Ofcom’s Five-Year Review: Diversity and Equal Opportunities in UK Broadcasting

Ofcom has published it’s five-year review of the data it has been collecting on diversity and inclusivity in the UK broadcast television and radio industries.

Ofcom feels that they now know more than ever about the makeup of the broadcasting sector, and that their monitoring programme has “increased transparency and narrowed the diversity data gap.”

Ofcom cite a number of examples where their data has improved:

• In 2016/17 Ofcom had no disability information on almost a third of broadcaster employees.
• Now Ofcom is able to account for the disability status of 76% of the Television workforce and of 85% of the radio workforce.
• Ofcom acknowledges, however, that there remain several significant gaps in their knowledge, such as information about the designations of employees according to religion, sexual orientation, socio-economic background. This information is provided to Ofcom on a voluntary basis.
• There are also areas that Ofcom has yet to establish any data collection, such as geographic location, gender identity and intersectional data (where different characteristics combine).

According to Ofcom, there is a general trend towards broadcast industries that are more representative of the UK working population, particularly in terms of ethnicity.

So, where minority ethnic groups were particularly underrepresented in 2017/18, they are less so now across the workforce as a whole.

Radio has typically started from a lower base than Television, but in some areas, including race and religion, broadcast radio has made more rapid progress in addressing the concerns of under-represents.

For example, people from minority ethnic backgrounds made up 6% of the radio workforce in 2017/18, but are now at 10%, which compares with 12% of the UK working age population.

Ofcom is concerned, however, that this increase is not sustainable for all groups, and that the relative scale of these increases are generally very small.

The limited pace of change in addressing issues of under-representation has also been impacted by the pandemic, with Ofcom reporting that “for the first time the number of people leaving the industry outweigh the number joining it.”

According to Ofcom, women are disproportionately represented in those who are leaving the broadcast industry.

Ofcom suggests that the proportion of television employees who are disabled will fall over the next five years, and so will that of radio employees who are female.

Key in Ofcom’s observation is the issue of a “woeful lack of diversity within senior positions and key decision makers.”

In fact, according to Ofcom, “in the case of disabled employees and those from MEGs [minority ethnic groups] the gap between overall diversity and diversity amongst senior managers has actually widened over the last few years in Radio and has not improved in TV.”

While there are some gains in the promotional prospects of some people, there is not enough evidence yet to correlate any significant and sustainable improvements at a senior management level.

Ofcom notes that “broadcasters appear to have focused on entry-level recruitment at the expense of retaining diverse staff and enabling them to progress.”

As Ofcom states:

“Overall gains in representation appear to be disproportionately due to entry level hiring and this is consistent with our impression that initiatives have often focused on recruitment and early careers. Neither is there evidence of progress towards an industry which retains older colleagues – only 16% of women in the TV workforce are aged 50+ (compared with 22% of men and 32% of the working age population).”

Ofcom suggests, therefore, that “across some underrepresented groups, retaining staff would have a bigger effect on future diversity than increasing recruitment alone.”

Ofcom’s projections suggest that across radio a 1% decrease in the proportion of disabled and minority ethnic people leaving the industry would “boost representation more over the next five years than a similar increase in recruitment alone.”

Thus, Ofcom’s key observation is that for both radio and television, “it is the combined effect of recruiting and retaining staff which has the greatest impact on increasing representation. So, recruitment and retention must go hand in hand.”

Clearly, this isn’t a healthy picture of an inclusive media sector. Some of this can be put down to a lack of information, as Ofcom suggests; some can be identified as cultural issues, such as the way that businesses and corporate organisations are operated in the UK; while other factors are structural and have been compounded by Ofcom’s regulatory approaches and service delivery mandates themselves.

Let’s mention a couple of issues in turn. These need comprehensive elaboration and substantiation, but if we don’t start by acknowledging them, then they will be easily brushed aside.

First, Ofcom has failed to include community radio in its data collection. It is impossible to report on diversity and inclusivity if Ofcom is not collecting information about voluntary and community-based media groups. Community radio is a key route for people from minority ethnic groups, disabled people, women, and so on, to gain access to broadcast platforms, but if the national regulator does not collect information on these areas of activity, the picture it reports is incomplete.

