Annual Review 2010/11

Effective governance is at the heart of everything we do. The Board is committed to maintaining high standards of accountability, transparency and probity within the framework of the Four Commercial Criteria (see below). Protecting the reputation of the BBC and ensuring that we continue to deliver sustainable returns, while providing the BBC and the wider UK creative community with an internationally recognised export platform, are fundamental to our purpose.

During the year we have made some changes as we continue our progress towards full compliance with the UK Corporate Governance Code. As a wholly owned subsidiary of a public body there are inevitably some departures from the Code which are explained within the report; for example, the requirement to hold an annual general meeting. It is also our aim to explain not only the extent of our compliance with the UK Corporate Governance Code, but also our approach to all commercial governance activities.

Robert Webb QC

Chairman, BBC Worldwide

Relationship with the BBC, our shareholder

BBC Worldwide is the principal commercial subsidiary of the BBC and has a first-look agreement relating to BBC in-house production. This gives BBC Worldwide the first opportunity to bid for commercial rights in BBC programmes. All negotiations are held on an arm's-length basis with the BBC's Commercial Agency which represents the BBC's interests. The Commercial Agency is free to, and often does, reject BBC Worldwide's purchase offer if better terms can be secured elsewhere. In addition, a proportion of BBC programme rights do not fall within the first look and are offered on the open market, providing an external benchmark.

While BBC Worldwide operates as a separate company, we follow the principles set out in the BBC Royal Charter and Agreement and the Trust Protocol C4 - Commercial Services (May 2010) and the BBC Trust's Commercial Review (November 2009).

In particular, BBC Worldwide must comply with the Four Commercial Criteria (4CC), which stem from the BBC Royal Charter and Agreement, requiring all the BBC's commercial activities to:

• Be commercially efficient.
  
  
• Fit with the BBC's Public Purposes.
  
  
• Not jeopardise the good reputation of the BBC or the value of the BBC brand.
  
  
• Comply with BBC Fair Trading Guidelines and the requirement not to distort the market.

The BBC Trust's Commercial Review proposed that the current requirement for BBC Worldwide to "fit with the BBC's public purposes" should be supplemented with an additional assessment around being "consistent" with them. There are a number of formal and informal arrangements that enable information to be cascaded to both the BBC Trust and BBC Executive.

As a wholly owned subsidiary of the BBC, there is no requirement for the Directors to seek annual re-election; nor do we hold a formal annual general meeting. The company is required to present an annual review of performance to both the BBC Trust and the BBC Executive.

4CC and Fair Trading framework

The 4CC approvals framework embedded within BBC Worldwide's governance structure ensures that key projects and investments are subject to rigorous evaluation, ensuring compliance with each of the 4CC prior to completion or launch. In addition, a 4CC Compliance Report is submitted annually to the BBC Executive Board and the BBC Trust.

BBC Fair Trading arrangements have been accredited with the ISO 9001:2008 quality standard. In December 2010, the British Standards Institute confirmed that these procedures were continuing to operate effectively. The BBC Trust commissions independent auditors, currently Deloitte, to undertake an annual Fair Trading Audit. In its report published in June 2010, Deloitte did not identify any specific Fair Trading audit risks in relation to BBC Worldwide for the year ended 31 March 2010. Further details of the audit and opinion can be found in the BBC Annual Report and Accounts for 2010/11.

BBC Worldwide's governance framework
1. Leadership

Role of the Board

The Board is responsible for setting the strategic objectives for the company and for monitoring progress against those objectives. The Board reviews both business and financial performance with a view to ensuring that the company has sufficient resources to execute the strategy effectively. The Board is accountable to the BBC in terms of delivering financial performance and protecting the longer-term financial return in the form of dividends. The Investment Guidelines (the company's policies for approving investment and expenditure) provide the framework for controlling the governance processes and providing clearly delegated authorities and robust processes.

The Chairman and Chief Executive

There is a clear separation of the roles of the Chairman and the Chief Executive, which is set out in writing and has been adopted by the Board. A copy can be found on the BBC Worldwide website. The Chairman's principal role is to lead the Board and to ensure that it works effectively and through its various committees. The Chairman is also responsible for setting the Board agenda and promoting a culture of healthy debate and challenge. The Chairman is also required to sit on the BBC Executive Board as a Non-executive Director.

