mediawatch-uk's response to Ofcom's consultation on strategy and priorities for promotion of media literacy
e note that the Office of Communications has a duty under the Communications Act 2003 to promote media literacy. We note also that there is a requirement to bring about "a better public understanding" of a range of issues related to the transmission and reception of media content.
mediawatch-uk believes that these are important issues and objectives and we welcome the opportunity to express our views on this consultation.
We note that the emphasis throughout the consultation is upon the viewing and listening public to inform themselves of television and radio content and thereby avoid anything they may find harmful or offensive. There is no indication in this consultation of what constitutes harmful or offensive content and there is no evident expectation that broadcasters will do anything to stop transmitting such content. There is a surprising absence of obligations or duties on broadcasters in this regard.
It is, of course, true that "people face greater media choice" but this is limited to channels rather than content. There are now many channels offering similar programming. It is stated that "parents may have to take more responsibility for what they and their children see and hear" but this is a function that surely ought to apply to the regulator in its quest to secure high standards. This is certainly in the public interest and worthy of the task in hand - to improve media literacy! We also wonder why it is simply assumed that there should be "risks" associated with the broadcast media that should require protection. Most people, if asked, expect television to be effectively regulated and expect the regulator to perform a protective role so that such "risk" is obviated. Given that Ofcom is costing in excess of £164 million in its first year of operation these expectations are not unreasonable.
We would agree that there are "media literacy needs" but we are not convinced that the present consultation adequately deals with these in their entirety. Indeed, there are no substantive proposals on how media literacy will be achieved among the viewing and listening public or the role in promoting it to be played by the regulator or by broadcasters.
We note the emphasis on "evidence based" research and the mysterious notion to "add value". It would be helpful to know, in a consultation of this importance, what proposals Ofcom has to conduct research and the likely subjects for such research and who it intends to commission. It is not good enough for Ofcom to expect the public to suggest this in a consultation with such a limited circulation.
It would also be helpful to know how Ofcom envisages that the information on "the nature of content" can be made "clear, accurate and timely". Is it envisaged that the programme magazines and Electronic Programme Guides include comprehensive programme information rather than the vague indications of "violence", "nudity", "sexual conduct", "swearing", that some magazines include or the verbal warnings of "strong language, etc" that frequently preface programmes? These rarely if ever convey the truth about the content that follows and often act as an enticement to keep viewing.
Is it Ofcom's expectation that all viewers and listeners, in making "informed choices", are to be instructed in relation to "harm and offence"? Why is there no mention of "generally accepted standards" in this consultation paper or how this is to be ascertained or how it fits in with aspirations to improve media literacy? Such an important statutory requirement surely ought to have been mentioned in this context.
We accept that a "content labelling framework" could assist the public in the making of "informed choices" but we do not agree that "a common content labelling scheme" is necessarily appropriate especially if the scheme is so accommodating that any material can be labelled. Television and radio, by their nature, are not the same as cinema or video or computer games. Historically, Parliament has recognised the truth that television and radio are primarily a means of information, education and entertainment that are transmitted directly into the home. Accordingly, the regulatory legislation has rightly required a much higher level of safeguard for viewers and listeners. It is a matter of debate how well this has succeeded and how well broadcasters complied with these provisions.
We wonder why Ofcom, in this consultation, which has to do with the public, says it "will work with industry players"? Industry players have, as their primary concern, the interests of the industry and not viewers and listeners. This is a serious imbalance and it would not be appropriate if any labelling scheme were determined solely in collaboration with the industry by the regulator.
We accept the general proposition that media literacy has parallels with traditional literacy but there are many levels of understanding and appreciation in the latter that are not evident in the former. Indeed, we would argue that the level of swearing, profanity and general bad language in film and on television is undermining communication skills and the beautiful English language.
The notion of "critical viewing" or "critical analysis" are good in theory but assume a level of capability that not all have or want. It would be helpful if Ofcom had set out some suggestions on how this objective might be achieved. Again we ask why it should be necessary to give people "skills … to protect themselves and their families from harmful or offensive materials"? Does the regulator and broadcaster not have a role at all?
