The Public Broadcasting Service (“PBS”) is committed to serving the public interest by providing content of the highest quality that enriches the marketplace of ideas, unencumbered by commercial imperative. Throughout PBS’s history, four fundamental principles have guided that commitment.
- Editorial integrity: PBS content should embrace the highest commitment to excellence, professionalism, intellectual honesty and transparency. In its news and information content, accuracy should be the cornerstone.
- Quality: PBS content should be distinguished by professionalism, thoroughness, and a commitment to experimentation and innovation.
- Diversity: PBS must be responsive to a diverse public and has a responsibility to explore subjects of significance and the marketplace of ideas.
- Local station autonomy: Local decision-making ensures topical and relevant content and allows PBS member stations to reflect the communities they serve.
PBS’s responsibility to the public also demands a continuing understanding of emerging technologies and the changing ways the public consumes information.
The PBS Editorial Standards and Policies that follow explain the best practices and procedures expected across multiple platforms and reflect these core principles and philosophy.
I. Introduction
This document is an update of the Public Broadcasting Service (“PBS”) program policies first adopted in 1971/72 and twice before updated, in 1987 and 2005. While the principles embodied in those policies are enduring and remain as valid today as when they were first adopted, changes in technology, public broadcasting, journalism, public expectations, and experience with the current guidelines necessitate, as the original program policies themselves anticipated, “periodic review of procedures to establish and implement program standards and practices, and a revision of the statement as required.”
In reviewing the PBS Editorial Standards and Policies adopted in 2005 (the “Policies”), the Editorial Standards Review Committee convened by PBS heard from producers and from PBS staff, and found from their own review, that the existing standards were well conceived and remarkably contemporary. The Committee further concluded PBS should continue to operate according to the overall principles articulated in those standards. The 2005 review focused, in part, on how to make the Policies less exclusively concerned with television programming and to address issues raised by digital platforms and the increasing engagement that technology allowed with the public. Five years later it is even more essential to recognize the ways in which new delivery systems, including social media, have affected and will continue to affect the production, distribution, and consumption of content, and the editorial implications of these changes. In that regard, the Committee believed that transparency and integrity should continue to be hallmarks for PBS in its approach and its content going forward.
II. Guiding Principles
The Public Broadcasting Service is a nonprofit membership corporation whose members are licensees of noncommercial educational (or “public”) television stations and is governed by a board comprised largely of representatives of its member stations. PBS operates in the public interest by serving the needs of its member stations. Four fundamental principles shape the content service that PBS provides to its member stations: editorial integrity, quality, diversity, and local station autonomy.
A. Editorial Integrity
PBS’s reputation for quality reflects the public’s trust in the editorial integrity of PBS content and the process by which it is produced and distributed. To maintain that trust, PBS and its member stations are responsible for shielding the creative and editorial processes from political pressure or improper influence from funders or other sources. PBS also must make every effort to ensure that the content it distributes satisfies those editorial standards designed to assure integrity.
B. Quality
In selecting content, for any platform, PBS seeks the highest quality available. Selection decisions require professional judgments about many different aspects of content quality, including but not limited to excellence, creativity, artistry, accuracy, balance, fairness, timeliness, innovation, boldness, thoroughness, credibility, and technical virtuosity. Similar judgments must be made about the content’s ability to stimulate, enlighten, educate, inform, challenge, entertain, and amuse.
C. Diversity
To enhance each member station’s ability to meet its local needs, PBS strives to offer a wide choice of quality content. Content diversity furthers the goals of a democratic society by enhancing public access to the full range of ideas, information, subject matter, and perspectives required to make informed judgments about the issues of our time. It also furthers public television’s special mandate to serve many different and discrete audiences. The goal of diversity also requires continuing efforts to ensure that PBS content fully reflects the pluralism of our society, including, for example, appropriate representation of women and minorities. The diversity of public television producers and funders helps to ensure that content distributed by PBS is not dominated by any single point of view.