Second, the reporting methods used by Ofcom are those used by the established media and broadcast industries to report on themselves. While Ofcom does cross-reference with other national datasets, they don’t themselves gather evidence that is independent of the industry reporting that it is supposedly examining. Compare this with the British Crime Survey, which is conducted independently of the data reported by police forces. Ofcom’s data therefore lacks cross-referenced verification with any independent separate dataset that are monitored by other independent organisations.

Third, Ofcom mentions conversations with ‘included’ respondents, but it is not specified or identified with who or what form these conversations took, or how the data has been coded and analysed. The accompanying methodology document reiterates the self-reporting nature of the data collection, which is supplied by the corporate organisations participating in the survey. This suggests that Ofcom is not conducting research into the ‘lived-experiences’ of those who are most effected by discriminatory and exclusionary practices.

Fourth, Ofcom does not facilitate or include participatory stakeholder groups to help guide the research, such as civic society organisations, equality campaign organisations, trade unions, faith groups, or other representative community associations. The data gathering highlighted in this report is defined by industry priorities alone, and does not encompass wider social or cultural matters that may be related to the experience of those who are affected by the clearly biased employment practices.

Fifth, it isn’t clear where the boundaries are in determining who are included in the ‘broadcast’ media. For example, people who provide services such as catering and cleaning may be contracted out, and therefore not reflected in the narrow determination of those adjudged to be active in programme making or broadcasting. Ofcom’s identification of ‘intersectional’ reporting is narrow and limited, and goes against the grain of the ethos of validated lived experiences in the first place.

So what are the consequences of these omissions. By relying on self-reporting and internal-verification process, Ofcom are not establishing a true picture of the diversity and inclusion practices of the UK radio and television industries. The repeated exclusion of community radio from the survey, and the failure to undertake significant research about community media, means that Ofcom are ignorant of a key access route into the commercial or public service media organisations.

Similarly, Ofcom’s inability to facilitate engagement with civic-society organisations as part of this data collection process, or to establish citizen juries and panels that are capable of contributing to the process of gathering evidence, severely limits the scope of the research. The lack of qualitative and testimonial data indicates that the voice of those who this research is supposed to assist, is further marginalised and excluded.

One can only draw the conclusion that this research is primarily driven by platform efficiency and economic integrity priorities, and not civic engagement and human rights determinations.

Furthermore, there is no acknowledgement of the role that Ofcom itself plays in compounding and reinforcing institutional bias and inequality in the UK broadcast industry. Ofcom’s policy of prioritising market efficiency has led to them unchallenged consolidation by international corporate media organisations of much of the local and independent radio sector on the UK.

In addition, the lack of a social value test means that Ofcom has weighted it’s decisions to facilitate and approve rapid market consolidation, focussed on an increasingly narrow number of economic actors, mostly international corporations. This means that local and independent media services are stifled by a lack of respect for market diversity, cultural diversity, and creative diversity.

Ofcom is ignorant, it would seem, of the need to support cultural diversity and civic plurality, by promoting access guarantees through platform diversity, and to promote social identity above the the narrow market test of efficiency, which lead to an impulse to standardise and consolidate services.

Perhaps one of the reasons that so many people do not take up senior positions in these organisations, is because the market model is sterile and monocultural, and they see little sense in trying to change things from the inside, because their unique personal heritage and experiences are reduced to mediocre and generalist public service obligations?

I concluded some time ago that Ofcom is not fit for purpose, and should be broken up, with clear separation given to Ofcom’s core functions. Economic regulation should be separate from platform regulation, and the civic and public regulation duties of Ofcom should be handled by an activist organisation that is given a mission to transform – call it level-up if you want – UK society by transforming the rights of citizens to control, manage, produce and share their own media. As noted in the IPCC report on climate crisis, we need total systems change at all levels of society, and this must include the regulatory work of Ofcom, which are clearly not serving the wider public good.

I would like to dedicate a future episode of the Decentered Media Podcast to this issue. Do contact me if you have experience in this area and would like to share what its been like to have been pushing-back against these challenges.

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