Complaints & Compliments Policy

1. Purpose

AIR 107.2 is committed to providing a responsible, inclusive and community-focused radio service.

As a licensed community radio station, AIR 107.2 recognises its responsibilities under its Ofcom licence, its Key Commitments, the Ofcom Broadcasting Code, applicable legislation and other relevant regulatory requirements.

We welcome feedback from listeners, members of our target community, contributors, guests, volunteers, advertisers and other members of the public.

Complaints help us identify where we can improve. We will therefore deal with complaints fairly, consistently, respectfully and, wherever possible, promptly.

 

2. What Can a Complaint Be About?

A complaint may concern any aspect of AIR 107.2’s service, including:

• Broadcast content.
• News, current affairs or factual programming.
• Accuracy or impartiality.
• Offensive or harmful material.
• Content involving children or young people.
• Hate speech, discriminatory or abusive material.
• Fairness or treatment of individuals or organisations.
• Privacy.
• Advertising, sponsorship or commercial references.
• Presenter, volunteer, contributor or guest conduct.
• Social media content published by AIR 107.2.
• Technical or transmission matters.
• Failure to meet AIR 107.2’s community commitments.
• Access and participation opportunities.
• AIR 107.2’s engagement with its target community.
• Any other matter concerning the operation or conduct of the station.

Complaints about broadcast content will be considered against the relevant provisions of the Ofcom Broadcasting Code. The Code covers areas including protection of under-18s, harm and offence, crime/disorder/hatred/abuse, religion, due accuracy and impartiality, elections and referendums, fairness, privacy and commercial communications. (www.ofcom.org.uk⁠)

 

3. Our Regulatory Responsibilities

AIR 107.2 will seek to ensure that its programming complies with the Ofcom Broadcasting Code.

Particular attention will be given to:

Accuracy and impartiality

News must be reported with due accuracy and due impartiality. Significant mistakes should normally be acknowledged and corrected promptly.

As a local/community radio service, AIR 107.2 will also take care not to give undue prominence to the views or opinions of particular persons or organisations on matters of political or industrial controversy or current public policy. (www.ofcom.org.uk⁠)

Harm and offence

AIR 107.2 will consider the potential harm and offence that may result from broadcast material and the context in which material is presented.

Fairness

People and organisations taking part in, or directly affected by, programmes should be treated fairly.

Privacy

AIR 107.2 will respect individuals’ privacy and will avoid unwarranted infringements of privacy.

Children and young people

AIR 107.2 will have regard to the protection of under-18s when producing and scheduling programmes and will comply with the relevant provisions of the Broadcasting Code.

Elections and referendums

During elections and referendums, AIR 107.2 will comply with the additional requirements of the Broadcasting Code concerning due impartiality, political candidates, election coverage and referendum coverage.

 

4. Community Radio Responsibilities

AIR 107.2 recognises that community radio has responsibilities beyond simply broadcasting programmes.

The station will operate in accordance with its Ofcom licence and applicable Key Commitments, including those relating to the service’s character, target community, social gain, access and participation and accountability to the community. (www.ofcom.org.uk⁠)

Complaints concerning these areas will be recorded and considered by AIR 107.2 management.

Where a complaint identifies a potential failure to meet a Key Commitment, the station will investigate the matter and, where appropriate, take remedial action.

 

5. How to Make a Complaint

Complaints should preferably be made in writing so that the station can accurately understand and investigate the concern.

Complaints can be submitted by:

Website: radioair.uk/complaints/

Post:
AIR 107.2
Jeffery House Studios, Maiden Street, Weymouth, DT4 8BA

A complaint should, where possible, include:

• Name and contact details of the complainant.
• Date of the broadcast or incident.
• Approximate time of the broadcast.
• Programme and presenter involved, if known.
• Details of the material or conduct being complained about.
• The reason for the complaint.
• Any relevant evidence, such as recordings, screenshots or links.
• Any particular outcome being sought.

For broadcast-content complaints, providing the date, time and programme is particularly helpful because it allows AIR 107.2 to identify and review the relevant material.

 

6. Anonymous Complaints

AIR 107.2 will consider anonymous complaints where sufficient information is provided to allow the matter to be investigated.

However, where no contact details are provided, AIR 107.2 may be unable to ask follow-up questions or provide the complainant with an individual response.

