The Public Record’s Code of Ethics and Journalistic Practice

Nature of Our Journalism

• Our primary news coverage to be fact-based, without expression of opinions, but journalists are encouraged to provide commentary in related blog posts or columns, being transparent about their opinions.
• Our journalists may express personal opinions in their own accounts on social networks.
• We encourage our journalists to express opinions about journalism matters, advocating for freedom of information and joining the conversation within the profession about important issues.
• Our staff will ensure that patrons have no influence over editorial content.
• If a family member’s political involvement would call into question the integrity of a journalist’s coverage, the journalist should avoid coverage of that issue or campaign. If avoiding such a family conflict is impossible, the family member’s involvement should be disclosed in related coverage.
• We encourage involvement in the community, politics and the issues we cover, but we disclose these involvements in our coverage.
• Despite our organization’s involvement in the issues we cover, we should provide factual coverage in a neutral voice. We should disclose our affiliation for transparency reasons, but the affiliation should not be evident from a promotional voice or content.

Accuracy

• We are disciplined in our efforts to verify all facts. Accuracy is the moral imperative of journalists and news organizations, and should not be compromised, even by pressing deadlines of the 24-hour news cycle.
• We make every effort to verify the identities and backgrounds of our sources.
• We seek documentation to support the reliability of those sources and their stories, and we are careful to distinguish between assertions and fact. The onus is on us to verify all information, even when it emerges on deadline.
• We make sure to retain the original context of all quotations or clips, striving to convey the original tone. Our reporting and editing will not change the meaning of a statement or exclude important qualifiers.
• There is no copyright on news or ideas once a story is in the public domain, but if we can’t match the story, we credit the originating source.
• While news and ideas are there for the taking, the words used to convey them are not. If we borrow a story or even a paragraph from another source we either credit the source or rewrite it before publication or broadcast. Using another’s analysis or interpretation may constitute plagiarism, even if the words are rewritten, unless it is attributed.
• We believe a link to a digital source is sometimes sufficient attribution; we need not always name the source in the text if the information is routine.
• When we are using someone else’s exact words, we should use quotation marks and attribution.
• We should always cite news releases if they are our sources, and should quote them if using their exact words.
• We should not publish rumors or other information we have not verified.
• If we are unsure of the accuracy of information, we should cite our sources, word stories carefully to avoid spreading false rumors, acknowledge what we don’t know and ask the community’s help in confirming or correcting our information.
• If staff members want to share unconfirmed information on social media, such as rumor or hearsay, they should explain in the post why they are posting this information, such as seeking community confirmation for the report.

Corrections and Archives

• When we make a mistake, whether in fact or in context, and regardless of the platform, we correct it promptly and in a transparent manner, acknowledging the nature of the error.
• We publish or broadcast all corrections, clarifications or apologies in a consistent way.
• If a mistake is made in a social media post, we will publish a corrected version indicating that the new post is a correction. We will include a link to the erroneous original post and allow it to stand with limited exceptions.
• We will show all changes that have been made to online stories if they involve corrections or rephrasing to fix unclear material.
• We will note when the post was updated.
• We will show all corrections in the place the incorrect material originally appeared (e.g., put corrections related to a story at the bottom of that same story).
• We will post all of your corrections in a single corrections and errors page.
• We generally do not “unpublish” or remove digital content, despite public requests, or “source remorse.” Rare exceptions generally involve matters of public safety, an egregious error or ethical violation, or legal restrictions such as publication bans.
• We will update a story in our archives, including the headline, if the story would damage someone’s reputation and is outdated.
• We will correct any errors we learn of in our archived content and note the corrections.
• For platforms that don’t allow editing of posts, we should leave original posts untouched, unless they are defamatory, harmful, or otherwise legally problematic.
• We may edit or delete inaccurate social media posts, so people who haven’t seen the corrections will not spread them on social media. We will note that we have edited or deleted inaccurate posts.
• We should note who has retweeted, liked or otherwise shared inaccurate social media posts that we are correcting, and attempt to message them directly to call attention to our corrections.
• We will never delete a post to prevent our embarrassment resulting from an error.

