Beyond the Black Card: Should Cinemas be Using Content Notices?

Posted on August 10, 2023 by Duncan Carson

Categories: General

Content notices are a contentious area. Some see them as a duty of care that film exhibitors owe to their audience, while others say they’re an unnecessary measure and can even be counterproductive. In this blog, the ICO’s Duncan Carson speaks to film professionals who have introduced content notices about their experience and what the benefits and challenges are, as well as looking at academic research in this area.

The lights go down in the movie house. You’re excited about what you’re going to see. It’s an older film, one you’ve heard is well worth your time. Except halfway through, there’s a disturbing scene, something the synopsis didn’t warn you about. Many people will be able to shrug it off. For others, especially those living in the long shadow of trauma, it can have serious consequences. What do we as exhibitors owe audiences in this situation? Is there more we could be doing beyond the BBFC black card?

A duty of care

In response to these considerations, many cinemas and festivals—especially those showing material not covered by the BBFC—are now providing content notices for potential audiences. They provide short descriptions—often longer than the BBFC’s extended guidance and with different sensitivities in mind—of specific depictions that have the potential to cause spiraling thoughts and lasting pain for audiences, covering areas like sexual violence or racial stereotyping. It’s something we’ve considered bringing in at our Screening Days programmes, especially as we are often showing films as previews before their certification is prepared. I spoke to film professionals who had introduced content notices about their experience and what the benefits and challenges are, as well as looking at academic research in this area.

Organisations we spoke to felt that this was another permutation of the care that independent cinema should have with its audience. We often talk about the value of building audience trust in venues and their programming, and content notices are a means to extend this care beyond what is legally required from the licensing authority. Alongside notes about flashing lights or loud noises for neurodivergent or epileptic audiences, content notes can be another strand of essential accessibility work.

Watershed’s Head of People Helen Jaffa puts the calculus like this, ‘I think venues have a responsibility to inform people of generally what to expect so they can make their own decision. In my experience if and when venues don’t do this, they need to be prepared to deal with the consequences of someone being emotionally impacted or feeling unsafe while using their space.’ Occasionally, exhibitors can be resistant to adopting content notes since there’s an anxiety that including them will be off-putting for general audiences. However, there are consequences either way, so offering people care in advance rather than dealing with their disgruntlement (whether it’s voiced to your staff or not), is the gentler route.

Who, what and how?

One of the major challenges to establishing content notes as a mainstream practice is in solidifying who should be creating them and what they should cover. For some organisations we spoke to, this work falls under operations, marketing or programming. Programmers most frequently took responsibility, since they are the most likely to have seen the film. The biggest barrier to adopting this practice for the programmers we spoke to was time pressure. Not every film viewed gets programmed, and it adds another layer of complexity and note-taking (or a second viewing once programming is confirmed) to the already overladen basket of tasks for a programmer. Others argued that this is upstream work for distributors to provide for the films they’re sharing with the public (and earlier on, with exhibitors).

As Sonia Zadurian, Cinema Curator at the Barbican, comments, ‘Catching all trigger warnings, even when I have been able to see the film, can be difficult as they are often subjective. What might distress one person, may have no impact on someone else.’ It can also be challenging when curating older material: social attitudes change, and even beloved classics contain moments that modern audiences find untoward. Finding time to rewatch films from this perspective is a luxury that is not always available to programmers. Perhaps a database—akin to the great work of Sidecard for access materials—is needed so there is less replication of this work?

Beside the Seaside (1935), part of our 2022 distribution project The Camera is Ours. Our archive partner for the project at the BFI included a content notice for this title due to an instance of blackface. Image courtesy of the BFI National Archive.

Whoever is doing this work, there needs to be consensus on what type of content is flagged. From the organisations we canvassed, the most common elements seen as especially worthy of note were:

  • Violence
  • Sexual or sexualised violence (including rape or sexual assault)
  • Suicide
  • Self-harm
  • Drug use and alcohol abuse
  • Animal abuse
  • Racist language or depictions (including stereotyping)
  • Sexism
  • Ableism
  • Homophobic language or depictions
  • Transphobic language or depictions

It would also be beneficial to host a list of the areas your content notes will attempt to flag. This helps audience confidence about what they can expect, especially in instances where there is nothing to note (arguably a ‘there is no content likely to offend’ should be included to avoid doubt). It’s also worth thinking about what scale of reference merits inclusion. If a character jokingly says, ‘I’m going to end it all!’ in response to a minor catastrophe, is it worth flagging ‘references to suicide’ or can we deem this part of general speech?

Having an established list of topics your audience can read in advance also helps set expectations about what isn’t going to merit a pre-warning. There are noble souls working to flag when there are instances of non-vegan behaviour in films, but for the average movie-goer, it’s fair to set reasonable limits on how far content notices will go, and to appraise staff that they shouldn’t take ultimate responsibility for any personal offence or distress. Content notices are a backstop for content that is genuinely disturbing and likely to create traumatic outcomes. It should be understood that there is a gulf between this and being personally offended. A horror film festival is a good case in point, as part of the genre’s raison d’etre is pushing at taboos. As Nia Edwards-Behi of Abbertoir Film Festival adds, ‘I do my best to note more things such as common phobias (e.g. snakes, needles, vomiting); some more specific things like eating disorders/strong food themes; substance abuse or addictions; racism/ableism/discrimination; and certain violent acts (e.g. specific suicide methods).’

A self-fulfilling prophecy?

