Section 4
An example EDMF

Your organisation’s Ethical Decision-Making Framework for Communications should be tailored to its needs. You can create a standalone Ethical Decision-Making Framework for Communications or you can add your EDMF to your existing Communications Policy. Both approaches are compliant with ACFID’s Code of Conduct. The sections below are suggested elements to include in your EDMF.

Commitments

Section A:

Introduction

If you’re creating a standalone Ethical Decision-Making Framework for Communications, it’s useful to include an introduction. This could:

  • explain what an EDMF is and why you need one
  • outline the scope of the EDMF and who will be using it
  • provide an overview of your organisation’s values
  • provide links to other relevant policies

An example is provided below. This should be adapted to reflect the expectations and approaches taken by your organisation.

Example

At [organisation name], we aim to empower the communities we work with through our storytelling and communications content. We strive to empower and protect the people who share their stories with us. We are committed to depicting people and contexts authentically and truthfully. We value the importance of self-determination and are committed to working with all stakeholders in a way that upholds their dignity and respects their values, history, religion, language and culture.

Our vision is [vision]. We bring this vision to life by carefully protecting those who share their stories with us, and amplifying the benefits of sharing stories with our supporters and the general public.

[Organisation name] is a not-for-profit entity that [description of programming activities]. As part of our work, we share some important – yet difficult – stories. Sometimes our stories will show injustice and harsh realities. We, and the people we work with, know these are important stories for the world to hear. However, inherent in undertaking these activities is a level of risk in relation to sharing these stories.  

We acknowledge it can be difficult to put our values into practice when sharing stories – especially stories dealing with trauma and injustice. We can face conflicting demands when collecting and sharing stories, and we acknowledge it’s sometimes challenging to know exactly what ‘dignity’ and ‘empowerment’ mean in different cultural contexts. We also acknowledge that unconscious bias plays a huge part in decision making – however, by its very nature, it is difficult to address and mitigate the risks that it causes.

Misunderstanding cultural norms and mismanaging storytelling content can harm both the people we strive to support, as well as our organisation. For example, asylum seekers may be targeted for sharing stories about human rights abuses. Children may be targeted by people seeking to abuse them. The personal reputation and confidence of people who’ve shared their stories may be damaged if their stories are misused and they may face retribution from their community. Our organisation may suffer damage to our brand and reputation if we publish insensitive materials. These are just a few possible risks.

This EDMF is one element in a suite of tools to reduce these risks, as far as possible. We seek to prevent harm from occurring and this EDMF is a proactive means of mitigating those risks and supporting ethical decisions about our communications.

Purpose

This EDMF aims to ensure our communications content is of the highest ethical standard. This means all stakeholders are respected and protected, and trust in our organisational is maintained. The EDMF aims to ensure our organisation is using best-practice communications methods that minimise the risks related to storytelling and publishing.

Scope

This EDMF must be followed by everyone who collects and publishes stories at [organisation name], including all staff, volunteers, partner staff and governing body members. It includes our offices in Australia and in other countries managed by [organisation name]. The EDMF applies to visitors to our programs, and contractors and consultants such as freelance writers, designers, multimedia producers, fundraising consultants, partner organisations and other external parties using our stories, images, name or logo.

Our values

Everything our organisation does is built on our values. For our foundations to remain strong and for our actions to be ethical, we must continue to look to our values in our everyday work.

Ethical principles relating to the treatment of human beings are codified in a number of widely-accepted documents, such as the Nuremberg Code (1947), the United Nations’ Declaration of Human Rights (1948), the Declaration of Helsinki (1964), the Belmont Report (1979), and the United Nations’ Convention on the Elimination of All Forms of Discrimination Against Women (1979), Convention on the Rights of the Child (1989), Convention on the Rights of Persons with Disabilities (2007) and Declaration of the Rights of Indigenous People (2007).

At their core, these policies include the fundamental rights of human dignity, autonomy, protection, safety, maximisation of benefits and minimisation of harms. While originally stemming from biomedical and human rights contexts, these principles have been adapted beyond these early contexts and rise above disciplines and methodologies. We accept them as basic to any endeavour relating to storytelling ethics and they are explored in our EDMF.

[Organisation name’s] values underpin our approach to storytelling:

[List your organisation’s values and explain how they related to storytelling.]

