ofcom’s strategy and priorities for promoting media literacy · ofcom’s strategy and priorities...

Ofcom’s strategy and priorities for promoting media literacyA Summary

2 November 2004

Ofcom’s strategy and priorities for the promotion of media literacy 1

Contents

Section 1 Summary 2

Section 2 Introduction and definition of media literacy 4

Section 3 Our approach 6

Section 4 Research 8

Section 5 Connecting, Partnering & Signposting 11

Section 6 Common labelling of audiovisual materials 14

Section 7 Other issues raised in the consultation 17

2 Ofcom’s strategy and priorities for the promotion of media literacy

www.ofcom.org.uk

Summary

Ofcom is the independent regulator forthe UK communications industries. Westarted work in late December 2003 andour role is to look after television, radio,telecommunications ('telecoms') andwireless communication services.

This statement gives our conclusionsfollowing the consultation we held fromJune to August 2004 about the need topromote media literacy. We held thisconsultation to meet an obligationplaced on us under Section 11 of theCommunications Act (2003).

There is no agreed definition of what‘media literacy’ actually is but, followingthe consultation, we will use this one:

Media literacy is the ability toaccess, understand and createcommunications in a variety ofcontexts.

The media has never given us so muchchoice. Changes in technology meanthat you may need to be more aware ofwhat you and your children see andhear, on screen and online. By being‘media-literate’, you will be in a betterposition to know what to expect, how tomake the most of what’s on offer and toprotect yourself and your family. Bybeing confident with communicationstechnology, you will gain a betterunderstanding of the world around you,and be part of it.

At Ofcom, we will work with everyoneinvolved, to focus on the media literacyneeds of everybody, now and in the future.Many people have an important role toplay in promoting media literacy in bothadults and children. They include:

• organisations which produce content;

• broadcasters;

• platform providers such as digitaltelevision and online services;

• educators;

• government departments;

• parents;

• children’s charities; and

• many other similar organisations.

Our main role will be to provide leadershipand to make things happen.

There are three main parts to our earlywork in promoting media literacy in theUK.

Research

We will carry out a wide-ranging researchprogramme to investigate howmedia-literate people are, and the issuesthat we need to face. We will also set up aprocess so that we can track progress in thefuture. The knowledge we gain from thisresearch will be extremely important, andwill shape our action and decisions.

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Connecting, partnering andsignposting

We plan to move media literacy higher oneveryone’s priorities. We will actively lookfor opportunities to create and encouragedebate at conferences and events. We willcreate our own initiatives, and contribute toother media literacy projects, to raiseawareness throughout the UK and inEurope. We will also offer funding tosupport projects that promote medialiteracy, and which couldn’t happen withoutextra help. We will also use our website todirect people to relevant information onissues to do with media literacy.

Labelling

Viewers and listeners need clear, accurateand timely information about the contentof programmes they might watch. Webelieve there should be a standard labellingsystem which would protect young andvulnerable viewers by highlighting anypossible harm and offence. We recognisethat some people are worried about howthis might be done, so we will be invitingkey people to form a working group toinvestigate how viewers (in particular, inhomes with digital television) would like toreceive this information.

We received 94 responses to the medialiteracy consultation and we’re grateful tothe wide range of people and organisationswho took part. If someone who contributedgave their permission, you can see theirresponses in full on our website(www.ofcom.org.uk).

In July 2004, the Doors section of TheSunday Times canvassed its readers' viewson the best ways to encourage medialiteracy. The Editor of Doors forwardedreaders’ e-mails and letters to us.

This is what readers were asked:

"What Doors wants to know is what you, astooled-up newspaper readers, think we should all doto encourage media literacy - sticks and carrots, even- and who is best placed to get a digital societymoving: parents, manufacturers, broadcasters,politicians, who? Choose one of the talking pointsthat we have proposed alongside - or any techieissue about which you have insider knowledge. Mailus with specific proposals to bring digital challengesinto focus, and we will give £50 to the 10 readerswho fare best. Within the month, we will analyseyour responses, put your concerns to the great andthe good, and report back on what they say. Finally,we will submit every one of your entries to Ofcom'sconsultation in time for its August 10 deadline. Ifyou need any more incentive, remember the mantraof the digital revolution: interaction is all."

We would like to thank David Johnson, theEditor of Doors, and his staff, and thereaders who contributed to this importantdiscussion. The views they expressed havehelped us to shape the main conclusions setout in this statement.

Media literacy - what is it?

There is no single, agreed definition ofmedia literacy.

But just as traditional literacy is aboutbeing able to read and write text, so medialiteracy is the ability to ‘read’ and ‘write’audiovisual information.

At its simplest level, media literacy meansbeing able to use a range of media and beable to understand the information it givesyou.

At a more advanced level, it also meansbeing able to question, analyse, appreciateand evaluate that information.

Someone who is media-literate may also beable to create communications in electronicform, such as write e-mails, and design webpages or video materials.

