Media bias and inaccuracy

Ask for a correction 

If the publisher has made a factual error, email and let them know. 

1. Write as soon as possible. 
2. Mark the email “Correction requested”.
3. Refer to the original article by title and date.
4. State clearly what the error is and exactly what the correction should say (keep this as brief as possible while maintaining accuracy).
5. If possible, provide a link to evidence backing up your statement. 
6. Keep it simple: you don’t need to go into background detail on the issue and why it matters.
7. Include your name and telephone number. The publication should not share this: you are covered by the Data Protection Act.
8. If you don’t get a reply, follow up. If the correction is made promptly, send a thank-you email. 

• Daily Mail: [email protected] 
• Express: [email protected] 
• Financial Times:  [email protected] 
• Guardian: [email protected] 
• Independent: https://help.independent.co.uk/hc/en-us/requests/new 
• Mirror: [email protected]
• Observer: [email protected] 
• Star: [email protected] 
• Sun: [email protected]
• Sunday Times: [email protected]
• Telegraph: [email protected] 
• Times: [email protected]

Ask for a right of reply

If a print or online publication has written about you or your organisation (or the gender-critical movement more broadly), and you disagree with their analysis, you could ask for a “right of reply” – an article written in response to another. If your proposal is considered promising, the editor will probably agree to publish it in principle, and give you a word count and a deadline for submission. 

Your article is likely to be edited, perhaps heavily (don’t take this personally: even professional journalists are used to having their work completely rewritten). You should insist on signing off all changes, but don’t complain about stylistic tweaks or anything trivial, since this may lead to your article being dropped. Only refuse to accept changes that mean your article no longer makes your substantive points or misrepresents your position.

Make an official complaint 

If the publisher refuses to make a correction, make an official complaint – write to the editor referring to the part of its regulatory code you think has been breached: 

• the Financial Times, Independent and Guardian have their own codes
• most other newspapers and magazines follow the IPSO Editors’ Code.

For IPSO, the clauses most likely to be relevant are: 

• Clause 1: Accuracy – “The Press must take care not to publish inaccurate, misleading or distorted information or images, including headlines not supported by the text.” 

It is inaccurate and misleading to call a man a woman, or to say that someone male is female or vice versa. Headlines such as “Woman charged with rape” are misleading, even if the text clarifies that the “woman” is in fact a trans-identifying male. 

• Clause 12: Discrimination – “The press must avoid prejudicial or pejorative reference to an individual’s race, colour, religion, sex, gender identity, sexual orientation or to any physical or mental illness or disability.” Note that this clause only relates to individuals. 

Describing an individual as bigoted, exclusionary or anti-trans because they hold “gender-critical” beliefs risks contravening this clause. 

The Editors’ Codebook gives further details about the clauses.

The IPSO Editors’ Code (Clause 1(2)) states: “distortion once recognised must be corrected, promptly and with due prominence, and – where appropriate – an apology published.”

Complain to IPSO 

If your official complaint is dismissed, you may want to complain to the regulator.

For publications this is usually IPSO; if a publication is not IPSO-regulated it will probably have a readers’ editor, ombudsman or panel. 

If an article contains significant misinformation about facts or the law, make a complaint under Clause 1 (Accuracy) of the IPSO Editors’ Code.

To complain as a representative group, explain: 

• which group you believe has been affected by the breach of the code
• how you are representative of that group
• how you believe the breach is significant 
• how you believe the public interest would be served by considering the complaint. IPSO’s complaints committee will then decide whether to take forward your complaint.

You can also complain to IPSO if you are the direct subject of an article or have been directly affected by the behaviour of a journalist.

