Cardiff and Belfast UGC campaigns: what briefs cover

What to take away

Welsh public sector campaign rules and how they shape a Cardiff UGC brief

Cardiff public sector campaigns sit under Welsh devolved policy. The Welsh Government's creative industries statement sets the direction for publicly funded creative work, including campaigns that use creator content. If a brand sources creators through a UGC marketplace or service, the brief should still identify the commissioning public body and its campaign owner: the marketplace is a sourcing route, not a substitute for the buyer's approval process. That means a Cardiff UGC brief is written for a public body, not a brand team.

The rules push briefs towards clear public value. The marketplace or service should receive a stated audience, a policy aim, and a named campaign owner inside the commissioning body. UGC is bought as a route to reach people the public body struggles to reach through paid ads alone.

The brief will name the platforms, the languages, and the accessibility standard. Welsh public bodies often work bilingually, so a Cardiff brief may ask for Welsh and English versions of the same UGC asset.

Price the Welsh version as a separate deliverable at the same rate as the English master, not as a translation add-on, because it needs its own script, performance and approval. For illustration only, if the English master is quoted at £1,000, the Welsh version is quoted at another £1,000.

Procurement also shapes the brief. A Welsh public body may buy UGC through a Welsh Government Commercial Delivery (WGCD) framework. It may also run a mini-competition or a direct award below the Public Contracts Regulations 2015 sub-central services threshold.

That threshold was £214,000 from 1 January 2024. The creator may never see the route, but it shapes the timeline and the paperwork.

Budget lines are public. A commission from Cardiff Council or NHS Wales may be published in contract award data, so the fee band can become visible. Creators who normally keep rates private should expect that.

Attribution matters more here than in a commercial campaign. A public body must show what the spend achieved, which is why the brief often includes a control or comparison group. The devolved policy for UGC campaigns article explains why one asset rarely proves a campaign worked.

Northern Ireland dual-market rules and how they shape a Belfast UGC brief

Belfast sits in a dual-market position. A campaign can reach audiences under UK rules and EU rules at the same time. That changes the brief before a creator is even approached. For work sourced through a UGC marketplace or service, specify whether each commission is for UK, EU or both audiences before matching creators.

A Belfast brief often states which market each asset is for. One asset may run in Great Britain, another in the Republic of Ireland or the wider EU. The creative may look similar, but the claims, disclosures and data flows differ.

Goods and services sold across that border follow the Windsor Framework and the Trader Support Service. For each asset, the brief should specify who checks product claims, prices and availability in its target market, and set out the supplier's responsibilities. The GOV.UK page concerns HM Land Registry's business strategy, not buying and selling outside Great Britain.

Advertising claims also split by market. A claim that is acceptable in one market may need qualification in the other. The UK side uses the Consumer Protection from Unfair Trading Regulations 2008; the EU side uses the Unfair Commercial Practices Directive 2005/29/EC. A Belfast brief should say which claim set applies to which asset, and who checks it.

Creator location matters. A creator based in Belfast may be inside the UK market but selling content into the EU market. The brief should say where the creator is treated as established for tax and data purposes.

The practical effect is a longer brief. Expect a market column, a claims column, and a data column for each deliverable. That is more work up front, but it prevents a re-shoot later. For illustration only, if the GB video is quoted at £1,200, the EU version is another £1,200, plus a claims-review line.

Approvals compared: who signs off Cardiff and Belfast campaigns

Approvals differ because the buyer differs. A marketplace may help coordinate delivery and review dates, but the brief should still identify who signs off each asset. In Cardiff, the commissioning public body owns the campaign, and its communications team signs off. In Belfast, a single campaign may need UK-facing and EU-facing approval.

In Cardiff, approvals usually run through the public body's press office, its legal team, and sometimes a minister's office. That can add rounds. A creator should expect two or three review passes on a script before filming.

In Belfast, approvals often split by market. The UK-facing asset may clear quickly, while the EU-facing asset waits on a separate claims check. The two approvals can land on different days, so the delivery schedule needs slack.

Both cities use the same advertising self-regulatory system. The Advertising Standards Authority (ASA) applies across the UK, so a Cardiff or Belfast asset must not mislead. Public bodies are not exempt.

The Competition and Markets Authority (CMA) also matters when a campaign touches pricing or comparisons. A public body promoting a service is usually outside that risk, but a partner brand in the same campaign may not be.

Approvals are not just a gate. They are evidence. A public body may have to show its approval trail if a campaign is challenged, so the creator's drafts and versions become part of the record.

Data handling compared under UK GDPR and cross-border transfer rules

Data handling is where the two cities diverge most. Both are in the UK, so UK GDPR applies in Cardiff and Belfast. When commissioning through a marketplace or service, identify its role and the data route in the brief and contract; using a platform does not by itself settle controller and processor responsibilities. The difference is what happens when audience data leaves the UK.

A Cardiff public sector campaign usually keeps audience data inside the UK. The public body is the controller, the creator is a processor if personal data is involved, and the contract should say so. That is the lawful basis to deletion chain in practice.

A Belfast campaign may transfer audience data to an EU service provider, or receive data from an EU partner. That triggers the ICO's rules on international transfers. The contract needs a transfer mechanism such as the International Data Transfer Agreement (IDTA) or the Addendum to the EU Standard Contractual Clauses (SCCs), plus a transfer risk assessment.

The UK treats the EEA as adequate under its own regulations, and the EU's adequacy decision for the UK governs the reverse flow; check the current expiry date of that decision.

Creators rarely own the transfer paperwork, but they often hold the data first. If a creator collects entries, comments or sign-ups, they are handling personal data. The brief should say what happens to it and when it is deleted.

Retention periods differ by buyer. A Cardiff public body may keep campaign data for audit, while a Belfast campaign may need to delete EU audience data sooner. The creator needs one instruction, not two guesses.

FOI adds a transparency layer in both cities. The Freedom of Information Act 2000 lets the public ask publicly funded bodies for campaign records. Creators should assume that briefs, fees and performance data may be disclosed, with limited exemptions.

Brief-writing differences a creator should expect between the two cities

A Cardiff brief reads like a public service commission. It names the policy aim, the audience, the languages and the accessibility standard. It may also name the evaluation method.

A Belfast brief reads like a two-market campaign. It names the markets, the claims per market, and the data route per market. It is longer and more conditional.

Here is a worked example. A public body wants UGC to promote a service in Cardiff and Belfast.

Use this checklist when sending or pricing a marketplace brief for either job.

Contract terms differ too. Check how the public body's terms work alongside the marketplace or service's terms; Belfast work may need extra warranties. The seven contract categories article sets out what to check when no model clauses are offered.

Common questions