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From Emails to Internal Chat: Applying the Communications Act 2003 to Workplace Harassment

Why this matters for screen sector businesses 

The CIISA Standards Framework makes it clear: screen sector businesses must comply with relevant UK law on harmful behaviours, including online harassment. This note explains what the Communications Act 2003 means in practice — and what production companies, studios, and other sector businesses should do about it. 

It covers: 

  • What counts as online harassment 

  • What the law says about offensive or threatening communications 

  • How common workplace tools (email, Slack, WhatsApp, etc.) can fall under the Act 

  • Practical steps to stay compliant and protect workers 

What is workplace harassment and how can it happen online? 

Harassment isn’t always loud or visible. In today’s working world, it can take the form of a private message, a passive-aggressive email, or a string of comments in a group chat. In law, harassment generally refers to behaviour that causes distress, alarm or humiliation, and when it happens online, it’s often harder to detect or challenge. 

In the screen sector, online harassment might involve: 

  • Sending or forwarding offensive messages 

  • Repeated late-night messaging about non-urgent work 

  • Inappropriate “banter” over group chats 

  • Spreading harmful rumours via email or text 

  • Using threatening or coercive language 

This behaviour can be especially damaging in an industry that relies heavily on freelancers, where many workers may feel they can’t speak up without risking future work. 

The Communications Act 2003...

...and what it Says 

Under Section 127 of the Communications Act 2003, it is a criminal offence to use a public electronic communications network to send: 

  • Grossly offensive, indecent, obscene, or menacing messages 

  • False information with the intent to cause annoyance, inconvenience, or needless anxiety 

This applies to emails, text messages, chat platforms, and social media, whether used inside or outside working hours. 

The Act doesn’t require that the message is sent directly to the person targeted, for example, forwarding a cruel or offensive comment about a colleague to others may still be caught. What matters is the content and the intent

How does this apply to the workplace? 

Many digital tools used by screen sector businesses (like email, WhatsApp, Microsoft Teams, and Slack) fall under the scope of the Act, because they operate over public electronic networks. 

Importantly, this law doesn’t just apply to employees, it applies to anyone using these platforms. That includes freelancers, contractors, casual workers, and others involved in a production or project. 

This means: 

  • Work messages can be criminal if their content breaches the Act 

  • Intent matters – even if you think it’s “just a joke,” if the result is harm or anxiety, the law may still apply 

  • Private messages between workers (e.g. via WhatsApp) can cause legal risks for the business if they relate to work or occur during production 

In short: if a message is grossly offensive, threatening, or intended to upset someone, it may be unlawful, even if sent from a personal device or outside of office hours. 

Compliance and best practice for screen sector businesses 

The CIISA Standards Framework (Standard 4: Responsive Learning Culture) expects businesses to learn from concerns raised about harmful behaviour, including concerns about inappropriate digital communication, and use that learning to improve their workplace culture and processes. 

This means that if someone raises concerns about harassing or offensive emails, chat messages, or other digital communications, businesses must: 

  • Take concerns seriously, even if raised informally 

  • Reflect on whether policies or team cultures contributed to the issue 

  • Implement improvements to prevent similar issues in future 

  • Encourage a culture where feedback leads to meaningful change 

Here’s what good practice looks like: 

 Set clear standards for digital behaviour 

Define what is and isn’t appropriate in written communications. Make it clear that offensive jokes, aggressive language, or personal comments will not be tolerated on any platform, work-related or not. 

Include these expectations in: 

  • Onboarding materials 

  • Production handbooks 

  • Crew or cast codes of conduct 

Update your anti-harassment policies 

Make sure your policies explicitly cover emails, messaging apps, and other digital platforms, including external platforms like WhatsApp or social media when used in a work context. 

Explain that: 

  • Harassment can happen online 

  • There are legal risks under the Communications Act 2003 

  • Workers can and should report offensive messages or patterns of behaviour

Give people safe ways to report concerns 

Workers may be unsure where to turn if harassment happens in a group chat or private message. Provide trusted, confidential route, ideally more than one, and clearly explain what will happen if a report is made. 

You could: 

  • Designate a digital safety lead 

  • Provide an anonymous reporting tool 

  • Train a trusted member of the production or management team to receive concerns 

Recommendations for screen sector businesses 

To comply with CIISA Standards and UK law, we suggest that screen sector businesses: 

  • Explicitly ban offensive or menacing messages in all work communications 

  • Include digital harassment in workplace policies, making sure everyone knows their rights and responsibilities 

  • Make rules clear to everyone, including freelancers, contractors and casual staff 

  • Provide accessible reporting routes and ensure staff know what happens when a report is made 

  • Train managers and team leaders to recognise online harassment and respond appropriately 

Final thoughts

The CIISA Standards expect the screen sector to comply with UK law, and the Communications Act 2003 is part of that legal landscape. Businesses don’t need to become legal experts, but they do need to: 

  • Understand what the law prohibits 

  • Put clear safeguards in place 

  • Create a culture where concerns about harmful communication are taken seriously, addressed appropriately, and used as a springboard for improvement 

By doing so, screen sector businesses can protect their teams, strengthen their productions, and build a more resilient and respectful creative environment. 

Last updated 07/05/2025

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