Consultation outcome

Consultation on a potential change of ownership of Channel 4 Television Corporation

Updated 18 July 2022

This was published under the 2019 to 2022 Johnson Conservative government

Ministerial foreword

When Channel 4, created by the Conservative Government under Margaret Thatcher, joined the airwaves in 1982, there were just three other terrestrial TV stations – two of them owned by the BBC – and there was a lively debate about how to put the latest available set of bandwidths to best use. The main reason Channel 4 won that competition and was set up as a publicly-owned, commercially-run station was to provide greater choice.

Four decades on, choice is no longer a problem. First came commercial satellite TV and then digital terrestrial TV, pushing channel numbers into the hundreds. Then video-on-demand services such as Netflix, Amazon Prime and Disney+ made their way onto our screens, changing everything. We now live in a world of smart TVs and streaming sticks, catch-up and on-demand.

Our public service broadcasters — both publicly and commercially funded — continue to be a vital part of this mixed ecology, contributing hugely important social, cultural and economic benefits. Channel 4 itself has done an excellent job in delivering its remit and more recently in managing the uncertainty in the market over the last few years. It has advanced its digital strategy, whilst supporting the independent production sector in the UK, contributing to the economies of our nations and regions, and creating diverse and risk-taking content.

But this is 2021, not 1982 — and the broadcasting landscape has changed beyond recognition. Increased global competition and changing audience habits pose challenges to linear TV broadcasters, including Channel 4. Its current reliance on advertising and events-driven sponsorship activities expose it to market fluctuations and the decline in linear TV advertising spend relative to digital. We are also seeing a wave of consolidation that may make the challenges for a publicly owned Channel 4 more pronounced.

We want to make sure Channel 4 thrives for another four decades. And we want to maintain, and, where possible, enhance Channel 4’s unique role in UK broadcasting – for example, its success in delivering content that serves every corner of the country. We want to see a Channel 4 that has access to capital, and the ability to invest dynamically in new technology and programming – giving it the ability to serve audiences better in a fast-evolving media sector. We want it to be able to diversify its income, take advantage of strategic partnerships and access international markets. We want its remit to be relevant for both today and tomorrow, and we want to support its valuable contribution to the social and cultural life of UK audiences now and into the future.

It is our current view, to be tested through this consultation, that a new ownership model for Channel 4 would be the best means of ensuring its future success and sustainability as a public service broadcaster and its continued contribution to the UK’s creative industries. There are constraints that come with public ownership, and a new owner could bring access and benefits, including access to capital, to strategic partnerships and to the international markets. Private investment would mean more content, and more jobs.

This is a success story we have seen in commercially-owned public service broadcasters in recent years. ITV has successfully increased and diversified its income with the creation of ITV studios – something Channel 4 is not easily able to replicate in its current ownership model. Similarly, Channel 5 has thrived following its sale to ViacomCBS, seeing its group audience share grow from 5.8% to 6.4% in the three years following its sale,^{[footnote 1]} winning ‘Channel of the Year’ in 2020 and being the only public service broadcaster to grow its all-hours share in 2019.

Ultimately we want Channel 4 to keep its place at the heart of British broadcasting. We want to see it flourish and contribute to our wider plans to supercharge the creative industries; driving economic growth, unleashing investment, creating jobs and building on our international competitiveness.^{[footnote 2]}

Your response will form part of the evidence to inform the decision-making process on this topic, and ultimately feed into our wider strategic review of public service broadcasting. I welcome your response.

The Rt Hon Oliver Dowden CBE MP
Secretary of State for Digital, Culture, Media and Sport

Executive summary

Objectives and scope

This government is committed to the continued success of the UK’s mixed broadcasting ecology. As we seek to ensure that success continues against the backdrop of technological change and rapid market developments, including the rate of consolidation in the sector, we need to ensure that the UK’s broadcasting system is fit for the future.

Channel 4 has successfully delivered on its remit, aims and objectives since it began broadcasting almost 40 years ago. It has also effectively managed the uncertainty in the market over the last few years as it has advanced its digital strategy. However, the evolving media landscape poses material challenges to Channel 4’s future success and sustainability under its current ownership model and remit.

In that context, the government is now considering changes to the operating model of Channel 4, including its ownership and its remit and obligations, to ensure it has the best chance of future success. This takes into account the challenges to the future of linear TV broadcasting, ensuring Channel 4’s future sustainability as a public service broadcaster (PSB) and putting it in the best position to innovate and grow. The government believes that this will allow it to continue to contribute economically, socially and culturally by taking advantage of the opportunities available outside of public ownership. The government’s preferred option is to facilitate a change of ownership of Channel 4 which we believe will give it greater access to new strategic and investment opportunities, allowing it to compete effectively in a more agile fashion and ensuring it has the best chance of a successful and sustainable future. We believe this will help us achieve our aims for the broader creative industries as set out in our Plan for Growth – to supercharge the sector by driving economic growth, unleashing investment, creating jobs and building on our international competitiveness.^{[footnote 2]}

Against this background, the aims of this consultation are therefore to seek views and collect information to help inform the government’s decision-making process on both the objectives the government might want to pursue in a change of ownership of Channel 4, and on the modernisation of Channel 4’s remit and obligations – with specific reference to its social public service value and creative economy impact. The government is looking for respondents’ views and supporting evidence on whether they agree that there are challenges in the current TV broadcasting market that present barriers to a sustainable Channel 4 in public ownership; and whether a continued Channel 4, with a continued public service broadcasting licence and remit, would be better placed to deliver sustainably against the government’s aims for public service broadcasting if it was outside public ownership. The government also wants to hear from respondents more broadly on what the economic, social and cultural costs and benefits might be to moving Channel 4 out of public ownership.

The scope of this consultation does not cover anything relating to the mechanics and execution of a potential change in Channel 4’s operating model. For clarity, Sianel Pedwar Cymru (S4C) is a distinct broadcaster and is therefore not in scope of this consultation, which concerns the future of the Channel 4 Television Corporation only.

We will publish a Welsh language version of this consultation document shortly. If you have any questions, please contact channel4consultation@dcms.gov.uk

Background

The Channel 4 Television Corporation (Channel 4) began broadcasting in 1982. A self-financing public corporation, it is publicly-owned but commercially run. Its current ownership model comes from having been made an independent statutory corporation by the Broadcasting Act 1990. The Corporation operates Channel 4, one of a handful of channels in the UK to be designated as a PSB channel.

There were a number of driving forces behind the then government’s creation of the Fourth Channel in 1980, including delivering more choice for consumers, providing a greater range of options for those wishing to advertise on TV, and driving competitive tension with the then major broadcasters (BBC1, BBC2 and ITV). Channel 4’s role in the UK’s TV landscape has of course evolved over the years – with its enduring and significant value to the public stemming from its support for the independent production sector in the UK, the production of diverse and risk-taking content, and its contribution to the broader goals of public service broadcasting.

The government is committed to the success and sustainability of the PSB system, of which Channel 4 is an integral component, and recognises that it provides significant economic, cultural and democratic value to viewers across the whole of the UK. However, a number of questions have been raised about the rapidly-evolving linear TV sector – including the challenges and increased competition which have stemmed from this, which will only continue to grow stronger in the near future. Such challenges relate to changing consumer habits (with all audiences and particularly younger audiences increasingly likely to consume content on non-linear platforms such as Video On Demand (VoD) services), a decline in the aggregate viewing of linear TV which has implications for all PSBs, and the ability of global players – including Netflix, Amazon and Disney – to leverage more significant financial resources than their traditional linear TV competitors.