Robert Webb, our Chairman, is thus a Non-executive Director on the BBC Executive Board. The Chairman has a fixed term of appointment until 31 December 2012 as Chairman of BBC Worldwide which may be extended by mutual agreement subject to the consent of the Director-General of the BBC. The terms of the employment contracts for the Chief Executive and Chief Financial Officer are set out in the Remuneration Report.

Non-executive Directors

The independent Non-executive Directors serve initially for a term of two years which may be extended subject to satisfactory performance and agreement from the shareholder. The two public service Non-executive Directors, Nicholas Eldred and Zarin Patel, are our shareholder's nominees on the BBC Worldwide Board. Neither Nicholas Eldred nor Zarin Patel has a fixed term appointment; however, both appointments may be replaced at any time by the shareholder. The Board has not appointed a senior independent Non-executive Director.

Independence

The Board considers each of the Non-executive Directors to be independent in character and judgment. Charlotte Hogg and Tim Weller do not have any relationships or circumstances which are likely to affect or could appear to affect their judgment and are therefore considered to be totally independent. Nicholas Eldred and Zarin Patel are employees of the ultimate parent; and, as previously mentioned, the Chairman is also a Non-executive Director on the BBC Executive Board.

Insurance indemnities

The company maintains liability insurance for its Directors and Officers which is renewed on an annual basis. The company has also entered into deeds of indemnity with its Directors.

Company Secretary

The Company Secretary reports directly to the Chairman. All Directors have access to the advice and services of the Company Secretary who acts as Secretary to the Board and its committees. The Company Secretary is accountable to the Board for ensuring that Board processes and corporate governance practices are followed. Directors are also given access to independent professional advice at the company's expense where they consider such advice is necessary to enable them to fulfil their responsibilities.

 

2. Effectiveness

Board composition and appointments

During the current financial year Simon Clift and Thomas Geitner retired from the Board both having served as independent Non-executive Directors for four years. Sharon Baylay, who was one of the BBC public service nominated Directors, retired from the BBC on 26 November 2010. Neil Chugani, the CFO, resigned on 17 June 2010 to join the Shine Group. External headhunters were engaged to undertake searches for replacements for each of these positions and job descriptions for the new roles were agreed.

Charlotte Hogg joined the Board on 24 September 2010. As stated in last year's report, Tim Weller joined the Board on 26 April 2010. In addition, Philip Vincent was appointed as CFO following a selection exercise. Philip was previously Deputy CFO of BBC Worldwide. His appointment commenced on 1 December 2010.

On joining the Board, each of the Directors undertook a formal induction programme. This is designed to give them an understanding of each of the strategic objectives and how these will be delivered within the context of the governance structure.

Click here for the current members of the BBC Worldwide Board together with details of their external commitments.

BBC Worldwide Board Attendance

Robert Webb	7/7
Sharon Baylay	3/5
Neil Chugani	2/2
Simon Clift	2/4
Nicholas Eldred	7/7
Thomas Geitner	3/5
Charlotte Hogg*	3/4
Zarin Patel	5/7
John Smith	7/7
Philip Vincent	2/2
Tim Weller*	5/7

^{*The Board calendar had been set before these Directors were appointed and they each notified in advance of their non-availability for meetings.}

3. How the BBC Worldwide Board operates

The Board has a schedule of matters reserved for its attention and the Company Secretary also maintains a forward agenda of matters requiring discussion and/or approval.

Financial and risk management

The Board receives regular updates on the company's financial position; agrees the budget; and monitors risk management and financial controls. One issue that the Board examined in some detail during the year was the impairment of the Lonely Planet investment and financial instruments. The implementation of the new Bribery Act was also discussed at Board level and the Board asked management to engage auditors to test the adequacy of the procedures in place. The restricted access to the debt market and the limited availability of headroom was also monitored by the Board during the year and the Board asked for greater visibility of cash flow and hedging.

Corporate transactions

Various corporate transactions were presented to the Board including the exercise by Tony and Maureen Wheeler of their put option in respect of the outstanding equity in Lonely Planet not then owned by BBC Worldwide. Following the exercise of the option, Lonely Planet became a wholly owned subsidiary of BBC Worldwide. The disposal of BBC Worldwide's interest in the Animal Planet and People&Arts joint ventures was successfully completed. The Board also received regular updates on the potential partnering of the Magazines business. Special Board meetings are called where necessary to review the specific detail of major transactions.