Before beginning to use content notices, it’s worth considering whether they are as beneficial for audiences as they appear on first impression. There is a growing body of research that runs counter to their value for people suffering from PTSD, and that they can even be counterproductive. Some studies have found that content notices (especially when delivered under the label ‘trigger warnings’) can stimulate people to anticipate a traumatised response, a self-fulfilling prophecy for some. Most of this research has been conducted on the effect on students as they take mandatory course syllabi that contain potentially triggering content. This is a very different environment to an elective cinema experience where a content note can help people participate in making active choices about what material they have the mental resilience (or simply preference) for on that given day.

Nevertheless, the jury is out on whether there are categorical gains for trauma survivors (as a subset of people who may find content notices useful). A study by Jones, Bellet and McNally ‘found that trigger warnings reinforced the belief on the part of trauma survivors that trauma was central (rather than incidental or peripheral) to their identity.’ What is clear is that rendering the information as the more neutral ‘content notice’ rather than ‘trigger warning’ is best if cinemas choose to pursue content notices.

Getting the balance right

One area that also requires consideration is how detailed content notes should be. How a moment is justified and contextualised by the narrative makes a difference to how it lands with audiences. As Access Consultant for Matchbox Cine, Charlie Little comments, ‘To just say “violence” is not descriptive enough. The amount of description needs to be mastered and there’s a degree of trial and error. I feel there’s a responsibility to offer audiences descriptive information about a film’s content, especially potentially distressing or harmful themes, so that audiences are equipped to make their own decisions.’ How can content notices capture this level of nuance? For Abertoir Film Festival, they provide short content notes but also offer up the opportunity for audiences to ask for a more nuanced description directly from the programming team. This allows for a more specific read on the material, and a personal touch that audiences benefit from.

It’s also worth thinking about context and surprise when considering the impact of challenging moments in films. The times we’ve had the most concerns at Screening Days from audience feedback are with instances when the copy cannot convey specific outlier moments in a film. Screening a heart-warming British film for older audiences recently, we were caught off-guard at a scene of suicide. This is a classic instance where copy needs to be supplemented by a content notice, as trailers would be unlikely to convey this and the depiction is relatively discreet so the BBFC report wouldn’t necessarily merit a mention.

Delegates at Screening Days browse the event programme – a suitable home for content notices? Photo: Jade Vowles

Where to place a content notice in the customer journey is something that requires thought and sensitivity too. If the note is too central to your listing, it overemphasises its importance to the overall film experience (should a disturbing scene that lasts less than a minute take precedence above explaining what the film is?). For the spoiler-averse, it can also create friction, since content covered by content notes are central to the plot and often a surprise. However, if content notes are hidden away, they serve limited purpose. Content notes are currently far from an expected part of an audience journey, so they need to be prominent enough as part of the journey so audiences don’t overlook them.

The BFI’s process splits the difference nicely, with the content note (‘Contains scenes of sexual violence that some users may find disturbing’) delivered in a separate pop-up once tickets have been ordered. This has the benefit of only becoming relevant if people intend to attend, but direct enough to be noticed by those who need them. Content notes are flagged on Abertoir’s listings, but are held on a separate page to avoid the spoiler factor. Some exhibitors we spoke to also considered flagging ahead of the screening verbally in case attendees hadn’t been made aware prior to joining the event.

Allergies and flavours

One argument we’ve encountered against content notices comes from those who believe it reflects audiences’ desire not to be challenged. While it’s certainly a core part of the appeal of arthouse films that they ask more of audiences, occasionally pushing us into uncomfortable spaces or thoughts we hadn’t considered before, we need to consider this alongside the breadth of reasons people come to our cinemas. Some come to be challenged, some to be disturbed, to be thrilled and moved into riskier realms. Other people come to escape, to be delighted, to be soothed. These impulses can sit side by side—indeed, most of us have moments along this spectrum from week to week—but we should be providing for a variety of experiences. Just as a cinema—or any venue—cannot offer a genuinely ‘safe space’, only move towards making a ‘safer space’ or ‘brave space’, so the content notice cannot ensure that audiences will not unintentionally have a negative, triggering experience at the movies. But they can contribute to audiences feeling more confident about selecting the experience they’re looking for.

Perhaps a good analogy lies in the idea of hosting, shared both by cinemas and restaurants. Just as restaurant hosts ask about intolerances or allergies in advance of serving, the aspirations for content notices are they provide allergy-level medical warnings for survivors with PTSD. However, it’s more realistic (according to current research) to look at them as part of a guide to what the flavour will be. The argument against content warnings—the idea that people need to have their consciousness raised by being challenged against their will—is akin to the idea that dumping down a vindaloo in front of someone who wants a korma is going to help them tolerate and enjoy spice. A flavour we’re not used to (and could enjoy discovering) is one thing; anaphylaxis is another. We should be in the business of encouraging people to expand their palate, but this should be done consensually. While they require time, effort and thoughtfulness to implement, the decision about whether to implement content notices asks us serious questions about the limits of our care for audiences, ones without simple answers.

If you are interested in this subject, we recommend speaking to Alice Duggan, who has produced a comprehensive guide on the subject. She can be reached via Twitter or via email at

Should film exhibitors be providing content notices? Let us know what you think on Twitter at @ICOtweets or email us at:

Header image: Beside the Seaside (dir. Marion Grierson, 1935), part of The Camera is Ours: Britain’s Women Documentary Makers. Image courtesy of the BFI National Archive.

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