Make a complaint 

Make an editorial complaint if you think an online article or broadcast programme has fallen below the standards set out in the BBC’s editorial guidelines. These include:

• Accuracy: The BBC must not knowingly and materially mislead its audiences. We should not distort known facts, present invented material as fact or otherwise undermine our audiences’ trust in our content.
• Impartiality: The BBC must scrutinise arguments, question consensus and hold power to account with consistency and due impartiality. This involves more than a simple matter of “balance” between opposing viewpoints. The BBC must be inclusive, considering the broad perspective and ensuring that the existence of a range of views is appropriately reflected. It does not require absolute neutrality on every issue or detachment from fundamental democratic principles, such as the right to vote, freedom of expression and the rule of law. It must not endorse campaigns, or allow itself to be used to campaign to change public policy.

If you make a complaint, it will get an initial response. 

If you are not happy with the response, you can ask for your complaint to be escalated to the next stage, which is getting a response from or on behalf of a BBC manager or a member of the editorial team. Don’t just repeat your initial complaint; engage with the substance of the reply that has been sent to you and point out why it is insufficient.

If you are still not happy, you can ask for your complaint to be considered by the Executive Complaints Unit. Again, point out why the response was insufficient.

If this process does not resolve your complaint, the final stage is to refer it to Ofcom – see Other TV or radio broadcast.

Make a complaint 

Write to the broadcaster referring to the part of its regulatory code you think it has breached. It may have its own code, or be regulated by the Ofcom Broadcasting Code.

For Ofcom, the key standards are:

• news must be reported with due accuracy and presented with due impartiality; significant mistakes should be acknowledged and corrected promptly
• factual programmes and portrayals of factual matters must not materially mislead the audience.

Ofcom will take into account, among other things:

• when the item was broadcast (before or after the watershed)
• the intended audience (children or adult, for example)
• any warnings and context
• editorial independence
• balance (not in each programme, but across a series, if relevant, or the broadcaster’s coverage as a whole). 
• the distinction between reporting on problematic material and presenting it as correct without challenge.

The clauses most likely to be relevant are: 2, 3, 5 and 7. Here are the relevant parts:

• Section 2 bars material that breaches “generally accepted standards” when it comes to offensive language and discriminatory treatment or language on grounds of sex, sexual orientation, gender reassignment and religion or belief. 
• Section 3 bars material that is likely to encourage or incite crime or disorder, including speech that is hateful or abusive concerning sex, gender reassignment and religion or belief.

Use these to complain about, for example, derogatory language (such as “TERF”) used by a presenter or guest if it goes unchallenged, or a show that unquestioningly presents those holding gender-critical beliefs as hateful or bigoted.

• Section 5 requires due impartiality, accuracy and balance between differing views and opinions, especially current debate about matters of public policy (but the balance is across all coverage, not each programme, and does not mean equal time, or that fringe views must be treated as on a level with mainstream ones). 

If a broadcaster or programme shows a pattern of giving gender-identity ideology significant prominence and ignoring opposing viewpoints, this could form the basis of a complaint.

• Section 7 says that broadcasters must avoid unjust or unfair treatment of individuals or organisations in programmes. They must not act unfairly when they present, disregard or omit facts; fail to offer someone an opportunity to contribute; portray facts, events, individuals or organisations; or refuse people an opportunity to respond to allegations.

If gender-critical voices were misrepresented or excluded, this could form the basis of a complaint.

Complain to Ofcom

If your official complaint is dismissed by the broadcaster, you may want to complain to Ofcom itself.

You can complain to Ofcom about broadcast media: use the guidance above to refer to the part of its regulatory code that you think has been breached. However, if your complaint is about the BBC you must complain to the BBC first.

Write to the publisher 

Email the editor, and if possible the journalist, explaining that this lack of clarity is likely to confuse readers or viewers, and attach our Media handbook. 

Make an official complaint 

IPSO does not consider misrepresenting a person’s sex to be a breach of the Editors’ Code (campaign group Fair Play For Women tried to change this in 2020).

But if the lack of clarity makes enough difference to the story that you think it breaches IPSO’s Editors’ code or Ofcom’s rules on accuracy, make an official complaint – write to the editor referring to the part of its regulatory code you think has been breached: 

• the Financial Times, Independent and Guardian have their own codes
• most other newspapers and magazines follow the IPSO Editors’ Code.

