Interview Recording and Collection Management for UK Journalists

Why Interview Management Matters

Interview recordings sit at the heart of almost every journalism story, yet they are often the element of a journalist's workflow most casually managed. Poorly handled recordings generate two categories of risk: regulatory and legal.

On the regulatory side, IPSO receives thousands of complaints each year under Clause 1 (Accuracy). A disputed quote, a paraphrase that distorts meaning, or a factual error that a source claims was corrected before publication can all lead to formal complaints, upheld findings, and mandatory corrections. In serious cases, IPSO can require a publication to publish a correction with equivalent prominence to the original story.

On the legal side, interview recordings may become evidence in defamation proceedings, breach-of-confidence claims, or data subject access requests under UK GDPR. A journalist who cannot produce a recording to verify an accurate quote — or who has retained recordings longer than their stated purpose permits — is exposed in both directions. Robust interview management is therefore not an administrative nicety; it is a professional necessity.

Recording Consent in the UK: The One-Party Rule

Unlike the United States, where a number of states require all parties to a conversation to consent before it is recorded, England and Wales operate on a one-party consent basis. There is no statutory prohibition on a journalist recording a conversation to which they are themselves a party, without informing the other party. This applies to both face-to-face interviews and telephone calls where the journalist is a participant.

The key legal boundary lies at the point of interception. Under Section 1 of the Regulation of Investigatory Powers Act 2000 (RIPA), it is a criminal offence to intentionally intercept a communication in the course of transmission over a public telecommunications network without lawful authority. This means that a third party — including another journalist or an editor — who listens in on a phone call without the knowledge of either participant commits a criminal offence. Similarly, hacking into voicemail or intercepting messages in transit is unlawful under RIPA regardless of the public interest value of the information obtained.

In practice, the vast majority of professional journalist interviews are conducted openly, with the source aware they are being recorded. This not only aligns with NUJ ethics but also strengthens the probative value of the recording if it is ever needed as evidence. At the start of a recorded interview, it is good practice to state on the record the date, your name, the source's name, and that the source consents to being recorded. This simple step takes seconds and pays dividends if accuracy is later disputed.

Transcription Tools: Otter, Descript, MacWhisper

Transcription software has transformed the speed at which journalists can work with interview material. Three tools dominate professional workflows in 2026, each with different accuracy, privacy, and UK GDPR implications.

Otter.ai is a cloud-based platform offering real-time and post-recording transcription with speaker identification and searchable archives. Accuracy on clear recordings with standard accents is high, though heavy regional accents and specialist technical vocabulary require manual review. Because Otter processes audio on its servers, uploads constitute a transfer of personal data to a third-party processor. If your interview contains personal data — which most interviews do — you must ensure your use of Otter is covered by a valid data processing agreement under UK GDPR Article 28, and that data transferred to US servers is subject to appropriate transfer safeguards (Standard Contractual Clauses or equivalent).

Descript offers transcription combined with audio and video editing. Its “Overdub” and script-based editing tools are powerful for podcast and video production. Like Otter, it is cloud-based and carries the same UK GDPR data-transfer considerations. Descript's transcription is processed on its servers, so sensitive interviews involving confidential sources or special category data (health, ethnicity, religion, sexuality, criminal allegations) should not be uploaded without careful consideration of whether the public interest justification for journalism overrides the standard data minimisation principle.

MacWhisper runs OpenAI's Whisper model entirely on-device on Apple Silicon Macs. Because audio never leaves your machine, it sidesteps cloud data-transfer concerns entirely. Accuracy is comparable to cloud services on clear recordings. For journalists handling sensitive source material, confidential whistleblower interviews, or special category personal data, MacWhisper (or another local Whisper implementation) is the privacy-preserving default. The trade-off is speed: local processing is slower than cloud transcription for longer recordings, though current Apple Silicon chips handle most interview recordings in near-real time.

Regardless of which tool you use, always treat the transcript as a working draft requiring human verification. Proper nouns, technical terms, and spoken ambiguities are common transcription failure points. Never quote directly from an unverified transcript without cross-referencing with the audio.

Quote Accuracy and IPSO Clause 1

Clause 1 of the IPSO Editors' Code of Practice obliges publications to take care not to publish inaccurate, misleading, or distorted information, and to correct any significant inaccuracies promptly and with appropriate prominence. Quote accuracy is one of the most frequently litigated aspects of this obligation.