Our values are aligned with the Australian Council for International Development’s Code of Conduct and our EDMF is connected to other [organisation name] policies, including:

  • Communications Policy
  • Image Policy
  • Child Safeguarding Policy
  • Privacy Policy
  • Risk Policy
  • Disability Policy
  • Gender Equality Policy
  • Staff Code of Conduct
  • Staff Selection and Recruitment Policy
  • Reconciliation Action Plan

Section B:

Our Ethical Decision-Making Framework

This section is the heart of your EDMF. It should explain who’s responsible for having the discussions outlined in the EDMF and at what point in the storytelling and publishing process they should occur. It should also include the topics and key questions that will be discussed and what to do if a decision can't be reached. We outline six key issues related to ethical storytelling that should be considered, but there may be others that are important to your organisation.

Making ethical decisions

This section introduces the concept of an Ethical Decision-Making Framework (EDMF) for Communications and explains its importance.

Example

Our Ethical Decision-Making Framework (EDMF) for Communications explains how to make ethical decisions when creating and publishing communications content. It uses a framework of structured discussions at ethically important moments during the storytelling process, with the aim of creating focused discussions that improve practice. It also aims to reduce risks associated with storytelling and protect contributors.

Ethical decisions can be very complex. When a situation has no clear ‘right and wrong’ answer, decision making can be difficult. Even more difficult is making ethical decisions when affected by unconscious biases. And everyone holds unconscious biases.

More than one set of cultural norms and organisational values can equally apply to an issue, even if those norms and values are conflicting. This makes decisions difficult, as individuals and teams are forced to choose.

This EDMF sets out important questions and explains when these questions ought to be asked throughout the storytelling process. It also explains who is responsible for having these discussions and what to do if a decision can’t be made.

Ambiguity and uncertainty are part of any ethical decision-making framework, and we encourage exploration of ethically grey areas. Indeed, this exploration is the most important part of the process. Our discussions help us to reach further outward, toward a fuller understanding of our contributors’ lives and contexts – and also of our own unconscious biases, norms and ways of working.

Risk assessment

This section contains an overview of your organisation’s risk assessment and explains how to apply it in your EDMF. The below is an example – yours should include detail specific to your organisation and refer to particular channels and audiences, depending on your organisation’s operations.

Example

In developing this EDMF, [organisation name] has considered the risks associated with all its communications activities and how they might impact on:

  • Contributors and the communities in which we work
  • Staff and volunteers across the organisation
  • Governing body
  • Our partners and contractors
  • Supporters and the general public
  • Overall activities of [organisation name]
  • The reputation of [organisation name] and other ACFID members

The following on-going risks have been identified:

  • [insert risks]

A more comprehensive communications risk log is updated as part of quarterly communications meetings and can be accessed here [link to relevant document].

This EDMF will be used to guide decision making across the organisation to help mitigate some of the risks mentioned above. It will be shared with partners who are involved in sourcing content for our communications materials, and training will be supplied where appropriate.

In addition, all of [Organisation name]’s communications activities related to humanitarian emergencies are considered high-risk and will therefore be subject to additional procedures outlined in the [Humanitarian Emergencies communications guidelines].

Who’s talking to whom?

This section explains who you are expecting to contribute to the conversations in your EDMF.

Example

While all staff, volunteers and members are responsible for ensuring our communications are ethical, lawful and protect contributors, some staff members will need to be involved in specific conversations as part of our EDMF. The staff involved in EDMF discussions are [list those positions as relevant to your organisation]:

Content gatherers: Including communications specialists, multimedia producers, writers and media relations staff, and their managers.

Programs: Including program staff and managers.

Child safeguarding: Including child safeguarding advisors and focal points.

Marketing: Including digital, marketing, fundraising and events, and their managers.

Ethically important moments

This section outlines the ‘ethically important’ moments in your storytelling process – i.e. when your EDMF might be used. It should explain which issues to discuss at these moments, and who’s responsible for discussing them. More information about each of the issues can be found in the next section, Key Ethical Issues.

Remember – the following is an example only. It’s up to your organisation to decide who is involved at each point in time and how this process might be adapted for different pieces of communications.

Example

While all ethical issues should be considered throughout the storytelling process, there are times when certain issues are more important. Below are seven ‘ethically important’ moments during the storytelling and publishing process, accompanied by key issues to discuss at those times and who’s responsible for the discussions.