Business oversight

At each Board meeting the Chief Executive presents his report on all aspects of the company's strategy and performance in the presence of the BBC Worldwide Executive Committee (WEX). Each of the Managing Directors has the opportunity to attend Board meetings and to comment on their business performance. In addition, the Board receives a report from each of the businesses. At regular intervals the businesses make presentations to the Board on specific initiatives.

Legal and governance issues

At each Board meeting the Chief Operating Officer presents a report on legal, editorial and fair-trading issues. The Board approves each quarterly fair-trading return which is then submitted to the BBC. Recognising the importance of editorial and reputational issues, the Board members received a condensed version of our Inspire Trust editorial standards training which is mandatory for every employee.

People and succession

The Board held a half-day session on people management and succession planning. Three senior executives had resigned during the year and the Board played an active part in supporting the Chief Executive in filling these important business positions. Health and safety updates are presented to the Board and a specific update was provided to the Board in March following the earthquake and tsunami in Japan relating to our employees in Tokyo.

Board Committees

The Board delegates to its committees as set out below.

Nominations Committee

The Nominations Committee is chaired by Robert Webb; Nicholas Eldred and John Smith are members. The committee is responsible for reviewing the composition of the BBC Worldwide Board and for proposing new Directors to the Board, and to the BBC Executive Board and the BBC Trust. No formal Board evaluation has taken place during this year as a consequence of the number of new Directors who have been appointed. During the year the committee recommended changes to the membership of the Audit Committee and was directly involved in the engagement of external headhunters and the appointment of the new Directors.

Under the terms of reference the appointment of the Chairman and the Chief Executive are conditional upon the specific approval of the Director-General of the BBC.

The Nominations Committee is not fully compliant with the UK Corporate Governance Code. Given the company's status as a wholly owned subsidiary of the BBC we believe, at the current time, the members of the committee are appropriate. The Company Secretary supports the activities of the committee.

Nominations Committee attendance during the financial year under review was as follows:

Attendance

Robert Webb	2/2
Nicholas Eldred	2/2
John Smith	2/2

 

Remuneration Committee

The UK Corporate Governance Code recommends that the Remuneration Committee should comprise three independent Directors. Robert Webb chairs the committee and Charlotte Hogg and Zarin Patel are members. Given the close relationship with the BBC we believe the membership of the committee to be appropriate to the company in its current evolution.

The duties of the committee include determining the framework for the remuneration of the Chief Executive, CFO and WEX to ensure that members of the Executive management are provided with appropriate incentives to encourage enhanced performance in a fair and responsible manner. The committee regularly reviews the appropriateness and relevance of remuneration policies as well as the individual packages of each WEX member.

The committee also approves the design of, and determines targets for, performance-related pay schemes and any long-term incentive programmes. It is responsible for establishing the criteria for selecting, appointing and setting the terms of reference for remuneration consultants who advise the committee. The committee also is responsible for ensuring that members have reliable and up-to-date information about remuneration in other companies, particularly in the media environment. Click here for the terms of reference for the committee.

Click here for a full report of the remuneration policies and activities of the committee, chaired by Robert Webb.

The Company Secretary and the Group HR Director support the activities of the committee and attend every meeting by invitation.

Charlotte Hogg was appointed to the committee on 1 April 2011. Remuneration Committee attendance during the financial year under review was as follows:

Attendance

Robert Webb	6/6
Zarin Patel	6/6

BBC Worldwide Executive Committee

The BBC Worldwide Executive Committee (WEX) meets weekly and is chaired by John Smith. John Smith, Philip Vincent (CFO) and the BBC Worldwide Executives comprise the core membership of WEX. The Company Secretary also attends and supports the activities of the committee.

WEX takes responsibility for all aspects of the company's activities as delegated to it by the Board. WEX is also responsible for devising and implementing the strategy which it proposes to the Board for approval. Every week, WEX concentrates on market, competitor and technology developments and these are supplemented with detailed presentations and workshops on new and future technology innovations such as the Apple iPad, connected TV and smartphones which will all impact our businesses in the future. The development of the global BBC iPlayer continues to be reviewed and assessed. Business developments and relationships are monitored including our relationships with existing and potential partners - for example, UKTV and the independent production community. Customer relationship management has also been a focus during the year.

