Letter to BBC Trust requesting full consideration of complaint regarding BBC's selective presentation of Iraq Body Count (IBC) figures and issue of editorial decision-making:
Ref: CAS-2109403-3PN7BB
To 
BBC Editorial Trust
This is a formal request to 
have my second stage complaint considered by the BBC Trust.
Following my initial enquiry 
and a subsequent reply to the points raised, I believe that no serious or 
satisfactory consideration of my concerns has been offered.
The essence of my complaint can be gleaned from the correspondence to date, which reads as follows:
Original letter to BBC 
(29 March 2013):
I'd like to request that the BBC end its selective use of Iraq Body Count (IBC) when denoting civilian war deaths in Iraq.
The issue of BBC bias towards IBC and the false impressions it serves is discussed here.
As noted, the following suggests a simplified alternative which, rather than IBC's limited and misleading count, offers a more informed and balanced range of figures:
Civilian war deaths in Iraq
(range):
Iraq Body Count (IBC)
(till Dec 2012)
110,937 - 121,227
Lancet/Johns Hopkins survey
(March 2003 - end of June 2006)
654,965
Opinion Research Business (ORB) survey
(August 12–19, 2007)
1,033,000
Source: Wikipedia
Please consider replacing sole reference to IBC with this fairer and more viewer-serving graphic.
The use of IBC as an 'authoritative' and singularly-mentioned figure is widespread across the BBC, which suggests that a specific executive/editorial decision has been taken in this regard.
I'd like to see any copy or/and details of that decision-making process.
As the BBC's own charter/editorial guidelines specify a requirement to be neutral and impartial, I look forward to a fairer presentation of this key information. If such an alteration is not undertaken, I intend to seek a ruling on this matter from the BBC Trust.
For the purposes of this complaint, I cite the following online report and its singular, biased use of IBC figures: Iraq 10 years on: In numbers
I'd like to request that the BBC end its selective use of Iraq Body Count (IBC) when denoting civilian war deaths in Iraq.
The issue of BBC bias towards IBC and the false impressions it serves is discussed here.
As noted, the following suggests a simplified alternative which, rather than IBC's limited and misleading count, offers a more informed and balanced range of figures:
Civilian war deaths in Iraq
(range):
Iraq Body Count (IBC)
(till Dec 2012)
110,937 - 121,227
Lancet/Johns Hopkins survey
(March 2003 - end of June 2006)
654,965
Opinion Research Business (ORB) survey
(August 12–19, 2007)
1,033,000
Source: Wikipedia
Please consider replacing sole reference to IBC with this fairer and more viewer-serving graphic.
The use of IBC as an 'authoritative' and singularly-mentioned figure is widespread across the BBC, which suggests that a specific executive/editorial decision has been taken in this regard.
I'd like to see any copy or/and details of that decision-making process.
As the BBC's own charter/editorial guidelines specify a requirement to be neutral and impartial, I look forward to a fairer presentation of this key information. If such an alteration is not undertaken, I intend to seek a ruling on this matter from the BBC Trust.
For the purposes of this complaint, I cite the following online report and its singular, biased use of IBC figures: Iraq 10 years on: In numbers
I look forward to your 
reply.
Regards
John Hilley
Regards
John Hilley
------------------------------ 
Reply from BBC's Gemma 
McAleer 
(17 May 
2013):
Dear Mr Hilley
Thanks for contacting us.
Please accept our apologies for the delay in replying. We know our correspondents appreciate a quick response and we’re sorry you have had to wait on this occasion.
[Administrative details...]
We forwarded your concerns to the BBC News website team who respond to your concerns as follows:
"We have reported over recent years on the various attempts to catalogue the death toll in Iraq, and on the controversy surrounding the different figures.
http://www.bbc.co.uk/news/world-middle-east-11107739
http://news.bbc.co.uk/1/hi/uk/6045112.stm
http://news.bbc.co.uk/1/hi/world/middle_east/7180055.stm
http://news.bbc.co.uk/1/hi/world/middle_east/3962969.stm
The Iraq Body Count is the only organisation to offer an actual count covering the period since the US-led invasion. Other organisations seek to estimate the death toll at particular points in time, using statistical and sampling techniques.
In the particular graphic you cite, we attempt to show the rise and fall in deaths and casualties over the 10 years since the invasion. The Iraq Body Count is the only source that we feel we can rely on for this specific data. This graphic is not about numbers, but about the pattern over that period and other sources do not provide this information."
Please be assured that your complaint has been registered.
Thanks again for getting in touch.
Kind Regards
Gemma McAleer
BBC Complaintswww.bbc.co.uk/complaints
---------------------------------
 
