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
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.
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.
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.
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:
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
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
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
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
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.