ASSESSING TRANSPARENCY A GUIDE TO DISCLOSING INFORMATION ONLINE

Transcription

1 ASSESSING TRANSPARENCY A GUIDE TO DISCLOSING INFORMATION ONLINE JULY 2015

2 ASSESSING TRANSPARENCY PRODUCED BY THE MEDIA INTELLIGENCE SERVICE (MIS) OF THE EUROPEAN BROADCASTING UNION JULY 2015 MEDIA INTELLIGENCE SERVICE The EBU's Media Intelligence Service (MIS) provides your broadcasting organization with the latest market data, research and analysis needed to plan your future strategies and stay ahead of the game. Our experts cover a broad range of topics, including TV and radio trends, new media developments, market structure and concentration, funding and public policy issues. HEAD OF THE MEDIA INTELLIGENCE SERVICE Dr Roberto Suárez Candel suarez.candel@ebu.ch Senior Media Analyst Dr Florence Hartmann hartmann@ebu.ch SENIOR MEDIA ANALYST Francesca Cimino cimino@ebu.ch SENIOR MEDIA ANALYST Dr David Fernández Quijada fernandez.quijada@ebu.ch SENIOR MEDIA ANALYST Alexandra Brenkman brenkman@ebu.ch DEVELOPMENT & COMMUNICATIONS Rachel McGowan mcgowan@ebu.ch CONTACT mis@ebu.ch CONFIDENTIALITY: The information contained in this document is confidential and only for EBU Members internal use. In the case of non- Members, the same and/or specific conditions apply. Public communication oral, printed or electronic is strictly forbidden without previous authorization by EBU-MIS. In addition, please avoid any unnecessary redistribution of this information within your company. If you have any doubt about how to use these data, please contact the Media Intelligence Service at EBU (mis@ebu.ch). DISCLAIMER: Please note that the EBU or the MIS are not liable for any errors or inaccuracies in data provided by third-parties. ASSESSING TRANSPARENCY 2

3 INTRODUCTION Public service media (PSM) are often seen as large organizations in which it is very difficult to keep track of what is going on. This opaqueness perceived by citizens and other stakeholders (governments, regulatory authorities, civil society organizations, etc.) is a barrier to their understanding of what public service media are and the value they deliver to society and citizens as individuals. To overcome this issue, PSM organizations are becoming more transparent and accountable, and increasingly make efforts to explain their remit, philosophy, objectives and activities. This is mostly reported to parliaments and governments but it can also be communicated directly to citizens. Nowadays, besides their annual reports, PSM also offer a vast array of information on their websites, from financial data to details of their remit accomplishment and social actions. By making this information available to their stakeholders, PSM reinforce their legitimacy. As any review of existing transparency initiatives shows, there are few guidelines for the development of transparency procedures within media organizations and, specifically, within public service media. As a consequence, the Media Intelligence Service of the EBU decided to launch the Assessing Transparency project. This aims to assist EBU Members in developing transparency standards, and enable them to build a closer and more trusting relationship with the citizens they serve. The goals of the Assessing Transparency project are threefold: Identify transparency indicators for PSM Develop an ad hoc methodology for assessing transparency Build the case for transparency among EBU Members In addition to this report, the Media Intelligence Service has produced an easy-to-use self-assessment tool for PSM organizations to analyse how they disclose information online. This is available on the Media Intelligence Portal ( ASSESSING TRANSPARENCY 3

4 Better accountability is accomplished through higher transparency,, ASSESSING TRANSPARENCY 4

5 content 6 WHAT IS TRANSPARENCY? How to report on transparency 8 METHODOLOGY Categories and indicators EBU Values and transparency 13 SELF-ASSESSMENT TOOL How the self-assessment tool works ASSESSING TRANSPARENCY 5

