User-generated content
Personal space for users on British Council sites
Communities on British Council sites
Editorial responsibility
Hosting
Moderation
Premoderation
Postmoderation
Postmoderation standards
Reactive moderation
Reactive moderation standards
Participation and escalation
Serious incidents
Chat
Weblogs
Defamation
Handing user-generated content over to a non-British Council archive
Online voting
Online voting for competitive awards
Competitions and prizes
Choice and description of prizes
Prizes offered as part of a sponsorship agreement
Donated prizes
Entrance forms and the Data Protection Act
Competitions involving children
Email
Interactivity allows our audiences to engage with us in many different ways. It provides choice and gives opportunities to be heard, and to create content. We aim to offer it to everyone by using our different platforms in different ways, but we will not exclude visitors who do not choose to interact.
There are many different kinds of user-generated content on the internet. Bulletin boards, web based chat forums, internet relay chat, virtual environments, mailing lists, weblogs and newsgroups are all examples which allow a visitor to add material to the internet as well as seeing what is already there. The British Council wishes to take advantage of the full range of user-generated services provided they fulfil our public purposes and can match the standards our users expect of our presence on the internet.
Where the British Council offers users the chance to have their own personal pages on our site, with room for more substantial content than is available from posting a message on a message board, the British Council will need to consider several factors:
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visitors must be aware that they are accessing content which has not been written or created by the British Council |
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to avoid giving the perception of British Council endorsement on a British Council branded page, it must be made clear at an early stage to users that these pages are intended for personal use only; the space must not be used as a campaigning platform to promote any political, commercial or charitable cause, or for fundraising; particular care needs to be taken to avoid this, when moderating, |
Staff will need to consider carefully which form of moderation is most suitable for any specific space. Further advice can be obtained from the Senior Internet Business Development Manager.
The British Council offers sections of its sites to serve communities of people. These may be people who share a professional interest, British Council members or UK alumni. These may be groups of people or local organisations as well as individuals. The same care must be taken when moderating such sites as outlined in the preceding paragraph. No group should use British Council online pages as a platform to promote campaigns that are commercial, political or particularly controversial.
Every online space where user-generated content is published must have a named person in the relevant operational team to take editorial responsibility for the content. That person will require the site to comply with all relevant guidelines and will see that the site maintains appropriate overall standards of hosting and moderation.
Hosts provide a visible and active presence on British Council websites on which the public places user-generated content. All such sites must have a host. A good host will meet and greet, stimulate discussion, monitor the overall tone of conversations, defuse rows and take pride in their space. The host’s presence should help create a distinctive experience for the visitor, whether the space is premoderated, postmoderated or reactively moderated. They may also be able to offer, or point to, some expert knowledge on the subject in question. The person who is editorially responsible for the content should ensure that all hosts are properly trained, adequately funded and able to respond to changes in circumstances which may affect the level of hosting required.
Every British Council internet site on which the public places material must be moderated. This may involve premoderation, postmoderation or reactive moderation. The moderator may, in some exceptional cases, also be the host:
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premoderation is where material cannot be accessed by visitors to the site until the moderator has seen it and decided it is suitable for placing on the internet |
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postmoderation is where the moderator sees the material and decides whether it is suitable to remain on the site, after it has been posted |
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reactive moderation is where visitors to the site alert the moderator to an inappropriate or offensive message; the moderator does not read every message. |
Sites dealing with particularly sensitive areas may require premoderation. Sites designed to appeal to children must be premoderated. Sites which have a history of controversy or polarised debate, personal or racist abuse or potentially defamatory comments need the level of attention provided by postmoderation. Other examples of sensitive areas that might require premoderation include those discussing personal health problems. Areas that invite users to e-mail images are premoderated. Live chats where users talk to a celebrity guest are generally premoderated.
It may sometimes be necessary to move an area or an individual from postmoderation or reactive moderation into premoderation for a limited period.
Many user-generated content areas on the British Council site will need to be postmoderated. Postmoderation allows users to see their messages being published without delay while every message is read by a moderator. Postmoderation is likely to be suitable, for example, for sites which attract robust debate about current affairs.
British Council sites that carry postmoderated content must ensure that messages from the public are seen, checked and, where necessary, removed within the agreed time limit. In cases of sensitivity, this may be within one hour of posting. The agreed time limit is the maximum period of time a postmoderated message should normally be visible before being checked by a moderator. It must not prevent a moderator from checking messages sooner after publication, particularly where special vigilance is called for. For example, when publishing potentially sensitive comments about an armed conflict, during the conflict itself, it may be necessary to check all such messages even more rapidly.