Although Channel 4 is already acting to adapt to the challenging sector backdrop, the government considers that there are a range of factors – including Channel 4’s status as a publisher-broadcaster and its limited access to capital by virtue of its public ownership – which restrict its ability to respond as effectively as it could to changing market dynamics, and which therefore place increased risk on its long-term sustainability.

As stated, the government’s preferred option is to facilitate a change of ownership of Channel 4 given this could afford it with an improved ability to respond to the rapidly-evolving landscape through, for example:

• improved and sustained access to capital
• the ability to take advantage of strategic partnerships and acquisition opportunities
• the ability to expand into international markets
• the ability to invest more heavily in an agile manner to ‘future-proof’ its business model
• the ability to diversify its revenue sources

Timings

We welcome comments from all stakeholders who may be interested. The consultation will close on 14 September 2021 at 23:45.

A summary of responses and the government’s response to this consultation will be published in due course and following the closure of the consultation.

The government’s response will take all in-scope responses submitted to this consultation into account, and will be based on careful consideration of the points made in consultation responses, not the number of responses received. 

1. Background

Channel 4 Television Corporation began broadcasting in 1982. A self-financing public corporation, it is publicly-owned but commercially run. Its current ownership model comes from having been made an independent statutory corporation by the Broadcasting Act 1990. The Corporation operates Channel 4, one of a handful of channels in the UK to be designated as a public service broadcasting (PSB) channel. The government is committed to the success of the PSB system, of which Channel 4 is an integral component, and recognises that it provides significant economic, cultural and democratic value to viewers across the whole of the UK.

Since its creation, Channel 4 has established itself as a distinctive broadcaster renowned for offering diverse and innovative content in the interests of communities across the UK, in line with its public service remit. Channel 4 has an extended qualitative remit that is more distinctive than those of the other commercially-funded PSBs, which includes requirements, amongst others, to demonstrate innovation and distinctive character in its programming.

More recently Channel 4 has articulated its ‘purpose’ as creating change through entertainment,^{[footnote 3]} which means creating change in the wider world through all of its activities, from TV to streaming, and from social media to film. These are key when Channel 4 considers its impact on the economy, society and culture. Channel 4’s ‘vision’ embodies how the organisation creates change for the good of the British public. It does this through:

• ‘representing unheard voices’ from diverse communities
• ‘challenging with a purpose’, including holding power to account in an impartial and balanced way
• ‘reinventing entertainment’ to ensure they are working with their partners to deliver genuinely innovative content that reaches new audiences

By law the Channel 4 licence is held, and can only be held, by the Corporation. Channel 4’s current licence is due to expire in 2024. The process for administering the Channel 4 licence is overseen by Ofcom. This PSB licensing process, underpinned by statute, requires that:

• Channel 4 must be free-to-air
• Channel 4 must be offered to all digital networks and satellite networks
• the Corporation must ensure that it fulfils the public service remit in relation to Channel 4 and meet certain production and content quotas

In exchange, Channel 4 receives:

• guaranteed access to spectrum, which facilitates reach of the PSB channels to nearly 99% of the population via Freeview
• the benefit of ‘must carry’ obligations on all networks under the Communications Act 2003
• guaranteed ‘prominence’ within the electronic programme guide on live TV, which makes their content easy to find and watch
• qualification for the listed events regime, which protects certain sporting events from being shown exclusively on pay-TV broadcasting services

In total, Channel 4 operates twelve linear channels: Channel 4 itself (the ‘main channel’), plus 11 ‘portfolio’ channels (E4, Film4, More4, 4Seven and 7 music channels). Only the main channel has been formally designated a PSB channel, although the Digital Economy Act 2010 gave Channel 4 additional obligations that apply across its full range of platforms and services. It also has an on-demand platform, All 4, and operates a film production company, Film4 Productions.

However, an increasing number of challenges are facing the linear TV sector. These relate to technological advances and changing consumer habits (with all audiences, and particularly younger audiences, increasingly likely to consume content on non-linear platforms such as Video On Demand (VoD) services, and doing so on non-traditional ‘second-screens’), a decline in the aggregate viewing of linear TV which has implications for all PSBs, and the ability of global players – including Netflix, Amazon and Disney – to leverage significant financial resources to attract viewers. These challenges are only expected to become more pronounced over time.

1.1 Channel 4’s success in meeting its original remit

There were a number of factors relevant to the then government’s creation of the Fourth Channel, including delivering more choice for consumers, providing a greater range of options for those wishing to advertise on TV, and driving competitive tension with the then major broadcasters (BBC1, BBC2 and ITV). The channel was established as a wholly owned subsidiary of the Independent Broadcasting Authority, the independent regulator for commercial television in the UK at the time. Channel 4 began broadcasting in November 1982, and the arrival of Richard Attenborough as Chairman in 1987 signalled the start of Channel 4’s long involvement with the UK film industry too.

Over the years, Channel 4 has made significant contributions to the UK’s cultural landscape through its diverse and innovative TV and film productions. Notable examples include Big Brother, which launched in the year 2000 and is widely recognised as the first interactive, cross media concept with mass appeal, and a long list of original British comedy, running from the Comic Strip Presents series in the early eighties, through to modern classics like Derry Girls and Catastrophe. As of 2021, Film4 films had produced 143 Oscar nominations and 37 wins. Channel 4 has been credited with launching the careers of many of the UK’s most well-loved and renowned writers, directors, presenters and entertainers, including the likes of Sasha Baron Cohen and Ricky Gervais, who came to prominence through the 11 O’Clock Show.

Clearly, the TV ecosystem has evolved and, to an extent, so has Channel 4’s role within it. In more recent years, Channel 4’s enduring, and significant, value to the public has been threefold:

• Support for the independent production sector in the UK, with a recent focus on the nations and regions in particular. This support comes primarily from original content spend, which was £492 million in 2019 (accounting for around 15% of the sector’s £3.3 billion revenue)^{[footnote 4]}, the third-highest level in Channel 4’s history,^{[footnote 5]} and a £130 million increase on 2010.^{[footnote 6]} Despite the challenging environment in 2020, Channel 4 was still able to spend £370 million on originated content.^{[footnote 7]} It also includes contributions from Channel 4’s other business activities, including Film4, the Indie Growth Fund^{[footnote 8]} and 4Skills.^{[footnote 9]} Channel 4 spent £189 million on production in the nations and regions in 2019^{[footnote 10]} and £141 million in 2020,^{[footnote 11]} still up from £125 million in 2010 despite the impacts of Covid-19.^{[footnote 12]} It worked with 274 producers in 2020 – of which 161 were independents. Overall, the UK independent production sector has grown exponentially from an estimated worth of £850 million in 2003 to in excess of £3 billion today, driven in particular by the boom in international revenues with 158% growth between 2014 and 2019 from £484 million to £1.25 billion.^{[footnote 13][footnote 14]} This has been driven in part by international VoD players with large balance sheets.
  
  
• The production of diverse and risk-taking content, and levelling up as a result of taking more creative risks than other broadcasters and providing programming that appeals to the tastes and interests of a culturally diverse society across the regions and nations of the UK. Part of the rationale behind Channel 4’s inception was that it would provide content that was distinctive from that shown on the BBC, and ITV in particular, at a time when there was limited choice for viewers in terms of their TV consumption – in contrast to today with more choice available to audiences than ever before and when there has been significant changes in how people consume TV in the digital age (particularly amongst younger audiences). In more recent times, Channel 4 has highlighted the importance of maintaining its distinctive channel ethos by championing unheard voices and tackling challenging territories. It has also increased its commitments beyond London with the creation of three new offices in 2019 in Leeds, Glasgow and Bristol and through 58% of first-run originated programme hours on the main channel coming from suppliers outside London in 2020, up from the 54% it achieved in 2019. This was greater than the 48% achieved by ITV and 21% achieved by Channel 5 in 2019.^{[footnote 15]} Evidence from Ofcom’s PSB tracker survey shows Channel 4 still consistently outperforms the other PSB channels in tackling issues that other broadcasters would not and performs particularly highly on statements relating to its originality and innovation.
  