6 WHAT IS TRANSPARENCY? In relation to organizations and their activities, the Oxford Dictionary defines transparency as openness to public scrutiny. In the public service media sector, transparency is one of the governance principles 1. It is closely related to another of those principles, accountability, since better accountability is accomplished through higher transparency 2. As a principle, transparency is also associated with openness and responsiveness. PSM are accountable to society, and to the individuals and organizations that are part of it. More and more, these stakeholders are demanding access to key information about public organizations as part of their rights as citizens. Transparency is therefore necessary to ensure that stakeholders have the appropriate information to effectively scrutinize how public service organizations are run and perform, and to be able to assess how public money and resources are used. Transparency gained momentum as a principle of governance in the media sector more than two decades ago, when the Council of Europe launched its first recommendation on media transparency in However, the topic has become central not only in media but in other sectors of society owing to increasing concerns about corruption. In this area, the role played by civil society organizations such as Transparency International has been crucial in shaping a strong public opinion around the topic. This non-profit organization, probably the world s largest and mostrenowned organization in this field, measures transparency in relation to political and business corruption together with what it calls organizational transparency, defined as transparency of ownership and control over subsidiary companies. Its reports are widely quoted by mainstream media and used as a measure of the level of transparency of governments and companies around the world 4. Other public bodies have also tackled the issue of transparency. In 2006, a Green Paper entitled the European Transparency Initiative 5 was presented by the European Commission as a way of increasing transparency within the European Union institutions. Among other reasons given, the initiative stressed the need to offer a high level of transparency to ensure that the EU is open to public scrutiny and accountable for its work. The European Commission also stated that high standards of transparency are part of the legitimacy of any modern administration: the European public is entitled to expect efficient, accountable and service-minded public institutions and that the power and resources entrusted to political and public bodies are handled with care and never abused for personal gain. Although useful in boosting the relevance of transparency in the public debate, as they stand these approaches are difficult to apply to PSM or to media in general. The main reasons for this are the market specificities of the media and the symbolic nature of the content they carry, which strongly impact on the public sphere. It is absolutely necessary therefore to examine media-related transparency documents. Article 5 of the Audiovisual Media Services Directive 6 defines a minimum level of information that audiovisual media service providers should disclose in an easy, direct and permanent way. Disclosing this information is essential if citizens are to have a well-informed opinion about who is responsible for the service provided. Another pan-european institution, the Council of Europe (CoE), also offers some guidelines on transparency. In a recommendation adopted in , which builds on a previous more basic recommendation from 1994, the CoE states that some key information about existing media outlets should be accessible to the public. The areas covered are those of ownership, support measures and the right of reply and complaint. We should differentiate between mandatory and voluntary disclosure of information. On the one hand, the provisions of the AVMSD need to be transposed into the legislation of EU Member countries, so the Directive requires a minimum mandatory disclosure of information. The way 1 EBU (2015). Governance Principles for Public Service Media. Le Grand-Saconnex: European Broadcasting Union. 2 Zankova, B. (2014). Governance, Accountability, and Transparency of Public Service Media in a Contemporary Mediatised World. The case of Bulgaria, in M. Głowacki and L. Jackson (eds.), Public Media Management for the Twenty-First Century. Creativity, Innovation, and Interaction. New York: Routledge, p Council of Europe (1994). Recommendation No. R (94) 13 of the Committee of Ministers to Member States on Measures to Promote Media Transparency. [Strasbourg]: Council of Europe. 4 See, for example, Transparency International (2014). Transparency in Corporate Reporting. Assessing the World s Largest Companies. Berlin: Transparency International. 5 Commission of the European Communities (2006). Green Paper European Transparency Initiative. COM(2006) 194 final. Brussels. 6 European Parliament and Council Directive 2010/13/EU on the coordination of certain provisions laid down by law, regulation or administrative action in Member States concerning the provision of audiovisual media services (Audiovisual Media Services Directive) dated 10 March Council of Europe (2007). Recommendation CM/Rec(2007)2 of the Committee of Ministers to Member States on Media Pluralism and Diversity of Media Content. [Strasbourg]: Council of Europe. ASSESSING TRANSPARENCY 6