A direct quote — marked with quotation marks — carries an implicit representation that these are the words the subject actually used. Changing words within a direct quote, even if the meaning appears similar, can constitute inaccuracy under the Code if the subject disputes the wording and the original recording does not support the published version. This is one of the strongest arguments for recording every interview: the recording is the arbiter of what was actually said.

Paraphrasing is permissible and often preferable for clarity, but it must accurately reflect the substance of what was said. A paraphrase that subtly shifts emphasis, omits a qualification, or misrepresents the speaker's position can be just as inaccurate as a fabricated direct quote. When paraphrasing, err on the side of fidelity to the speaker's meaning, and retain the recording and transcript to demonstrate that fidelity if challenged.

Where a source contacts you after publication to assert that they were misquoted, you should immediately review your recording and transcript. If you made an error, correct it promptly under Clause 1. If your recording demonstrates the quote is accurate, document that fact and retain the evidence. IPSO investigations can occur months after publication; having your recording readily accessible is critical.

UK GDPR and Archive Retention

Interview recordings almost invariably contain personal data: the subject's voice, their personal views, and in many cases information about third parties. This makes them subject to UK GDPR and the Data Protection Act 2018 (DPA 2018).

The UK GDPR storage limitation principle (Article 5(1)(e)) requires that personal data is kept only for as long as necessary for the purpose for which it was collected. For journalists, this raises a practical tension: recordings are often retained indefinitely as a defence against future accuracy challenges, but indefinite retention is difficult to justify under storage limitation.

The ICO's guidance on journalism and data protection acknowledges this tension. It advises that journalistic organisations should have a clear retention schedule that specifies how long different categories of material are kept and the justification for each period. A reasonable approach for news organisations is to retain recordings for the duration of the relevant limitation period for defamation (one year from first publication) plus a margin, or longer where the story involves ongoing litigation or public interest that justifies continued retention.

Special category data — information revealing health, racial or ethnic origin, religious beliefs, sexual orientation, political opinions, criminal allegations, or trade union membership — attracts heightened protection under UK GDPR Article 9. Recordings that contain such information require a specific lawful basis for processing. For journalists, the relevant gateway is DPA 2018, Schedule 2, Para 26, which provides an exemption from several UK GDPR provisions (including some subject access rights and the requirement to notify data subjects) where the processing is for journalistic, academic, artistic, or literary purposes, and where compliance with the exempted provisions would be incompatible with those purposes.

Secure Storage for Sensitive Interviews

The security requirements for interview recordings vary with their sensitivity. A recorded press conference with a public official carries minimal security risk. A recording of a confidential source alleging corporate wrongdoing demands the highest level of protection your infrastructure allows.

At a minimum, recordings containing personal data should be stored in encrypted form. On macOS and Windows, full-disk encryption (FileVault and BitLocker respectively) provides baseline protection for locally stored files. For cloud storage, use services that offer zero-knowledge encryption or apply your own encryption layer before upload. End-to-end encrypted storage platforms such as Proton Drive provide stronger protection than standard cloud services for sensitive material.

For recordings involving confidential sources — particularly whistleblowers or sources at risk of retaliation — the NUJ advises that you consider whether the recording itself should exist in a permanent form at all. In extreme cases, the most secure storage is no storage: listen back, take written notes of what you need, and then securely delete the recording. If you do retain such recordings, access should be restricted to those with a genuine need to know, and the file should not be stored in any system accessible to IT administrators or cloud backup services that could be subject to legal process.

Signal is the NUJ's recommended platform for source communications. Its disappearing message feature means that if a source has consented to a message conversation being used in your notes, you can set a deletion timer that limits the exposure window. However, Signal is a communications tool, not an archive; do not use it as your primary storage system for interview material.

Organising Your Archive

A well-organised archive is the foundation of effective interview management. The goal is simple: when a complaint, legal challenge, or follow-up story arises months or years after publication, you should be able to locate the relevant recording, transcript, and notes within minutes.