We welcome the reference to "writing to or e-mailing the broadcaster with their point of view". Why not also use of the telephone? We believe that this aspect of media literacy has been and continues to be greatly under-emphasised by the regulator. We suggest that every household in Great Britain should be sent Ofcom's leaflet 'Who to complain to about television and radio'. We also believe that every household should be sent a summary of the Broadcasting Code, once it is finalised, so that the viewing and listening public have some guidance on how to assess programmes. We also believe this should include a tick box to request comment or complaints forms. The Broadcasting Standards Council had such forms and Ofcom should carry this facility forward.
Access information should be required to be transmitted regularly on every licensed television and radio channel. The viewing and listening public should be invited to comment on programmes and that way Ofcom's determination of "generally accepted standards" might be achieved.
We believe that public service broadcasters ought to be encouraged to provide access programmes, like Right to Reply and we note the BBC's good intention in this regard. The remit of such a programme should be broad and not limited to airing complaints or criticism. It should include news and information about Ofcom, the BBC Governors and management, the role of Parliament and culture select committee, the work of the Culture department as it relates to broadcasting and the role and policies of the European Commission as it relates to communications in general.
It is clearly fatuous to suggest that the 'off-switch' is the best form of regulation. We believe that 'off-switch' regulation works against the very concept of media literacy and is a way of perpetuating a system where broadcasters rarely have to account for what they do or the influence they exert. It changes nothing and why should we be expected to pay for equipment and services that have to be frequently switched off?
The proposal to "create their own video and audio content" is a very fine aspiration and could be achieved through locally available further education courses. Ofcom's role in this regard ought to be to promote such courses and, perhaps, provide some resources. It would also be appropriate for Ofcom to ensure that the best material is aired rather than the amateur pornography currently finding its way on to ITV1 in Rudest Home Videos!
The consultation paper nowhere mentions the use of the media itself to promote media literacy. Nor are television and radio programmes apparently considered as appropriate vehicles for this subject. We believe that there should be programmes, particularly on channels claiming a public service remit, about television and radio and about the regulator and internal workings of the BBC and Ofcom. There should be serious and substantial programmes about audience reaction to programmes. In an open democracy broadcasting seems to be the only industry that remains closed to any sort of public access or scrutiny and where cameras are not allowed. It is not enough for the Chairman and Director General of the BBC to appear once or twice a year before the Culture Select Committee to give an account of themselves and their stewardship of the corporation. If cameras can be installed in Parliament there cannot be any good reason why the inner workings of Ofcom or the BBC Governors and management should any longer remain closed to public gaze.
We welcome Ofcom's undertaking to involve "stakeholders" throughout the nations and regions and look forward to receiving information on how this is to be achieved.
It is a pity that in this consultation Ofcom has not referred to previous research conducted by the ITC and BSC with respect to public attitudes to programme content or to the nature and volume of public complaints. From this it is evident that many people object to violent or sexually explicit content, nudity, the use of swearing and profanity. By failing to acknowledge these aspects of programme content, which many people find unacceptable, the impression is given that they do not object or complain. It is not enough to suggest that such material should simply be avoided on the basis of information provided somehow or the other and that the regulator plays little or no role in stopping such material being transmitted in the first place.
We believe that the public has an expectation that the regulator ought to take on a role of leadership in ensuring a high degree of quality control - as in all other public utilities. Broadcasters ought to do more to comply with prescribed standards that ought to be known and understood by the public. To achieve this we recommend again the use of the licence fee renewal system or the telephone billing system to convey 'fact sheets' or 'updates' of such public information relevant to viewers and listeners.
In conclusion we believe that Broadcasting is not an unassailable force that is above proper regulatory intervention. 'Freedom of expression' is not an absolute concept and must be balanced by the exercise of responsibilities and legitimate safeguards. Audiences too have rights, including the right not to be offended by gratuitously offensive or harmful programme content. Broadcasting is a human activity with huge influence that is largely unaccountable to those who receive the output.
We recall the remarks made by Lord Currie of Marylebone, Ofcom's Chairman, at the English National Forum in July last year: "there are certain points beyond which a broadcaster may not go without abusing the immense privilege which is implicit in the right to broadcast".
We believe that the primary and overriding objective of any scheme of media literacy should be to determine what these "certain points" are, where abuse of the "immense privilege" begins and ends and above all, to explain this to the viewing and listening public. With this achieved we can have high expectations that we all will indeed be media literate in the 21st century!
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