 

7. Complaints About Broadcast Content

Where a complaint concerns something broadcast on AIR 107.2, the station will, where reasonably possible:

1. Identify the relevant programme or broadcast.
2. Review the relevant recording or available material.
3. Consider the complaint against the applicable Ofcom Broadcasting Code provisions.
4. Consider the context in which the material was broadcast.
5. Speak to the presenter, producer, volunteer or other relevant person where appropriate.
6. Consider whether an error, breach of policy or regulatory concern occurred.
7. Decide whether remedial or preventative action is required.
8. Provide an appropriate response to the complainant.

Ofcom makes clear that context is important when applying the Broadcasting Code, and that the Code should be considered alongside the nature of the programme and the audience’s likely expectations. (www.ofcom.org.uk⁠)

 

8. Corrections

Where AIR 107.2 identifies a significant factual error, the station will consider whether a correction or clarification should be made.

Where appropriate, corrections may be made:

• On air;
• On the AIR 107.2 website;
• Through social media;
• Directly to affected individuals or organisations; or
• Through another appropriate method.

Corrections to significant mistakes in news will be made promptly and appropriately, consistent with the requirements of the Ofcom Broadcasting Code. (www.ofcom.org.uk⁠)

 

9. Complaints Involving Presenters or Volunteers

Where a complaint concerns the conduct of a presenter, volunteer or member of AIR 107.2, management will consider the complaint objectively.

Depending on the circumstances, action may include:

• Advice or guidance;
• Additional training;
• Editorial supervision;
• A formal management review;
• Amendment or removal of content;
• An apology or correction;
• Temporary or permanent changes to programme responsibilities; or
• Other appropriate management action.

Any action taken against an individual will remain confidential where appropriate.

 

10. Complaints About Advertising and Sponsorship

Complaints concerning advertising, sponsorship or commercial communications will be considered against the relevant Ofcom requirements and, where applicable, the Advertising Standards Authority (ASA) rules.

AIR 107.2 will maintain appropriate separation between editorial programming and commercial communications and will not allow commercial interests to improperly influence editorial decisions.

Where a complaint falls primarily within the ASA’s remit, AIR 107.2 may refer the complainant to the ASA.

 

11. Complaints About Community Commitments

Where a complaint alleges that AIR 107.2 has failed to deliver its Ofcom Key Commitments, management will review the relevant commitment and consider whether the station has complied with it.

Where appropriate, AIR 107.2 will:

• Investigate the concern;
• Review relevant records;
• Consult relevant volunteers, staff or community representatives;
• Identify any shortcomings;
• Take corrective action where necessary; and
• Record any lessons learned.

Ofcom has specific arrangements for monitoring and enforcing compliance with community radio Key Commitments. (www.ofcom.org.uk⁠)

 

12. Timescales

AIR 107.2 aims to acknowledge complaints within 5 working days.

A substantive response will normally be provided within 14 working days.

Where a complaint requires more extensive investigation, including review of recordings, consultation with management or consideration of regulatory requirements, the complainant will be informed that additional time is required.

We will aim to provide an update within 28 days where a full response cannot be provided within the initial timescale.

These timescales are internal AIR 107.2 targets and do not replace any specific regulatory timescales or requirements that may apply.

 

13. Escalation Within AIR 107.2

If a complainant is dissatisfied with the response, they may request an internal review.

The request should:

• Explain why the complainant remains dissatisfied;
• Identify any part of the original response they believe was incorrect or incomplete; and
• Provide any new relevant information.

The review will normally be undertaken by a senior member of AIR 107.2 management who was not directly responsible for the original decision, where reasonably practicable.

The outcome of the internal review will normally represent AIR 107.2’s final response.

 

14. Escalation to Ofcom

AIR 107.2 recognises that members of the public may complain directly to Ofcom about broadcast content.

A complainant does not have to obtain AIR 107.2’s agreement before contacting Ofcom.

Where a person believes that a programme broadcast by AIR 107.2 may have breached the Ofcom Broadcasting Code, they may submit a complaint directly to Ofcom.

Ofcom assesses complaints about television and radio programmes against the Broadcasting Code and decides whether a matter requires further investigation. Ofcom does not necessarily investigate every complaint it receives. (www.ofcom.org.uk⁠)

Ofcom complaints:
Complain to Ofcom about TV or radio programmes⁠

When submitting a complaint to Ofcom, complainants should provide as much relevant information as possible, including:

• The name of the broadcaster: AIR 107.2
• Programme name;
• Date and approximate time of broadcast;
• Details of the material complained about;
• The reason they believe the Broadcasting Code may have been breached; and
• Any relevant supporting information.