A consistent folder structure eliminates ambiguity. One approach that works well for most journalists is a top-level organisation by year / publication or outlet / story slug, with subfolders for audio, transcripts, notes, and correspondence. Each interview recording should be named with a consistent format: YYYY-MM-DD_surname-firstname_topic.ext. This makes chronological sorting automatic and prevents the accumulation of files named “recording_final2_actual_FINAL.mp3.”

Metadata tagging adds a further layer of searchability. Applications such as Apple Photos, Adobe Bridge, or dedicated document management systems allow you to tag audio and text files with keywords. Tagging by source name (using a codename where appropriate for confidentiality), topic, story slug, and date makes full-text search across your archive possible without relying solely on file names or folder structure.

For freelance journalists working across multiple publications, a separate client or outlet tag helps when assessing retention obligations, since different publishers may have different retention policies, and some may hold copyright in recordings made in the course of employment.

Off the Record, Background, and Embargo

The terms off the record, on background, and embargo are used inconsistently across the industry. The NUJ does not prescribe a single binding definition, but it does require that journalists honour agreements made with sources. Misunderstandings about these terms are a significant source of disputes, damaged relationships, and potential legal liability.

Off the record conventionally means that information provided cannot be published, attributed, or used in any form that might lead to the source being identified. Some sources use the term to mean simply that they do not wish to be named, but are content for the information to be used as background. Never assume: always clarify at the outset of a conversation exactly what the source means and confirm the agreement explicitly before they continue.

Background (or “on background”) typically means that information can be used and published but without attribution to the source. The journalist may attribute it to a generic description such as “a senior government official” or “a source familiar with the matter.” Again, clarify the meaning before proceeding.

Embargoes are agreements not to publish information before a specified time or date. They are not legally enforceable contracts in most circumstances — a journalist who breaks an embargo is not committing a legal offence — but breaking an embargo without a compelling public interest justification will typically result in loss of access and reputational damage within the industry. The NUJ expects members to honour embargoes they have accepted.

When an interview contains a mix of on-the-record and off-the-record material, note this clearly in your transcript with bracketed annotations at each transition. A recording that is not annotated becomes difficult to use safely after time has passed.

Handling Post-Publication Disputes Over Quotes

When a source contacts you after publication to dispute a quote, the handling of that dispute is itself a professional test. Resist the impulse to be defensive. Listen carefully to what they are actually claiming: are they saying the words are wrong, that the words are accurate but the context has been stripped, or that they said it off the record?

If you have a clear recording that supports the published quote, locate it immediately and listen back. If the recording confirms the published wording, say so in writing to the source, indicating that you retain the recording. If the source wishes to escalate to an IPSO complaint, your recording will be central evidence. IPSO investigators expect to see primary source material, including recordings and transcripts, when adjudicating accuracy disputes.

If the recording reveals that you did make an error — a misheard word, a transposed phrase — acknowledge it promptly. Under IPSO Clause 1, you are obliged to correct significant inaccuracies swiftly and with appropriate prominence. A correction published the next day is far better for your professional reputation than one forced by an upheld IPSO adjudication weeks later. Document your correction process, including when you became aware of the error, when you notified your editor, and when the correction was published or broadcast.

In cases where a source claims a quote was given off the record or under embargo, check your contemporaneous notes and any written communication from before or during the interview. Good practice means that any off-the-record agreement is noted in your transcript or notebook at the point it is made. If you cannot demonstrate such an agreement existed, you are in a difficult position. Prevention — clarifying terms explicitly at the start — is far preferable to managing the dispute afterwards.

Source Protection Through Records Management

Source protection is a journalistic obligation recognised in UK law, the NUJ Code, and international press freedom standards. But records management is one of its least-discussed dimensions. If you are compelled by a court order to disclose interview material, the question of what you actually hold becomes critical. Material you do not hold cannot be disclosed.

The Contempt of Court Act 1981, s.10 provides some protection for journalistic source material, allowing courts to order disclosure only where it is necessary for national security, the prevention of disorder or crime, or the interests of justice. This is a meaningful — but not absolute — protection. Police and prosecutors have in the past sought production orders under Schedule 1 of the Police and Criminal Evidence Act 1984 (PACE) to compel disclosure of journalistic material. Whether such an order is challenged successfully depends partly on the strength of the public interest argument and partly on the sensitivity of the material sought.

