We cannot increase diversity if we do not define it

Just over a week ago Ofcom (the body that regulates British television) finished its consultation process on how the industry should define whether a programme is made outside of London.

Creating a definition is more complicated than you might think. 

Ofcom’s current definition is almost ten years old and there are concerns that production companies are effectively “gaming the system”. For example some London based production companies are thought to be “opening” satellite office outside of London to claim they are “regional” just for one programme and then “closing down” immediately after the programme is completed or that key production talent living in London are shipped out of London to a hotel just for a few months.

It is also important to recognize that it is not only production companies who "game the system", there are also the concern that some broadcasters might be intentionally “turning a blind eye” to productions which they know are not really “regional” so they have more freedom to commission whoever they want.

Creating a definition evefryone has to abide by is important because the major UK broadcasters all have to produce a certain percentage of their programmes outside of London. So being able to define what qualifies as an “Out of London” production is essential.

Ofcom first came up with a definition following the 2003 Communications Act which protects TV productions outside of London.

Although many people think the current definition has its flaws (hence Ofcom is updating it) having an agreed definition has been essential in measuring how well broadcasters are doing in meeting their license agreements.

When there isn't an agreed definition broadcasters can simply make up a definition that suits them and they can claim to be making progress when in reality they are not making progress at all.
 
This is the fear that this is exactly what is happening to TV diversity right now.  

How will we know if the broadcasters are really increasing diversity or just creating a definition that suits them and then claiming success? 

Currently Channel 4 has a two tick system (where productions must be able to tick two different criteria from a complicated list) to qualify as “diverse”.

Channel 4 also talks about championing “BAME-led-indies” but does not make it clear what its definition of a “BAME-led-indie” is. Is it the ethnicity of the CEO, board members of percentage of shareholders, or something else?

BBC is even vaguer with its definition of “diversity”. It implicitly has one as Danny Cohen (when he was Head of Television) told a Parliamentary Select Committee that the BBC was going to ring-fence 15% of its development spend on diverse productions – so he must have known what did and did not qualify as a diverse production. But there did not seem to be a clear definition publically as to what was and was not a diverse production.

At the same time the British Film Institute has a three tick system, similar to Channel 4, to decide whether a production is diverse or not.

There is no industry standard definition. And as far as I am aware none of the broadcasters conducted open public consultations on how to define diversity.

In short the whole thing is a bit of a mess.

They are all defining "diversity" themselves and then surpise surprise most of them are doing really well according their own made up definition.

It is precisely for these reasons that a lot of people interested in increasing diversity in the media are now calling on Ofcom to do exactly what it has done for regional diversity and conduct a public consultation and create an industry standard definition.

And it is not just the usual suspects like Sir Lenny Henry calling on Ofcom to do this.

The Mayor of London Sadiq Khan, the mayor of a city with a 40% BAME population, has openly written to Ofcom telling them it is essential for them to define diversity.

Scotland’s First Minister Nicola Sturgeon also wrote to Ofcom “urging” them to create an industry wide definition - drawing parallels between defining BAME diversity and “what constitutes a Scottish production”.

Ofcom has been charged with ensuring that the different broadcasters increase their diversity but as Nicola Sturgeon said “Targets are unlikely to be met in the absence of robust definitions”

As someone who worked in Scotland for eight years I applaud Ofcom tightening the rules around what qualifies as an “Out of London” production because as an exec producer I saw firsthand how production companies and commissioners sometimes played fast and loose with what should and shouldn’t be counted as an out-of London production.

But as someone who also cares about diversity of women, disabled people and BAME people working in the industry I believe Sadiq Khan, Nicola Sturgeon and others are right that Ofcom now need to define “diversity” in the TV industry.