D. Local Station Autonomy
PBS believes that public broadcasting’s greatest potential is realized when it serves the unique needs of the local community and that there are wide variations in local needs and tastes. No one is better qualified to determine and respond to those local needs than the public media organization licensed to that community. PBS’s role is to assist each station in the exercise of its independent responsibilities by: giving its member stations a broad range of content options, consistent with these Public Broadcasting Service Editorial Standards and Policies; providing stations with timely information necessary to make informed judgments about a program’s suitability for local broadcast; and making PBS’s content selection process responsive to stations’ needs.
III. Roles and Responsibilities
Content producers, PBS, local public television stations, digital content partners, and the Corporation for Public Broadcasting (“CPB”) play essential and distinct roles in content development and distribution.
A. Producers
PBS content is produced by a diverse group that includes public television stations and organizations, independent producers (ranging from individual filmmakers to major studios), foreign producers and broadcast organizations, individuals or organizations not normally in the content production business, and, to the extent that it produces Digital Content, PBS itself.
Primary responsibility for content necessarily rests with the producer; generally, producers create the content, particularly on television, and are uniquely positioned to control its elements. Not only would it be impractical for PBS to second-guess the producer’s decisions at each step of the production process, but respect for that process demands that producers be allowed the freedom required for creativity to flourish. Thus, in selecting content for distribution, PBS must rely heavily on the producer’s honesty, integrity, talent, skill, and good faith.
Producers of content for PBS have an obligation to inform themselves about and adhere to these Standards and Policies and all applicable PBS production and funding guidelines.
B. PBS
PBS is actively involved in encouraging and otherwise fostering the production of quality content. PBS does not itself produce any television Program Content. Instead, Program Content and often other content distributed by PBS, is produced by people who are not employed by PBS. While producers bear responsibility for content production decisions, PBS, on behalf of member stations and ultimately the audience, exercises oversight of the integrity of the content. In that role, PBS is the arbiter of whether content meets these Standards and Policies and whether it is appropriate for distribution as part of PBS’s national services. PBS bears responsibility and discretion for deciding whether to accept and distribute content, as well as deciding when to schedule it for national distribution, link to it or otherwise make it available. Acceptance of Program Content by PBS is signified by the placement of the PBS logo at the conclusion of a program, while acceptance of Digital Content by PBS is signified by the availability of the content on www.pbs.org or on another PBS digital application, such as the “PBS for iPad” app.
PBS and the producer have a mutual obligation to maintain effective liaison during the production process. The goal of this liaison is to provide opportunities for early notice and resolution of problems. Thus, PBS has a responsibility to make these Standards and Policies, as well as all applicable PBS production and funding guidelines, known to producers.
The final authority for the decision to distribute content as part of any PBS service rests with PBS. PBS makes its overall decisions about which content to accept and distribute with a view towards assuring, over time, a diversity of subjects, viewpoints, formats, techniques, and content sources.
PBS is committed to providing a nonsectarian, nonpolitical, noncommercial educational program service, in accordance with PBS’s membership policies. Although it is expected that a wide range of views and opinions will find expression in various ways across all PBS Content platforms, note that federal funding cannot be used to advocate for political action.
C. Local Public Television Stations
As a licensee of the Federal Communications Commission, each public television licensee bears a non-delegable duty to assure that its broadcast program services fulfill its statutory obligations as a broadcaster. Therefore, each station is ultimately responsible for assuring an appropriate balance of subjects and viewpoints across its broadcast schedule and for complying with all applicable federal statutes and regulations. While other entities, including PBS, may assist the local station in fulfilling those obligations, final responsibility for the quality and integrity of its broadcast services rests with each individual station. Thus, even though PBS has accepted Program Content and made it available to the local station, that station has sole discretion to decide whether and when to broadcast it.
In addition to broadcasting PBS television Content, public television stations produce their own programs and obtain programs—including some not accepted by PBS–from suppliers other than PBS. Thus, denying PBS distribution to a program does not prevent that or other programs from being broadcast on local public television stations and distributed over their other platforms. There are many alternative means of distributing programs to and by public television stations, including the statutorily-mandated alternative of distribution over the public television satellite interconnection system. PBS, however, makes no judgment as to the suitability for broadcast of programs distributed by parties other than PBS.