The practical implication for records management is this: for confidential sources where disclosure would put the source at risk, consider carefully whether material needs to exist in a form that could be subject to a production order. Encrypted local storage is far harder to compel than cloud-hosted material. Recordings that have been deleted in line with a documented retention schedule cannot be produced. Material on a journalist's personal device stored in an end-to-end encrypted environment presents greater practical obstacles to disclosure than material stored on a publication's server network.

None of this means destroying material to obstruct legal process — that itself would be a criminal offence. It means building records management practices that minimise the volume of sensitive source material you hold beyond its functional purpose, so that when legal pressure arrives, you have the minimum possible material at risk. For detailed guidance on source protection legal risks, see the NUJ Source Protection Guide.

Phone, Video Call, and Messaging App Interviews

The majority of journalist interviews now take place remotely, via phone, video call (Zoom, Teams, Google Meet), or messaging platforms. Each medium raises distinct recording and consent considerations.

For phone interviews, the one-party consent rule applies as described above. Many journalists use a secondary recording device placed near the phone speaker, or a dedicated call-recording app. Review the terms of service for your phone provider and any app you use; some platforms prohibit recording in their terms even where it is legally permissible. The audio quality of phone recordings is often lower than face-to-face recordings, which increases transcription error rates and the importance of human verification.

For video call interviews, most platforms offer built-in recording functionality, but this typically notifies all participants that recording is in progress. This is both an advantage (explicit consent is documented) and sometimes a disadvantage (sources who are willing to speak candidly by video may be less forthcoming once they are formally on the record). Where a platform does not offer built-in recording, screen-recording software can capture the session — but again, the ethical question of disclosure applies.

For messaging app interviews (WhatsApp, Signal, Telegram), the conversation itself constitutes a written record. Screenshots are a common form of evidence but carry risks: they can be edited, they do not capture the full thread context, and they raise questions about whether the source consented to their messages being used as quotes. Always treat a messaging app conversation as a source record, store it securely, and seek explicit permission before publishing verbatim messages as quotes.

The UK GDPR data processing considerations that apply to audio recordings apply equally to recorded video calls and saved message threads. A Zoom recording stored on Zoom's cloud is a third-party data transfer; a WhatsApp thread containing personal data is personal data in scope of your UK GDPR obligations as a controller.

Practical Checklist

Use this checklist for every recorded interview:

• Stated on the recording: date, names, and that the source consents to being recorded
• Clarified and documented any off-the-record, background, or embargoed portions before they were spoken
• Chosen an appropriate transcription method — local (MacWhisper) for sensitive material, cloud only where no special category data is involved
• Verified all direct quotes against the recording before publication
• Annotated transcript with on/off-the-record transitions clearly marked
• Stored recording in encrypted storage with file name following consistent naming convention
• Tagged file with source codename (if sensitive), topic, outlet, and story slug
• Noted the retention review date in line with your publication's retention schedule
• For confidential source recordings: restricted access and considered whether permanent retention is necessary

Managing Pre-Interview Research and Background Notes

The records you assemble before an interview — background research, previous interview transcripts, public statements, company filings, correspondence — are as much part of your interview archive as the recording itself. These materials provide the context against which the interview can be understood, verify or contradict claims made during the interview, and serve as evidence of the due diligence you undertook when preparing.

Maintain a consistent approach to pre-interview documentation. Before significant interviews, create a research folder that contains the source's public statements, any previous coverage, relevant official records, and your list of prepared questions. After the interview, add the recording, transcript, and your contemporaneous notes. This creates a single coherent record for each interview that is self-contained and easy to locate.

Pre-interview correspondence — emails arranging the interview, confirming the subject matter, or addressing logistical details — should be retained alongside the interview record. Where a source later claims they were misled about the purpose or scope of an interview, the correspondence record is your primary defence. Never delete this correspondence during the active life of a story.

Research notes that contain the personal data of third parties — information about people who are not the subject of the interview but who are mentioned in the research — are subject to UK GDPR in the same way as interview recordings. Apply the same retention and security standards to all personal data in your archive, not just to the primary interview recording.

Managing Long-Running Interview Series and Longitudinal Projects

Investigative and feature journalism often involves multiple interviews with the same source over months or years. Long-running projects introduce specific records management challenges: maintaining consistency of reference across a large archive, managing evolving off-the-record agreements as a relationship develops, and ensuring that older material is reviewed when circumstances change.