For IPSO, the clauses most likely to be relevant are: 

• Clause 1: Accuracy – “The Press must take care not to publish inaccurate, misleading or distorted information or images, including headlines not supported by the text.” 

It is inaccurate and misleading to call a man a woman, or to say that someone male is female or vice versa. Headlines such as “Woman charged with rape” are misleading, even if the text clarifies that the “woman” is in fact a trans-identifying male. 

• Clause 12: Discrimination – “The press must avoid prejudicial or pejorative reference to an individual’s race, colour, religion, sex, gender identity, sexual orientation or to any physical or mental illness or disability.” Note that this clause only relates to individuals. 

Describing an individual as bigoted, exclusionary or anti-trans because they hold “gender-critical” beliefs risks contravening this clause. 

The Editors’ Codebook gives further details about the clauses.

The IPSO Editors’ Code (Clause 1(2)) states: “distortion once recognised must be corrected, promptly and with due prominence, and – where appropriate – an apology published.”

Make an official complaint 

If the lack of clarity makes enough difference to the story that you think it breaches Ofcom’s rules on accuracy, make an official complaint – write to the broadcaster referring to the part of the Ofcom rules you think has been breached.

On its own, such language is unlikely to breach any codes, but there are actions you can take: 

1. For a print item, write a letter to the editor for publication or broadcast. 
2. Email the editor and if possible the journalist to explain the problem with the language used, and attach our Media handbook.
3. For a BBC item, if the language used results in unbalanced coverage, complain specifically about lack of impartiality.
4. If the lack of impartiality concerns you or a group you represent, also ask for a right of reply. 

If this was a bad enough misrepresentation of opinion to be a breach of the Editors’ Code, or BBC or Ofcom rules:

5. Make an official complaint to the outlet. 
6. If you are not happy with the response, escalate to the regulator (but remember that they do not police ordinary differences of opinion or stifle fair comment).

Send a letter to the editor for publication

If you disagree with an opinion piece or want to comment on a news story, submitting a letter to the editor for publication is a good way to turn a poorly reported or presented story into an opportunity to make better arguments in public. 

1. Write your letter as soon as possible after the item appears.
2. Keep it short – no longer than 300 words, and 150 words is better.
3. Make a single point clearly and forcefully rather than attempting to debunk an entire article.
4. Paste the text directly into the email. Do not send an attachment. 
5. Refer to the article you are responding to by title and date.
6. Avoid jargon, acronyms, insults and sarcasm. Make sure your letter is comprehensible to people who haven’t read the original article.
7. Include your name, address and telephone number – if you do not want some or all of these details to appear with your letter, say so. 
8. If you can, get a friend to proofread it before sending. 
9. Mark your email “Letter for publication”.
10. If your letter is published, share it on social media. If you would like Sex Matters to tweet it, send us a direct message or email [email protected].

Email addresses for letters pages of the main national papers:

• Daily Mail: [email protected]
• Express: [email protected]
• Financial Times: [email protected]
• Guardian: [email protected]
• Independent: [email protected]
• Mirror: [email protected] 
• Observer: [email protected]
• Standard: [email protected]
• Star: [email protected]
• Sun: [email protected]
• Sunday Telegraph: [email protected] 
• Sunday Times: [email protected] 
• Telegraph: [email protected] 
• The i: [email protected] 
• Times: [email protected]

What if your letter isn’t published? 

Don’t be disheartened: media outlets get many more letters than they publish. Treat unpublished letters as practice, and remember that all letters are read. If an outlet gets a lot of correspondence on an issue, it may reconsider its approach even if it does not publish those letters. You can also consider turning your letter into a blogpost or “open letter”, and publishing it online yourself. 

Make a complaint

If the language used results in unbalanced coverage, complain specifically about lack of impartiality. Email [email protected] for broadcast on the Feedback show on Radio 4.

If this was a bad enough misrepresentation of opinion to be a breach of the BBC’s editorial guidelines, make an official complaint. 

If you are not happy with the response, escalate to Ofcom (but remember that they do not police ordinary differences of opinion or stifle fair comment).