7 the Directive is applied, including how information should be disclosed, may change from country to country. On the other, the CoE recommendation proposes the voluntary disclosure of information. One of the most usual reasons why PSM are open to voluntarily disclosing accounting information is their interest in showing off their more favourable aspects to their stakeholders, including citizens (directly or through the press), governments and regulatory authorities. In addition, a transparent organization can show off its good governance principles and its good management practices. Altogether, this helps to achieve or improve the legitimacy and social acceptability of PSM. Besides, the most proactive organizations in this field are capable of setting performance standards as well as the agenda on media transparency. There are concerns about providing some competitive advantage to other media that compete with PSM for the time and attention of the audience. However, it can be argued that the long-term benefits in terms of legitimacy and case-building for PSM outweigh any possible disadvantages of being transparent. Finally, it must be taken into account that transparency is a value very much affected by culture. As a result of tradition and history, but also the conception of the state and its public institutions, each society attributes a different value or meaning to transparency, and it therefore has a different degree of relevance. A final comment should be made on the need to uphold transparency without damaging the principles of freedom of trade and industry. Data protection and trade secrecy must also be considered, although they should never be used to justify the avoidance or unnecessary limitation of transparency. How to report on transparency There are no standardized systems for reporting on transparency. The nearest thing to a standardized approach, which partially applies to transparency, is that included in the different standards for listed companies. These mainly refer to the disclosure of financial information and therefore their applicability to a holistic transparency approach is useful but rather limited. Some institutions have also worked on reporting transparency. For example, the Institute of Chartered Accountants in England & Wales (ICAEW) has produced several pieces of research about the way to report on financial issues by different companies. In its report on digital reporting 8, it distinguishes between two levels: Level 1 discusses the publication of a company's existing reports on the internet, so that these are disseminated more widely. Level 2 involves standardizing the format in which the information is stored, thereby facilitating and improving the process of analysis and exchange with other technical systems. The International Financial Reporting Standards Foundation (IFRS Foundation) has developed standardized reporting systems based on the principles of transparency, accountability and efficiency. These IFRS standards are at the core of the current EU regulation in this area 9. Apart from the disclosure of financial figures, other information is not disclosed in standardized ways. Often, the information is included throughout the companies annual or corporate social responsibility reports. Listed companies are usually obliged by law to disclose a certain amount and type of information to help investors make informed decisions. Other companies disclose information voluntarily as a way to raise their profile. Public companies also increasingly report on their activities as a way of communicating with their stakeholders, especially to citizens. We aim to help EBU Members to disclose their information about transparency. The indicators and categories proposed in this project are initial guidelines and do not exclude other possible indicators. In terms of the format, easy and quick access is central but the specific format will vary depending on the technology and design principles of the websites. A high degree of usability is a core recommendation, as well as its adaptation to the various platforms used to access those websites. 8 ICAEW (2004). Information for Better Market. Digital reporting: a progress report. London: The Institute of Chartered Accountants in England & Wales. 9 European Parliament and Council Regulation (EU) No 258/2014 dated 3 April 2014 establishing a Union programme to support specific activities in the field of financial reporting and auditing for the period of and repealing Decision No 716/2009/EC Text with EEA relevance, Official Journal of the European Union, L 105/1, 8 April. ASSESSING TRANSPARENCY 7