Reply to BBC's Gemma 
McAleer 
(19 May 2013):
Dear Gemma McAleer
The deceit and evasion in your reply is glaringly obvious.
The first link here gives distinct prominence to IBC, with only cursory mention of Lancet/Johns Hopkins and no mention of ORB, the others providing only basic news/assessment of the Lancet study and Iraqi Family Health Survey.
However, the issue is not just about discussions of those latter studies - sparse as they are in overall BBC output - but, more specifically, fair and equal presentation of such sources/data in viewer graphics.
It's clearly evident that the BBC has selected IBC's data because it reflects UK/US war killing in its least damaging light. Your every excusing word makes the BBC complicit in disguising that crime.
Also, if, as you claim, the point of the graphic is "not about numbers", why insist on a count-based graphic at all?
And even if it's about showing "a pattern over that period", why still exclude illustration of the other studies?
I've suggested that, for balanced information, the BBC could show a (simplified) caption with all these sources and their respective data. Why is this so problematic?
I've also asked for specific information on who at the BBC made the editorial decision to 'adopt' IBC and how that decision was arrived at.
Since neither that nor a satisfactory answer to my question about using additional sources has been received, I wish to have my enquiry elevated to 'stage 2' consideration.
Regards
John Hilley
Dear Gemma McAleer
The deceit and evasion in your reply is glaringly obvious.
The first link here gives distinct prominence to IBC, with only cursory mention of Lancet/Johns Hopkins and no mention of ORB, the others providing only basic news/assessment of the Lancet study and Iraqi Family Health Survey.
However, the issue is not just about discussions of those latter studies - sparse as they are in overall BBC output - but, more specifically, fair and equal presentation of such sources/data in viewer graphics.
It's clearly evident that the BBC has selected IBC's data because it reflects UK/US war killing in its least damaging light. Your every excusing word makes the BBC complicit in disguising that crime.
Also, if, as you claim, the point of the graphic is "not about numbers", why insist on a count-based graphic at all?
And even if it's about showing "a pattern over that period", why still exclude illustration of the other studies?
I've suggested that, for balanced information, the BBC could show a (simplified) caption with all these sources and their respective data. Why is this so problematic?
I've also asked for specific information on who at the BBC made the editorial decision to 'adopt' IBC and how that decision was arrived at.
Since neither that nor a satisfactory answer to my question about using additional sources has been received, I wish to have my enquiry elevated to 'stage 2' consideration.
Regards
John Hilley
-------------------------
To BBC's Fran 
Unsworth
(19 June 
2013)
Reference 
CAS-2109403-3PN7BB
Dear Fran Unsworth
Further to my initial correspondence, I wish to elevate my complaint to a second stage enquiry.
I assume from the above reference supplied by the BBC that you have details of my original letter and the BBC's reply.
Here is the text of my last 
response:
[As to Gemma McAleer, above.]
Since my original request, the results of a significant poll have been published showing that the general public have been very poorly informed as to the extent of war-related fatalities in Iraq:
A key reason for this must surely be the media's failure to present that core information to the public. As a leading news organisation, supposedly dedicated to the provision of wide and balanced information, the BBC must take a considerable level of responsibility for that failure.
I wish to offer this poll evidence in support of my above-noted request for an explanation as to why the BBC has favoured the IBC data and how that decision was arrived at.
I look forward to hearing your considered thoughts.
Kind regards
John Hilley
-------------------------
Reply from BBC's Stephanie 
Harris 
to second stage complaint letter 
(17 July 
2013)
Dear Mr 
Hilley
 
As you know, your 
concerns have been passed to me to respond to as it is my role to investigate 
complaints at the second stage of the BBC ‘s complaints process on behalf of the 
Director of BBC News. I realise that this 
will disappoint you but there is very little that I can usefully add to the 
responses you have already received and which I endorse. 
 