To reflect the investment in the USA, WEX accompanied the Board to New York in January 2011 and received presentations from the BBC America channels and Los Angeles production teams together with external US media experts.

Our employees are fundamental to our success and WEX devotes significant time to reviewing: the framework for pay and reward; succession planning; training and development; and how our Values are embedded within the culture of the company. Following the launch of the Aspire programme (which targets and offers aspirational employees a year-long development programme with a WEX member as mentor) each successful Aspire candidate presented their business project at a WEX meeting.

WEX delegates to a Content Investment Committee, which is responsible for approving programme and product investments of between £0.5m and £2.0m, and to the Investment Review Group, which approves other financial commitments between £1.0m and £2.0m. Both these committees are chaired by the CFO. Each business has authority for approving non-content budgeted spend up to £1m.

Accountability and risk

Audit Committee

The Audit Committee is chaired by Tim Weller; Nicholas Eldred and Charlotte Hogg are members. The committee is responsible for monitoring the integrity of the financial statements including critical accounting policies and estimates. The committee spends time reviewing emerging issues and understanding the impact of matters such as impairments and exchange-rate implications. The committee also reviewed hedging and treasury policies together with tax compliance.

The Talent Accounting department at BBC Worldwide is responsible for paying royalties to contributors, independent producers and third-party profit participants, from sales of programmes and many other activities such as live events and games. The committee receives an annual report detailing the accuracy and timeliness of payments to talent and producers.

The committee also reviews the effectiveness of systems for internal control and reporting, together with those ensuring adequate procedures are in place for staff to raise concerns. It regularly reviews the risk profile of the company, focusing on key risks as appropriate. The implementation of the Bribery Act 2010 has been considered closely during the year and, following a review of the Whistle Blowing procedures, a campaign to increase awareness was undertaken both in the UK and overseas. The enhanced powers of the Information Commissioner also resulted in the committee asking the management team to review data protection and information security.

The committee also undertook a review of the effectiveness of the KPMG external audit. The committee was satisfied with the performance of the audit team and welcomed changes in its key members in line with KPMG's policy of regularly refreshing its teams. The policy for non-audit services is reviewed on an annual basis. The committee also reviews the independence of KPMG and receives confirmation that such independence has not been compromised in accordance with ISA(UK&I) 260 and the APB's Ethical Standard 5. Representatives from KPMG attend each of the audit committee meetings and the committee meets regularly with them privately without the Chief Executive, CFO and management representatives being present.

The committee reviewed the effectiveness of the internal audit function. Internal audit resources are provided to BBC Worldwide via the BBC and the members of the committee meet privately with the BBC Director of Risk and Assurance without the CEO, CFO and management representatives being present.

The committee is supported in its activities by the Company Secretary, the BBC Director of Risk and Assurance, and the company's Risk Advisory team. The committee submits quarterly returns to the BBC Executive Audit Committee detailing the key issues discussed by the committee. The terms of reference for the committee can be found on the company's website. The committee is not fully compliant with the UK Corporate Governance Code as not all the members of the committee are independent. Given the company's status as a wholly owned subsidiary of the BBC we believe at the current time the members of the committee are appropriate.

Audit Committee attendance during the financial year under review was as follows:

Attendance

Tim Weller	3/3
Nicholas Eldred	4/4
Charlotte Hogg	1/1
Zarin Patel	2/3

Zarin Patel resigned as a member of the Audit Committee on 22 November 2010.

