverted? ‘Great Canadian Wish List’: homophobic? Why youth fans like me are tuning out”, 21 June 2007, The Tyee, http://thetyee.ca/Mediacheck/2007/06/21/CBC/. 58 Mathew Ingram, “CBC's Facebook Wish List: experiment or disaster?”, 28 June 2007, Globe and Mail’s Ingram 2.0, http://www.theglobeandmail.com/servlet/story/RTGAM.20070628.WBmingram20070628115038/WBStor y/WBmingram. 59 Dee Dee Nilsen, online reporter for the Missouri Springfield Business Journal, quoted in Amy Gahran, “External Links from Stories Are a Service, Not a Threat”, 30 August 2006, Poynter Online’s E-Media Tidbits, http://www.poynter.org/column.asp?id=31&aid=109769. 60 Amy Gahran, “External Links from Stories Are a Service, Not a Threat”, 30 August 2006, Poynter Online’s E-Media Tidbits, http://www.poynter.org/column.asp?id=31&aid=109769.

Consultation Paper 1 – Blogging page 27 July 2007

ABC Editorial Policies

61 The BBC’s Editorial Guidelines also address links in the context of impartiality (http://www.bbc.co.uk/guidelines/editorialguidelines/onguide/impariality/links.shtml), children (http://www.bbc.co.uk/guidelines/editorialguidelines/edguide/children/childrenonlinec.shtml, http://www.bbc.co.uk/guidelines/editorialguidelines/onguide/children/linksbetweenbbc.shtml, http://www.bbc.co.uk/guidelines/editorialguidelines/onguide/children/linkstoexternal.shtml), politics (http://www.bbc.co.uk/guidelines/editorialguidelines/onguide/politics/linkstoexternal.shtml), sponsors' sites (http://www.bbc.co.uk/guidelines/editorialguidelines/onguide/externalrel/coverageofspons.shtml), charities (http://www.bbc.co.uk/guidelines/editorialguidelines/onguide/externalrel/charities.shtml), and harmful or unsuitable content (http://www.bbc.co.uk/guidelines/editorialguidelines/onguide/harm/programmerelate.shtml). 62 “Online Ethics: A Poynter Critical Issues Conference: Participants”, posted 31 January 2007 and updated 5 February 2007, Poynter Online, http://www.poynter.org/content/content_view.asp?id=117353. 63 The Director Editorial Policies tried something similar in early 2007, inviting policy specialists and some staff who were understood to have particular interest or expertise to participate in a wiki. Jimmy Wales, creator of Wikipedia (http://www.wikipedia.org/), also kindly assisted the ABC’s internal discussions about blogging guidelines during his 2007 visit to Australia. 64 Dow Jones & Company Inc., Code of Conduct, as amended 21 January 2004, pages 5-6, http://www.shareholder.com/dowjones/downloads/CG_Conduct.pdf. An online (html) version of this code is available at http://www.shareholder.com/dowjones/governance/documents.cfm, along with other Dow Jones codes and policies. 65 Jem Stone, “New BBC staff blog guidelines”, 5 May 2006, Common User, http://commonusers.blogspot.com/2006/05/new-bbc-staff-blog-guidelines.html. 66 The CBC Blogging Manifesto was developed by Dan Misener, Tod Maffin, Ouimet, Peter J., Justin Beach, Joe Mahoney, John Gushue, Paul Gorbould, Robin Rowland (staff of Canadian Broadcasting Corporation) and can be found at The CBC Blogging Manifesto, posted 14 August 2006, http://cbcmanifesto.blogspot.com/. Background material explaining the genesis for the Manifesto can be found at: Ouimet’s blog, The Teamakers: “Bazay on Blogging”, 31 October 2005, http://teamakers.blogspot.com/2005/10/bazay-on-blogging.html; “CBC Blogging Manifesto”, 14 August 2006; http://teamakers.blogspot.com/2006/08/cbc-blogging-manifesto.html; and “Just call me Lynn MacDonald”, 30 August 2006, http://teamakers.blogspot.com/2006/08/just-call-me-lynn-macdonald.html.

Consultation Paper 1 – Blogging page 28 July 2007