Is Ofcom’s Diversity and Inclusion Work Planning Fit for Purpose?

Ofcom Diversity Report
Ofcom Diversity Report

One of the continual challenges in the democratic renewal of our media, is to ensure that we fully understand the scope and the extent of embedded and structural inequality. The UK media industries have been shown to be resistant to change when it comes to opening-up the professional circles of management and production. It is easier to get a senior executive role in a major media corporation if you are privately educated and went to one of the so-called top universities. Being able to afford to undertake unpaid internships with media companies, being plugged into a network of family connections, and speaking with the right tone of voice, that indicates that you are a ‘cultural fit’ with a production company or media organisations, are all part of the cycle of privilege retention that goes unaccounted for in what are now called the creative industries.

In recent years Ofcom, the UK’s media regulator, has started to publish diversity and inclusion reports, that indicate in what way the broadcasters and media organisations that it regulates, are meeting expectations of a diverse and inclusive culture of employment. The results that are demonstrated in the Ofcom reports are patchy at best. Senior positions in most organisations are elusive if you are female, if you are from an ethnic minority background, or if you are from a working-class background. Disabled people and gay people lack representation in the media workplace, or even go unseen and unaccounted for, because of the potential stigma that is exercised by some employers, with low levels of self-identification in the equal opportunities monitoring that they undertake.

Coupled with the concentration of resources and organisations in London, the effect of discrimination and exclusion goes unaccounted for. Either you can commute long distances or put up with sub-standard accommodation, or you can pursue a career outside the media industries. Attempts to move broadcasters to the ‘provinces’, as people in London are prone to call the rest of the country, have made only a marginal impact on the culture of expectation that is associated with jobs and roles in mainstream media companies. A shift to Salford, Cardiff or Leeds is of no value if it only results in more local people being employed as cleaners and service works, and given no fair crack at being appointed to senior management and leadership roles.

If we are to achieve the sweet dream of an inclusive and representative media culture, then we need to keep organisations like Ofcom on their toes. We see a lot of management spin from large organisations that promote their effectiveness in fostering a more inclusive organisational culture, but it’s clear that we have to go much further and work to tackle the structural principles and practices that leaves inequality largely unchallenged in practice. In tackling these challenges, we need to ensure that Ofcom and the organisations that it monitors, don’t just have the policies to monitor what goes on, but also has the resources to make sure this monitoring works operationally and in practice. We need more than glossy reports from numerous organisations about identity, we need a fundamental shift in the way that we manage our media economy, away from being dominated almost exclusively by private interest, to a pluralistic model that incorporates civic rights and media platforms that are designed to maximise social and civic participation in the first place.

When we examine the principles and resources that are included in Ofcom’s workplan, for example, which includes provision for the monitoring of diversity and equality across the broadcast media sectors, on significant problem stands out. Community media is not accounted for by Ofcom in its diversity monitoring work, which in my view, represents a significant area of concern. The effect of this omission is that in neglecting to gather essential information about the role, purposes and practices that relate to community media in the UK, such as the work undertaken by the community radio stations that it licences, it is omitting a whole sector of media practice that is related to people who are otherwise marginalised by or excluded from engagement in mainstream media discourse. Community media plays an essential role in promoting diversity in broadcasting and media production, because it acts as a vital, independent route, that enables many people from minority or marginalised groups to engage in their communities using common media platforms. Community media is a principal route for people of a BAME and other protected characteristic social groups to gain access to broadcast media platforms.

As we have seen with the differential impact of Covid-19, along with other public health indicators, people from BAME communities have been impacted disproportionately and have suffered in greater numbers from the effects of Covid-19. It is essential, therefore, that Ofcom and the organisations that it regulates, are informed by up-to-date public policy research and practices, particularly research that accounts for the considerable differences that different social groups have to access to media resources, opportunities for participation in media programming, and self-determination when it comes to the stories that are told about them and their communities, which themselves contribute to public perceptions of health and wellbeing for members of these communities.

Community radio has effectively been overlooked in Ofcom’s work planning, which doesn’t account for grassroots and community media practices. Ofcom is therefore potentially missing the opportunity to identify and understand emerging and ad hoc patterns of media engagement that are not accounted for in the previous research that Ofcom has undertaken to determine its workplan. It’s my view that this oversight amounts to systemic discrimination and should be addressed urgently. The framework of the 2010 Equality Act is relevant here. Discrimination can be both direct and indirect, therefore any failure to collect information about the non-traditional and grassroots forms of media engagement, is effectively discriminating against those who are not well represented in the corporate media sector. To correct this, it is essential that Ofcom commissions research that accounts for the vital lived experiences of people participating in different community media projects, particularly those from BAME communities.

Ofcom is not meaningfully accounting for the civic engagement work of many community media activists and participants. The effect of this oversight is that any differential effects of Ofcom’s regulatory policies and operational practices are not being accounted for or compensated for in this workplan. For example, Ofcom is prioritising the rollout of SSDAB licencing in a series of staged rounds across the UK. But they are doing this without due regard to the impact the model of licencing implementation and rollout is having in practice on minority groups. Ofcom have indicated that no analogue Community Radio Licences will be advertised or issued during the SSDAB rollout period, which is due to take at least four years. This structured regulatory approach, however, discriminates against protected characteristic groups and minority communities who may have identified a specific social need that a community radio broadcasting service may urgently wish to respond to at this immediate point in time, but which they are denied access to because of the capacity restraints of the proposed workplan.

While this might be viewed as a largely technical issue on the part of Ofcom, in relation to the efficient use of management capacity, spectrum and broadcast choice for consumers, it is clear that Ofcom also has an obligation to assess the impact of these policies under the Equalities Act 2010 and to test if they are likely to discriminate against groups who do not have privileged access to the systems of decisions making, resource allocation and governance. No equalities evaluation has been produced to accompany Ofcom’s workplan, which is an oversight that needs correcting. Ofcom must therefore revise its consultation, planning and capacity management with due regard to the relevant equalities legislation and statutes, and address issues of inclusion, not simply in theory, but in practice as well.

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