When a source who has been interviewed repeatedly changes their position — retracting a previously on-the-record statement, moving previously background information to the record, or requesting that earlier recordings not be used — you face a complex set of journalistic and legal questions. In general, a source cannot retrospectively withdraw consent to use material that was properly obtained and agreed at the time. A statement made on the record in a recorded interview belongs to the journalistic record; a subsequent request to treat it as off the record has no legal force, though it may create ethical considerations depending on the circumstances.

For longitudinal projects involving vulnerable sources — people in difficult personal circumstances, sources who have been through significant life changes, or sources whose situation at the time of earlier interviews was substantially different from their current position — revisit the original consent and consider whether the material is still appropriate to use in the form originally planned. This is not a legal obligation but an ethical one.

• Version control for long-running transcripts: When you return to a long-running project and add new interview material, version-control your transcripts. Clearly label each version with the date of the session it covers, and do not overwrite earlier versions with new additions. The chronology of what was said when matters for accuracy and potential legal proceedings.
• Informed consent refresher: Where a significant period has passed since initial consent was given — particularly in documentary or book projects that may take several years to complete — consider whether to refresh the source's consent at the point of publication. Circumstances change; a source who consented to being named in a report three years ago may now face risks they did not anticipate. A brief conversation to confirm that they remain content with the agreed use of their material is good practice.
• Retention in ongoing projects: For projects that are ongoing, the UK GDPR storage limitation principle is interpreted in light of the active journalistic purpose. Material held as part of an active investigation for which publication is anticipated in the foreseeable future can reasonably be retained for the life of the project, provided it is held securely and access is appropriately restricted.

Ethics of Ambush and Doorstep Interviews

Ambush journalism — approaching a subject without advance warning, typically in a public space — is a legitimate investigative technique in specific circumstances but carries significant ethical and legal risks that must be carefully weighed. The NUJ Code requires that only fair and honest means are used to obtain information, and the IPSO Code's Clause 4 requires that journalists not pursue individuals in a manner that could reasonably be described as harassment.

A doorstep interview or public ambush is generally justifiable where: the subject is a public figure who has declined to engage by conventional means; the subject matter is one of genuine public interest; the ambush is conducted in a public place; and the approach is firm but not physically intimidating or designed to cause distress. It is not justifiable as a first resort when conventional interview requests have not been made, or where the subject is a private individual who is not in a public role.

Recording a doorstep interview raises the same consent questions as any covert recording. In public spaces, there is generally no legal prohibition on recording what occurs there, but you should be aware that the subject is unlikely to have consented, and that the material should be used only if there is clear public interest justification for the approach. Document your reasoning contemporaneously: note why the ambush was judged necessary, what attempts to engage by other means were made, and who in your editorial chain approved the approach.

• Private property: Approaching a subject on private property without consent risks trespass. Even in situations of clear public interest, the legal exposure of approaching someone at their home or business without invitation is real. Seek editorial and legal advice before any approach on private property.
• Filming in public: In England and Wales, there is no general right to photograph or film in public spaces, but in practice the default position is that photography and filming in public is lawful unless a specific restriction applies (security areas, court precincts, etc.). You do not need to obtain the consent of people in a public place to photograph or film them, but context and editorial judgement govern whether and how to use such material.
• Retention of doorstep recordings: Retain doorstep recordings and any footage with the same care as interview recordings. Where a doorstep approach becomes controversial — if the subject makes a complaint or the coverage is challenged — the original footage may be needed to establish what was said and how the encounter unfolded.

Common Mistakes

• Quoting directly from an unverified transcript: Transcription software makes errors, particularly on proper nouns, technical terms, and overlapping speech. Always cross-reference with the audio before using direct quotes.
• Uploading sensitive interviews to cloud transcription services: Special category data and confidential source material should not be uploaded to cloud services without a valid Article 28 data processing agreement and appropriate transfer safeguards.
• Failing to clarify off-the-record terms at the start: Never assume that “off the record” means the same thing to the source as it does to you. Define terms explicitly and confirm them before sensitive information is shared.
• Indefinite retention without a schedule: Keeping recordings forever creates ongoing UK GDPR liability and can complicate data subject access requests. Establish a retention schedule and apply it consistently.
• Poor file naming and folder organisation: Recordings named with default device names or timestamps alone become impossible to locate under time pressure. A consistent naming convention costs nothing and saves considerable time.
• Assuming covert recording is ethically straightforward: Legal permissibility does not equal ethical permissibility. The NUJ expects journalists to apply the highest ethical standards, including in their recording practices. Covert recording should require editorial sign-off.
• Neglecting to record right-of-reply contact: For IPSO and defamation purposes, document all attempts to put allegations to subjects, including when you made contact, what you asked, and the response received. This forms part of the evidentiary record, not just the recording itself.