  
• Its contribution to the broader goals of public service broadcasting. Channel 4, along with the other designated public service broadcasters, is expected to contribute to the purposes of public service broadcasting as expressed in the Communications Act 2003, namely, the provision of diverse, high-quality, accessible programming on a free-to-air basis. Channel 4 also has an extended qualitative remit that is more distinctive than those of the other commercially-funded public service broadcasters, and includes requirements to, amongst other things, demonstrate innovation and distinctive character in its programming. Ofcom previously concluded that Channel 4 shows a broad range of high-quality programmes, with audiences consistently rating Channel 4 more highly than other PSB services in taking creative risks, tackling issues that other broadcasters would not, and enabling alternative voices to be heard.^{[footnote 16]}

1.2 Challenges to the future of Channel 4 under public ownership

The government is committed to the success and sustainability of public service broadcasting, including continuing the success of Channel 4, and preserving its unique and vital role in UK broadcasting to ensure audiences can enjoy a wide range of high-quality programmes. However, recent changes to the linear TV broadcasting backdrop call into question whether its current public ownership model (with the associated restrictions and obligations) is the right one to allow it continued success and long-term sustainability. Specifically:

• Channel 4’s revenue is largely undiversified, and driven by advertising activities, which accounted for over 90% of Channel 4’s revenue in 2020 (Figure 1). While the growth of digital television advertising revenues (which have increased from £84 million in 2016 to £161 million in 2020^{[footnote 17]} and are forecast to continue growing with a digital advertising target of at least 30% of total revenue by 2025)^{[footnote 18]} have made up for reductions in linear TV advertising revenues (which have declined across the sector at a compound annual growth rate of 2.5% since 2015)^{[footnote 19]}, this is mostly advertising spend moving from one platform to another. Unlike other broadcasters, Channel 4 does not derive significant revenues from productions – mainly as a result of the prohibition, by way of its publisher-broadcaster status, from being involved in the making of programmes to be broadcast as part of the Channel 4 service without first seeking regulatory approval – and limited revenue from the sale of secondary rights. A key pillar of Channel 4’s Future4 Strategy is to achieve 10% of total revenue from non-advertising revenue by 2025. Beyond this, its publisher-broadcaster status may restrict Channel 4’s ability to go much further in diversifying its revenue streams over this timeframe.

Figure 1: C4C revenue by source (£millions)

Year	Linear advertising revenue	Digital advertising revenue	Non advertising revenue	Total
2016	884	84	67	995
2017	785	100	75	960
2018	774	120	81	975
2019	767	145	73	985
2020	689	161	84	934

• Increased competition from Video on Demand (VoD) and Video Streaming Platforms (VSPs) has resulted in changes in consumption habits. Since Channel 4 was first established to give audiences greater choice, the number of TV channels has increased significantly (Figure 2). There is more choice available to audiences than ever before and the way that people consume TV in the digital age has changed. 16-34 year olds are a key audience for Channel 4, which is the only public service broadcaster to attract significantly greater viewing amongst this age group than across the general population. In 2020, viewing amongst 16-34-year-olds was 55% higher across the Channel 4 portfolio than the corresponding all-audience share.^{[footnote 20]} However, all audiences, and particularly younger audiences, are also increasingly likely to consume content on non-linear platforms such as VoD services, meaning Channel 4 needs to continually adapt to keep pace. Linear TV viewing is down almost 60% amongst 16-25 year olds since 2010,^{[footnote 21]} whilst 16-34 year olds now spend almost twice as much time with YouTube and subscription VoD services (205 minutes per day) than they do with broadcast content (117 minutes per day).^{[footnote 22][footnote 23]} Nonetheless, Channel 4 has continued to perform successfully over recent years, generating £985 million in revenue in 2019. Even with the challenges presented by COVID-19, Channel 4 continued to perform well in 2020 generating £934 million in revenue, including a record £161 million in digital advertising revenue, despite cutting content spend from £660 million in 2019 to £522 million in 2020.^{[footnote 24]} Channel 4’s digital streaming service All 4 saw a 26% increase in views in 2020 and now has 24 million registered viewers including 80% of 16-34 year olds in the UK.^{[footnote 25]} Linear TV audiences have remained strong, with a main channel viewing share of 5.9% and portfolio viewing share of 10.1% in 2020 despite the increasingly competitive broadcasting landscape (Figure 3.^{[footnote 26]} However, viewing share is considerably down on the 7.0 % main channel share and 11.4% portfolio share achieved in 2010,^{[footnote 27]} with changing consumer habits meaning today’s viewers now have a huge amount of choice in terms of what they watch and how they watch it – and they are taking advantage of it. Third party ownership and the benefits it would bring could allow Channel 4 to build on this success and compete more effectively with new players, allowing it to be more agile than is possible under public ownership.

Figure 2: Number of BARB reported TV channels^{[footnote 28]}

Year
1982 (Channel 4 established)	5
1990	12
2000	102
2010	286
2020	315

Figure 3: Channel 4 and Channel 4 portfolio audience shares

• Growing production budgets across Video on Demand (VoD) platforms make it increasingly difficult for domestic players without access to significant capital to support strategic investment to compete. This is reflected across a number of genres, including high-end dramas. Channel 4 has limited resources and content budgets by virtue of its public ownership. Conversely, global players including Netflix, Amazon and Disney have been able to leverage significant financial resources, with Netflix spending on content projected to be close to $18 billion in 2019,^{[footnote 29]} compared with total PSB content spend of £2.5 billion on first-run originations in 2019.^{[footnote 30]} Hourly budgets as a whole are increasing to reflect higher quality content, with Netflix and Amazon spending as much as £15 million per hour on production.^{[footnote 31]} Indeed, across High End Television,^{[footnote 32]} the average spend per hour on purely domestic productions has remained well under £2 million per hour, whilst the budget for shows with international investment is now almost £6 million per hour – with the gap set to widen as domestic players get out-spent by better resourced international groups.^{[footnote 33]} Third party ownership with the improved access to capital it would bring could allow Channel 4 to innovate and adapt to stay ahead.
  
  
• Technological changes also represent new opportunities for PSBs to invest and adapt, as audience preferences for where they watch content changes. Of those who watch both Subscription VoD (SVoD) services and PSB services, 77% say it is ‘easier to find something new to watch’ on SVoD services.^{[footnote 34]} With the change in viewing habits, Channel 4 would benefit from the ability to invest and transform itself more rapidly into a hybrid broadcaster with both a linear and VoD offering across multiple platforms. To date, its VoD platform, All 4, has performed well with total views reaching over 1.25 billion in 2020, more than double the 620 million views in 2016 (Figure 4).^{[footnote 35]} The platform performed particularly well throughout the Covid-19 pandemic, with All 4 use up 54% year-on-year at the height of lockdown.^{[footnote 36]} A new owner with improved and sustained access to capital, an ability to take advantage of strategic partnerships, and to support expansion into international markets could help build on Channel 4’s success in this area – in particular in terms of hours of content available online.