Ask for a right of reply

If the lack of impartiality concerns you or a group you represent, also ask for a right of reply – an article written in response to another. If your proposal is considered promising, the editor will probably agree to publish it in principle, and give you a word count and a deadline for submission. 

Your article is likely to be edited, perhaps heavily (don’t take this personally: even professional journalists are used to having their work completely rewritten). You should insist on signing off all changes, but don’t complain about stylistic tweaks or anything trivial, since this may lead to your article being dropped. Only refuse to accept changes that mean your article no longer makes your substantive points or misrepresents your position.

Journalists, editors and broadcasters have considerable editorial freedom. 

But even if you don’t think that a story has breached the relevant regulator’s code you can write to the outlet’s editor or the journalist, or both, to explain why you are concerned by particular language used in the story, and to give feedback. Attach a copy of our Media handbook.

Make your complaint as soon as possible after publication or transmission (there may be a time limit).

Say which clauses of the code your complaint refers to. 

Keep complaints as brief as possible and to the point – refer specifically to the relevant clause in the code. 

If you have requested a correction and been ignored or refused, include details of this correspondence.

Outline what you would like to be done to redress the situation. 

Give your name, address and phone number – the outlet should not share these: you are protected by the Data Protection Act.

If you have to complete an online form, keep a note of your complaint. 

Tell others. The more complaints made about a particular item, the more likely outlets are to rethink their approach to similar items in the future. You can share the item and your complaint on social media, along with a link to this guide.

Dear X 

I am writing about [article / programme], [published / broadcast] on [date]. 

I am concerned with the way it dealt with issues of sex and gender, in particular:  

[copy and paste the relevant issues]