AI Transcription Accuracy: What Journalists Need to Know

The rapid improvement in AI-powered speech recognition has made automatic transcription an essential part of many journalists' workflows. However, understanding the specific failure modes of these systems is essential before trusting them for professional purposes. No commercially available AI transcription service achieves 100% accuracy, and the errors they make are not random — they cluster in ways that carry particular risks for journalism.

Named entity errors are among the most dangerous. AI transcription systems will confidently substitute a similar-sounding common word for an unfamiliar proper noun — a councillor's name, a company name, a place name — and the substitution often reads plausibly in context. A source discussing “the Whitmore contract” may be transcribed as discussing “the Whitmore contact” or “the Wetmore contract.” These errors pass a casual reading and can introduce inaccuracies directly into published copy.

Negation errors are particularly serious. A transcription system that mishears “we did not agree” as “we did agree” can invert a source's position entirely. Short function words are precisely where AI transcription fails most often on clear audio. Always listen back to key claim passages rather than relying solely on the transcript.

Speaker attribution errors occur when multiple speakers are present. Most AI systems offer speaker diarisation (labelling who said what), but it is imperfect, particularly where speakers have similar vocal qualities, where there is crosstalk, or where the recording quality is poor. Misattributing a quote from one speaker to another can create serious accuracy problems if the two parties hold different positions. Always verify speaker attribution against the audio where it matters.

For dialect and accent recognition, AI transcription systems generally perform better on Received Pronunciation and standard American English than on regional UK accents, non-native English speakers, or speakers with speech differences. Journalists covering communities outside the standard demographic profile of AI training data should apply particular caution. The gap in accuracy between RP speakers and speakers of Scottish, Welsh, Northern Irish, Black British, or other regional varieties of English is a real equity issue in the use of these tools for journalism.

• Quality assurance workflow: Treat AI transcription output as a first draft requiring substantive review, not a final record. The minimum quality assurance step is to read the transcript while listening to the audio at 1x speed for all sections you intend to quote directly.
• Training on your sources: Some transcription platforms (including Otter and Descript) allow you to train speaker recognition on specific voices. If you conduct repeated interviews with the same sources, investing time in voice training can improve accuracy significantly for those individuals.
• Documenting your QA process: If an IPSO complaint arises about a quote, being able to demonstrate that you verified the transcript against the audio — and noting when and how you did so — strengthens your position considerably. Keep a simple log of transcript review for significant pieces.

Right of Reply and Pre-Publication Contact

IPSO Clause 1 and good journalistic practice both require that where a story contains serious allegations about an individual or organisation, that individual or organisation is given a reasonable opportunity to respond before publication. The right of reply is both an ethical obligation and a practical safeguard: a denial, correction, or contextual response obtained before publication can prevent an inaccuracy from appearing in the first place.

The right of reply process generates its own records that should be managed alongside interview recordings. Document every approach made to a subject for comment: the date and time of contact, the channel used (email, phone, letter), the specific allegations or questions put, and any response received. If a subject declines to comment or fails to respond within the deadline, document that too. This contemporaneous record is essential if an IPSO complaint or defamation action arises after publication.

Right of reply contact is not the same as an interview, but recordings of phone conversations in which right-of-reply contact is made should be treated with the same care as interview recordings. If the subject makes statements in the course of a right of reply conversation that are themselves newsworthy, these should be recorded and documented with the same rigour. Never paraphrase a denial or response to serious allegations without verifying the precise wording against a recording or contemporaneous note.

For stories involving criminal allegations, ongoing legal proceedings, or sensitive personal information, the right of reply must be particularly carefully managed. Seek your legal team's advice before approaching the subject of such a story. The letter or email putting allegations is itself a legal document that may become relevant in subsequent proceedings. Draft it carefully, put only verifiable allegations, and allow a reasonable time for response.

