Channel 4

https://www.channel4.com · 47/92 checks passed · media

Compliance report (framework 0.8)

Gate passed (every Core check must pass) · not counted towards the gate: paused 35, draft 48, ready for review 54.

Site level: 0 (no scored checks yet).

By level

LevelResult
Level 1 — Basic 26/37 (11 failed)
Level 2 — Enhanced 9/27 (18 failed)
Level 3 — Advanced 0/10 (9 failed)

By category

CategoryResult
Accessibility 8/13
Accountability 1/5
AI & Automation 3/8
Interoperability 1/3
Privacy 11/16
Provenance 1/2
Security 4/11
Transparency 6/13
Responsibility to the Future 0/3

Level 1 — Basic

Accessibility

AI & Automation

FAIL AI use policy in place
  • policy_exists: The About page contains no mention of an AI use policy or statement.
    Fix: Publish a clear AI use policy or statement accessible from the About or Corporate section of the site.
  • scope_clear: There is no explanation of what AI is used for anywhere on this page.
    Fix: Add a section describing the specific purposes for which Channel 4 uses AI (e.g., content recommendations, captioning, personalization).

Privacy

Security

Transparency

Level 2 — Enhanced

Accessibility

Accountability

FAIL Named responsible person
  • named_person: The page lists generic 'Contact us' details but does not identify any named person or specific role responsible for handling enquiries.
    Fix: Add the name or role title (e.g., Head of Viewer Enquiries) of the person or team accountable for responding to contacts.
FAIL Published response timeframes
  • response_timeframe: The page provides contact methods (form, phone numbers) but does not state any timeframe within which responses will be issued.
    Fix: Add a clear statement on the contact page indicating how long users should expect to wait for a response (e.g. 'We aim to respond within 10 working days').
  • specific: Because no response timeframe is published at all, there is no specific duration given in days or hours.
    Fix: Publish a specific, measurable response time (e.g. '5 business days') rather than vague language or no commitment.
FAIL Clear appeals process
  • independent: The page does not describe any independent or escalated review path (e.g., to Ofcom or an external ombudsman) for users dissatisfied with Channel 4's response.
    Fix: Add explicit text and a link explaining how complainants can escalate unresolved issues to an independent body such as Ofcom after exhausting Channel 4's internal review.

AI & Automation

FAIL Published AI use policy (detailed)
  • detailed_scope: No AI policy is present, so the scope of AI use is not detailed.
    Fix: Create a dedicated AI policy page detailing each use case, systems involved, and departments responsible.
  • limitations: The page does not acknowledge any limitations of AI systems.
    Fix: Include a section that explicitly acknowledges the limitations, risks, and potential errors of AI systems in use.
  • safeguards: No safeguards or quality controls for AI are described on the page.
    Fix: Describe the human oversight, review processes, and quality controls applied to AI outputs in a published AI policy.
FAIL AI-assisted content clearly marked
  • marking_policy: The About page contains no policy or statement regarding the marking or labelling of AI-assisted content.
    Fix: Publish a clear policy describing how AI-assisted content is labelled or disclosed, and link to it from the About or corporate pages.
  • consistent: Without any AI content marking policy visible on the page, consistent application cannot be demonstrated.
    Fix: Once a marking policy is in place, apply AI disclosure labels consistently across all content and document examples on the corporate site.
FAIL Human oversight of AI documented
  • oversight_exists: The page does not mention any human oversight mechanism for AI outputs.
    Fix: Add a section describing how humans oversee AI-generated or AI-assisted outputs across Channel 4's operations.
  • review_process: No review or approval workflow for AI-generated content is described on the page.
    Fix: Document the specific review and approval steps AI outputs must pass through before publication.
  • accountability: No individual, role, or team is named as accountable for AI-generated content on the page.
    Fix: Identify a named role or governance body (e.g., an editorial or AI ethics lead) responsible for AI-generated content and publish their remit.