Principal risks and uncertainties:
impacts and mitigation

Risk and uncertainties	Potential impacts	Mitigation
Financing/uses of cash
Increased challenge of balancing capital repatriation to the BBC against investment in long-term business growth.	BBC Worldwide may not have the resources or the agility to take full advantage of emerging market opportunities.	Rigorous approach to investment approvals and the allocation of capital to projects to ensure the maximum value return. Monitoring performance of investments and ensuring underlying trading performance is sufficient to fund any new investment prior to commitment. Ongoing dialogue with the BBC regarding BBC Worldwide's investment needs and future returns against the BBC's immediate requirements and short-term returns.
Competitive/market pressure
Increased competitive pressures arising from industry consolidation and increased competitor focus on key markets. Tougher trading conditions in major markets.	Increased competition for key content and talent. Reduced trade and consumer demand for products and services, including broadcast and format rights, advertising and consumer products. Reduced access to high-quality content, affecting sales catalogue and wider intellectual property (IP) exploitation opportunities, and applying greater downward pressure on pricing.	Building own-production capability, both wholly owned and through partnerships with selected independent production companies. Diverse portfolio and global business. Ensuring that performance is maximised from existing businesses through recruitment and retention of specialist staff and ongoing review of strategy and performance against internal targets and external benchmarking. Driving growth from emerging formats and markets to complement established businesses.
Strategic execution
Execution of business priorities may not meet strategic targets.	Financial performance below anticipated levels or not delivering adequate returns on investment. Future expansion outside core areas may increase company risk profile.	Ownership of strategic risk held by CEO; progress on strategic delivery regularly reviewed by WEX and the Board. Regular review of strategy in the context of the market and prompt revision of plans to reflect changing circumstances. Diversified business portfolio, with a number of partnership agreements in place, limiting overall risk exposure.
Technology
Changing technology may undermine/replace core businesses.	Radical shift in consumption habits or disruptive technology rendering business models obsolete. Systems and processes unable to provide support for changing business. Increased importance of digital rights and ability to exploit IP in a variety of formats. Digital business skills required to manage business to consumer.	Strategic focus on digital services, integration of digital teams into core business divisions and partnering with technology innovators. Focus of investment in growth businesses, including digital formats and moving away from more traditional hard formats. Chief Technology Officer and Digital Director now in place to ensure all digital strands of activity are brought together and opportunities are not missed.
Reputation
Unethical activities (including those of suppliers and service providers) that are not consistent with the BBC Values in respect of ethical standards, may jeopardise the value of the brand.	Adverse publicity or damage to BBC Worldwide's or to the BBC's reputation. Loss of revenue in key territories or on key brands.	Risk assessment of third parties, including due diligence, training and contractual obligations. Active monitoring of suppliers and vendors by management, including site visits. Compliance with the Four Commercial Criteria (4CC) reviewed annually by the BBC and with the BBC's editorial policies. Commercial Policy provides 4CC and editorial training to staff. All new or changed commercial service proposals require a 4CC compliance assessment to be approved prior to launch or completion. Reputational safeguards built into agreements with joint-venture partners and equity investments (eg, the appointment of an editorial guardian and prescribed product approval processes). Common Values with BBC incorporated into the ethical sourcing programme, requiring all licensees and vendors to operate to a high ethical standard. Monitoring of third parties built into internal audit planning and execution.
Compliance
Challenge of complying with statutory obligations and regulatory requirements in all countries in which we operate, including data protection. Failure to obtain required approvals.	Failure to comply with tax and statutory accounting requirements could affect the ability to continue to operate within a jurisdiction. Non-compliance, resulting in fines, litigation or prosecution. Reputational risks associated with non-compliance, including loss of trust from customers when handling personal data. Becoming subject to future enquiries or proceedings from regulatory authorities.	Compliance and other business risks monitored in each business area and regularly reviewed by Risk Management and Internal Controls Committee. esponsibility for tax compliance, including transfer pricing negotiations, taken by the BBC. Tax and accounting compliance overseen by BBC Worldwide Audit Committee. Company Secretariat and the BBC monitor adherence to key statutory and regulatory filing obligations. Robust approach to data protection and information security, including procedures to ensure compliance, both internally and by third party service providers, and mandatory data protection training for all staff.
Currency
Exposure to fluctuations in major currencies and interest rates, particularly against the key currencies of the euro, and US dollar and Australian dollar.	Adverse impact on cash flows and reported financial results. Potential to undermine value of key assets.	Risk-averse approach to the management of foreign-currency trading. Clear hedging policy to minimise volatility in the financial results. Hedging policy reviewed and challenged by Audit Committee.
International expansion
Inherent risks involved with international expansion and overseas markets.	Complexity of doing business in multiple territories and markets, including ongoing control over overseas activities. Potential failure to comply with specific local legislation. Inability to attract quality staff and ensure staff act in accordance with BBC Worldwide Values. Challenge of ensuring BBC Values are protected in face of local custom and practice.	Executive Board members given regional accountability and regional Executive Vice Presidents to be put in place for each region (dedicated management already in place for USA and Australia). Market and risk assessments from local experts including due diligence on third parties. Review of controls and governance for major acquisitions. Compulsory training in all areas for editorial and commercial compliance for nominated roles. Implementation of policies and procedures that underpin BBC Worldwide's Values. Internal audit plan takes into account existing international operations and areas of expansion.
People
Economic, regulatory and political constraints may affect our ability to recruit, retain and motivate personnel. Increased competition in the market to attract skilled staff.	Reduction in overall competitiveness, including loss of key skills, relationships and knowledge, and business disruption. Higher acquisition and retention costs.	Increased focus on management development and training, with new programmes and appraisal system in place. Alignment of incentives to reward superior performance. Succession planning in place for senior managers and WEX plan reviewed by Board.
Business Continuity
Exposure of UK and international offices to natural disasters, terrorism and other unforeseen events.	Health and safety risks to staff. Disruption to operations, infrastructure and loss of revenue.	Business Continuity officer reporting to nominated Executive Sponsor. Extensive continuity plans encompassing international offices and business operations. Rolling plan of testing and rehearsal at all levels of the organisation.
Fraud and Corruption
Increased levels of fraud seen across businesses as a result of economic downturn. Increase in global anticorruption legislation.	Financial loss and impact on reputation and attractiveness as a business partner. Increased international scrutiny and joint prosecutions. Financial penalties, and monitoring procedures in event of incident occurring.	Anti-bribery and corruption framework in place supported by zero-tolerance messages, compulsory training and communication programme and detection. Framework subject to independent external assessment. Assessment procedures to identify key risk areas. Executive sponsor in place and regular reporting to Audit Committee and Executive Board. Robust controls framework subject to regular audit review.