1. When scoping a story

When:

  • Developing a storytelling concept
  • Scoping story leads
  • Writing a Terms of Reference

Issues to discuss:

  • Developing a storytelling concept
  • Scoping story leads
  • Writing a Terms of Reference

Who:

  • Developing a storytelling concept
  • Scoping story leads
  • Writing a Terms of Reference

 

2. When planning to gather content

WHEN:

  • Planning a content-gathering trip
  • Planning a phone/email/video interview
  • Sourcing content directly from program staff and contributors

ISSUES TO DISCUSS:

  • Informed consent
  • Fuzzy boundaries (using the Unconscious Bias Tool is helpful at this point)
  • Protection
  • Privacy

WHO:

  • Content gatherers
  • Programs
  • Child safeguarding

3. While gathering content

WHEN:

  • While on a content-gathering trip
  • While conducting an interview

ISSUES TO DISCUSS:

  • Informed consent
  • Fuzzy boundaries
  • Protection
  • Connection to values
  • Privacy
  • Authorship and ownership

WHO:

  • Content gatherers
  • Programs
  • Child safeguarding

 

4. Directly after gathering content

WHEN:

  • Directly after gathering content from the field or via an interview

ISSUES TO DISCUSS:

  • Informed consent
  • Fuzzy boundaries
  • Protection

WHO:

  • Content gatherers
  • Programs
  • Child safeguarding

 

5. While creating the storytelling content

WHEN:

  • While creating materials to publish, such as writing a story, editing videos/photos, and writing social media content

ISSUES TO DISCUSS:

  • Connection to values
  • Authorship and ownership
  • Fuzzy boundaries
  • < li style="position: relative; padding-left: 15px; margin-top: 8px;">Privacy

WHO:

  • Content gatherers
  • Programs
  • Marketing

 

6. When publishing a story

WHEN:

  • When publishing content on social media and via the website, print (such as DMs) and the news media

ISSUES TO DISCUSS:

  • Connection to values
  • Fuzzy boundaries (using the  Unconscious Bias Tool is helpful at this point)
  • Informed consent
  • Protection
  • Privacy
  • Authorship and ownership

WHO:

  • Marketing
  • Content gatherers
  • Child safeguarding

 

7. After publishing a story

WHEN:

  • Once a story is in the public domain

ISSUES TO DISCUSS:

  • Informed consent
  • Fuzzy boundaries 
  • Authorship and ownership

WHO:

  • Programs
  • Content gatherers
  • Marketing

 

Key ethical issues

This section explains the key ethical issues relating to your storytelling process and includes some questions to guide your discussion. Below are some example questions, however you may want to include other questions that are relevant to your context.

Example

There are six key ethical issues that are relevant for our storytelling and publishing process. Below are some questions to help us reflect on and discuss these issues as part of the decision-making process. Some of these questions may be easy to answer. Others might not have a clear answer and are best considered in conversations with others, as outlined above.

1. Connection to values

[Organisation name's] values

  • [insert questions directly related to how your organisation’s values affect your storytelling processes]

Human rights

  • Have we put the best interests of the contributor first?
  • Have we ensured we ‘do no harm’ to the contributor during the storytelling process?
  • Have we treated the contributor with dignity and fairness?
  • Have we respected the personal freedom and privacy of the contributor?
  • Have we encouraged the contributor to freely express their thoughts and feelings?
  • Have we given the contributor control over how their identity and thoughts are portrayed in their story?
  • Have we ensured the content is accurate?

Children's rights

  • Have we ensured the best interest of children have been put before the interests of adults and our organisation?
  • Have we adequately protected children?
  • Have we respected children’s rights to dignity and fairness?
  • Have we attempted to reduce stereotyping of children?
  • Have we treated all children equally?

Women's rights

  • Have we carefully considered how women are portrayed?
  • Have we considered how sex-role stereotyping is portrayed?
  • Have we given voice to women?
  • Are we empowering girls and women through this story?
  • Have we considered the unique protection needs of women in this story?

Disability rights

  • Have we given people with disabilities the opportunity to contribute to this story?
  • Have we considered how ableism has affected this story?
  • Have we carefully considered how people with a disability are portrayed?
  • When published, will this story be accessible to people with disabilities?