Program Content distributed by PBS carries the PBS logo at the conclusion of each program, identifying the program as one accepted and distributed by PBS as distinct from other program distributors. As the symbol of acceptance by PBS, the PBS logo conveys important information to viewers, and a station may not remove the PBS logo from the end of a program without PBS’s consent. By contrast, use of the PBS logo in conjunction with the station’s own logo (e.g., use of an on-screen identifier or a print logo that includes both logos) serves only to identify the station as a PBS member station and does not signify PBS approval of the underlying content.
Although PBS strives to provide balanced program services, member stations often choose not to carry the Program Content offered by PBS in its entirety, and each station makes different decisions about how best to supplement PBS’s programs.
While PBS distributes Program Content through its member stations (which retain discretion to broadcast such Program Content or not), PBS distributes Digital Content directly to the public, at all times and on a worldwide basis, through its Web site, www.pbs.org and other digital platforms and devices. Although pbs.org includes functionality that allows stations to associate their local brands with PBS Digital Content, a station can choose to limit its association to certain portions of the Digital Content available on pbs.org and other digital platforms and devices, at its discretion. Pbs.org and other digital means also provide access to local station information. PBS member stations make their own digital content available to the public through their own independently operated Web sites.
D. CPB
The Corporation for Public Broadcasting (“CPB”) is a private, nonprofit corporation created by Congress in 1967 to distribute federally appropriated funds to public broadcasting organizations nationwide. To that end, each year CPB distributes congressionally appropriated funds to local public broadcasting stations, PBS, and other public television distributors and producers. CPB is a major source of funding for public broadcasting, and provides content funding directly to PBS.
The Public Broadcasting Act (47 U.S.C. § 396 et seq.) authorizes CPB to “facilitate the full development of public telecommunications in which programs of high quality, diversity, creativity, excellence, and innovation, which are obtained from diverse sources, will be made available to public telecommunications entities, with strict adherence to objectivity and balance in all programs or series of programs of a controversial nature.” CPB is governed by a Board of Directors whose members are appointees selected by the President of the United States and confirmed for six-year terms by the U.S. Senate. To shield public television producers and distributors from political influence, the Public Broadcasting Act prohibits CPB from owning or operating public television stations and from producing or distributing public television programs. In addition, the Act requires CPB to “carry out its purposes and functions and engage in its activities … in ways that will most effectively assure the maximum freedom of [public television] from interference with, or control of, program content or other activities.”
IV. Editorial Standards
Precision in editorial standards is especially difficult because it is impossible to articulate every criterion that might enter into the evaluation of the quality and integrity of particular content. Moreover, a criterion considered mandatory for straight news reporting may not always be appropriate for a documentary, dramatic or other type of program or content.
Content evaluation is an art, not a science; it requires professional judgments about the value of content in relation to a broad range of informational, aesthetic, technical, and other considerations. PBS’s task, therefore, is to weigh the merits of the content it acquires or produces, submitted to it or produced by its own Digital staff and assure that, viewed in its entirety, the content it distributes strikes the best balance among these considerations. These Standards and Policies embody the goals of integrity and quality to which PBS aspires, recognizing that judgments about how these standards apply may differ depending on format or subject, and that not all content succeeds equally in satisfying all of these standards.
PBS recognizes that the producer of informational content deals neither in absolute truth nor in absolute objectivity. Information is by nature fragmentary; the honesty of a program, Web site, or other content can never be measured by a precise, scientifically verifiable formula. Therefore, content quality must depend, at bottom, on the producer’s professionalism, independence, honesty, integrity, sound judgment, common sense, open mindedness, and intention to inform, not to propagandize.
By placing its logo at the end of a program or hosting a Web site, PBS makes itself accountable for the quality and integrity of the content. Editorial integrity encompasses not only the concerns addressed in these Standards and Policies, but also the concerns about improper funder influence and commercialism addressed in PBS’s funding and production guidelines. If PBS concludes that content fails to satisfy PBS’s overall standards of quality or any applicable journalistic standard or production practice, PBS may reject the content for distribution.
A. Fairness
Fairness to the audience implies several responsibilities. Producers must neither oversimplify complex situations nor camouflage straightforward facts. PBS may reject a program or other content if PBS believes that it contains any unfair or misleading presentation of facts, including inaccurate statements of material fact, undocumented statements of fact that appear questionable on their face, misleading juxtapositions, misrepresentations, or distortions.
