mediawatch-uk's response to Ofcom's consultation on strategy
and priorities for promotion of media literacy
W |
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!
Click here for Ofcom: Latest
Developments
Click here
for more mediawatch-uk responses to Ofcom consultations
Click
here for mediawatch-uk directory
Click here
for joining form