Broadcast Interview Considerations and Ofcom

Journalists working in broadcast — radio, television, online video — face additional regulatory considerations when recording and using interview material. Ofcom's Broadcasting Code applies to licensed broadcasters and sets standards for accuracy, due impartiality, and the handling of contributors that go beyond the IPSO framework applicable to print and digital journalists.

Under the Ofcom Broadcasting Code, broadcasters must ensure that contributors to programmes are not misled about the nature or purpose of the programme or interview. They must obtain consent before broadcasting material, particularly material that was recorded without the contributor's knowledge. The Code also sets specific requirements around the editing of interview material: edits that materially change the meaning or fairness of what a contributor said are prohibited.

For digital journalists who produce video content for online platforms — YouTube, TikTok, social media — Ofcom does not directly regulate unless the platform or channel has a broadcast licence. However, the ASA's online advertising rules and IPSO's accuracy obligations still apply to online-only video journalism. Journalists who move between broadcast and digital contexts need to maintain awareness of which regulatory framework governs each piece of content.

• Contributor consent forms: Broadcast journalists typically use standard contributor consent forms that specify what the recording will be used for, whether the contributor will be named, and how the material may be repurposed across different platforms. These forms should be retained for the same period as the recording itself.
• Children and vulnerable contributors: Ofcom and IPSO impose additional obligations when interviewing minors or vulnerable adults. The Broadcasting Code requires that due care is taken over the welfare of contributors who may be under 18 or in vulnerable circumstances. Parental consent is required for broadcast interviews with children in most circumstances.
• Archive broadcast material: Historical interview recordings held in broadcaster archives may be subject to different consent frameworks than those obtained under current practice. If repurposing archived material, check whether the original consent covered the proposed new use.

Building Interview Policies for Newsrooms

Individual journalists managing their own interview records is necessary but not sufficient. Publications and broadcasters that take their regulatory obligations seriously will have formal interview recording and retention policies that set consistent standards across all journalists, staff and freelance. These policies serve multiple functions: they demonstrate compliance with UK GDPR accountability requirements, they protect the organisation in IPSO complaints and legal proceedings, and they protect individual journalists who might otherwise face inconsistent expectations.

A well-designed newsroom interview policy will address: the requirement to record significant interviews (with guidance on what counts as “significant”); the consent procedure to be followed at the start of each recording; the approved transcription tools and the circumstances in which each may be used; the retention schedule for different categories of interview material; the security requirements for storage; the procedure for managing data subject access requests relating to interview recordings; and the process for secure deletion of material that has reached its retention end date.

For freelance journalists, a personal version of such a policy — documented and applied consistently — serves the same function. The ICO expects data controllers (which includes individual freelance journalists who process personal data in the course of their work) to be able to demonstrate their data protection practices. A written personal data policy, even a brief one, is evidence of that accountability.

• Training: Policies are only effective if the journalists they apply to understand them. Newsrooms should include interview recording and retention policy in their induction programmes and provide refresher training when the policy is updated or when significant legal changes occur (such as the UK GDPR coming into force in 2018, or significant ICO or IPSO guidance being issued).
• Policy review: Designate a policy owner — typically the legal or editorial standards team — responsible for reviewing the interview recording policy at least annually and updating it in response to regulatory changes, significant IPSO adjudications, or court decisions affecting journalistic material.
• Freelance onboarding: When commissioning freelance journalists, share the publication's interview recording policy and ask them to confirm they will apply it to work produced for the publication. This is part of meeting your UK GDPR obligations as a controller where the freelance is acting as a data processor on your behalf.

Primary Sources

• Regulation of Investigatory Powers Act 2000 — legislation.gov.uk; s.1 covers phone interception offences
• NUJ Code of Conduct — ethical obligations including on recording, sources, and honesty
• IPSO Editors' Code of Practice — Clause 1 Accuracy obligations
• ICO UK GDPR Guidance and Resources — including journalism and data protection guidance
• Data Protection Act 2018, Schedule 2 — Para 26 journalistic exemption
• Otter.ai — cloud transcription platform
• Descript — cloud transcription and audio/video editing platform