To avoid misleading the public, producers also should adhere to the principles of transparency and honesty by providing appropriate labels, disclaimers, updates, or other information so that the public plainly understands what it is seeing. For example, content that includes commentary, points of view, or opinion should be appropriately identified, as should all sources of funding. Transparency also suggests producers maximize attribution of information and limit the use of anonymous sourcing to those cases when there is no alternative and the information is essential. Content that contains adult themes or other sensitive material should contain an appropriate disclosure.
Producers should treat the people who are the subjects of, who appear in, or who are referenced in the content they produce with fairness and respect. PBS will reject content if, in PBS’s judgment, it unfairly treats the people or misrepresents their views. Fair treatment of individuals generally requires that a producer represent the words and actions of the people portrayed or identified in a way that presents their strongest case, and gives individuals or organizations that are the subject of attack or criticism an opportunity to respond. Fairness also requires that a producer be willing to consider all relevant information and points of view.
B. Accuracy
The honesty and integrity of informational content depends heavily upon its factual accuracy. Every effort must be made to assure that content is presented accurately and in context. Programs, Digital Content, and other content containing editorials, analysis, commentary, and points of view must be held to the same standards of factual accuracy as news reports. A commitment to accuracy and transparency requires the correction of inaccuracies and errors in a public and visible manner. These principles also require that PBS, Stations and Producers actively respond to feedback and questions from audiences.
PBS may undertake independent verification of the accuracy of content submitted to it. Producers of informational content must exercise extreme care in verifying information, especially as it may relate to accusations of wrongdoing, and be prepared to correct material errors. PBS will reject content that, in its judgment, fails to meet PBS’s standard of accuracy.
C. Objectivity
Along with fairness and accuracy, objectivity is a third basic standard to which journalists are held and by which the guidelines have recognized PBS might be judged. While PBS holds all news and informational content to standards of objectivity, PBS recognizes that other types of content may not have the objective presentation of facts as their goal.
Objectivity, however, encompasses more than news and information presented in a neutral way. It also refers to the process by which a work was produced, including work that involves analysis or, as a result of reporting, arrives at conclusions. To begin with, journalists must enter into any inquiry with an open mind, not with the intent to present a predetermined point of view.
Beyond that, for a work to be considered objective, it should reach a certain level of transparency. In a broad sense, this spirit of transparency means the audience should be able to understand the basics of how the producers put the material together. For example, the audience generally should be able to know not only who the sources of information are, but also why they were chosen and what their potential biases might be. As another example, if producers face particularly difficult editorial decisions that they know will be controversial, they should consider explaining why choices were made so the public can understand. Producers should similarly consider explaining to the audience why certain questions could not be answered, including why, if confidential sources are relied on, the producers agreed to allow the source to remain anonymous. And the spirit of transparency suggests that if the producers have arrived at certain conclusions or a point of view, the audience should be able to see the evidence so it can understand how that point of view was arrived at. One aspiration implicit in the idea of transparency is that an audience might appreciate and learn from content with which it also might disagree.
Opinion and commentary are different from news and analysis. When a program, segment, digital material or other content is devoted to opinion or commentary, the principle of transparency requires that it be clearly labeled as such. Any content segment that presents only like-minded views without offering contrasting viewpoints should be considered opinion and should identify who is responsible for the views being presented.
No content distributed by PBS should permit conscious manipulation of selected facts in order to propagandize.
D. Balance
PBS seeks to present, over time, content that addresses a broad range of subjects from a variety of viewpoints. PBS may, however, choose to consider not only the extent to which the content contributes to balance overall, but also the extent to which a specific piece of content is fairly presented in light of available evidence.
Where appropriate, PBS may condition acceptance of content on the producer’s willingness to further the goal of balance by deleting designated elements or by including other points of view or material from which the public might draw conclusions different from those suggested by the content. Material to be added may range from a few words, to a complete content segment, to an added episode in a series of programs, to the production of an entirely separate, new program or new elements of digital content. Where PBS deems it appropriate, PBS may arrange for the production of additional content by a producer other than the producer of the original content material. For Digital Content, links to credible, high-quality, related resources may be used to provide access to additional information or viewpoints.