Figure 4: Channel 4 digital VoD views (millions)

Year
2016	620
2017	719
2018	915
2019	995
2020	1253

1.3 Levers to modernise and adapt

With more choice available to audiences than ever before and changes in how people consume TV in the digital age, there is an urgent need for traditional linear TV broadcasters to adapt their business models and innovate to remain relevant and competitive in the market. Improved network connectivity has reduced barriers to entry and led to players like Amazon entering the broadcasting market from adjacent markets. The emergence of large international players like Netflix, and the increase in viewing across non-linear platforms, present real challenges to all PSBs in terms of maintaining audience share. As of the first quarter of 2021, 66% of households watched Netflix with over half watching Amazon Prime, whilst 41% watched All4 (Figure 5).^{[footnote 37]}

Figure 5: Share of households that watch programmes, shows or films across different video platforms (2021 Q1)

Platform
Netflix	66%
BBC iPlayer	64%
Amazon Prime Video	53%
ITV Hub or STV Hub	49%
All4	41%
YouTube Channels	41%
Disney+	27%
My5	25%
Sky on Demand or Sky Go	18%
Virgin TV Catch-up of Virgin Media Go	9%
NOW TV Entertainment Pass or NOW TV Cinema Pass	9%

In order to rise to these challenges, it is the government’s view that broadcasters firstly require access to sufficient capital, since innovation and adaptation require up front and ongoing investment. This investment needs to be able to be sustained over time given the sector continues to evolve, and broadcasters will therefore need continued access to sufficient capital to avoid being left behind. Secondly, they need to be well positioned to act quickly, taking advantage of strategic partnerships, international growth opportunities, new technologies and industry know-how in real time in order to stay ahead in a highly dynamic market.

Under public ownership, Channel 4 is currently constrained in taking these steps in full. The government’s preferred option is to facilitate a change in ownership of Channel 4 to an owner that can provide the necessary access to capital and other strategic and investment opportunities required for Channel 4 to adapt and stay ahead, therefore securing Channel 4’s future as a viable and sustainable public service broadcaster. A parallel here could be drawn with the success of Channel 5 following its sale to ViacomCBS, with the channel growing its group share from 5.8% to 6.4% in the three years following its takeover,^{[footnote 38]} winning ‘Channel of the Year’ in 2020 and being the only PSB to grow its all-hours share in 2019.^{[footnote 39]}

Channel 4 is working to modernise its business model within the parameters of its current operating framework. Last year Channel 4 launched its Future4 strategy,^{[footnote 40]} an ambitious and comprehensive plan to transform the organisation into a digital first public service broadcaster by growing its streaming and social platforms whilst maintaining its linear schedule. The strategy builds on Channel 4’s strong track record of digital innovation and will accelerate its pivot to digital by driving both online viewing and new revenues.

Future4 has clear targets against which success will be measured:

• to double All 4 viewing by 2025
• aim for digital advertising to be at least 30% of total revenue by 2025
• aim for non-advertising to be at least 10% of total revenue by 2025

These targets are then underpinned by four strategic pillars to ensure that they are met:

1. Prioritising digital growth over linear ratings

2. Putting viewers at the heart of decision-making

3. Diversifying new revenue streams to underpin sustainability

4. Focusing on strategic partnerships to compete more effectively

However, the government considers that Channel 4’s status as a publisher-broadcaster, and its limited access to capital by virtue of its public ownership, restrict Channel 4’s ability to respond to changing market dynamics now and in the future, including beyond the 2025 time horizon associated with the current Future4 strategy.

• Status as a publisher-broadcaster – Channel 4 operates as a publisher-broadcaster, broadcasting programmes that it has commissioned (or otherwise acquired) from others. Unlike other commercially-funded public service broadcasters, it is prohibited by section 295 of the Communications Act 2003 from being involved in the making of programmes to be broadcast as part of the Channel 4 Service, except to such extent as Ofcom may from time to time allow. As such, its business model is heavily reliant on advertising revenues, which are cyclical in nature and shifting away from linear TV platforms to digital platforms. Channel 4’s competitors have been able to diversify their revenues through investment in production. For example, total ITV Group external revenues were around £3.3 billion in 2019 of which £2.1 billion was derived from non-advertising revenue. Despite Covid-19, its non-advertising revenues still accounted for nearly £1.7 billion in 2020. ITV Studios is the largest commercial producer in the UK with a combined content library of over 46,000 hours. It achieved total production and distribution revenue of almost £1.4 billion in 2020 despite production delays caused by Covid-19, down from around £1.8 billion in 2019. Over half of ITV Studios’ revenue is generated outside the UK.^{[footnote 41]} Meanwhile, Channel 4 remains reliant on advertising revenue with over 90% of its £934 million total revenue in 2020 coming from advertising and sponsorship revenue.^{[footnote 42]}
  
  
• Access to capital – Under the current borrowing limits set out in legislation Channel 4 has restricted access to capital, which limits its opportunities to pursue diversified income stream. This leaves Channel 4’s revenues and financial sustainability under public ownership vulnerable to shocks that impact advertising revenues. Channel 4 managed the 2020 downturn in advertising revenues effectively by cutting back on investment. The market-wide impact of the pandemic limited the impact of these short-term measures on Channel 4’s audience share and competitive positions. However, this reliance on advertising poses material risks going forward, given the need for linear broadcasters to keep pace with an increasingly competitive market for content and talent and to make sustained investments into digital platforms such as All 4 (which are central to the success of Channel 4’s Future4 strategy). To date, Parliament has restricted Channel 4’s borrowing to £200 million, and under its existing ownership model, Channel 4 does not have the option to raise capital by issuing equity to third party investors. As a public corporation, Channel 4’s borrowing is accounted for as public sector borrowing and scores against total public sector net debt. New ownership would afford Channel 4 the opportunity to access capital and the associated benefits.
  
  
• Public service remit – Over time, the high-level policy goals for Channel 4 have gradually been embedded into a formal remit which is both qualitative (requirement to broadcast diverse, innovative and distinctive programming) and quantitative (quotas set and monitored by Ofcom covering both how Channel 4 invests in content and how that content is received). The government strongly supports the existence of PSB remits and recognises that obligations imposed on PSBs are balanced against material benefits, notably prominence and guaranteed access to the digital spectrum. However, at a time when media consumption habits are changing, players who do not have the same remit obligations have entered the market, as seen in the emergence and growth of commercial non-PSB players across the free to air TV landscape over the last decade. Ofcom’s most recent multi-year review concluded that Channel 4 largely met its media content duties between 2014 and 2018,^{[footnote 43]} and it is important that the remit continues to deliver for the audience and remains relevant. As part of the ongoing strategic review of the PSB system, the government will consult in due course on the regulation of video-on-demand services.

To ensure its long-term sustainability in the face of persistent competition from well-funded global organisations such as Amazon, Netflix and YouTube, it is the government’s view that Channel 4 requires access to significant and sustained capital to innovate and adapt on a larger scale. Channel 4 also needs to be able to take advantage of opportunities to be sufficiently agile in its investment decisions to benefit from potential strategic partnerships, expansion opportunities and technological advancements.

The government is therefore considering changes to the ownership of Channel 4 to a new owner who could provide the necessary private sector access to capital and agility to secure Channel 4’s future as a viable and sustainable PSB.

2. Government objectives

The government wants to see the creative industries supercharged so they may drive economic growth, unleash investment, create jobs and build on our international competitiveness. Public service broadcasters, including Channel 4, have a crucial role to play in this. To ensure the future sustainability of Channel 4 and provide the best environment for it to innovate and grow – thereby allowing it to continue to contribute economically, socially and culturally – the government is now considering changes to the ownership model of Channel 4. There is also a compelling case to consider modernisation of the remit and obligations placed on Channel 4.