Transparency of Journalistic Gathering and Reporting

• We generally declare ourselves as journalists and do not conceal our identities, including when seeking information through social media. However, journalists may go undercover when it is in the public interest and the information is not obtainable any other way; in such cases, we openly explain this deception to the audience.
• We normally identify sources of information. But we may use unnamed sources when there is a clear and pressing reason to protect anonymity, the material gained from the confidential source is of strong public interest, and there is no other reasonable way to obtain the information. When this happens, we explain the need for anonymity.
• We avoid pseudonyms, but when their use is essential, and we meet the tests above, we tell our readers, listeners or viewers.
• When we do use unnamed sources, we identify them as accurately as possible by affiliation or status. (For example, a “senior military source” must be both senior and in the military.) Any vested interest or potential bias on the part of a source must be revealed.
• We independently corroborate facts if we get them from a source we do not name.
• We do not allow anonymous sources to take cheap shots at individuals or organizations.
• If we borrow material from another source we are careful to credit the original source.
• We admit openly when we have made a mistake, and we make every effort to correct our errors immediately.
• We disclose to our audiences any biases that could be perceived to influence our reporting.
• We openly tell our audiences when another organization pays our expenses, or conversely, when we have made payments for information.

Advertorials and Fluff Stories to Gain Favour

• The Public Record contains no advertising, advertorials, or stories which attempt to gain favour with those in power in exchange for access.
• We do not seek or try to gain favour from those we cover.
• The Public Record does not engage in the practice of Access Journalism.

Fairness

• We respect the rights of people involved in the news.
• We give people, companies or organizations that are publicly accused or criticized opportunity to respond before we publish those criticisms or accusations. We make a genuine and reasonable effort to contact them, and if they decline to comment, we say so.
• We do not refer to a person’s race, colour, religion, sexual orientation, gender self-identification or physical ability unless it is pertinent to the story.
• We avoid stereotypes of race, gender, age, religion, ethnicity, geography, sexual orientation, disability, physical appearance or social status. And we take particular care in crime stories.
• We take special care when reporting on children or those who are otherwise unable to give consent to be interviewed. While some minors, such as athletes, may be used to being interviewed, others might have little understanding of the implications of talking to the media. So when unsure, or when dealing with particularly sensitive subjects, we err on the side of seeking parental consent. Likewise, we take special care when using any material posted to social media by minors, as they may not understand the public nature of their postings.
• We do not allow our own biases to impede fair and accurate reporting.
• We respect each person’s right to a fair trial.
• We do not pay for information, although we may compensate those who provide material such as photos or videos. We sometimes also employ experts to provide professional expertise, and pay for embedded activities. We are careful to note any such payments in our stories.
• To ensure fairness, we believe in covering not only the most powerful voices on an issue, but also those who are not normally heard (e.g. in election coverage, mainstream and non-mainstream candidates).
• We encourage staffers to seek diverse sources, both in specific stories and in routine beat coverage.
• We will refrain from presenting multiple points of view if one perspective on an issue has been credibly established as fact. In other words, we will avoid “false balance.”
• In breaking news situations, we will attempt to gather comments from key sides of an issue; if comments are not immediately available, we will publish or air the story without them, make clear that we were unable to get some comment and update our story as needed.

Right to Privacy

• The public has a right to know about its institutions and the people who are elected or hired to serve its interests. People also have a right to privacy, and those accused of crimes have a right to a fair trial.
• However, there are inevitable conflicts between the right to privacy, and the rights of all citizens to be informed about matters of public interest. Each situation should be judged in light of common sense, humanity and relevance.
• We do not manipulate people who are thrust into the spotlight because they are victims of crime or are associated with a tragedy.
• We believe interviewing bystanders of traumatic events is voyeurism and unlikely to add relevant material to articles or programs. We generally will not conduct interviews recognizing that traumatized individuals may not be able to give informed consent.
• We consider the standard for publishing material about private individuals who are thrust into the public eye as higher than that for public individuals.
• We do not believe that everything celebrities and public officials say and do should be made public, even though they cede a great deal of privacy when they enter the public eye. We analyze cases on an individual basis, taking into account the news value of the public figure’s action.
• We will voluntarily withhold information we have gathered when requested if we deem the individual’s request to be valid, based on our news judgment and professional standards.
• We reserve the right to publish material that we have voluntarily withheld if we determine that the material has valid public interest or if we feel that the requesting party has deceived us as to his or her motives.
• Journalists are increasingly using social networking sites to access information about people and organizations. When individuals post and publish information about themselves on these sites, this information generally becomes public, and can be used. However, journalists should not use subterfuge to gain access to information intended to be private. In addition, even when such information is public, we must rigorously apply ethical considerations including independent confirmation and transparency in identifying the source of information.

