Privacy Policy & Terms Of Use

Scripps Media Broadcast Policy on Online User Generated Content (UGC)
May, 2010

Scripps Media, Inc.’s Broadcast Division recognizes the value that user generated
content features can bring to our online news, information and community sites.
We have a practice of opening up parts of our online platform to let users interact
and participate. Such interaction can take several forms, including text commenting
around our professionally produced news content, user uploaded photos and
videos, as well as blogs hosted within the community sections of our sites. Scripps
recognizes the place citizen journalists have in expanding the potential coverage of
our communities through our online platforms. Because of the special nature of this
content, Scripps has a policy (“Policy”) designed to encourage user engagement,
stand firmly on the side for the protection of free speech, and fall within the
protection of the protections of the Communications Decency Act (“CDA”) and other
legal protections.

The Scripps policy regarding User Generated Content (“UGC”) focuses on four main
areas.
1. Text commenting on professionally published content
2. User uploading of photo, video and audio content
3. User blogs
4. Managing user accounts and access to the system, including our obligations,
as they may be, to protect our users information under the guidance of our

Terms of Service and Privacy Policy.

Text Commenting:
The Policy recognizes real value in encouraging online users to engage in a dialogue
around our professionally produced content. At the same time, the Policy
recognizes that conversations that occur under the quasi anonymous nature of UGC
are sometimes uncomfortable, and even distasteful, to some users.
In order to stay safely within the safe harbor provisions of the CDA, we do not proactively
moderate or edit UGC comments. Instead, Scripps sites depend on “the
community” to police the comments. If a user deems another user’s comment to be
inappropriate, they may “flag” that comment as such. At that point, designated
station employees and managers will determine whether the flagged comment will
be removed. If determined to be inappropriate, comments may be removed all
together, but they may never be altered or edited in any way.

Comments may be removed from the conversation if they fit into one of four
categories.
1. They are considered profane or obscene, based the community’s standards.
2. They reveal the private information about a party that would not be
published under generally accepted journalistic principles.
3. They would be considered spam, either manually or electronically initiated.
Scripps Media Broadcast Policy on Online User Generated Content (UGC)
May, 2010
4. They would be considered a vitriolic personal attack, for example
disparaging a private individual based on their race, sexual orientation,
religion or gender. The expression of opinion or critique of someone’s
quality of work does not rise to the level of a personal attack.
The commenting functionality should be left active, by default, on stories. There
may be some cases where the sensitive nature of the subject of a story may lead to
an editorial decision to deactivate or hide text commenting, either initially or after
the story has been published.

Usergenerated photo, video and audio content:
The Policy is designed to encourage users to share photos, videos and audio with
other users through our sites. Additionally, we recognize the value of opening up the
platform to citizens interested in contributing both first hand stories (citizen
journalism) as well as opinion. Unlike text commenting, it is policy to moderate
these uploads, prior to making them visible to the public on the site.

UGC photo, audio and video should be published live, as long as it adheres to the
following standards:
1. Content uploaded is not considered profane or obscene, based on the
community’s standards.
2. Content uploaded does not reveal the private information about a party that
would not be published under generally accepted journalistic principles.
3. Content is not considered spam, either manually or electronically initiated,
including that which might otherwise be considered an unsolicited
advertisement.
4. Content would not be considered a vitriolic personal attack, for example
disparaging a private individual based on their race, sexual orientation,
religion or gender. The expression of opinion or critique of someone’s
quality of work does not rise to the level of a personal attack.
5. Content may not violate another’s copyright, trademark, or patent,
intentionally or otherwise.

The Policy calls for special attention to be paid to content that could potentially
violate a copyright, trademark or patent. For example, a user-generated slideshow
set to a soundtrack of popular songs should not be made live on the site as the use of
the song could violate the copyright.

Upon submission to a Scripps site, a user acknowledges granting a non-exclusive,
worldwide, royalty-free license to Scripps to use the submitted content in any
format, including print and electronic platforms. Scripps stations and sites will not
substantially edit submitted videos, audio or photos. Editing, such as shortening
submitted video or audio, or resizing a photo, is acceptable, so long as the edit does
not substantially change the nature of the submitted work. As is made clear in the
Terms of Service for our sites, UGC submissions are permitted to be used on any
platform we control, and may also be licensed by us to any third party.

Scripps Media Broadcast Policy on Online User Generated Content (UGC)
May, 2010
User Blogs:
Where appropriate, Scripps sites should encourage registered users to participate
through UGC blogs. Blogs that are truly user-generated should be contained within
the “community” sections of the site to be clear of their origin. Scripps stations
should follow the advice as above in Text Commenting, to guide the approach to
userâ€ï¿½generated blogs.

Managing user accounts and access:
For a user to participate in most of the features of our UGC platform, they must
register with us, often sharing personal information. From time to time, a site may
desire to learn more about its users by soliciting more information to add to the
database.

In the event a user’s behavior within the UGC platform calls for intervention after
multiple “flags,” a site may opt to take the following actions, as they are warranted:

1. Warn the user: The UGC platform allows site managers to send warning emails
from the site to each user. The warning message should cite specific
violation(s) and should direct the user to review the site’s Terms of Service.
Copying and pasting the applicable section of the Terms of Service is useful to
coach the user to behave appropriately on the site, and to provide support
for the warning. The warning e-mail should also stipulate what additional
measures the site will take if the user continues to violate the Terms of
Service.

2. Suspend the user: The UGC platform allows site managers to suspend
individual users for any length of time for any reason, even without issuing a
warning first. In most cases, a suspension will follow one or more warnings.
The suspension e-mail should cite specific violation(s) and should direct the
user to review the site’s Terms of Service. Copying and pasting the
applicable section of the Terms of Service is useful to provide support for the
suspension. The suspension e-mail should stipulate the length of the
suspension and should tell the user his/her account and his/her access will
be restored to the site when the suspension term ends.
3. Delete the user: The UGC platform allows site managers to delete individual
user accounts. In most cases, this step will follow one or more warnings or
suspensions. There is no e-mail option with the “Delete User” tool. Deleting
a user’s account also deletes the user’s profile and contributions to the site.
Warning: once a user account is deleted, it cannot be restored.
4. Ban the IP address: The UGC platform allows site managers to prohibit any
computer using a specific IP address from logging on to the site. This should
be done only in limited situations, including situations where a previouslydeleted
or suspended user is creating multiple accounts in order to
improperly (re)gain access to the community. Beware: most users do not
have a static IP address, so if you ban an IP, you may be banning additional
users from accessing the site. Further, it’s impossible to keep a
suspended/deleted user from accessing your site via another IP.

Though neither the Privacy Policy nor the Terms of Service make any guarantees of
neither confidentiality nor anonymity, as a matter of Policy, Scripps sites take efforts
to protect the identities of their users. In the event law enforcement contact a
station seeking any information about users of our sites, Policy would dictate
referring any such request to Scripps Associate General Counsel David Giles.