You refer to the 
lack of a reference to ORB in this report: http://www.bbc.co.uk/news/world-middle-east-11107739 but this 
article was just given as an 
example of how we have reported on the issue of numbers of civilian deaths in 
the past. For now, the question is why we 
didn’t put the range of sources in our recent coverage ten years on from the 
invasion.
 
When looking at Iraq 
ten years on, we wanted to give a sense of the scale of what has happened over 
time and only the Iraq Body Count figures are able to do that. If you look at the graph in this 
case, the movements are so small as to be imperceptible. As previously explained, 
what matters here is the pattern over a number of years. 
 
Other agencies cannot 
provide this information so the Middle East editor felt that IBC was the right 
source in this instance. Using other studies as 
well – based on different methodologies – would have been pointless and 
confusing for readers. 
 
In concluding, I  should point out that it is now open to you to ask the BBC Trust  to review your complaint on appeal. However, please note that the Trust does not  consider every appeal brought to it. In general, the Trust only considers those  appeals which may result in a breach of the BBC’s Editorial Guidelines. If a  question arises as to whether an appeal ought to be taken, the Trust is the  final arbiter.
 
Appeals must be received within 
20 working days of the date of this email. The Trust may, exceptionally, take an 
appeal brought after this date if it considers there is a good reason for the 
delay. The appeal should not exceed 1,000 words and should clearly state the 
points you raised at Stage 2 which you want the Trust to address, with your 
reasons. The Trust will not normally consider new points. You can find full 
details of the complaints procedures here: http://www.bbc.co.uk/bbctrust/governance/complaints_framework/
 
Correspondence for the Trust 
should be addressed to the Complaints Adviser, BBC Trust Unit, 180 Great 
Portland Street, London W1W 5QZ or to trust.editorial@bbc.co.uk. If you have any access 
issues please contact the BBC Trust for assistance on 03700 103 100 or textphone 
03700 100 212.
 
Yours 
sincerely
 
Stephanie 
Harris
Head of Editorial 
Compliance & Accountability
BBC News
-----------------------------
Reply to Stephanie 
Harris
(19 July 
2013)
Dear Stephanie 
Harris
You have failed to 
answer my questions.  
 
Allow me to go through the 
main parts of your letter:
 
"As you know, your 
concerns have been passed to me to respond to as it is my role to investigate 
complaints at the second stage of the BBC ‘s complaints process on behalf of the 
Director of BBC News. I realise that this 
will disappoint you but there is very little that I can usefully add to the 
responses you have already received and which I endorse."
Actually, no, I'm not in the least disappointed. Disappointment usually only comes on the back of  hopeful expectation. In this case there was no sense in which I expected  anything other than what's stated here: blanket dismissal and paltry  excuses.
"You refer to the lack of a  reference to ORB in this report: http://www.bbc.co.uk/news/world-middle-east-11107739but this  article was just given as an  example of how we have reported on the issue of numbers of civilian deaths in  the past."
As already stated, this article  is token, both in its discussion of ORB and against the nominal use of other  sources.
"For now, the question is why we  didn’t put the range of sources in our recent coverage ten years on from the  invasion."
That's just one of the questions I put. You have, quite obviously, ignored or sought to avoid the others.
"When 
looking at Iraq ten years on, we wanted to give a sense of the scale of what has 
happened over time and only the Iraq Body Count figures are able to do 
that." 
Any true sense of scale would want to show how many war-related fatalities had actually occurred. Are you seriously arguing that only IBC has been able to provide that qualitative data? Are you really claiming that a methodology based only on registered media reports, with all the limitations that entails, is any way to quantify a serious war death figure?
"If you look at the graph in this case, the movements are so small as to be imperceptible. As previously explained, what matters here is the pattern over a number of years."
No, what fundamentally matters to the public is the actual number of people dead in this period, not patterns over the years.
"Other agencies cannot provide this information so the Middle East editor felt that IBC was the right source in this instance."
They most certainly can, 
and have done. This is a truly shocking evasion and an insult to viewers' 
intelligence.
"Using other studies as well – based on different methodologies – would have been pointless and confusing for readers."
Again, this is 
an utterly deceitful and patronising excuse. Are you actually suggesting that 
other research bodies involved here are unable to provide such informed data 
and simple explanation? Are you seriously proposing that the public at 
large would be either indifferent to or unable to comprehend basic 
figures from the Lancet or ORB studies?
I am not satisfied  that the key questions contained in my complaint were even acknowledged, never  mind answered.  I will now pass on my complaint to the BBC Trust for  consideration.
Regards
John Hilley
-------------------------------
 