8 METHODOLOGY The transparency matrix was built in three steps 1. Desk research A thorough and systematic literature review on regulatory and academic documents was conducted to identify transparency indicators for PSM. This included the main European standards and regulations along with academic articles. In terms of standards, the two main sources were the Audiovisual Media Services Directive of the European Union and the 2007 recommendation of the Council of Europe. Other indicators were found in several academic documents on regulation. However, these sources offered general indicators that did not reflect the complex and specific nature of PSM organizations. Consequently, we used other academic texts focusing on PSM and the EBU s own recommendations to identify additional indicators. Some of these were not PSM-specific but more media-related, so they were identified in a fifth category of sources. 2. Designing the assessment matrix An analysis matrix was created listing the transparency indicators identified in the previous phase. The procedure was carried out in five stages. 1. Defining each indicator, aiming to standardize the meanings of the terms so that they are properly applied in various cultural contexts. 2. Defining the way each indicator is measured, considering two dimensions: value and format. The first refers to the availability of certain information, while the second explains how accessible it is. If the information is available but is difficult to find, it is less valuable than if it is prominently displayed. 3. Grouping indicators into comprehensive categories. The selected indicators were placed into four categories: corporate, financial, remit and social. In this stage, the research tries to maintain a balance between traditional management indicators (corporate and financial) and those that are specific to PSM (remit and social). 4. Weighting indicators and categories. Once the indicators were chosen and categorized, the need to weight them was examined. Several options were considered in regard to the weight of the indicators within each category, and in the final transparency index. The weight of each category in the final transparency index was also considered. However, as the transparency matrix is to be applied across a wide diversity of territories, in which the various indicators and categories might be perceived differently in terms of their value, it was decided to give the same weight to all categories. This results in each indicator having a different weight in the final transparency index (those in a category with more items hold less weight), but at the same time avoids too much weight for areas where more indicators are available, which would distort the outcome. 5. Assessing and weighting the format in which the information is presented. While the official documents reviewed for this research made no reference to how the information should be displayed, 12 format measurements were identified in the academic literature. To prevent the selfassessment tool from becoming too complex, it was decided to apply only one of them: the number of clicks needed to reach the information. This choice was for three reasons: it is one of the most widespread criteria; it is relatively easy to understand and assess; and it can be applied to any of the transparency indicators selected. Independently of its depth, if a website has a good search engine and is well indexed, the information can be easily retrieved. However, the position given to a specific piece of information also indicates its relevance. Even when both dimensions, content and format, are taken into account, there is the debate about the weight they should carry when creating a transparency index. Reflecting on the relevance of transparency but also on how it is communicated, both content and format were given the same weight, 50% of the final Transparency Index (TI). 3. Protocol for data collection A data collection protocol was designed, to ensure consistency in this process across markets. On account of how the self-assessment tool is built, it is possible to calculate partial indexes for both content and format. It is also possible to calculate an index for both content and format in each of the four categories of indicators proposed, as explained in the next few pages. ASSESSING TRANSPARENCY 8

9 CHART 1. Sources for transparency indicators AVMSD CoE Bib PSM Other CORPORATE 1 NAME OF MEDIA SERVICE PROVIDER 2 LEGAL DESCRIPTION 3 CONTACT INFORMATION 4 PHYSICAL ADDRESS 5 OWNERSHIP 6 BOARD MEMBERS 7 INFO ABOUT BOARD MEMBERS 8 GOVERNANCE 9 STRUCTURE OF COMPANY 10 WHO'S WHO 11 RIGHT OF REPLY AND COMPLAINT 12 LEGAL FRAMEWORK 13 REGULATORY OR SUPERVISORY BODY 14 PRESS RELEASES 15 EMPLOYMENT OFFERS 16 SUPPLIERS FINANCIAL 17 TOTAL INCOME 18 SOURCES OF INCOME 19 LICENCE FEE INFORMATION (IF APPLICABLE) 20 EXPENDITURES 21 RESULTS 22 NUMBER OF EMPLOYEES 23 STAFF COST 24 BOARD PAYMENTS 25 AUDIT REPORT REMIT 26 MISSION/GOALS 27 CONTRACT-PROGRAMME, CHARTER, ETC. 28 REMIT FULFILMENT INFORMATION 29 EDITORIAL GUIDELINES SOCIAL 30 CONTRIBUTION TO CULTURE 31 CONTRIBUTION TO ECONOMY 32 CORPORATE SOCIAL RESPONSIBILITY 33 ENVIRONMENTAL POLICY 34 LIST OF SERVICES 35 CONTENT QUALITY INDICATORS 36 TRUST INDICATORS 37 ACCESSIBILITY POLICY 38 DIVERSITY POLICY Sources: AVMSD: Audiovisual Media Services Directive CoE: Recommendation of the Committee of Ministers of the Council of Europe to member states on media pluralism and diversity of media content Bib: previous studies PSM: specific PSM values linked to the PSM remit ASSESSING TRANSPARENCY 9

