Media Policy
This is the Gangmasters and Labour Abuse Media Policy. Here you will find the background of the policy, its aims, scope and how the policy should be applied.
Last updated 8 November 2018
1. Aims and objectives of the policy
Background of the Media Policy
Purpose of Policy
1.1 The Gangmasters and Labour Abuse Authority (GLAA) is a national law enforcement and compliance agency charged with protecting vulnerable people from exploitation. Its broad remit covers a labour market in excess of 10m people and it works closely with the Police Service and a raft of other agencies and strategic partners to achieve its aim of working in partnership to protect vulnerable and exploited workers.
1.2 As well as being reliant upon those partnerships, the GLAA also works with labour providers and stakeholders across a wide range of employment sectors to ensure regulatory compliance where necessary and raise awareness of issues relating to labour exploitation. This makes it imperative that the GLAA is regarded as a trusted organisation.
1.3 To maintain and enhance public confidence in the GLAA, the authority must have a relationship with the people it serves based upon understanding, active support and trust.
1.4 It is therefore vital that the GLAA equips the public and its stakeholders with information and knowledge of its activity to engender that understanding, participation and trust. We must inform the public about what, strategically, we are trying to do, and encourage the public’s help in preventing labour exploitation and protecting vulnerable workers.
1.5 The traditional media (print and broadcast) provides a mass communications channel through which we can communicate to a significant proportion of the population.
Principles
1.6 Our relationship and interaction with media organisations locally, regionally, nationally and internationally, will at all times be ethical, professional, transparent, accountable, auditable, appropriate and justified in law.
Aim of Policy
1.7 The aims of this policy are to:
- Inform the public through the media about the work of the GLAA and its corporate and strategic priorities
- Prevent labour exploitation and protect vulnerable workers using the media as a communications conduit
- Enhance the public’s understanding of, support for, and active participation around issues relating to modern slavery and labour abuse
- Provide the public with an honest and transparent picture of the GLAA’s activity
- Demonstrate public accountability
Content and Scope of Policy
1.8 This policy forms part of a wider framework of governance which sets out how the GLAA will deliver an effective and transparent media and communications service. This framework also includes policies or strategies on:
- External Communications
- Internal communications
- Stakeholder engagement
- Social media
2. Policy statement
Supporting Framework and Guidance
Legal Framework
2.1 Every interaction we have with journalists and media outlets must be conducted within a legal framework to ensure that the disclosure of information to the media is lawful.
Numerous acts of parliament provide a context in which information will be disclosed including, but not limited to, the Contempt of Court Act, the Magistrates Court Act, the Data Protection Act, the Freedom of Information Act and Human Rights legislation.
2.2 The GLAA will, at all times, operate within this legal framework.
3. Application of the Media Policy
Integrity and Communication of Information
3.1 The GLAA will seek to raise awareness of issues relating to labour exploitation and promulgate positive stories about operational successes whenever possible. Equally, the GLAA will be transparent and honest about its failings and adopt a proactive stance to these issues, unless there is an operational reason not to do so.
Information Categories
3.2 The GLAA will disseminate, either proactively or in response to requests from journalists, a range of information including:
- Strategic priorities
- Tactical / operational activity (i.e. ongoing enforcement activity, successful prosecutions)
- Policy issues (i.e. information about new or revised legislation related to labour exploitation)
- Thematic issues (i.e. prevention, awareness, education)
- Organisational issues (i.e. the GLAA’s roles and responsibilities)
- Accessibility issues (how the public can contact the GLAA)
Freedom of Information Requests
3.3 Responses to FOI requests will be published on the GLAA’s website, in accordance with our Publication Scheme.
3.4 Responses to certain FOI requests from media outlets are shared with the GLAA’s Communications and Engagement Team so that context around the information to be disclosed can also be provided to the media outlet concerned.
Speaking to Journalists
3.5 It is one of the principle responsibilities of the Communication and Engagement Team to liaise with the media on a regular basis and manage information flows between the GLAA and the media.
3.6 However, any GLAA colleague is authorised to speak to the media proactively or in response to enquiries, provided they are sufficiently knowledgeable about the subject in question and, where necessary, have the approval to so do from their line manager.
Anyone with any doubt, concerns or questions about what information they can and should release should contact the Communication and Engagement Team.
Mechanisms for Liaison
3.8 The Communication and Engagement Team uses a range of different mechanisms for liaising with the media and for the dissemination of information including:
- Telephone
- The GLAA website
- Social media platforms (Twitter, Facebook, Youtube, LinkedIn, etc)
- Face to face (in one to one meetings, media conferences, etc)
- Broadcast interviews (television and radio and certain on-line sites)
Working with partner agencies
3.9 Numerous communications products (media statements, press conferences, campaigns, etc) involve and affect other agencies (for example, Home Office, policing, NCA, HMRC, local authorities, and the Third Sector). Wherever practical and possible, the GLAA’s communications products will be shared in advance, and, when appropriate, approved by, those agencies involved or affected.
For further advice and policy information, contact should be made with the Communication and Engagement Team.
Imagery – releasing of images
3.10 Where the GLAA proactively publicise successful prosecutions, or respond reactively to media enquiries, there will be occasions when the authority wants to use images (ie photographs of those convicted of offences, evidential pictures).
Because suspects are detained in police custody suites, their photographs are taken by the relevant police force. These images remain the copyright of that force.
The GLAA will be reliant therefore on police forces to supply images for media use. However, the GLAA will ensure that all requests for images are given due consideration in regard to severity of offence, public interest and risk assessment of individuals involved, ensuring compliance with the GLAA: Release of Images Guidance document.