I trust the above  provides sufficient indication of the questions I still wish considered,  together with the particular information I'm seeking. 
To reiterate the  two main requests, as derived from my initial letter and second stage  exchange:
I've suggested that, for balanced  information, the BBC could show not just an IBC count, but the wider range of  sources and their respective data. Why has the BBC consistently refrained from  doing so?
I've also asked for specific information on who at the BBC made the editorial decision to adopt IBC as a principal source, to the almost blanket exclusion of the other sources noted, and how that decision was arrived at.
Please could you fully address  these two main concerns and give your view on whether the almost sole use of IBC  figures maintains a biased and limiting understanding of Iraq war deaths.
Please be reminded that  information on the true scale of war-related deaths should be conveyed as a  matter of vital public importance by the BBC. As indicated by the recent Com  Res poll (noted in the above correspondence), there appears to be a shocking  absence of such public awareness. I would ask you to consider this as  substantive evidence for my complaint over the BBC's selective and misguided use  of IBC figures. 
I look forward to your considered deliberations.
Kind regards 
John Hilley
-----------------------------------
Update:
response from BBC Trust
 
 
-----------------------------------
Update:
response from BBC Trust
Dear 
Mr Hilley
I am 
writing to acknowledge receipt of your appeal which we received on 19 July 2013. 
We 
will now consider your request for a final appeal under the BBC’s Editorial 
complaints procedure. In order to do this we will review your complaint and your 
previous correspondence with the BBC and decide whether your appeal qualifies 
for consideration by the Trust. We will only consider the points you raised at 
Stage 2 that you want the Trust to reconsider.  Therefore, unless there are 
exceptional circumstances, we will not consider new points at this stage. We 
also ask that you do not now submit any further documentation unless you 
consider this to be necessary for the purposes of your appeal.
The 
Trust’s Editorial complaints procedure explains that we will write to you with 
our decision within 40 working days of the receipt of your appeal (i.e. by 16 
September 2013), but we are usually able to do this sooner. We will also keep 
you informed if for any reason we meet with delay during this 
process.
If we 
decide your appeal qualifies to be considered by the Trust, we will write 
explaining the process and setting out the timescale for taking your appeal. In 
considering whether or not an appeal qualifies for consideration, we may decide 
to take only part of the appeal, and consider only some of the issues 
raised.
If our 
conclusion is that your appeal, or any part of your appeal, does not qualify for 
consideration by the Trust, we will write and explain the reasons for that. If 
you disagree with our view then you may ask the Trust to review the decision by 
writing to us within 10 working days of the date on which you received our 
response.
If we 
decide your appeal qualifies for consideration, or if you challenge the decision 
of the Trust Unit not to proceed with some or all aspects of your appeal, the 
matter will be considered at the next monthly Editorial Standards Committee 
meeting. We aim to provide you with their final decision within 80 working days 
of our decision to accept your appeal or challenge. 
The 
Trust Unit reports on its performance against these target response times in the 
BBC’s Annual Report and Accounts (http://www.bbc.co.uk/annualreport/) 
Full 
details of the BBC’s complaints procedure, including the appeal stage, can be 
found here: http://www.bbc.co.uk/bbctrust/contact_us/complaints/appeal_trust.html
Yours sincerely
Christina Roski
Complaints Adviser, BBC Trust Unit
 
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