E. Responsiveness to the Public
Producers must work with PBS to respond to and interact with the public. This may include providing an outlet for public feedback about content and helping to create material for the Web that allows audiences to learn more, seek background information, access documents alluded to in a program, answer questions that a program might not have been able to address, and even customize information. Accountability is a goal, including answering audience questions and responding to criticisms about programs or content. When public feedback is published by PBS it should be labeled as such, and standards for publication–such as those relating to obscenity or personal attacks — should be clearly communicated.
F. Courage and Controversy
PBS seeks content that provides courageous and responsible treatment of issues, and that reports and comments, with honesty and candor, on social, political, and economic tensions, disagreements, and divisions. The surest road to intellectual stagnation and social isolation is to stifle the expression of uncommon ideas; today’s dissent may be tomorrow’s orthodoxy. The ultimate task of weighing and judging information and viewpoints is, in a free and open society, the task of the audience. Therefore, PBS seeks to assure that its overall content offerings contain a broad range of opinions and points of view, including those from outside society’s existing consensus, presented in a responsible manner and consistent with the standards set forth in these Standards and Policies.
G. Substance Over Technique
Advances in production technology carry with them the possibility that technique may overwhelm substance, distorting the information, making it technically inaccessible or distracting the public’s attention from its central thrust. Neither people nor ideas ought to be victimized by technical trickery. PBS will reject content that, in its judgment, disserves the viewer or its subject matter by inappropriately pursuing technique at the expense of substance.
H. Experimentation and Innovation
PBS seeks content that is innovative in format, technique, or substance. The absence of commercial considerations accords PBS the freedom to experiment in ways not always tolerable in the commercial environment. The potential for innovation can be fully realized only if PBS is bold enough to take occasional risks.
Given that freedom and responsibility, PBS should strive to be a leader in experimenting with innovative techniques for presentation, story-telling, information delivery and engagement with the public, as long as they adhere to the spirit and the understanding of the PBS editorial standards and guidelines.
I. Exploration of Significant Subjects
Unlike their commercial counterparts, public television stations do not sell time for profit and are, therefore, free from the constraints that compel commercial broadcasters to pursue the largest audience. PBS seeks programs that will enable its member stations to explore significant subjects even if those subjects or their treatment may not be expected to appeal to a large audience.
J. Unprofessional Conduct
PBS expects producers to adhere to the highest professional standards. PBS may reject content if PBS has reason to believe that a producer has violated basic standards of professional conduct. Examples of unprofessional conduct by a producer include such things as plagiarism, fabrication, obtaining information by bribery or coercion, insensitivity to tragedy or grief, and real or perceived conflicts of interest such as accepting gifts, favors, or compensation from those who might seek to influence the producer’s work. Illegal conduct is on its face unprofessional.
K. Unacceptable Production Practices
It is impossible to anticipate every situation with which a producer of informational content must contend. Nevertheless, certain areas present such frequently encountered dangers that they merit explicit warning. In general, they would fall under two broad concepts:
- Never invent or add elements that were not originally there; and
- Never make choices that mislead or deceive the audience.
These principles, and the intellectual honesty underlying them, also relate to plagiarism and misappropriation. Even as the distributive power of digital technology makes it easier to pass along other content, PBS, Producers and Stations should not take someone else’s work and pass it off as their own. The spirit of transparency and intellectual honesty dictates that audiences should clearly understand who the true author of any content was.
In addition:
- Staging. Producers of news content should not stage events or suggest that others stage events for the sake of media coverage.
- Re-creations and Simulations. In instances where re-creations or simulations of actual events are necessary and desirable, they should be clearly identified if there is any possibility that the viewer would be confused or misled.
- Distorted Editing. All producers face the necessity of selection–which material is to be left in, which is to be edited out. Reducing and organizing this information is part of the producer’s craft. It is the objective of the editing process to collect and order information in a manner that fairly portrays reality. Producers must assure that edited material remains faithful in tone and substance to that reality. When editing, producers of informational content must not sensationalize events or create a misleading or unfair version of what actually occurred. When significant interruptions of time or changes of setting occur, they should be unambiguously identified for the viewer.