A general agreed time limit, which is the norm for our sites, will be agreed by the Senior Internet Business Development Manager. There may be local variations depending on the expectations of the likely audience for the specific service and the sensitivity of the site. But any proposal for a longer interval between publication and moderation for any service must be agreed by the Senior Internet Business Development Manager.
Reactive moderation may be suitable for less sensitive sites where a higher degree of self-regulation is appropriate. This is more likely to be suitable for an active, mature online community where few messages have to be removed. It is more likely to suit topics which tend not to attract polarised or extreme responses. In order to maintain the quality of contributions, reactive moderation requires consistently active and visible hosting of the site. It is not suitable for a site which is likely to attract a high proportion of children.
It may be necessary to move a reactively moderated site to postmoderation for a limited period, for example in war, national crisis or during elections.
Any proposal to reactively moderate a site with user-generated content must be referred in advance to the Senior Internet Business Development Manager. A trial period may be necessary.
Before contemplating a move to reactive moderation, the person who is editorially responsible for the site must become familiar with its history, be satisfied that it is editorially appropriate, and be committed to putting the appropriate hosting and escalation arrangements in place. Site owners must recognise that users may not alert moderators to every breach of the house rules. While hosts are not expected to read every message, they must monitor the overall tone of conversations and be across the issues discussed on the site.
The community’s standards, the quality of contributions and the method of moderation must be kept under active review and we may, if necessary, revert to postmoderation or even premoderation at short notice.
Reactive moderation relies on alerts from members of the public and moderators must treat each one with care and consideration. If in doubt, moderators must refer an alert to the host for advice and keep the Senior Internet Business Development Manager informed. Each alert must get a clear response in a reasonable time from the moderator. A record must be retained of the complaint, the message complained about, the decision reached and the reason given for the decision.
If adequate funding is not available for the appropriate levels of moderation and hosting, it may be necessary to consider closing a site.
Message boards and other interactive areas are offered on the British Council site as a shared space for contributors to use and enjoy. While moderators must be rigorous about defamatory or other illegal or offensive messages, successful online communities operate by consent and encourage a genuine sense of ownership among their users.
British Council moderators will not normally edit contributions for grammar or spelling although they may edit for use of strong language. Messages with substantial problematic content are normally rejected as a whole, rather than edited. A reason must be given, and they may be resubmitted once altered.
In order to protect our users and our brand, it may sometimes be necessary to go further than simply rejecting a single message. It is the responsibility of every individual host and moderator to be able to implement a swift and robust escalation strategy where appropriate. This may range from temporarily removing a contributor from a board or forum to putting a board into 'read only' mode or ending a live chat early. Hosts and moderators must refer in the first instance to the person who is editorially responsible for the space.
House rules reflecting these guidelines must be published for visitors to see on the British Council site.
All staff with responsibility for delivering websites are expected to behave in accordance with the British Council’s Code of Conduct. These standards are particularly important where the users of websites include children and young people.
Any incident of suspected 'grooming' online where a child abuser seeks to prepare a child for possible abuse must be reported to Director Customer Service, who will be responsible for reporting it to the Senior Management Team and to the police.
Any proposal to reveal a child’s personal information to a third-party without consent, for example if we suspect child abuse, must be referred to Director Customer Service, who may wish to consult a Legal Advisor.
Chat rooms, where users talk to each other, need careful hosting. Levels of hosting will vary, depending on the expectations of the likely audience. A public chat room that may be likely to appeal to children will need special care. Advice should be sought from the Senior Internet Business Development Manager before it is commissioned.
We will exercise the same level of editorial care with weblogs as we do with other forms of content. This policy will also apply to associated external links and user-generated comments.
Members of staff who write and publish weblogs must refer to their line manager for agreement to do so.
We must take particular care to avoid publishing defamatory material through our user-generated content. One option is to premoderate the high-risk sites but this will not be suitable for all sites or necessarily the best legal solution.
For advice about the degree of moderation a site should receive, refer to the Senior Internet Business Development Manager who will liaise with a Legal Advisor, if necessary.
Hosts and moderators must be familiar with the law of defamation. Where a potentially defamatory message has already been posted, the host or moderator must first remove it from public view and then contact Senior Internet Business Development Manager. If the message appears for posting on a premoderated board, a Legal Advisor should be consulted before a decision is taken about whether to post it or not.
The British Council may have plans to collect material online with a view to handing it over in due course to a third party as a permanent archive. We must aim to be transparent with contributors about any likely future use of the material at the point they make their contribution. We must also bear in mind that their wishes should be respected. For example, if they are contributing to a permanent national archive, they may not expect their material to be exploited commercially.