Indigenous rights

  • Have we respected indigenous people’s rights to dignity and fairness?
  • Have we given indigenous people the ability to freely express themselves, through their own culture and language?
  • Have we considered how racism has affected this story?
  • Have we carefully considered how indigenous people are portrayed?
  • Have we given indigenous people control over how their identity and thoughts are portrayed in their story?

2. Protection

[Organisation name] puts the wellbeing of its stakeholders first. We explain how we protect our stakeholders in our [Child Safeguarding Policy], [Image Policy], [Privacy Policy] and [Risk Policy]. All staff and stakeholders must uphold these policies. There are no exceptions. However, there are also context-related issues that arise in relation to protection. Our discussions should ask:

Protection of life

  • Could the contributor’s life be put at risk by sharing their story?
  • Do we know enough about the contributor’s history to make a confident assessment of their safety?

Protection of health

  • Could the contributor’s health be put at risk by sharing their story?
  • Could the contributor risk being cut off from important services by sharing their story?

Protection of dignity

  • Could we be putting the contributor or their community at risk of vilification or retribution by sharing their story?
  • Have we considered how the contributor’s family, friends and community might feel about the storytelling project?

3. Informed consent

[Organisation name’s] informed consent process is clearly defined in [policy name]. All staff and stakeholders must follow this process. There are no exceptions. However, there are also context-specific issues that arise in relation to informed consent. Our discussions should ask:

Correct information

  • Have we provided all the necessary information to the contributor so they can decide whether to consent to participate?
  • Have we shown the contributor appropriate examples of how their story might be used (including where it may be published and who will see it)?
  • Have we explained different ways the contributor’s identity can be revealed and concealed?
  • Have we consulted with the right people (including children’s guardians and community elders)?

Clear comprehension

  • Does the contributor fully understand the risks and opportunities associated with sharing and publishing their image and story with our organisation?
  • Have we given the contributor enough advance notice about the project so they have time to consider the risks and opportunities?
  • Have we explained the storytelling process in a way the contributor fully understands (including children), using the best-possible language?
  • Is there a single point of contact for the contributor to discuss the project and any consent issues? Is it easy for the contributor to discuss the project with us?

Voluntary consent

  • Is there a power imbalance between the contributor and the organisation?
  • If there is a power imbalance, can you describe it?
  • If there is a power imbalance, how can we reduce it?
  • Is there an element of duress in the contributor’s consent?
  • If there is an element of duress, how can we address it?
  • How can we ensure the contributor can say ‘no’ to being involved in the storytelling project?
  • How can we ensure the contributor can withdraw their consent at any time?

4. Privacy

[Organisation name] values and upholds the privacy of their contributors. All staff, governing body members, partners and volunteers must abide by our [Privacy Policy]. However, there are also context-related issues that arise in relation to privacy. Our discussions should ask:

Protection

  • Have we adequately protected the privacy of the contributor?
  • Have we discussed how the contributor’s story may expose them to the public?
  • If appropriate, have we adequately concealed the name, location and visual identity of the contributor?
     

Information storage

  • Have we safely and securely stored the contributor’s personal information?
  • Does the contributor understand how their personal information is stored and used?
     

Access to information

  • Who has access to the contributor’s information and are they aware of who can access it?
  • Have we explained how the contributor can access their personal information, make amendments to their story and withdraw consent?

5. Authorship and ownership

We respect the right of contributors to control their stories. We respect the right of contracted writers and photographers to moral ownership of their works. And we acknowledge that ownership and ‘control’ of stories can raise difficult ethical questions. While we always abide by our [Privacy Policy], there are some discussions that can help us understand our responsibilities regarding authorship. Our discussions should ask:

Authorship

  • How will contributors and content creators be acknowledged when publishing their stories?
  • Does acknowledgement of authorship have implications for the privacyanonymity or confidentiality assurances given to contributors?
  • What ethical obligations do contributors and content creators have to the truthful representation of stories and data?

Copyright

  • Who owns the copyright of our storytelling content?
  • Are there any conflicting copyright claims for storytelling materials we’ve published (or seek to publish)?
  • How do we ensure contributors and content creators understand their legal rights?

6. Fuzzy boundaries

We understand the storytelling process is built on relationships, and sometimes the network of relationships is complex. We acknowledge that relational boundaries between contributors, content collectors, program staff and others can become blurred. In addition, the stories they create may be used to serve multiple purposes, such as fundraising, advocacy, and community engagement. This blurring of roles and purposes is referred to as ‘fuzzy boundaries’.