With this in mind, the consultation cameup with a definition of media literacy asbeing “the ability to access, analyse,evaluate and produce communications in avariety of forms”. Or, put simply, beingable to use the technology to:

• find what you’re looking for;

• understand what it is about;


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Introduction and definition of media literacySection


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Our response

Although our working definition of medialiteracy is short and simple, we believe it isbroad enough to cover all types ofcommunication technology, types ofcontent and the different ways people usethem.

However, we do go along with AndreaMillwood Hargrave and Sonia Livingstone,who suggested using ‘create’ rather than‘produce’ to recognise the creative aspect ofthe communication process. We also agreewith replacing ‘forms’ with the more wide-ranging ‘contexts’. This means that thesame content (for example, video) can beaccessed on different platforms (forexample, television, PC or a mobile phone),and that they have their owncharacteristics. In other words, they work todifferent rules, are seen in different placesand circumstances, and so on.

Although we do see a difference between‘analyse’ and ‘evaluate’, we take the pointmade by BT that it is a fine distinction. Weconsider that we can describe both theseabilities with the word ‘understand’.

As a result, we will use this definition.‘Media literacy is the ability toaccess, understand and createcommunications in a variety ofcontexts.’

However, we recognise that everybodyinvolved will continue to use a definitionthat emphasises their own priorities andaims.

• have an opinion about it; and

• where necessary, respond to it.

Media-literate people are able to makeinformed choices about what they watchand the services they use. They’re able totake advantage of the full range ofopportunities offered by newcommunications technologies, and arebetter able to protect themselves and theirfamilies from harmful or offensive material.

Responses to the consultation

A number of the people and organisationswho responded had comments on ourworking definition. Other definitions,mainly put forward by stakeholders in film(UK Film Council and bfi) and education(Institute of Education, NIACE), felt thatbeing able to question and evaluatecontent, to know what people like, theirability to see quality and show imaginationwere more important to media literacy thantechnology or production skills (ScottishScreen and others), knowledge of costs(ICSTIS and TUFF) and an understandingof copyright issues (British Music Rightsand others).

BT commented that the difference between‘analysis’ and ‘evaluation’ is so small thatwe shouldn’t separate the two into differentcategories.


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This is a golden opportunity to focuseveryone’s attention on the future needs ofall members of society. Our main role willbe to show leadership in promoting medialiteracy. We will use our influence to makethings happen. This may include providingfunding for other people’s projects in thesame direction which, otherwise, might notget off the ground. We will be setting outour priorities and consulting people fromall walks of life, of all ages, and in all areasof the UK to get to the widest possiblespread of views.

But whatever we achieve in promotingmedia literacy will be through persuasionand debate. We have no powers, or desire,to make people do what we want them to.

Improving media literacy involves all kindsof different people and organisations.Content producers, broadcasters, platformproviders such as digital networks andonline services already have a responsibilityin this area. They’re well placed to offeradvice, support and guidance to theircustomers.

Education plays a vital role in laying thefoundations of media literacy. Schools,colleges and universities can develop theskills of students of all levels, and to carryout research which will help shape futureaction. There are also opportunities in lessformal settings, such as libraries, UKOnline and community art centres, to givepeople over school age a taste ofcommunication technology and theexperience they can offer.

The Home Office, the Department forEducation and Skills, the Department forCulture Media and Sport and theDepartment of Trade and Industry all haveresponsibilities when it comes to medialiteracy.

Parents, carers, children’s charities, viewerand listener organisations and others quiterightly focus on issues of harm and offence,and protecting young and vulnerablepeople.

There are also many organisations who canhelp people get to grips with newtechnologies. These include theIndependent Committee for theSupervision of Standards of TelephoneInformation Services (ICSTIS - forpremium-rate telephone calls and services),the Internet Service Providers’ Association,the British Board of Film Classification, theEntertainment & Leisure SoftwarePublishers Association (ELSPA - for thegames industry), the British EducationalCommunications and Technology Agency(BECTA) and various European Unionprojects related to a European project tomake the internet a safer place called theSafer Internet Action Plan.


There weren’t many views about theapproach we are planning to take. Peoplewho did comment supported our aim toshow leadership and encourage action.There were some calls for us to take a more

Our approachSection


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active role (Voice of the Listener andViewer (VLV) and others). NewsInternational said that the media operatorsalready promote media literacy veryeffectively, because it’s good for business.

Some organisations (The Centre for theStudy of Children Youth and Media, theInstitute of Education, the Regional ScreenAgencies and others) said we should helppeople to think and form opinions aboutwhat they hear and watch. Some (BECTAand others) suggested that actuallyproducing content improved media literacyand should be encouraged.

Our response

At Ofcom, we welcome the support we’vereceived to take a leadership role inpromoting media literacy. We will beactively encouraging all those involved tofocus on the future needs of all members ofsociety.