2.1 Rationale for considering changes to Channel 4’s operating model

As stated, the government considers that Channel 4 has been successful in delivering the aims set out by the creation of the channel, including supporting the independent production sector in the UK, the production of diverse and risk-taking content and contributing to the wider public goals of public service broadcasting. It is entirely commercially funded, and is able to function without direct financial support – though the presence of a direct sovereign backstop does have an impact on the organisation.

Despite that success, future challenges are foreseeable for the linear TV sector as a whole. These clearly apply to Channel 4 and, therefore, to secure its continued contribution economically, socially and culturally, it needs to keep pace with the competitive environment it operates in and changing audience preferences. This includes being able to diversify its income streams, invest in new technology, and compete effectively with new players at pace.

Given Channel 4’s current limited access to capital, a change of ownership could provide access to new collaboration and investment opportunities to allow it to compete effectively with well-funded players in a more agile fashion – something that would be difficult to achieve under public ownership given the limited levers available to Channel 4 resulting from its current status. It is for these reasons that the government judges that now is the right time to review Channel 4’s relationship with the government. The government’s preferred option is to facilitate a change of ownership of Channel 4, in order to ensure it has the best chance of a successful and sustainable future, ultimately contributing to our plans for growth in the sector and wider creative industries, as set out in the government’s Plan for Growth.^{[footnote 44]} The objectives of any such change in ownership are outlined further in Chapter 4 (Objectives of a change of ownership).

More broadly, it is a clearly stated government policy that where the public policy purpose of a government asset may be more efficiently realised with the asset in private ownership, the government may choose to sell, or consider the sale of, that asset, subject to being able to achieve value for money and market conditions being supportive. Recognising the challenges faced by the PSBs, and the restrictions placed on Channel 4 by virtue of its public ownership, the government considers that Channel 4’s ability to compete, continue serving its public purpose and contribute value to the UK is likely to be best served by private ownership.

2.2 Aims and priorities for public service broadcasting

The UK’s system of public service broadcasting is the result of a series of regulatory interventions designed to ensure that UK audiences can enjoy a wide range of high-quality programmes that meet people’s needs as citizens and their interests as individuals. At its heart is the concept that TV has the opportunity to contribute to the cultural, economic and democratic life of the United Kingdom, at home and abroad, but for reasons including market failure will not achieve this effectively without a robust regulatory framework. The PSB ecosystem also plays an important role in supporting the wider creative economy through its contribution to the wider broadcasting ecology, such as through the continued investment in the nations and regions, the ongoing development of the skills and talent pipelines, and the broader competition between PSBs and other players which continues to build the UK as a creative hub.

There is no single piece of legislation covering public service broadcasting, but the Communications Act 2003 provides many of the key building blocks. For example, it designates certain broadcasters as ‘public service broadcasters’ (currently the BBC, ITV, STV, Channel 4, Channel 5 and S4C).

The government recognises that the PSB system provides significant value across the UK, keeping people informed, educated and entertained every day. However, there is an increasing consensus that the UK’s PSB system needs to evolve, if it is to transition successfully to the digital era. Changing technology, increasing competition from well-funded global companies (where we are seeing a wave of consolidation) able to leverage significant financial resources, as well as wider developments in areas such as audience habits and expectations are having significant impacts on the financial sustainability and overall structure of the industry. The government is therefore keen to ensure that the UK continues to benefit from a modern, sustainable and successful system of public service broadcasting that remains relevant and can continue to meet the needs of UK audiences in the future. Channel 4 should continue to play a role in, and indeed be an important contributor to, the future success of the PSB system, though it remains appropriate for that role to be considered in the context of the government’s wider aims and priorities for PSB. The government’s current view is that Channel 4 should, under any ownership structure, continue to play an important role in PSB, as discussed further in Chapter 3 (Modernisation of Channel 4’s remit and obligations). However, in light of the evolving structural dynamics facing the broadcasting industry as a whole, it is right to examine all possible ownership models.

3. Modernisation of Channel 4’s remit and obligations

Taking account of the government’s aims and priorities for public service broadcasting and the need to examine all possible options, it is appropriate that the modernisation of Channel 4’s remit and obligations is considered. Channel 4’s current remit and obligations are largely based on the key building blocks for public service broadcasting as set out in the 2003 Communications Act, with further changes made in the 2010 Digital Economy Act. This gives rise to the question of how relevant Channel 4’s remit and obligations are today in view of the changed broadcasting landscape.

3.1 Social public service value

Levelling up

The government recognises Channel 4’s commitment to levelling up and its support for national and regional economies. Channel 4 contributed £992 million to the UK economy in 2019, including £274 million to the regional economy, and also supported over 3000 jobs in the nations and regions.^{[footnote 45]} In 2018, Channel 4 announced ‘4 All the UK’, a strategy to ensure that Channel 4 serves the whole of the UK. At the heart of the strategy is a significant increase in Channel 4’s ‘nations and regions’ content spend, from its current quota of 35% of spending outside the M25 to a new voluntary target of 50% by 2023, worth up to £250 million in total. This quota applies to both spend and number of hours of programming. Furthermore, 9% of UK programming hours and spend must be produced outside England (i.e. in Wales, Scotland or Northern Ireland). Channel 4 has consistently exceeded its quota for both spend and number of hours of programming commissioned from production companies based in the nations and regions.

In 2017, the government consulted on increasing the regional impact of Channel 4 and in 2019, Channel 4 officially launched its new National headquarters in Leeds,^{[footnote 46]} which will help support the development of a new creative cluster in the region as Channel 4 builds stronger relationships with local commissioners and producers, as well as opening up new opportunities for people to begin a career in the media industry. Channel 4 recently announced that nearly 400 jobs would be based outside of London by the end of 2021. Channel 4’s activity in Glasgow has helped support a strong production ecosystem, including spending £148 million on Scottish productions for its main channel since 2011.^{[footnote 47]}

In 2021, Channel 4 launched the first tranche of its 4Skills initiatives designed to give career development and training opportunities in the broadcast industry for people across the nations and regions. These initiatives – the Channel 4 Production Trainee Scheme, Channel 4 Apprenticeships, 4Studio Placements, and the Aspiring Lawyers partnership – will provide training, work experience and placements to more than 50 people across the nations and regions. Most recently, Channel 4 launched a new training scheme, Content Creatives, aimed at 18-24 year-olds from lower socio-economic backgrounds from across Yorkshire. The scheme works with Job Centre Plus to recruit candidates and offer them a 12-week paid training plan, including 4 weeks working with the 4 Studio team in Leeds.

The government therefore considers that a continued and renewed commitment to levelling up may be appropriately tied to any change in ownership as the government looks to improve living standards, investment, opportunity and outcomes across the whole country. This could include commitments that Channel 4’s newly-created national headquarters in Leeds are retained as a requirement as part of any change of ownership. Similarly, if it is desirable, there is an opportunity to continue (or even enhance) requirements for Channel 4’s spending to be made across the whole of the UK and for the provision of content which is representative of communities across the UK.