Withholding Names

• Unless we have good reason to withhold a name, we always publish names of people involved in the stories we cover.
• We do not publish names of sexual assault victims unless they agree to speak on the record.
• In breaking news stories, we do not publish the names of dead people until authorities have notified their families and released the names, unless extremely compelling circumstances justify publication as soon as we have verified the names.
• We withhold the names of mass killers to deny them the attention they appear to seek. Other than names, we cover other details of these crimes based on their newsworthiness.
• In covering active police or military operations, we will withhold such details as location or tactics planned, until after the operation, to avoid endangering police, troops or civilians who could be affected.
• We will consider potential harm to sources facing intolerance in their societies before naming them in stories.

Independence of Journalists

• As journalists, we serve democracy and the public interest by reporting the truth. This sometimes conflicts with various public and private interests, including those of sources, governments, advertisers and, on occasion, the interests of The Public Record as a business.
• Defending the public’s interest includes promoting the free flow of information, exposing crime or wrongdoing, protecting public health and safety, and preventing the public from being misled.
• We do not give favoured treatment to patrons, special interests, or those connected to The Public Record.
• We pay our own way whenever possible. However, not all journalists or organizations have the means to do so. So if another organization pays our expenses to an event that we are writing about we say so. (There are some generally understood exceptions; for instance, it is common practice to accept reviewers’ tickets for film previews, concerts, lectures and theatrical performances.)
• We do not solicit gifts or favours for personal use, and should promptly return unsolicited gifts of more than nominal value. If it is impractical to return the gift, we will give it to an appropriate charity.
• We do not accept the free or reduced-rate use of valuable goods or services offered because of our position. However, it may be appropriate to use a product for a short time to test or evaluate it. (A common exception is unsolicited books, music, food, or other new products sent for review.)
• We do not accept payment for speaking to groups we report on or comment on.
• We do not report about subjects in which we have financial or other interests, and we do not use our positions to obtain business or other advantages not available to the general public.
• We do not show our completed reports to sources – especially official sources – before they are published or broadcast, unless the practice is intended to verify facts. Doing so might invite prior restraint and challenge our independence as journalists.
• We gather information with the intent of producing stories and images for public consumption. We generally do not share unpublished information – such as notes and audio tapes of interviews, documents, emails, digital files, photos and video – with those outside of the media organizations for which we work. However, sometimes such sharing may be necessary to check facts, gain the confidence of sources or solicit more information. We publish as much source material as possible with the publication of our stories.
• Columnists and commentators should be free to express their views, even when those views conflict with those of their organizations, as long as the content meets generally accepted journalistic standards for fairness and accuracy.

Handling of freelancers

• We will publicly credit the work of freelancers.
• We will pay reasonable fees to freelancers for their services but not for contributing as sources on a story.

Conflicts of interest

• Our journalists are encouraged to be involved in the community and the issues we cover, but we will disclose these involvements in our coverage.
• Our journalists are free to engage in activities that we encourage readers to engage in such as voting, membership in non-partisan organizations, service clubs, and community organizations.
• We carefully consider our political activities and community involvements – including those online – and refrain from taking part in demonstrations, signing petitions, doing public relations work, fundraising or making financial contributions if we will be covering the campaign, activity or group involved.
• In the event a journalist are involved in any of the above, or make financial contributions to non-partisan campaigns, our journalist shall disclose it. (An example being a fund raiser such as the Westdale Cinema)
• We shall not engage in active partisan involvements or activities.

Financial Interests

• We will implement a disclosure page on our website that lists our financial interests if we cover business or finance regularly.
• Our journalists should immediately disclose to a supervisor any interests they have in a company they are asked to cover. Supervisors should consider putting another journalist on the story.
• Our journalists may invest in equity index-related products and publicly available diversified mutual funds or commodity pools, but should disclose them if they happen to cover a particular fund in which they have an interest.

Personal Ethics Statements by Staff

• Our journalists are encouraged to make personal ethics statements, which provide more information about themselves and their attitudes, even though they must follow the standards of The Public Record.
• Our organization’s policy prevails if personal ethics codes and organizational policy conflict.

