The UK Model for Handling Captioning Problems

By Cheryl Heppner

Editor: Pretty much everyone I've talked to who has tried to submit a complaint to the FCC has been surprised at how hard it is to find out what to do and to do it. The FCC has just released a new process, and we're all hoping it is better than the previous two iterations. For comparison, Cheryl Heppner recently took a look at how they handle these kinds of complaints in the UK. Here's her report.

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February 2008

Larry Goldberg, Director of the Media Access Group at WGBH, remarked recently that the United Kingdom version of our Federal Communications Commission really knows how to get things right. I couldn't agree more. Granted, they have a much smaller geographical area and population to cover than the US and its territories. Granted too, they have far fewer broadcasters, telecommunications providers, etc. to deal with. And while I don't know how effective they really are, I love their model for providing consumer information and responding to complaints .

The UK's Office of Communications, better known as Ofcom, has a very user-friendly home page at http://www.ofcom.org.uk/. A box at the top left gives these links to other pages.

* Advice for Consumers
* How to complain
* Find a document
* Research and Market Data
* Consultations
* Competition and Consumer Bulletin
* Media and Analysts
* Contacting Ofcom
* About Ofcom

Click on "How to complain" and you get these choices:

* Problems with your landline phone
* Problems with your mobile phone
* Problems with your internet service
* Programmes on TV/radio
* Advertising and sponsorship on TV/radio
* Digital TV/radio availability
* TV/radio interference and reception
* Complaints about Ofcom

Dealing with Subtitling Complaints

I clicked on the link for programs on TV or radio, and one of the selections was for complaints about subtitling, signing or audio description. Subtitling is the UK equivalent of our closed captioning. The UK has requirements for minimum obligations to provide signing, though they are far below those of subtitling.

A click on the subtitling, signing or audio description link took me to another page. There I could click to read the Code on Television Access Services, which sets targets for the amount of TV subtitling, signing and audio descripton that broadcasters must provide, and guidance about how access services should be presented. Reading this, I learned that broadcasters to whom the Code applies were required to submit quarterly "returns" starting January 1, 2005. They are also required to keep a recording "in sound and vision in a form acceptable to Ofcom" of every program included in the service for a period of 60 days from the date of its broadcast, and provide a copy of the recording for examinating and reproduction on request by Ofcom.

If I wanted to ask a question of a broadcaster and didn't know how to contact them, I could type in the broadcaster's name in the box on this page and get contact details from Ofcom's database. Since the only broadcaster I know is BBC, I typed that in. Up came two choices, one to use if I wanted to send complaints and one to use if I wanted reception advice. Both provided a link to BBC websites or a phone number for direct contact.

UK television viewers who feel that a broadcaster isn't following the rules for subtitling, signing or audio description can also click on an Action Link without having to first go to the broadcaster. There's a form to fill out your contact information and then you fill in information about the program you were watching. If you aren't submitting the complaint within 60 days, you must give a reason for the delay in order for it to be considered.

Next you give details about the complaint. For subtitling, the choices are: absence of subtitling on a program advertised as being with subtitling, loss of subtitling during program, significant inaccuracies in the subtitling, legibility of the subtitling, subtitling that was too slow, subtitling that was too fast. For other kinds of complaints, you can fill in details in the box provided. At the end, there's another box you can use to fill in details if you have already complained to the broadcaster, program maker or some other body.

Check it out at: http://www.ofcom.org.uk/

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