Interoperability

Privacy

FAIL Data collection limited to necessity
  • necessity: The visible content does not explicitly state that data collection is limited to what is necessary for the stated purposes.
    Fix: Add an explicit data minimisation statement confirming that only data necessary for the stated purposes is collected.
  • proportionate: There is no language on the visible page addressing proportionality of data collection relative to the service provided.
    Fix: Include a statement explaining that the amount and type of data collected is proportionate to the services (e.g., streaming, advertising, Channel 4+) offered.
FAIL Published data retention periods
  • retention_stated: While the table of contents references 'How long do we keep your data for?', the visible content does not actually state retention periods.
    Fix: Surface explicit retention periods in the visible policy text rather than only referencing the section in the table of contents.
  • specific: No specific retention durations (e.g., months or years) are shown on the visible page.
    Fix: Provide concrete retention timeframes for each data category, such as 'account data retained for 24 months after account closure'.
FAIL No dark patterns in consent flows
  • no_dark_patterns: The page shown is the privacy policy text only and contains no visible consent interface, so it cannot be verified that consent is gathered without dark patterns.
    Fix: Expose or link to the actual consent banner/preference center from the privacy policy and ensure its language is neutral and non-manipulative.
  • equal_choices: No consent banner with accept/reject controls is visible on this privacy policy page, so equal prominence of choices cannot be confirmed.
    Fix: Provide an accessible consent management interface with 'Accept' and 'Reject' buttons of equal visual weight, size, and color.
  • no_forced_consent: The policy mentions combining data with third parties and personalising advertising but no consent mechanism is shown here to verify consent is not bundled or forced.
    Fix: Offer granular, unbundled consent toggles for each processing purpose (e.g., personalisation, advertising, analytics) with access to the service not conditioned on accepting non-essential processing.
FAIL Cookie banner partner disclosure
  • partner_sharing_mentioned: The banner mentions using cookies for reliable service, relevant adverts, and show creation but does not disclose data sharing with third-party partners.
    Fix: Update the banner copy to explicitly state that data is shared with third-party advertising and analytics partners, with a link to the partner list.
  • partner_count_specific: No numeric count of partners is stated anywhere in the banner copy.
    Fix: Include a specific partner count (e.g., 'We share data with X partners') in the banner, linked to a full vendor list.

Provenance

Security

Transparency

FAIL Named responsible person in contact
  • named_person: No named individual or specific team (only the generic '4Viewers'/Contact Us area) is identified as responsible for enquiries.
    Fix: Identify the responsible team or individual by name (e.g., '4Viewers Enquiries Team, led by [Name]') on the contact page.
  • role_clear: Because no person or team is named, their role or authority over enquiries is not stated.
    Fix: After naming the responsible party, clearly describe their role and decision-making authority for handling queries and complaints.
FAIL Funding disclosed with detail
  • detail: The page only mentions 'commercially-funded' without any amounts, percentages, or breakdown of revenue categories such as advertising, sponsorship, or content sales.
    Fix: Add a brief summary of funding categories (e.g., advertising, digital, content sales) with percentages or figures, or embed key financial highlights from the Annual Report directly on this page.
  • complete: The disclosure does not enumerate all major funding streams (e.g., advertising revenue, Film4 investment returns, digital/streaming revenue, sponsorship).
    Fix: Include a complete breakdown of all major revenue streams—advertising, sponsorship, digital, and any public or commercial partnerships—on the About page rather than only linking to the Annual Report.
FAIL Governance structure disclosed
  • roles_clear: While the board is mentioned, no specific roles, members, or responsibilities (e.g., CEO, directors, committees) are identified on this page.
    Fix: Add a section or link listing the board members, executive leadership, and their specific responsibilities, or link to a dedicated governance page detailing these roles.
FAIL Algorithm explanation if applicable
  • algorithm_explained: The About page describes Channel 4's purpose and model but does not mention or explain any algorithms used (e.g., on its streaming service).
    Fix: Add a section or link explaining the purpose of any recommendation or personalisation algorithms used across Channel 4's streaming and digital platforms.
  • impact_clear: There is no description of how algorithmic decisions affect users, such as content recommendations or ad targeting.
    Fix: Include clear statements describing how algorithmic decisions influence what users see and experience on Channel 4 platforms.
FAIL Annual data practices statement
  • annual_statement: The page links to a Privacy Policy but shows no evidence that data practices are reviewed on a regular or annual basis.
    Fix: Add a statement in the Privacy Policy or About page indicating the policy is reviewed annually (or periodically) and note the last review date.
  • dated: The Privacy Policy link on this page is not accompanied by any date, version number, or last-updated indicator.
    Fix: Display a 'last updated' date or version number alongside the Privacy Policy link and within the policy itself.

Level 3 — Advanced

Accessibility

FAIL Published accessibility statement
  • statement_exists: The page is a corporate 'About Channel 4' page with no dedicated accessibility statement present.
    Fix: Create a dedicated accessibility statement page and link to it from the site navigation or footer.
  • known_issues: No accessibility statement exists, so no known accessibility issues or limitations are acknowledged.
    Fix: Include a section in the accessibility statement listing known accessibility barriers and non-compliant areas.
  • remediation_timeline: There is no statement and therefore no timeline or commitment to fix accessibility issues.
    Fix: Add target dates or a remediation commitment for resolving identified accessibility issues in the statement.
  • feedback_channel: While the page shows a generic 'Get in touch' link, there is no accessibility-specific feedback mechanism with a response commitment.
    Fix: Provide a dedicated accessibility feedback channel and state a specific timeframe within which users will receive a response.