Gifts, Free Travel and Other Perks

• Our journalists should accept no gifts from subjects or potential subjects of our coverage. If gifts sent to journalists cannot be returned, we should donate them to charity.
• Our journalists should pay their own way to all events we cover, including entertainment and sporting events, though we can accept, for our admission price, access to media areas such as a press box.
• Our journalists may accept a small gift in cases where people are being kind and clearly not trying to influence us. Our gift policy does not require us to be rude; sometimes there’s a common-sense need to accept a small gift.

Political Activities by Staff

• We allow our journalists to be involved in the community, politics and the issues we cover. We will disclose these involvements in our coverage.
• Our journalists should disclose community and political involvements, particularly those involving topics they might cover, both in general statements we will publish on our website and in stories relating to their involvement.
• Our journalists should avoid political involvement such as running for or holding office, joining political parties, volunteering in campaigns, donating to campaigns or displaying campaign materials on their property or persons. When they do engage in political involvement, it shall be disclosed.

Freelance Work by Employees

• We permit freelancing by full-time employees if it meets our overall criteria, and we do not require advance notice.
• We allow part-time employees to perform freelance work without prior notice to direct managers.
• The Public Record strongly believes that our contributors enjoy the freedom to engage in their own activities; trusting that our contributors will act in a manner that does not harm their public reputations or ability to conduct journalism.

Social Networks

• Our journalists are free to express opinions on social media.
• We encourage staff members to retweet, reblog, share and otherwise pass along things they find interesting on social media. We trust them to provide context where appropriate.
• Staff members should always identify themselves in social media profiles, and, if they are using the profile for professional purposes, they should identify themselves as working for our organization.

Sources: Reliability and Attribution

• We may use sources with a conflict of interest in stories, but details that signal the conflict of interest should be included (e.g. a scientist who conducted a study about a drug’s effectiveness when the study was funded by the manufacturer).
• We disclose how sources In “ordinary people” stories were identified (e.g. through Twitter).
• We use links, if available, for source attribution in online stories.
• We include source attribution in online stories themselves as well as links, if available, that provide additional information.
• We report things that have clearly been established as fact at the top of the story and put the attribution in later.
• We consistently include clear attributions throughout a story, even if something has been established as fact.
• We include attributions throughout a story in a chronological account.

Confidential Sources

• We use confidential sources sparingly to provide important information that cannot be obtained through on-the-record sources. Reporters should disclose the identity of unnamed sources to at least one editor.
• We only promise anonymity when the material is of high public interest and it cannot be obtained any other way. And when we make these promises to sources, we keep them.
• We will disclose to readers or viewers the reasons for granting confidentiality, such as fear for the source’s safety or job, when we use unnamed sources.
• We do not attend “background briefings” where officials try to spoon-feed information to the media without speaking for the record.
• We are more open to granting confidentiality to sources we approach for interviews than to sources approaching us with tips or with dirt about political opponents or business rivals.
• We recognize that many sources cannot talk to us freely. We grant confidentiality if we think the source has a good reason. We will use information and quotes from unnamed sources we consider reliable.
• We always assume that government snoops, law enforcement or hackers might access our regular communication channels when we grant confidentiality to a source. We should use technology such as encryption software to protect confidentiality.
• Because we may be ordered by a court or judicial inquiry to divulge confidential sources upon threat of jail, we must understand what we are promising. These promises – and the lengths we’re willing to go to keep them – should be clearly spelled out as part of our promise. The following phrases, if properly explained, may be helpful:
  • Not for attribution: We may quote statements directly but the source may not be named, although a general description of his or her position may be given (“a government official,” or “a party insider”). In TV, video or radio, the identity may be shielded by changing the voice or appearance. The Public Record extremely rarely engages in this activity as it is a hallmark of Access Journalism. We do grant non-for-attribution to sources who are not in positions of power when it exposes the machinations of those in power.
  • On background: We may use the essence of statements and generally describe the source, but we may not use direct quotes.
  • Off the record: We may not report the information, which can be used solely to help our own understanding or perspective. There is not much point in knowing something if it can’t be reported, so this undertaking should be used sparingly, if at all.  The Public Record extremely rarely engages in this activity as it is a hallmark of Access Journalism.
• When we are not willing to go to jail to protect a source, we say so before making the promise. And we make it clear that the deal is off if the source lies or misleads us.