Online voting gives audiences the chance to participate and to see a result but votes linked to a website will only represent those people who have chosen to respond and must be clearly reported as such. They should not be reported with the editorial prominence of carefully conducted opinion polls.
We must take particular care about the robustness and integrity of online votes for competitive awards from the earliest stages in order to protect the integrity of the activities around which they are built. A great deal may ride on the result for participants - there may be a life-changing opportunity given as a prize. Or, in other cases, lobbying or campaigning organisations may have a strong interest in the outcome of the result.
We must ensure that the robustness of the online voting mechanism matches the vote’s editorial significance, and that we undertake additional checks where necessary. Output that relies on online voting should normally be based on a vote that is run or directly commissioned by the British Council.
Some votes may not be suitable to run online. We must allow enough time in the period between closing the online vote and announcing the result for the votes to arrive, be processed and checked. We must also consider carefully whether to announce running totals before the final verified result.
We should normally publish rules when running votes so that, for example, we can disqualify for cheating or fraud.
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All competitions must have a clear editorial purpose. |
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All competitions must require a genuine test of knowledge, judgement or skill appropriate to the target audience. |
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All competitions with prizes must have competition rules to make sure they are run properly, fairly and openly. |
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The rules must ensure that the competition is held under English law. This is particularly important when holding a competition on the internet. |
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How to play the competition must be clear – confusion causes complaints. |
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We must not promote any competition which is not organised by us or run in conjunction with the British Council. |
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Except where decisions are to be taken by voting, or some other participatory mechanism, the rules of the competition or award must make it clear that the decision of the British Council will be final. |
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Website managers should aim to offer original, rather than overly expensive prizes. It is unacceptable to spend Grant in Aid money on prizes of excessive value. |
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Cash prizes must be avoided in competitions and must never be offered on web pages for children. |
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Donations of substantial prizes must not bring the British Council’s editorial integrity into question. |
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When running competitions and awarding prizes, the British Council needs to maintain its reputation for impartiality and must take care not to promote any service, product or publication. |
Where a prize is offered as part of a sponsorship agreement, the guidelines governing the benefits we can offer a sponsor apply. Refer to section 14 (Partnerships, including partnerships with business). Provided that the sponsorship has been processed through the mechanism of British Council Trading International, the following benefits may be offered to the sponsor in return:
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prizes may be described in an informational and promotional manner; if an image of a product is used, product branding may be visible |
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the name of the supplier may be given, the brand may be mentioned and product logos may be used |
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we may link to the website of a supplier or manufacturer of a prize in connection with the prize or competition. |
In return for donated prizes, modest acknowledgement on print and web material is permitted but display of a company's logo is not. If a British Council site accepts donated prizes, it must ensure that we do not appear to favour any institution or company. We must take care to see that we do not use the same company’s products in close proximity or succession anywhere on the site.
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Entrants to a competition should normally complete an electronic entrance form, which should only request the minimum amount of personal information necessary to enter the competition. The reasons for requesting any additional information must also be declared under the Data Protection Act. The user must be offered a clear option to enter the competition without providing the additional information, for example by putting an asterisk in the fields which are optional. |
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Personal information (which can be as little as a name and e-mail address) must not be passed on to third parties without the user’s prior knowledge and consent. If this is a possibility, it must be made clear to the user. |
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Competitions for children must include a statement to the effect that all children and young people up to the age of 18 are required to confirm (for example, via a clickable box) that their parent’s or guardian’s permission has been obtained before entering their personal details (name, e-mail address etc) onto the competition entry form. |
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Where details other than name and e-mail address are requested (for example, mobile phone number) verifiable parental consent is essential (for example, a signed letter or personal phone call from a parent or guardian). |
Sometimes websites receive thousands of e-mails and careful decisions need to be made about how they should be handled. If any site gives an e-mail address it must be made clear under what circumstances those who send an e-mail can expect a reply.
Requests for generic information about the British Council must be referred in the first instance to the British Council main web site (www.britishcouncil.org).
When sending e-mails such as fact sheets to the public, via electronic lists or list servers, we must make it clear how those on the list may get their names removed. We must also take great care to see that the e-mail addresses of other list members are not published.
We must not send e-mails to people who have not agreed to receive them (this is classed as spam).
Although e-mail may seem ephemeral, staff must bear in mind that it may be treated like any other form of communication as far as legal discovery of documents is concerned. Staff should be aware that e-mail may be required to be produced as evidence in a legal proceeding.
All requests for registration and use of new e-mail addresses and urls should be referred to the Senior Internet Business Development Manager.
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