We acknowledge there is the potential for the content-collector role to become blurred in storytelling processes that involve building rapport with contributors. We also acknowledge that this potential is intensified in storytelling projects where content collectors spend significant periods of time engaged in fieldwork. Our discussions should ask:

Content-creator responsibilities

  • How should we develop a relationship with the contributor?
  • Should we explore how our unconscious biases affects this project? How might we change the storytelling process as a result of exploring our unconscious biases?
  • What are the moral responsibilities that fall directly on the content collector?

Other people's responsibilities

  • What are the different roles of those involved in the storytelling project?
  • Does everyone in the project understand their role and others’ expectations of them?
  • How do different people involved in the project see the purpose of the storytelling project? If there are different perspectives, how do we manage any conflicts?

Blurred boundaries

  • How do we respect the personal relationships (and possible friendships) developed during the project?
  • How do we respond to any blurred roles and relationships during the course of the project?
  • What impacts do blurred roles have on the ethical conduct of the project?
  • Can content collectors, contributors or others become personally over-invested?

A few Golden Rules

You may want to create a few ‘golden rules’ to help your staff make ethical decisions.

Example

During the entire storytelling and publishing process, keep these three questions in mind:

1. If I share this story, will this person be safe?
2. If I share this story, will this person be empowered?
3. If I share this story, will this person feel respected – by themselves and others?

Who to talk to if you’re still unsure

This section of your EDMF should outline the process staff and volunteers can take if they are unable to come to a decision after discussing the questions above. This should include contact information for other staff members who have expertise in a certain area, and information on how to escalate an issue if needed.

Example

Making decisions about some of these issues can be difficult. There may be times when you or your team are still unsure whether an image, story or information should be used even after discussing the key issues and reviewing other policies and guidelines. If you have discussed the questions outlined above and need more information to make a decision:

Contact the following people:

  • Child safeguarding: [insert contact details]
  • Protecting identities:
  • Consent:
  • Authorship and ownership:
  • Privacy requirements:
  • [insert others as required]

If you have discussed the questions outlined above, have all the relevant information, but have not come to a decision, bring it to the attention of your manager.

The final decision on all communications materials lies with the CEO.

Section C:

Definitions

You may want to include definitions so your stakeholders clearly understand your EDMF.

Example

Content gatherer

Someone who documents a contributor’s story via photographs, videos, oral interviews and written testimony.

Content

What stories are made of. Content can include copy, images, sound, video and data.

Contributor

Someone who shares their storytelling content with an organisation that intends to publish their content. In the context of not-for-profit organisations, contributors are usually program participants, staff, volunteers and members.

Copy

Written words and numbers.

Cultural norms

Informal understandings of group conduct that govern the behaviour of members of a society.

Dignity

The feeling of having decision-making power, freedom and autonomy over life choices, together with the feeling of self-worth and self-confidence, and feeling that one has the respect of others.

Empowerment

Authority or power given to someone to do something.

Ethical decision-making framework

A structured series of questions and issues for consideration that help people make choices when they are faced with situations that require value judgements.

Ethical dilemma

A situation that has no clear right or wrong answer.

Images

Two-dimensional visual representations. Images include ‘still’ images such as photographs, artworks and illustrations, and ‘moving’ images such as videos, animations and GIFs.

Informed consent

When a contributor grants permission to publish their story with full knowledge of the possible consequences, including possible risks and benefits. Informed consent must be granted without duress.

Privacy

A person’s right to control access to their information and identity.

Publisher

A person or organisation that publishes stories using methods such as print, websites, social media, press releases etc.

Respect

Due regard for the feelings, wishes or rights of others.

Story

A story can include written, visual, verbal and data elements. These elements can exist alone or in a combination with other story elements.

Storytelling

The act of sharing stories.

Unconscious bias

A bias we are unaware of, and which happens outside of our control. It is a bias that happens automatically and is triggered by our brain making quick judgments and assessments of people and situations. It is influenced by our cultural environment and personal experiences.

Vicarious trauma

The inner transformation that occurs in the inner experience of the therapist [or other professional] that comes about as a result of empathic engagement with clients' trauma material. (Pearlman and Saakvitne, 1995)