Interviewing

• We never pay for interviews.
• We never permit interview subjects to review or revise their comments.
• When reporting on an interview, we do not require our staff to state the type of interview (i.e., whether it was in person, by telephone, video, Skype or email.)
• Articles and reports must state the method of interviewing (i.e., whether it was in person, by telephone, video, Skype or email) if doing so enhances the context of the interview and article.

Race and Gender

• We will seek out people in the groups we cover to gain perspective on our coverage and terminology.
• We will use racial, ethnic, gender and sexuality identifiers when specifically germane to a story but not otherwise.
• We will Identify transgender people by the gender they express publicly.
• We will alternate between male and female pronouns.

Mental Health and Suicide

• We will cover mental health and suicide as broad public health issues as consistently as we cover other health matters.
• We will use the phrases “died by suicide” or “killed himself or herself” and avoid the phrases “committed suicide” and “took his or her own life.”
• We will not detail specific means of suicide in news stories or obituaries.
• We will not use sensational headlines on stories about suicide.
• We will not use graphic images on stories about suicide.
• We will opt for everyday images of a person who dies by suicide (such as a school photo) instead of images of people grieving.
• We will Include contact information for resources for people in mental health crises. (e.g. “The Hamilton COAST team is available 24 hours a day at 905-972-8338.)
• We will include the method used in a suicide when it is important for audience understanding but not specific details (e.g., noting that a victim shot themselves but not covering the type of weapon).

Quotations

• We will clean up random utterances such as pauses, “um” or “you know” unless they materially alter the meaning.
• We will allow separate phrases of a quote separated by ellipsis. (“I will go to war … but only if necessary,” the president said.)
• We will allow separate phrases of a quote separated by attribution. (“I will go to war,” the president said. “But only if necessary.”)

Obscenities

• We will replace obscenities, vulgarities and slurs with a descriptor (e.g. “an anti-gay slur”).
• We will replace obscenities, vulgarities and slurs with something that implies the word rather than stating it directly (e.g. “f—”).
• We will apply the same standards on obscenities, vulgarities and slurs to reader comments on stories that are applied to the story itself.

Photo and Video

• When documenting private or traumatic moments, we will not seek permission to shoot, but will be sensitive to subjects’ situation.
• We will use drones to capture images in public areas only.
• We will not ask subjects to pose or to re-enact an event.
• We do not need to label a photo or video if it is clearly posed (e.g. an award-winner holding up a trophy).
• We will refrain from intentionally becoming an active participant in a news story (e.g. taking part in a rescue operation or using our camera to influence a situation).
• If we believe we can provide help or mitigate harm by actively participating in a situation (rather than only documenting it), do so and then disclose your participation to your viewers.
• We will not manipulate images through Photoshop or other means.
• We will clearly label any edit or manipulation that would lead viewers to “see” something other than what the photographer/videographer saw through the camera lens.
• We will obscure or pixellate images only when the intent is to protect the identify of someone in the image or to protect viewers from gory or graphic material.
• We will refrain from using any photos or video provided by outside organizations (governments, companies, agents, etc.).
• We will refrain from using “handout” photos or video unless your own photographers are unavailable to cover the story.
• We will clearly label the source of all “handout” photos or video.
• We will refrain from using any generic photos or video to illustrate a specific story.
• We will use generic photos only when viewers would not expect to see a photo specific to the story (e.g. using a photo of a plane from an airline’s fleet to illustrate the kind of plane that was involved in a crash.)
• If using music in video stories, we will be cognizant of the emotional effect the music may have, and avoid using music if the story is intended to have a neutral voice.
• We will verify photos or videos from social media before using them.

Audio

• Audio cuts of newsmakers may be edited to remove insignificant stumbles.
• Cuts and programs may be heavily edited and rearranged as needed, as long as there’s a disclosure the audio was edited, the meaning of statements remains the same after editing, and rearrangements of audio do not affect the original meaning.
• We will fully identify person-in-the-street-type speakers in audio cuts unless there is a compelling reason not to.
• Our journalists may mix sound from different sources as long as it gives a true picture of what happened (even if it was not all recorded at the same time).
• Our journalists may never combine sound from different sources in such a way as to create an audio scene that never happened.
• Cut and programs will only be heavily edited when creating review style material that is clear that the clips are selected, and links shall be provided to full unedited (with the exception of insignificant stumbles and verbal crutches) content.