Accountability

FAIL Published moderation policies
  • policy_exists: The page only contains SU2C donation terms and conditions, with no published moderation policy visible.
    Fix: Publish a dedicated moderation policy page (or link to one) covering user-generated content and community standards.
  • criteria_clear: No moderation criteria (e.g., what content is allowed or prohibited) are stated anywhere on this page.
    Fix: Add clear, itemized moderation criteria that define prohibited content types and acceptable behavior.
  • enforcement: The page does not describe any enforcement process, appeals, or actions taken against violating content.
    Fix: Document the enforcement workflow, including reporting channels, review timelines, sanctions, and an appeals process.

Interoperability

Security

FAIL Incident response plan published
  • plan_exists: The About page describes Channel 4's remit and business model but contains no published incident response plan or policy.
    Fix: Publish a dedicated incident response plan or security policy page and link to it from the site.
  • notification_commitment: The page makes no commitment to publicly notify users of significant security or data incidents.
    Fix: Add an explicit statement committing to public notification of significant incidents affecting users.
  • timeframe: No timeframe for disclosing incidents to affected users is mentioned anywhere on the page.
    Fix: Specify a concrete disclosure timeframe (e.g., notifying affected users within 72 hours) in the incident response policy.

Transparency

FAIL Algorithmic decision criteria published
  • criteria_published: The page does not publish any specific criteria used in algorithmic decision-making.
    Fix: Publish a dedicated page listing the specific signals and criteria (e.g., viewing history, demographics) used by Channel 4's algorithms.
  • weighting: No information is provided about how criteria are weighted or prioritised in any algorithmic process.
    Fix: Document and publish the relative weighting or priority given to each criterion used in algorithmic decisions.
  • auditable: The page contains no technical or procedural detail that would enable external audit or review of algorithms.
    Fix: Provide an algorithmic transparency report with sufficient technical detail and a contact route for independent auditors.
FAIL Open source code or tech docs
  • open_source: The page contains no links to source code repositories or any open-source projects.
    Fix: Add a link to a public code repository (e.g., GitHub) for any open-source components of Channel 4's platforms, or a statement about open source practices.
  • tech_docs: No technical documentation is published or linked from the about page.
    Fix: Publish and link to technical documentation, API references, or developer resources relevant to Channel 4's digital services.

Responsibility to the Future

FAIL Environmental / sustainability disclosure
  • disclosure_exists: The page at /carbon contains only Channel 4 News team listings and program headlines, with no published environmental impact or sustainability disclosure.
    Fix: Publish a dedicated environmental or sustainability statement on the /carbon page describing the site's or organisation's environmental impact and reduction commitments.
  • specific_metrics: There are no specific figures on carbon, energy use, or emissions anywhere on the page, which only shows news content.
    Fix: Add concrete quantitative metrics such as annual CO2 emissions, energy consumption (kWh), or per-page-view carbon figures to the disclosure.
  • hosting_disclosure: The page provides no information about the carbon or energy profile of the hosting infrastructure.
    Fix: Disclose the hosting provider's energy source (e.g. renewable-powered data centres) and its carbon or energy profile on the page.
FAIL Succession and continuity plan
  • plan_exists: The page describes Channel 4's model, purpose, and history but contains no published plan for what happens if the organisation fails or exits.
    Fix: Publish a succession or continuity plan describing the steps and responsible parties should Channel 4 cease operations or wind down its services.
  • data_and_content_fate: The page makes no mention of what would happen to user data or published content in the event of organisational failure.
    Fix: Add a section specifying how user data would be deleted, transferred, or protected and how published content would be preserved or handled upon exit.
  • custodians_or_mirrors: No custodians, mirrors, or archive partners are identified anywhere on the page.
    Fix: Name specific custodians, archive partners, or mirror arrangements responsible for safeguarding content and services if the organisation ceases to exist.
FAIL Worker wellbeing policy
  • policy_exists: The page is a Channel 4 News team listing showing presenters and articles, with no published policy on worker wellbeing or working conditions despite the /careers path.
    Fix: Publish a dedicated worker wellbeing or working conditions policy on the careers page describing the organisation's commitments to staff.
  • specific_commitments: The content contains only news headlines and journalist bios, with no specific commitments on pay, hours, mental health, or benefits.
    Fix: Add concrete, measurable commitments covering pay, working hours, mental health support, and employee benefits.
  • accountability: No individual, team, or oversight mechanism responsible for worker conditions is identified anywhere on the page.
    Fix: Name a responsible role or committee (e.g., an HR or People director) accountable for overseeing worker conditions and provide contact details.