10 Categories and indicators The indicators were chosen as a list of minimum transparency requirements. This means that PSM organizations can increase their transparency standards by including other indicators. Variations are certainly expected depending on the national context, so it is important for each organization to develop its own ways to uphold their standards. The category including corporate indicators is the one with the highest number of items. They mainly refer to descriptive information that can be applied to almost every organization, plus two additional indicators (right of reply and complaint, and regulatory or supervisory body) that are mediarelated. Financial indicators are the most standardized within the matrix and refer to the performance of the company. At this point, it is important to remember that transparency is one of the key principles of public PSM funding 10. Two additional categories were defined: remit and social indicators, that contain PSM-specific indicators. The first includes all those indicators directly related to the remit of the organization. The second, social indicators, comprises a diverse set of indicators covering areas considered relevant for media, and especially for PSM organizations, but which in many cases can also apply to companies in other sectors. These indicators mainly refer to the way operations are performed and their impact on society. Corporate transparency Name of media service provider: complete name of media service provider. Legal description: type of organization according to national laws (non-profit organization, commercial company, foundation, government department, etc.). Contact information: at least one telephone number and/or address/ contact form that allows citizens to contact broadcaster. Physical address: location of the media service provider. Ownership: information about who owns broadcaster. Board members: names of all board members. Information about board members: information about background of board members. Governance: at least name and function of governing bodies (executive board/ committee, trust, councils, etc.). Company structure: organization chart or description of departments in which broadcaster is organized. Who's who: directory of employees with contact information (at least departmental directors). Right of reply and complaint: information and contact details of ombudsman or equivalent institution in charge of defending audience interests, including rights of reply and complaint. Legal framework: information or link at least to relevant national broadcasting regulations. Regulatory or supervisory body: information about bodies or agencies supervising or regulating activities of broadcaster. Press releases: availability of press releases about organization (not just about programmes and services offered) over the last month. Employment: information about job vacancies and application procedure. Suppliers: information for providers content related or not about conditions and opportunities to work with organization. 10 EBU (2015). Public Funding Principles for Public Service Media. Le Grand-Saconnex: European Broadcasting Union. ASSESSING TRANSPARENCY 10

11 Financial transparency Remit transparency Social transparency Total income: income received by company during previous completed fiscal year. Sources of income: information about sources of funding received by organization Licence fee: basic description and cost for citizens/households. Expenditure: how company spends its money. Results: financial results of company (profit/loss). Employees: information about number of in-house staff. Staff cost: total amount or percentage of budget used to pay employees. Board payments: total amount of budget used to pay board members. Audit report: availability (or link to) last report signed by an external audit company or public body regarding the organization's accounts. Mission/Goals: brief explanation of broadcaster's mission and/or list of objectives. Contract-programme, charter, etc.: availability of or link to current official contractprogramme, charter or equivalent document defining broadcaster's objectives. Remit fulfilment: information about broadcaster's performance in relation to its goals. Editorial guidelines: information about the criteria for broadcaster's content. Contribution to culture: information about company's impact on arts and culture. Contribution to economy: information about the organization's investment in the broadcast industry or its economic impact on national economy. Social responsibility: description of corporate social responsibility activities. Environmental policy: any scheme or initiative addressing environmental issues (energy saving, recycling, campaigns, etc.). List of services: services and platforms where offered. Content quality indicators: list of indicators used to measure quality of content offered. Trust indicators: list of indicators used to measure citizens' trust in organization or in its channels/ stations. Accessibility policy: information about the institution's policy regarding access to its content by people with disabilities. Diversity policy: information about policies developed to ensure content diversity (gender, age, ethnic, region, language, etc.) 10 EBU (2015). Public Funding Principles for Public Service Media. Le Grand-Saconnex: European Broadcasting Union. ASSESSING TRANSPARENCY 11