Data Journalism

• We will never pay for data, as it may be tainted by financial motives.
• In collaborative projects, we insist that all parties are clear on shared ethics, values and roles.
• In collaborative projects, we may not be able to insist on shared ethical values with partners, but we will disclose to our readers and viewers that we have separate policies from our partners.
• We will put all data in relevant context.
• We will make original data available for download when it is not covered by a usage agreement that bars such public posting. Any usage agreement will be disclosed publicly.
• We will not use personally identifiable data without specific and valid news value to support disclosure.
• We will secure data to the best extent possible to prevent hacking.
• We will pay reasonable technical costs (copying, transmission, etc.) for providing data to us.

Robot journalism

Note: we presently do not publish any content produced by bots

• We will publish a statement with all automatically produced stories, explaining that they are the work of robot journalism.
• We will identify for the reader the source of data for automatically produced stories and the people or company providing the story-writing automation.
• We will “tune” our software for certain purposes; for example, we will try to encourage children’s soccer by having the software highlight goals and downplay mistakes. We will disclose such tweaking.

Interactives

• We will organize and internally link our interactives in a way that users entering and navigating in different ways will be able to grasp the essential points of the story.
• Links among the parts of an interactive will be retained over time, including when the story is archived.
• Links among the parts of an interactive will be retained in the archive if the parts are still correct and relevant.
• We will reconstruct or preview events through infographics or animations only if we are sure that every detail we show is correct.

Online Commenting

• We have established a registration and approval system permitting “favorite” commenters to post and publish their comments immediately without editorial review.
• We permit comments on selected articles.
• We allow anonymous commenting.
• We allow pseudonyms for commenting as long as a user has registered an account with us.
• We will access and review the identity of a registered commenter only when subpoenaed by law enforcement. We will determine if releasing information to law enforcement would compromise our journalism and protection of free expression, and publicly declare our decision.
• As of June 2017, we have received no sealed orders from the government.

Awards and Contests

• The Public Record does not enter award contests with the exception of the Hamilton Independent Media Awards. We believe our journalism should be focused on readers, not award juries.
• The Public Record declined to participate in the first year of the HiMAs in line with our practice on awards. This decision undermined these community awards by creating the impression TPR was boycotting. TPR stood for nomination thereafter.
• The Public Record‘s Reporter/Blogger Joey Coleman has applied for fellowships in the past, and may in the future.
• If our policy on awards changes, we will notify readers.

Accepting Funding

• Our funder(s) will not be able to see our stories before publication.
• Our funder(s) will have no say in topics to be covered or specific stories.
• We will publicly disclosure all corporate, foundation, or grant funding sources.
• We will disclosure any funder who provides more than $1000 in combined patron or crowdfunding support in any calendar year.
  Patrons who have chosen to be anonymous same remain so when contributing less than $1000 in a calendar year.

Reporting On Our Own Organization

• We will avoid all potential conflicts of loyalty by refraining from covering the story when our organization has done something newsworthy. We will let others cover our organization. If an issue is particularly newsworthy, we will limit ourselves to publishing official company statements.

Sensational Material

• We will run sensitive material that might be offensive to specific members of the audience after internal debate has demonstrated a clear public interest in and value from the publication.
• We will run sensitive material when it reflects reality.
• We will consider the differing impact of sensitive material on differing segments of the population (e.g., effects on minors, vulnerable groups or victims of crime).
• We will refrain from running sensitive material specifically or solely for the revenue purposes, such as increased digital traffic.
• We will run sensitive material with stories with notes of warning.

Clickbait and Metrics

• We do not engage in clickbait.
• We will accurately reflect the content of related stories in headlines and social media posts.
• We will not use metric considerations in determining what we cover and how we place stories.
• The Public Record minimizes third-party calls on our websites, and does not use third-party analytics. We do embed YouTube videos, which do contain Google Trackers as per the YouTube Privacy Policy.

User-Generated Content

• We will guard against using UGC in situations that might be dangerous to the person who created it or to others in the images. We will stress to possible providers of UGC that they must not take risks to gather information or imagery.
• We consider UGC an extension of our own journalism. We don’t run such material unless we’re sure it’s authentic.
• We will not distribute UGC content unless we’re certain we have the rights to do so. The only exception might be an urgent situation where a rights-holder cannot be found.
• If we cannot find the rights-holder in an urgent situation and use the UGC, we will make continued efforts afterward to locate and reach an agreement with the rights-holder.

Bombs and Other Threats