3.11 No imagery will be released to the media unless there is a genuine purpose (ie promoting the work of the GLAA and highlighting the issue of labour exploitation) to be achieved. Where images of individuals are concerned these will only be released following positive identification by GLAA colleagues(s).
Audit – Record of Information Released
3.12 The Communication and Engagement Team maintains a log of information released to the media, for disclosure and other reasons.
Other GLAA colleagues who release information to the media are strongly advised to keep a written note of what information has been divulged, to whom, and when and notify the Communication and Engagement Team.
Sponsorship
3.15 The sponsorship of certain aspects of activity (for example, award ceremonies, specific campaigns) is legitimate provided a number of criteria are met. These include, but are not limited to, the following:
Editorial control over “the message” rests with the GLAA and not the sponsoring body
The “event” being sponsored must be for a legitimate and sound purpose in accordance with the GLAA’s corporate and/or strategic objectives
The sponsoring body will not obtain, directly or indirectly, any exclusive or advantageous access to information that would not otherwise be available to it in accordance with this policy
The final decision whether to accept any offer of sponsorship will rest with the Chief Executive of the GLAA.
4. Interacting with External Media and Journalists
Formal Interaction
4.1 The GLAA will engage in formal interaction with journalists at a variety of levels including, but not restricted to:
4.1.1 Meetings/conversations between GLAA communications colleagues and individual journalists to discuss matters of media policy, protocol and critical incident. Notes of these meetings will be kept.
4.1.2 Meetings/conversations between GLAA communications colleagues and editors of local and regional media outlets on a one to one basis to discuss specific matters of policy, campaign and thematic issues (for example, modern slavery). Minutes of these meetings will be kept.
4.1.3 Senior Investigating Officers/ media outlet meetings: held between SIOs and individual media outlets to discuss specific operational issues to ensure the media’s comprehensive understanding (and therefore contextualised reporting) of often complex issues. Minutes of these meetings are kept.
4.1.4 Pre-trial briefings: held with media outlets to ensure accurate reporting of major criminal trials. Minutes of these meetings are kept.
4.1.5 Broadcast interviews: held between journalists and individual GLAA colleagues about specific operational or thematic labour exploitation issues.
Social Interaction
4.2 There is a difference in perception between GLAA colleagues and journalists attending a social event in the company of many other professionals (for example, an awards night), and one to one interaction in a public house, for example..
4.3 However, one to one interaction on a social level between GLAA colleagues and journalists can be perfectly legitimate and for a sound purpose. It is vital that the GLAA has a good, honest and robust relationship with the media to ensure the public receive accurate and honest information about its work relating to labour exploitation. However, such interaction, however well-intended, is open to misinterpretation. Where possible, prior advice should be sought from senior managers and the Head of Communication and Engagement before such one to one social interaction is conducted and/or declared to the GLAA as soon as is practical afterwards.
Impartiality / Exclusives
4.4 Most information released by the GLAA will not be of interest to all media outlets regionally, let alone nationally or internationally. For example, information about a successful prosecution in one area will be of limited interest, if any, to media outlets other than those circulating / broadcasting to audiences within that area. However, information deemed suitable by this policy and by other specific media policies for release to the media will be made available to all media outlets upon request.
4.5 A sophisticated and professional media strategy, predicated upon this policy, acknowledges that, in the interests of protecting vulnerable people from exploitation and raising awareness of the GLAA, a targeted media approach is often necessary. For example, the GLAA would be right to target a campaign to just those media outlets covering a specific geographic location about a labour exploitation issue that related just to that area, but upon request, readily release such information to other outlets.
4.6 The GLAA will not, however, treat any media outlet unfairly or partially, nor – unless there are exceptional circumstances to be determined by the Head of Communication and Engagement - operate “exclusive” arrangements with any media outlet.
Unauthorised Disclosure
4.7 The GLAA will not hesitate to instigate internal proceedings under its disciplinary procedures policy – and potentially criminal inquiries – against any member of staff who deliberately breaches this policy, engages in the unauthorised disclosure of information to journalists or seeks in any way to obtain financial benefit or benefit in kind in exchange for information.
Managing Interaction and Media Interests
Specific Media Policies / Strategies
4.8 Individual policies and strategies relating to the management of media interest / interaction regarding specific issues will continue to be produced and implemented.
Challenge to Media Inaccuracies
4.10 The media is not an extension of the GLAA’s public relations activity. As an independent industry it has a vital role on behalf of the public to hold public bodies, including the GLAA, to account.
4.11 There will therefore be times when it publishes or broadcasts articles and comments that may be critical of the GLAA and its performance. Such coverage should not taint our corporate relationship with the media nor influence our approach and principles, set out in this policy.
4.12 However, coverage that is incorrect, inaccurate or unbalanced should and will be challenged with the media outlet concerned and where appropriate, corrections sought. This will be done by the Communication and Engagement Team and not by individual GLAA colleagues
5. Policy Review and Monitoring
Policy Review
5.1 This policy will be reviewed, annually, by the Head of Communication and Engagement in liaison with the Chief Executive and approved and adopted thereafter by the GLAA Board.
Monitoring
5.2 All GLAA colleagues engaged in regular media liaison have a responsibility under this policy to monitor coverage and output. Specific responsibility for the monitoring and recording of media coverage and output rests with the GLAA Communication and Engagement Team.
Governance
5.3 The Communication and Engagement Team is responsible to the Head of Communications and Engagement for the governance and review of this Media Policy. Specific responsibility rests with the Head of Communications and Engagement.
5.4 See also:
GLAA External Communications Policy
GLAA Records Management Retention and Disposal Policy