- Deception. The credibility of content is jeopardized whenever the audience or a source is duped or feels duped. Deceiving the audience would include such examples as when time is conflated so that it appears that several interviews were actually one. Duping a source would include when a producer misleads an interviewee concerning the purpose of the interview. Honesty, candor, and common courtesy must govern producers’ behavior.
- Pre-trial Publicity. Our legal system presumes that criminal defendants are innocent until proven guilty. In reporting on crimes and related legal proceedings, producers must be sensitive to the rights of the accused to a fair trial and the effect of pre-trial publicity. Producers should be wary of self-serving statements from both prosecuting and defense attorneys. They should also remain cautious about using alleged evidence in any content to be made available to the public pre-trial.
- Media Manipulation. Manipulation can be effected either by the media or by others seeking to use the media for their own purposes. Television is an extraordinarily powerful instrument; the mere presence of television cameras can change or influence events. Producers must minimize and, to the extent possible, eliminate this interference. In crowds, demonstrations, and riots, during terrorist incidents, and in other similar circumstances, camera crews and production teams should seek to be as inconspicuous as possible, and, as appropriate, cap lenses or withdraw completely when their presence might incite an extreme reaction or unduly influence the course of events.
- Manipulation of the Audience. The use of music and sound effects, dramatic lighting or staging, or other artificial effects can subtly affect the impression left with the audience. Producers must exercise care not to use such techniques in a way that is unfairly manipulative by distorting the reality of what occurred.
PBS may reject and decline to distribute any content that, in its judgment, violates the production practices identified above or shows evidence of any other production practice that is not consistent with accepted professional standards.
L. Objectionable Material
Responsible treatment of important issues may sometimes require the inclusion of controversial or sensitive material, but good taste must prevail in PBS content. Morbid or sensational details, or material that is gratuitously offensive to general taste or manners (e.g., extreme violence, racial epithets, strong language, nudity, sexism), should not be included unless it is necessary to an understanding of the matter at hand.
Questions of taste cannot be answered in the abstract, but when specific problems arise, they must be resolved in light of contemporary standards of taste, the state of the law, and the newsworthiness and overall value of the material. If PBS concludes that the exclusion of such material would distort an important reality or impair the content’s artistic quality, PBS may accept the content provided it carries appropriate notice to the viewer. Conversely, PBS may reject content that, in its judgment, needlessly contains objectionable material that compromises the content’s quality or integrity.
M. Social Media
Given the mandate of public media as a place to engage citizens, PBS should engage with the public in all appropriate forms of media and be mindful of how audience behavior is changing. Social media is emerging as an important expression of the marketplace of ideas and a powerful venue by which citizens are interacting and educating themselves.
- User-Generated Content: Another feature of digital technology and social media is the expanded dimension of the audience participating in and inspiring public discourse. This user-generated content describes a range of different kinds of material. In general, content from the audience has a special value. It allows those involved in media to interact with the audience in a way that enriches and broadens public engagement. There are various levels of user-generated content—from user comments, to eye witness accounts of events, to video and pictures from the public, to using audiences as sources in stories, and more. PBS and its producers must strive to accurately and transparently explain their practices and policies for each level of this content. The spirit of transparency also suggests that PBS and its producers should anticipate when content may raise questions in the minds of audience members or involve controversy, and in those instances, make some effort to explain why that user content is included. PBS and producers should also be clear about their expectations for the public in participating and producing content, including tone and level of civility. PBS and its producers also have a responsibility to solicit and structure the user-generated content in a way that is fair and responsible.
N. Partnerships
As PBS and its producers enter into formal editorial partnerships and more informal collaborations with other organizations and institutions, PBS should be mindful of the impact on its credibility. As such, PBS, Stations and Producers should help the audience understand who is a formal partner and who is an informal content provider with no ties to PBS. It should not be assumed that the public will automatically know these differences. If there are questions, steps should be taken to make transparent the relationship between PBS and linked or distributed content. This is particularly important if links refer audience members to potentially objectionable, controversial or partisan content.