Ofcom publishes information about complaints it has assessed and may publish decisions where it finds that a broadcaster has breached the Broadcasting Code. In serious cases, Ofcom can consider further regulatory action, including financial penalties. (www.ofcom.org.uk⁠)

 

15. Complaints About AIR 107.2’s Community Radio Licence

Where a complaint concerns AIR 107.2’s compliance with its community radio licence or Key Commitments, a complainant may also raise the matter directly with Ofcom.

Ofcom has arrangements for considering whether community radio stations are complying with their Key Commitments and can pursue compliance issues with the relevant station where appropriate. (www.ofcom.org.uk⁠)

This may include concerns about matters such as:

• The station’s target community;
• Social gain;
• Access and participation;
• Accountability to the community;
• The character of the service; or
• Other requirements contained within AIR 107.2’s Ofcom licence.

 

16. Important Distinction Between AIR 107.2 and Ofcom

AIR 107.2 will make every reasonable effort to resolve complaints directly and learn from them.

However, AIR 107.2 cannot determine whether it has legally or regulatorily breached the Ofcom Broadcasting Code. That determination ultimately rests with Ofcom where Ofcom chooses to investigate the matter.

A complaint being made to AIR 107.2 does not prevent the complainant from also contacting Ofcom.

Likewise, the fact that AIR 107.2 does not uphold a complaint does not prevent Ofcom from considering a complaint about the same broadcast.

Ofcom’s role is independent of AIR 107.2.

 

17. Serious Complaints

Certain complaints will be escalated immediately to senior AIR 107.2 management.

These may include allegations involving:

• Serious harm;
• Safeguarding;
• Child protection;
• Hate speech;
• Serious discrimination;
• Threats;
• Criminal conduct;
• Serious breaches of privacy;
• Significant editorial failures;
• Significant breaches of the Broadcasting Code; or
• Matters that could expose AIR 107.2 or its licence to significant regulatory risk.

Where appropriate, matters may also be referred to the relevant authorities.

 

18. Vexatious, Abusive or Repeated Complaints

AIR 107.2 will always seek to distinguish genuine complaints from unreasonable or abusive behaviour.

The station may limit correspondence where a complainant:

• Uses threatening, abusive or discriminatory language towards staff or volunteers;
• Repeatedly submits substantially identical complaints without providing new information;
• Makes excessive demands on station resources;
• Attempts to disrupt the operation of the station; or
• Behaves in a manner that prevents a reasonable investigation from taking place.

Any restriction will be proportionate and will not prevent a genuine regulatory complaint from being made to Ofcom.

 

19. Confidentiality and Data Protection

AIR 107.2 will handle complaints confidentially and in accordance with applicable UK data protection legislation.

Information will only be shared with those who reasonably require it for the purpose of investigating, managing or responding to the complaint, subject to legal or regulatory requirements.

Where a complaint results in management or disciplinary action involving an individual, AIR 107.2 will not normally disclose confidential details of that action to the complainant.

 

20. Recording and Learning From Complaints

AIR 107.2 will maintain an appropriate record of complaints received.

Records may include:

• Date received;
• Nature of complaint;
• Programme or service concerned;
• Relevant Broadcasting Code or licence issue;
• Investigation undertaken;
• Outcome;
• Corrective action;
• Lessons identified; and
• Date the complaint was closed.

Complaints will be reviewed periodically by AIR 107.2 management to identify recurring issues or opportunities for improvement.

Where appropriate, learning may result in:

• Presenter training;
• Changes to editorial procedures;
• Additional programme supervision;
• Changes to station policies;
• Corrections or clarifications;
• Improved community engagement; or
• Changes to access and participation arrangements.

 

21. Compliments and Positive Feedback

AIR 107.2 also welcomes positive feedback.

Compliments about presenters, volunteers, programmes, community activities or other aspects of the station may be submitted using the same contact details as complaints.

Positive feedback will be shared with relevant members of the AIR 107.2 team where appropriate.

 

22. Policy Review

This policy will be reviewed regularly by AIR 107.2 management and whenever there are significant changes to:

• The Ofcom Broadcasting Code;
• AIR 107.2’s Ofcom licence;
• AIR 107.2’s Key Commitments;
• Relevant legislation; or
• Applicable regulatory guidance.

The current version of this policy will be made available to listeners and members of the community..