12 EBU values and transparency Most of the 38 indicators proposed here to measure transparency relate to the core values of public service media as defined by the EBU 11 : universality, independence, excellence, diversity, accountability and innovation. Logically, accountability is the closest value to transparency, since both concepts rely on very similar principles. Nevertheless, other values are also related to some of the indicators. Independence becomes especially relevant in the corporate indicators as well as in the remit indicators. Social indicators are more diverse, encompassing universality, excellence and innovation among their most relevant values. CHART 2. Values linked to transparency indicators EBU PSM VALUES TRANSPARENCY INDEX Universality Independence Excellence Diversity Accountability Innovation CORPORATE 1 NAME OF MEDIA SERVICE PROVIDER 2 LEGAL DESCRIPTION 3 CONTACT INFORMATION 4 PHYSICAL ADDRESS 5 OWNERSHIP 6 BOARD MEMBERS 7 INFO ABOUT BOARD MEMBERS 8 GOVERNANCE 9 STRUCTURE OF COMPANY 10 WHO'S WHO 11 RIGHT OF REPLY AND COMPLAINT 12 LEGAL FRAMEWORK 13 REGULATORY OR SUPERVISORY BODY 14 PRESS RELEASES 15 EMPLOYMENT OFFERS 16 SUPPLIERS FINANCIAL 17 TOTAL INCOME 18 SOURCES OF INCOME 19 LICENCE FEE INFORMATION (IF APPLICABLE) 20 EXPENDITURES 21 RESULTS 22 NUMBER OF EMPLOYEES 23 STAFF COST 24 BOARD PAYMENTS 25 AUDIT REPORT REMIT 26 MISSION/GOALS 27 CONTRACT-PROGRAMME, CHARTER, ETC. 28 REMIT FULFILMENT INFORMATION 29 EDITORIAL GUIDELINES SOCIAL 30 CONTRIBUTION TO CULTURE 31 CONTRIBUTION TO ECONOMY 32 CORPORATE SOCIAL RESPONSIBILITY 33 ENVIRONMENTAL POLICY 34 LIST OF SERVICES 35 CONTENT QUALITY INDICATORS 36 TRUST INDICATORS 37 ACCESSIBILITY POLICY 38 DIVERSITY POLICY 11 EBU (2012). Empowering Society. A Declaration on the Core Values of Public Service Media. Le Grand-Saconnex: European Broadcasting Union. ASSESSING TRANSPARENCY 12

13 SELF-ASSESSMENT TOOL As a practical add-on to this report, EBU Members can download the assessment matrix from the Media Intelligence Portal ( This easyto-use excel file will enable them to measure the level of transparency in their organizations according to the indicators defined above. How the self-assessment TOOL works In the matrix, each indicator is displayed in a separate row. For each of them, two columns need to be completed: 1. CONTENT: The first column asks Is this indicator available on your organization s website? 2. FORMAT: The second column asks Can this indicator be reached in fewer than 3 clicks from the homepage? In both cases a drop-down list with two possible answers (Yes / No) is displayed, so that completing the matrix a very straightforward. Once the information for all the indicators has been provided, the intermediate indexes and the final transparency index are automatically calculated. As a result, 15 different values are displayed. The results are displayed on a scale from 0 to 100 and show the level of transparency according to the indicators. This scale is easy to understand by all relevant stakeholders since it takes the form of a percentage measurement. This transparency tool is designed to enable each EBU Member organization to assess itself. It will provide insights into which areas require greater communication/transparency efforts. Additionally, by repeating the exercise over a period of time, the organization can monitor its progress regarding transparency. FIGURE 1. Transparency indexes available CORPORATE TRANSPARENCY INDEX FINANCIAL TRANSPARENCY INDEX TRANSPARENCY INDEX REMIT TRANSPARENCY INDEX SOCIAL TRANSPARENCY INDEX ASSESSING TRANSPARENCY 13

14 Self-assesSment tool available for download through the MIS Portal: ASSESSING TRANSPARENCY 14

15 PHOTO CREDITS shutterstock: cover Stefano Santucci: pages 4, 14 ASSESSING TRANSPARENCY 15

16 EUROPEAN BROADCASTING UNION L Ancienne-Route 17A CH-1218 Le Grand-Saconnex Switzerland T +41 (0) F +41 (0) ebu@ebu.ch ASSESSING TRANSPARENCY 16