Use of the expression “assigned at birth”	This phrase is scientifically inaccurate. In very rare cases (< 0.02%), there may be some doubt as to which sex a newborn baby is. In these cases further investigation may be required to see if the child has a DSD (difference, or disorder, of sex development). This investigation will also establish the child’s sex, since DSDs are sex-specific (that is, each condition affects only males, or only females).
The way the word “gender” was used	This word is sometimes used as a polite synonym for sex, but some people use it to indicate an inner sense of being a man or woman. Journalists should take care not to mix and match these meanings, for example using “gender” to mean the objective reality of sex and then switching without warning to mean a self-declared identity.
Use of the expression “gender identity” to describe a supposedly innate human characteristic	The idea that everyone has an innate gender identity, and that this is what decides who is a man, woman or non-binary, is neither scientifically sound nor universally held. Many people will not know what you mean by “gender identity”, and do not regard themselves as having one. Most people think that what makes a person a man or woman is their sex – an immutable biological characteristic.
Use of the word “cisgender” or “cis”	Cis and cisgender are neologisms for people who do not identify as trans. They are not neutral, impartial words, but part of a contested ideology which holds that everyone has a gender identity, which for “cis” people matches the sex of their body and for “trans” people does not.    Most people call themselves men or women on the basis of their sex, not their gender identity, and therefore do not think of themselves as “cis” or “cisgender”. Journalists should not use these words to describe people who do not use these words of themselves. To do so is to present those people as within a belief system they do not share – rather like calling an atheist a “heretic” or “apostate”, which suggests that they know God exists but reject him, rather than disbelieving in God altogether.
Use of phrases such as “used to be a man”, “transitioned from female to male” or “changed sex”	Since sex is binary and immutable for all mammals, including humans, these phrases are misleading. A male person cannot actually become a female, or vice versa.
Use of the word “intersex”	“Intersex” is an outdated and misleading umbrella term used to refer to people with differences, or disorders, of sex development (DSDs). Contrary to what the word suggests, these people are not somewhere between male or female. DSDs are around 40 distinct conditions that influence the development of the reproductive organs, and are sex-specific – that is, some affect only males and some affect only females.
Use of the words “transphobic” or “anti-trans”	The words “transphobic” or “anti-trans” are often used for people campaigning for women’s rights, or for sex-based rights more generally. But what motivates these campaigners is concern for everyone’s sex-based human rights, not animus for trans people. Using these words is not just inaccurate and insulting towards these campaigners; it harms trans people by implying that trans rights are incompatible with sex-based rights that command wide support.
Use of the expression “TERF” or “trans- exclusionary radical feminist”	Avoid this term for two reasons: it is inaccurate, and it is a slur.    Most people throughout history and around the world accept that people cannot change sex, no matter how they identify. But they aren’t radical feminists.    Moreover, the word is associated on social media with sexualised insults and threats of violence against women. No reputable media organisation should use it.
Reference to “hate speech”	“Hate speech” is not a legal concept and is not prohibited per se by UK law. There is no standalone offence of inciting hatred on grounds of transgender identity in England and Wales (although there are laws relating to incitement to hatred on grounds of race, religion and sexual orientation).
Use of phrases such as “cervix havers”, “uterus owners”, “chest feeders” or “bleeders” to refer to women and girls	It is offensive to describe half of humanity by reference to body parts and functions. Many women find this grossly offensive.    In many contexts these terms are exclusionary of people with low literacy or English as a second language, who may not know, for example, that they have a cervix, but know perfectly well that they are women.
Description of children as “trans”	Scientific evidence suggests that most trans-identified children become reconciled with their sex over time. There is no way to distinguish between children who will continue to identify as trans into adulthood, and those who won’t. This means the expression “trans children” is inaccurate and confusing. Your audience will incorrectly assume that this refers to children who are certain, or nearly certain, to identify as trans for the rest of their lives. It is better to follow the lead of Dr Hilary Cass, the eminent paediatrician commissioned to carry out a government review of child gender services in the NHS, and speak of “gender-confused and gender-distressed children”.
Reference to “trans inclusion” in sport	Whether trans-identified people can participate and compete in sport at every level is not at issue: they can, on exactly the same terms as everyone else. What is at issue is whether sport categories should be based on sex or self-declared gender identity. The phrase “trans inclusion” is therefore inaccurate. The question is whether male people are included in categories that are supposedly for female athletes only.
Lack of clarity about sex (where sex matters)	If sex or trans status is relevant to the story you should make this clear right at the start. It is your duty to ensure your audience has all the information it needs to evaluate the standpoint and contribution of every contributor or person quoted.
Transwomen’s voices taken as representative of women	This is not appropriate. If you are asking a transwoman for an opinion, remember this is someone who is male, not female. It is not the same as asking someone who is a woman. Avoid presenting transwomen’s achievements as if they are female people’s achievements, since that is inaccurate and misleading. A transwoman cannot be the “first self-made female billionaire” or “first female winner of a certain prize”, for example, because transwomen are by definition male, not female.
Suicide linked to “transphobia”; threats of suicide if children don’t transition	Journalists and editors should always remember that self-harm and suicidal ideation are known to be contagious. You should follow the Samaritans’ guidance, which says that the media should avoid attributing suicide to any one particular issue, or implying that people with certain characteristics are highly likely to kill themselves.  As a matter of fact, there is no evidence suggesting that “transphobia” plays any part in trans people’s suicides. Suicidality among trans-identified people is not disproportionate, considering other mental-health conditions known to be linked to trans identification.
Claims that trans people are at extremely heightened risk of being victims of crime.	There is no evidence of this.
Retroactive transition	It is not accurate or truthful to transition people retroactively.    If a man presented and self-described as such when he did something you are writing about – fathered children, founded a company, acted in a film, committed a crime, won a sporting competition – you will be confusing and misleading your audience if you use a name and pronouns he did not use at the time.
Discrimination excused or promoted	Journalists should not suggest that it is lawful to discriminate at work or in the provision of a service on the basis of what people believe, or don’t believe, about gender, since to do so would be inaccurate.

I am enclosing a copy of the media handbook produced by Sex Matters, which provides more detail about these issues. It explains when and why it is both reasonable and right to talk about people’s sex, and the harms that result if the media fail to do so. 

Yours sincerely…