Commercial governance

Magazines Annual Review

Editorial Advisory Boards (EABs) work alongside all BBC magazines and websites and play a key role in ensuring that the magazine portfolio reflects the BBC's public purposes and editorial values. The EABs are overseen by an Annual Review Panel (ARP), consisting of external experts and senior representatives from BBC Magazines, BBC Vision and BBC Audio and Music. It is chaired by the BBC's Chief Adviser, Editorial Policy.

The ARP conducted its sixth review of BBC magazine output during the course of 2010/11 (the first was completed in May 2006) and concluded that, overall, BBC magazines are quality publications, which display originality and editorial integrity. The portfolio is strong, with successful, varied titles which reflect a range of viewpoints and interests.

The EAB system continues to be a considerable success, with members offering invaluable advice and insights. Connectivity with BBC output remains particularly strong in the pre-school and pre-teen titles; it is good in Gardeners' World magazine, Good Food, Lonely Planet, BBC Music, Countryfile magazine, BBC Wildlife and Radio Times. For further details on the Editorial Framework see Corporate responsibility.

Brand Protection

BBC Worldwide's brand-protection team continues (together, where appropriate, with local investigators and enforcement authorities, including customs, trading standards and police) to investigate infringements of the Group's and its partners' intellectual property rights. It undertakes takedowns, seizures and prosecutions around the world, to help control the market for pirate audiovisual products, counterfeit goods and other infringements,  with an increasing emphasis on online infringements, notably on auction and content-sharing sites. BBC Worldwide is a member of various industry and enforcement bodies, including the Anti-counterfeiting Group, Television Against Piracy and Internet Enforcement Group in the UK, ABAC-BAAN in Belgium, and SNBREACT in the Netherlands. The team also manages trade-mark protection across the BBC Worldwide brands globally, including the clearance and registration of brands and resolving conflicts with other brands.

Respecting the privacy of individuals

BBC Worldwide engages with millions of individuals on a daily basis. This will continue to grow as the company creates more direct relationships with consumers. The organisation is committed to respecting and protecting the privacy of its customers and audiences as well as that of employees, contributors and talent.

BBC Worldwide and its subsidiaries are registered with the Information Commissioner's Office as Data Controllers and are regulated in the UK by the Data Protection Act 1998 and the EU Data Protection Directive. As a global organisation with a significant international following, BBC Worldwide also complies with local data protection requirements in the territories in which it operates.

BBC Worldwide strives for the best systems in data protection and information security compliance. At the heart of this are the eight principles of the Data Protection Act. With brands such as Doctor Who and CBeebies, the organisation attracts a youthful audience and BBC Worldwide adopts a strict approach when handling any data provided in relation to minors.