Background
Scrutiny of the Public File, along with content sampling, forms a mainstay of Ofcom's move from input to output regulation.
Ofcom carries out both 'spot' and planned monitoring of output and the Public File.
Ofcom's processes with regard to content and Public File scrutiny are designed solely to confirm that stations are operating within their Format with particular regard to localness and music obligations.
Any other compliance problems which emerge will be dealt with via the normal complaints process.
Given the different nature of individual Formats there is no one template against which to judge stations' performance.
The purpose of the Public File is to provide a snapshot of localness and musical output and it is likely to be an Ofcom monitor's first port of call, as it should act as signpost to features and characteristics of a station, helping to form an idea of station character before output sampling is begun.
As with localness, it may be that particular important elements of music content are delivered outside monitored times. This can be ascertained through dialogue with the licensee. It might also be that Public File content could provide additional context with regard to music content.
Failure to allow public access to the Public File will be seen as a compliance failure. The seriousness with which this is viewed will depend entirely on which elements are missing/unsatisfactory, and the circumstances. A serious compliance failure could result in the triggering of the process as set out above.
As with output monitoring, we select stations for arranged inspections of Public File content in order to traverse the radio landscape over a period of time. Given that much of the information required by the Public File is already both to hand and on many station websites Ofcom does not feel the obligation is an onerous one, but one that moves the industry further towards self-regulation.
The Public File should have its own specific and clear link from a station's homepage. It should explain the purpose of the Public File and should contain either the information or clear links to the information required (below). An explanation of the purposes of a Public File should be along the lines that "Each local commercial station in the UK has obligations with regard to its programmes, including its music and local content. These obligations are set out in the station Format which forms part of this station's Public File. The Public File is also available in hard copy by post upon request by any member of the public, and serves as one indicator of each station's output. Comment on the contents of the Public File should be made to the station or to the industry regulator, Ofcom."
Ofcom also urges stations to make the existence of the Public File known to its listeners through occasional on-air mentions.
What the Public File must show
The Public File must include all the following unless the station's specific Format indicates that particular areas might be irrelevant. The Format, too, must appear in the Public File:
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* Note that more precise detail of automated programming will be sought privately by Ofcom on a regular basis (given security concerns raised by licensees during the consultation)
What the Public File looks like both in hard copy or on the web - is entirely up to individual stations. However, a link to the Public File must be included on the station's homepage.
Any queries on the public file should be addressed to jon.heasman@ofcom.org.uk