Original and diverse content

At present and like other commercially-funded public service broadcasters, Channel 4 must broadcast a certain proportion and range of ‘original’ content – with Channel 4 focussing on the production of innovative and risk-taking content that appeals to the tastes and interests of a culturally diverse society. Channel 4 is subject to qualitative requirements across its channels and quantitative requirements – or quotas – for its main broadcast channel. In 2020, Channel 4 showed 165 new and one-off programmes on its main channel in its evening schedules (between 6pm and midnight). This was the most of any PSB channel except Channel 5, which was in the process of replacing Big Brother with new commissions.^{[footnote 48]} Channel 4 consistently performs above average in Ofcom’s PSB Tracker Survey against the statements: ‘It shows programmes with new ideas/different approaches’ and ‘The style of the programmes is different to what I’d expect to see on other channels’.

Taking into account that Channel 4’s remit explicitly requires it to appeal to the tastes and interests of a culturally diverse society, Channel 4 seeks to drive diversity both on-screen and off-screen – alongside through its supply chain and advertising. Channel 4’s new Leeds HQ and creative hubs in Bristol and Glasgow, alongside its offices in Manchester, will be home to 400 Channel 4 jobs when fully established, including key creative decision makers – responsible for commissioning Channel 4 content and programmes from producers right across the UK and that reflect the diversity of its population. The government sees the value delivered to society through the obligations placed on Channel 4 to broadcast content appealing to young and diverse audiences, and to adopt a more risk-based approach to content compared with other commercially-funded PSBs. As such the government is minded to retain such obligations, though it will be important to ensure its remit does not prohibit Channel 4’s future sustainability and its ability to broadcast relevant and quality content given the developments in the media landscape – with young audiences increasingly likely to consume content on non-linear platforms such as VoD services for example.

News and current affairs

Although public service broadcasters are subject to obligations to deliver news and current affairs programming, Channel 4 is currently obliged to broadcast more national news and current affairs than ITV or Channel 5. Overall, Channel 4 must broadcast no less than 208 hours per year at peak time, plus 208 hours per year of current affairs (80 at peak). By comparison, Channel 5 is currently obliged to broadcast 280 hours per year of news though only 120 hours must be shown at peak time, alongside 130 hours per year of current affairs (10 hours at peak time). In 2019, Channel 5 exceeded its quotas, broadcasting 163 hours of its 305 hours of news at peak time and broadcasting 548 hours of current affairs programming, though only 21 hours were shown at peak time, well below Channel 4.^{[footnote 49]}

The government is currently of the view that Channel 4’s existing obligations relating to a high provision of news and current affairs content, should be broadly retained in any potential reform.

Should Channel 4 continue its contribution to levelling up the regions and nations of the UK through retaining a presence outside London and a strengthened regional production remit? Please provide supporting evidence.

Should the government revise Channel 4’s remit and obligations to ensure it remains relevant in an evolving broadcasting market? If yes, what changes should be made (which could include new freedoms or changes to its obligations)? Please provide supporting evidence.

3.2 Creative economy impact

In considering the future role of Channel 4, a core objective of the government is not just to protect Channel 4’s considerable contribution to the UK creative economy, but to enhance it. It forms part of the creative industries, an undoubted strength of our economy, and one of its fastest growing sectors. The creative industries contributed over £116 billion in GVA and supported over 2 million jobs in 2019.^{[footnote 50]} Channel 4 itself makes significant economic and social contributions to the UK, generating a total GVA contribution of £992 million in 2019, of which £274 million is generated in the nations and regions. It also supported around 10,600 jobs across the UK including nearly 3,000 in the nations and regions.^{[footnote 51]} Channel 4 is currently required to support the UK’s independent production sector – something it has had great success in doing, with Channel 4’s investment in the sector still accounting for c.15% of its revenues.^{[footnote 52]} In parallel, Channel 4 is also required to invest in the making of films – achieved through the Film4 division – and support the development of a talent pipeline supporting those entering the sector.

When considering other key government objectives in Channel 4’s potential future role within the UK’s creative economy, the government is minded to maintain the commitment to operating the main broadcast channel as a free-to-air PSB channel. However, although a similar commitment to continued support for the UK’s independent production sector may be favoured, it is worth considering whether current measures such as the publisher-broadcaster restriction are still necessary, particularly as they would have a constraining impact on Channel 4’s ability to grow its commercial income and therefore its investment.

The UK’s independent production sector is now flourishing and increasingly less reliant on income from UK public service broadcasters. In the 10 years between 2008 and 2018, the contribution of PSB commissions to sector revenue fell from 64% to 42%, due in large part to the growth of international revenue.^{[footnote 53]} Although Channel 4 remains a significant player in the sector (contributing £492 million in 2019,^{[footnote 52]} around 15% of the sectors £3.3 billion revenue^{[footnote 54]} before falling to £370 million in 2020 given the impacts of COVID-19^{[footnote 55]}), on balance, the government assesses that either the weakening or removal of the publisher-broadcaster restriction in potential reform could enable Channel 4 to achieve greater financial diversification given the limitations which stem from the restriction at present. These prohibit Channel 4 from being involved in the making of programmes to be broadcast as part of its own service, which affects its ability to both generate new intellectual property for sales worldwide and diversify its revenues. It also prevents Channel 4 from opening up strategic benefits, such as being able to retain programmes on renewal without the risk of price inflation.

ITV is not subject to the same restriction and has therefore been able to successfully grow its production arm, ITV Studios, which creates and produces content across 12 countries, whilst its global formats and distribution business sells, commercialises and distributes formats and finished programmes worldwide. In the years prior to Covid-19, ITV consistently produced over 8,000 hours of content per year and even despite the pandemic it still produced 7,120 hours of content in 2020, with ITV Studios bringing in almost £1.4 billion in revenue (Figure 6).^{[footnote 57]} Diversifying into production is also made difficult by the commercial constraints resulting from Channel 4’s existing model. For example, it limits its opportunities to co-own production houses. Channel 4 may be able to similarly diversify into production should the existing publisher-broadcaster restriction be weakened or removed and if it had the access to capital and new partnerships that allowed it to do so. Such diversification would also open up new opportunities for Channel 4 to exploit secondary rights both domestically and internationally, including through greater use of tie-in merchandising and digital products such as games. In doing so, this could open up opportunities for greater economic growth and job creation.

Figure 6: Channel 4 and ITV 2020 revenues by source (£millions)

Channel	Total advertising revenue	Total non-advertising revenue
Channel 4	850	84
ITV	1577	1683

In making any change to the publisher-broadcaster restriction, it is noted that this may have implications for the UK’s independent production sector, and the government is willing to consider other options to mitigate this impact. For example, Channel 4 (and all other public service broadcasters) are already required to ensure 25% of their PSB content is commissioned from independent producers. This obligation could be enhanced to mitigate the implications for independent producers whilst also affording Channel 4 the opportunity to diversify into production in order to insulate itself against changes in the sector.

The government also acknowledges the significant and continued impact of Film4 as Channel 4 has met existing obligations relating to investment in the UK film sector. The impact of any change in the ownership of Channel 4 on the film sector should be considered, and the government would ensure that any reform of Channel 4 does not have undue impacts on the film sector.

Should the government remove the publisher-broadcaster restriction to increase Channel 4’s ability to diversify its commercial revenue streams? Please provide supporting evidence.

4. Objectives of a change of ownership

The government is now considering changes to the operating model of Channel 4, including its ownership. The current licencing period for Channel 4 will expire at the end of 2024 and therefore it is important to have long-term certainty about the future of the Corporation before that process is concluded. The current process, as set out in the Broadcasting Act 1990, means the Channel 4 licence can only be held by the Corporation. Given that an alternative ownership model could secure a more successful and sustainable Channel 4, the government believes that now is the right time to review Channel 4’s relationship with the government.

