Are all these subtitles reminders really necessary?

For many years now, the main UK television networks have offered subtitles for all their programmes.  Whether a programme is pre-recorded or live, subtitles are a standard feature.

The primary audience – deaf viewers – certainly know about the service.  So, why do many of our most popular TV channels consider it necessary to continue to remind us of the existence of subtitles, by overlaying ‘Subtitles’ text on their channel idents or over the opening of their programmes?  Some, such as Channel 4 and Channel 5, choose not to.

Many of these channels already pollute the screen with other text/information, such as their channel logo (or DOGs as they’re also known – Digital On-Screen Graphic) and animating text (sometimes very large and intrusive), promoting an upcoming new programme (example: the recent monstrosity on ITV, promoting the new series of I’m a Celebrity Get Me Out of Here).

Channel bosses insist that such graphics are necessary to help them stand out and promote their brand/programmes in a very crowded marketplace.  Much as they annoy some of us, there is at least a logical and understandable marketing rationale for them.

But what of the on-screen ‘Subtitles’ indicator?   The case for such ‘promotion’ seems much less convincing.  For someone such as myself, who has a keen interest in graphic design, branding and marketing, I find the BBC’s execution of this on-screen reminder particularly frustrating.

On BBC One, BBC Two and BBC Four, they continue to position the ‘Subtitles’ text (on their idents) within the 4:3 safe area and in Gill Sans (rather than the font used for the channel’s on-air branding/presentation).  I feel particularly aggrieved that BBC Two’s splendid new idents have been blemished by this utterly pointless, badly positioned text.

We asked the BBC, ITV, Channel 4 and Channel 5 to comment on their use (or otherwise) of an on-screen ‘Subtitles’ indicator.  This is what they had to say.  First up, the Beeb:

The primary aim is to promote subtitles more than to inform the audience of their presence.

It may be of interest to know that Ofcom Guidelines on the Provision of Access Services says: “2.11 Publicity: the word ‘Subtitles’ should be displayed legibly on the screen at the start of the programme”.

The BBC takes its responsibilities in this area very seriously and we work closely with lobby groups, the regulators and our own internal policy teams on these issues.

BBC

Odd that the BBC has referenced an old version of Ofcom’s Code on Television Access Services.  Clause 2.11 is A1.21 in the latest incarnation of the Code (published January 2017).  It’s perhaps worth noting that there’s no suggestion in the Ofcom Code that the use of ‘Subtitles’ text is a mandatory requirement.

The BBC is not necessarily implying the Code forces them to highlight subtitles in this way but I do think it’s worth clarifying the extent of Ofcom’s expectations of broadcasters.  A1.21 appears within the Subtitles section of Annex 4 of Ofcom’s Code on Television Access Services, in a sub-section titled Best Practice.

Not entirely sure I understand the logic of the BBC’s intent here though: they say the use of the ‘Subtitles’ text on their idents is about promoting subtitles more than informing the audience of their presence?

Surely a key aim of promoting a product/service is to make your target audience aware of the presence of that product/service?  If they wanted to properly promote the service (they take their responsibilities in this area “very seriously” after all), surely something akin to the recent trail for audio description, voiced by Richard Osman, would be more appropriate? Sticking a relatively small piece of text on a channel ident isn’t much of a promotion.

Curiously, BBC Northern Ireland and BBC Wales dropped the ‘Subtitles’ text from their BBC One and BBC Two idents quite a few years ago.  Even more curious was the reappearance of the ‘Subtitles’ indicator on BBC One Northern Ireland and BBC Two Northern Ireland idents earlier in 2018 – albeit in the correct channel font.

During the summer, the new batch of Oneness idents seemed to be supplied to the nations with the Gill Sans ‘Subtitles’ text burnt on: meaning BBC Wales viewers would once again see the subtitles pointer – but only on this small number of recently added Oneness idents; and BBC Northern Ireland would now have a handful of Oneness idents with ‘Subtitles’ in Gill Sans, rather than their preferred BBC One channel font.

And needless to say, when BBC Two launched its new look in September 2018, all of the new idents seemed to be supplied to Wales, Northern Ireland and Scotland with the Gill Sans ‘Subtitles’ text.

Over on ITV, they opt for a slightly different format, overlaying ‘Subtitles’ text in the top right corner of the screen during the initial seconds of the programme.  In fact, they also include an audio description logo, where appropriate.

This is the case across ITV plc’s portfolio of channels, with the exception of UTV, where the ‘Subtitles’ text and audio description logo are nowhere to be seen.  We asked ITV about their policy on subtitles promotion.  A number of weeks later, we’re still waiting on a response.

Over at Channel 4 Towers, there are no ‘Subtitles’ indicators, with the exception of 4Music.  We asked Channel 4 about their promotion of subtitles and where they stand in relation to Ofcom’s A1.21 clause.  This is their response:

As of 2011 we have had 100% subtitled programming across our channels. This coincided with a decision to stop broadcasting the subtitle symbol/wording. The reference to point A1.21 in the addendum of the Ofcom Code on Television Access Services is a suggestion of best practice.

We are in full compliance with all elements of points 39 and 40 of the Code itself, which sets out the requirements for the promotion of awareness of Access Services.  Additionally, we do advise the availability of subtitles and/or audio description, where available, on our on demand service, All 4.

Channel 4

So, Channel 4 seems to share our view that the ‘Subtitles’ indicator is somewhat pointless.  Channel 5 doesn’t bother with an on-screen ‘Subtitles’ reminder either.  We asked Channel 5 to provide some insight into their policy in this regard.  Unfortunately, no response yet.

With such inconsistency amongst the big players, it’s perhaps no surprise that when we look across the vast array of channels available on DTT, satellite and cable, there are similar disparities – with some mirroring the practices of the BBC and ITV, and others taking their lead from Channel 4 and Channel 5.

The key message here is that broadcasters are under no obligation to promote subtitles using an on-screen identifier but a number of them choose to do so.

Acknowledgements