Currently, Channel 4’s opportunities to pursue diversified income streams are limited by public ownership, particularly the publisher-broadcaster restriction (examined in earlier sections) and its limited access to capital. The restriction on access to capital is a core feature of Channel 4’s status as a public corporation, being part of the public sector and therefore part of the government’s fiscal framework. This means Channel 4’s investment is directly tied to public sector net borrowing and its liabilities contribute to public sector net debt. To date, Parliament has restricted Channel 4’s borrowing to £200 million, and in practice it has not made significant use of external finance. Channel 4’s approach in this scenario has instead been to maintain a solid financial position with substantial cash balances to ensure it remains financially self-sufficient. Indeed, even following the hit to the sector caused by Covid-19, the Channel avoided using any of the £75 million revolving credit facility it initially drew down, instead opting to reduce content budgets £138 million ^{[footnote 58]} and find savings within the organisation to safeguard its financial position. Similarly, as a statutory corporation, Channel 4 does not have the option to raise capital by issuing equity to third party investors.

If Channel 4 were to secure a new partner with access to capital, and were free from the limits on its borrowing set by virtue of its public ownership, this could accelerate its ability to weather changes in the market whilst continuing to invest in content and the organisation. It could also allow it to transition to a ‘digital first’ future and safeguard the long-term sustainability of its business. A new partner could potentially also provide new expertise and opportunities for collaboration and scale.

The government has a track record of selling assets to improve access to capital, reduce taxpayer risk and continue to deliver for the public, including the 2013 sale of Royal Mail shares. Prior to the sale, Royal Mail was less efficient than many postal companies elsewhere in Europe, and lacked the commercial confidence, capital and corporate experience to modernise quickly and effectively. Privatisation has improved access to private sector capital and reduced taxpayer risk without compromising the Universal Service Obligation placed on the postal service.^{[footnote 59]}

Securing a new partner for Channel 4 is not mutually exclusive from modernising its remit and obligations to ensure its future sustainability and continued economic, social and cultural contribution to the UK. The government would want to see strong commitments to these objectives from any new owner to ensure that Channel 4, with its ongoing status as a public service broadcaster and a relevant remit, delivers for its audience, and continues to contribute to the wider PSB ecology. We believe this would allow it to meet the challenges presented in today’s market and beyond. Retention of PSB status would also allow Channel 4 to continue to benefit from a prominent position in electronic programme guides. Ultimately the government wants to see a successful and thriving Channel 4, that continues to drive economic growth and create jobs. It is the government’s view that this could be best achieved by a Channel 4 outside of public ownership.

The rationale for Channel 4’s creation no longer reflects the broadcasting landscape since consumers now have more choice than ever, driving competitive tension across the market. With that in mind, and given the rationale set out for considering changes to Channel 4’s operating model, the government does not consider there to be merit or justification for a proportion of the Corporation to be retained in public ownership. On balance, the government would be minded to pursue a full sale (100%) of the Corporation should any change of ownership be pursued. Given Channel 4 is a statutory body at present, if a change of ownership was to be pursued then primary legislation would be required to enable this and convert it into a body which prospective purchasers are able to own.

5. List of all consultation questions

Respondent details

Are you responding:

• as an individual (viewer)
• on behalf of a business
• other (please specify)

If responding on behalf of a business, which industry best describes the work of the business?

Topline questions

1. Do you agree that there are challenges in the current TV broadcasting market that present barriers to a sustainable Channel 4 in public ownership? Please provide supporting evidence.

• Yes
• No
• Not sure

2. Would Channel 4, with a continued public service broadcasting licence and remit, be better placed to deliver sustainably against the government’s aims for public service broadcasting if it was outside public ownership? Please provide supporting evidence.

• Yes
• No
• Not Sure

Social public service value

3. Should Channel 4 continue its contribution to levelling up the regions and nations of the UK through retaining a presence outside London and a strengthened regional production remit? Please provide supporting evidence.

• Yes
• No
• Not sure

4. Should the government revise Channel 4’s remit and obligations to ensure it remains relevant in an evolving broadcast market? If yes, what changes should be made (which could include new freedoms or changes to its obligations)? Please provide supporting evidence.

• Yes
• No
• Not sure

Creative economy impact

5. Should the government remove the publisher-broadcaster restriction to increase Channel 4’s ability to diversify its commercial revenue streams? Please provide supporting evidence.

• Yes
• No
• Not sure

Other questions

6. With reference to supporting evidence, what would the economic, social and cultural costs and benefits of Channel 4 moving out of public ownership be on:

a. overall audience experience?
b. the Channel 4 Television Corporation itself?
c. investment in the independent production sector?
d. investment in the independent film sector?
e. the TV advertising market?
f. investment in the creative industries sector more widely?
g. competition between Channel 4 and other PSB and non-PSB channels?
h. the regions and nations of the UK?

6. Next steps and how to respond

6.1 Next steps

A summary of responses and the government’s response to this consultation will be published in due course following the closure of the consultation.

The government’s response will take all in-scope responses submitted to this consultation into account, and will be based on careful consideration of the points made in consultation responses, not the number of responses received.

Nothing in this consultation is intended to prejudge the outcomes, nor limit the implementation, of the government’s broader strategic review of public service broadcasting. That review will take into account, among other things, the recommendations from Ofcom’s PSB review (Small Screen: Big Debate).

Subject to the outcomes of the strategic review, the Government intends to bring forward a White Paper later this year which will consider the future of the country’s broadcasting landscape with the ultimate aim of making sure it serves listeners and viewers on all platforms and across the UK.

Further information on the consultation principles can be found here. We would welcome views on all aspects of the consultation paper.

6.2 How to respond

We welcome comments from all stakeholders who may be interested. The consultation will close at 23:45 on 14 September 2021.

Please click on the link to the survey on the GOV.UK webpage. If you cannot access the link, please email your response to Channel4consultation@dcms.gov.uk or post your response to:

Consultation on a potential change of ownership of Channel 4 Television Corporation
TV & Broadcasting Team
DCMS
4th Floor, 100 Parliament Street
London
SW1A 2BQ

We will publish a Welsh language version of this consultation document shortly. If you have any questions, please contact channel4consultation@dcms.gov.uk

Alternatively, you can request a response form by emailing Channel4consultation@dcms.gov.uk

7. Disclosure of responses and data protection

Department for Digital, Culture, Media & Sport Privacy Notice

Who is collecting my data?

The Department for Digital, Culture, Media & Sport (DCMS) helps to drive growth, enrich lives and promote Britain abroad.

We protect and promote our cultural and artistic heritage and help businesses and communities to grow by investing in innovation and highlighting Britain as a fantastic place to visit. We help to give the UK a unique advantage on the global stage, striving for economic success.

Purpose of this Privacy Notice

This notice is provided within the context of the changes required by the Article 13 & 14 of UK General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (DPA). This notice sets out how we will use your personal data as part of our legal obligations with regard to Data Protection.

DCMS’s personal information charter explains how we deal with your information. It also explains how you can ask to view, change or remove your information from our records.

What is personal data?

Personal data is any information relating to an identified or identifiable natural living person, otherwise known as a ‘data subject’. A data subject is someone who can be recognised, directly or indirectly, by information such as a name, an identification number, location data, an online identifier, or data relating to their physical, physiological, genetic, mental, economic, cultural, or social identity. These types of identifying information are known as ‘personal data’. Data protection law applies to the processing of personal data, including its collection, use and storage.

What personal data do we collect?

We will process the names and email addresses provided by respondents who respond to the consultation by email. We will also process the information that all respondents provide in relation to your age, ethnic origin and region of residence, as well as details on any organisation you are responding on behalf of. We will also process your views on the proposed changes contained in the consultation, which may, of course, include commercially sensitive data. When the consultation ends, we will publish a summary of the key points raised on the Department’s website.

This may include a list of the organisations that responded, but not any individual’s personal name, address or other contact details. All responses and personal data will be processed in compliance with the Data Protection Act 2018 and the General Data Protection Regulation.

If you want some or all of the information you provide to be treated as confidential or commercially sensitive, it would be helpful if you could clearly identify the relevant information and explain why you consider it confidential or commercially sensitive. Please note that DCMS may be required by law to publish or disclose information provided in response to this consultation in accordance with the access to information regimes: primarily the Freedom of Information Act 2000, the Environmental Information Regulations 2004, the Data Protection Act 2018 and the General Data Protection Regulation. If we receive any request to disclose this information, we will take full account of your explanation, but cannot give you an absolute assurance that disclosure will not be made in any particular case. We will not regard an automatic disclaimer generated by your IT system as a relevant request for these purposes.

Once you have submitted your response to the consultation you will not be able to withdraw your answers from the analysis stage. However, under the Data Protection Act 2018 (and the General Data Protection Regulation), you have certain rights to access your personal data and have it corrected or erased (in certain circumstances), and you can withdraw your consent to us processing your personal data at any time. How will we use your data?

We use personal information for a wide range of purposes, to enable us to carry out our functions as a government department. This includes:

Your personal data is being collected as an essential part of the consultation process, including for statistical purposes.

What is the legal basis for processing my data?

To process this personal data, our legal reason for collecting or processing this data is: Article 6(1) e. it is necessary to perform a public task (to carry out a public function or exercise powers set out in law, or to perform a specific task in the public interest that is set out in law). The lawful basis that we rely on to process your personal data will determine which of the following rights are available to you. Much of the processing we do in DCMS will be necessary to meet our legal obligations or to perform a public task. If we hold personal data about you in different parts of DCMS for different purposes, then the legal basis we rely on in each case may not be the same.

What will happen if I do not provide this data?

You are not required to provide personal data.

Who will your data be shared with?

No personal data will be shared.

We will let you know if we are going to share your personal data with other organisations – and whether you can say no. You can ask us for details of agreements we have with other organisations for sharing your information.

How long will my data be held for?

We will only retain your personal data for 2 years in line with the purposes set out in this document.

Will my data be used for automated decision making or profiling?

We will not use your data for any automated decision making.

What are your data protection rights?

You have rights over your personal data under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA 2018). The Information Commissioner’s Office (ICO) is the supervisory authority for data protection legislation, and maintains a full explanation of these rights on their website. DCMS will ensure that we uphold your rights when processing your personal data.

How will Qualtrics store my data?

Qualtrics is the online survey platform used to conduct this survey. Their privacy policy can be found here: https://www.qualtrics.com/privacy-statement/

How do I complain?

Consultation on a potential change of ownership of Channel 4 Television Corporation
TV & Broadcasting Team
DCMS
100 Parliament Street
London
SW1A 2BQ
Email: Channel4consultation@dcms.gov.uk

The contact details for the data controller’s Data Protection Officer (DPO) are:

Data Protection Officer
DCMS
100 Parliament Street
London
SW1A 2BQ
Email: DCMSdataprotection@dcms.gov.uk

1. Enders Analysis (2017): Channel 5: three years on from Viacom’s acquisition ↩

2. UK Government (2021): Build Back Better: Our Plan for Growth ↩ ↩²

3. Channel 4 (2020): Future4 Strategy ↩

4. O&O/PACT (2020): UK Television Production Survey Financial Census 2020 ↩

5. Channel 4 (2020): Annual Report 2019 ↩

6. Channel 4 (2011): Annual Report 2010 ↩

7. Channel 4 (2021): Annual Report 2020 ↩

8. A £20 million fund which takes minority stakes in independent production companies to help them grow and develop their business. ↩

9. Channel 4’s initiative to develop and support new talent in careers across the media industry. ↩

10. Channel 4 (2020): Annual Report 2019 ↩

11. Channel 4 (2021): Annual Report 2020 ↩

12. Channel 4 (2011): Annual Report 2010 ↩

13. DCMS Select Committee (2021): The future of public service broadcasting ↩

14. O&O/PACT (2020): UK Television Production Survey Financial Census 2020 ↩

15. Ofcom (2020): PSB Annual Compliance Report 2020 ↩

16. Ofcom (2020): Channel 4 Corporation’s performance in delivering its media content duties 2014–2018 ↩

17. Channel 4 (2021): Annual Report 2020 ↩

18. Channel 4 (2020): Future4 Strategy ↩

19. Enders Analysis (2020): Channel 4 2019, 2020 and beyond ↩

20. Channel 4 (2021): Annual Report 2020 ↩

21. Enders Analysis (2020): TV Set Viewing Trends 2020 lockdown and full year 2019 ↩

22. Ofcom (2020): Media Nations 2020 ↩

23. ‘Broadcast content’ comprises live TV, recorded playback and broadcaster VoD services ↩

24. Channel 4 (2021): Annual Report 2020 ↩

25. Channel 4 (2021): Annual Report 2020 ↩

26. Channel 4 (2021): Annual Report 2020 ↩

27. Channel 4 (2020): Annual Report 2019 ↩

28. BARB reported channels list ↩

29. Lords Communications Committee (2019): Public service broadcasting: as vital as ever ↩

30. Ofcom (2020): Media Nations 2020 ↩

31. Lords Communications Committee (2019): Public service broadcasting: as vital as ever ↩

32. Television productions that meet the criteria for the high-end TV tax relief (over £1 million an hour budget, at least 10% of core spend in the UK, and meeting a cultural test) ↩

33. British Screen Forum (2021): High-end Television Drama Investment: An Update ↩

34. Ofcom (2020): Public service broadcasting: quantitative research findings ↩

35. Channel 4 (2021): Annual Report 2020 ↩

36. Enders Analysis (2020): Channel 4 2019, 2020 and beyond ↩

37. Ofcom (2021): Ofcom Technology Tracker 2021 ↩

38. Enders Analysis (2017): Channel 5: three years on from Viacom’s acquisition ↩

39. Broadcast (2020): Channel of the Year: Channel 5 ↩

40. Channel 4 (2020): Future4 Strategy ↩

41. ITV (2021): Annual Report 2020 ↩

42. Channel 4 (2021): Annual Report 2020 ↩

43. Ofcom (2020): Channel 4 Corporation’s performance in delivering its media content duties 2014–2018 ↩

44. UK government (2021): Building Back Better: Our Plan for Growth ↩

45. EY/Channel 4 (2021): Channel 4’s contribution to the UK ↩

46. UK government (2017): Consultation on Increasing the Regional Impact of Channel 4 ↩

47. EY/Channel 4 (2021): Channel 4’s contribution to the UK ↩

48. Channel 4 (2021): Annual Report 2020 ↩

49. Ofcom (2020): PSB Annual Compliance Report 2020 ↩

50. DCMS analysis ↩

51. EY/Channel 4 (2021): Channel 4’s contribution to the UK ↩

52. DCMS analysis ↩ ↩²

53. O&O/PACT (2020): UK Television Production Survey Financial Census 2020 ↩

54. Channel 4 (2020): Annual Report 2019 ↩

55. O&O/PACT (2020): UK Television Production Survey Financial Census 2020 ↩

56. ITV (2021): Annual Report 2020 ↩

57. Channel 4 (2021): Annual Report 2020 ↩

58. National Audit Office (2014): The Privatisation of Royal Mail ↩