Our first action will be focused on areaswhere we can have the biggest effect, andwhere we see the greatest risks to people.While our research will show us whetherpeople think critically about programmesand services, most of our work will focus onthe general need for media literacy, how tomake the most of what’s on offer and howto control content. These are areas wherewe can make the most difference.

Our first work falls into three main areas,and we have outlined these on the followingpages.


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Research is essential if we’re to promotemedia literacy. The answers we receive willidentify the issues, shape our priorities and,later, show us how we’re performing.

Research carried out by the IndependentTelevision Commission (ITC) theBroadcasting Standards Commission (BSC), and others (see note 1 below) foundthat “little research on adults’ awarenessand understanding of the new andchanging media and informationenvironment has been conducted, so muchremains to be discovered and understood,this being crucial as increasingresponsibility for accessing content is beingdevolved to the public.

“Clearly, a well-defined vision - of the keydimensions of consumers’ skills andabilities, of the minimum and desired levelsof literacy required, of the populationsectors which risk being left out, of themost appropriate means of both promotingand evaluating media literacy – must bedebated and agreed if media literacy is toreach satisfactory levels across the wholepopulation.”

Together with others who have an interest,our research will begin to answer some ofthese questions and contribute to the policydebate in the future.

Our research will help us understand justhow media-literate people actually are, inall sections of society. Some groups, such aschildren, young people, parents and olderpeople may have particular needs. Somemay be vulnerable or risk being left behind.This research will show us which sections ofsociety are at risk and where we shouldfocus our resources.

We will also find out if anything ispreventing people from becoming moremedia-literate. For example, we need toknow if there are physical, learning, social,economic or technical barriers in the way.If so, which members of society are morelikely to be excluded? These answers willalso tell us who is best placed to helppeople get over those barriers.

Attitudes are also important. We will findout what people expect from a programmeor service, and this will help those whocreate content to give the right level ofinformation to avoid any risk of harm oroffence.

Technology can help here. You mayalready use electronic programme guides(EPGs) and filtering tools for the internet tohelp you access and control content. Ourresearch will help producers focus clearly

Research

1 Assessing the media literacy of UK adults, a review of the academic literature. Sonia Livingstone withNancy Thumim, March 2003. ITC, BSC and NIACE

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on your needs, with effective tools that areeasy to use.

Research will tell us about the moreadvanced skills people need. Whereappropriate, we’ll contribute to researchthat has been started by otherorganisations, and which can also help us.

Our research will include long-runningstudies of how people’s attitudes andexpectations of content may change withthe way they receive it. In particular, wewant to test new media literacy, and anyprotection worries, that may come withpersonal video recorders and the latestmobile phones that let you see the internetand can tell people where you are.

We particularly want to identify anythingthat could threaten the growth and use ofaccess tools, particularly on equipment thatlets you use the internet on the move.

We also plan to use research to form thebase of our two other main areas of work –connecting, partnering and signposting, andlabelling (audiovisual content).


There was strong support for our proposalto carry out research into media literacy.Most people agree that little is knownabout the level of media literacy in theUK. Several people who responded

suggested, as a first step, that we need toreview the research that already exists.Some offered research they had alreadycompleted. Several of those who responded(Media Literacy Task Force, Institute ofEducation and others) suggested questionsthat we should ask. The BBC and BTcommented that our research should not bedriven by the academic community, butshould offer practical information to directaction.

We discussed a number of importantresearch issues at a consultation meeting inJuly. Members of our Media Literacy andMarket Research teams noted some usefulcomments from the session.

Our response

The results of our research will form thebasis of our early work to promote medialiteracy. The basis of this research will be tocomplete an audit of media literacy skillsacross the UK, measuring people’sknowledge and understanding of thevarious media platforms. The results willhelp us assess not only the levels of medialiteracy, but different types of literacy aswell.


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We think that this early research willhighlight the need for more in-depth,specific research into areas such as:

• children using the latest mobile phones,and issues such as access to adult contentand using location-based services;

• attitudes towards harmful and offensivecontent and services on the internet (forexample, extreme websites promotingsuicide and race hate) and people’sunderstanding of the controls that alreadyexist; and

• barriers to using online services, due tothe abuse of personal information (forexample, theft of identity and bankdetails, unwanted e-mails and systemsecurity), and people’s experiences ofvirus protection software.

Other research activities include:

• two literature reviews of academicresearch into the media literacy of bothchildren and adults (these are alreadyunder way and will be published later thisyear);

• in-depth, opinion-based research onseparate areas of media literacy;

• research repeated over time to track theeffect of any media literacy programmes;and

• an invitation to form a media literacyresearch forum. We will askrepresentatives of broadcasting, theinternet, the mobile phone industry, andeducation to join with consumerorganisations and representatives ofEngland, Scotland, Wales and NorthernIreland to set up the forum. They will giveus expert comments on our research plansand tell us how future research can give usthe most valuable results.

The main principles behind the research

Our research principles will be to:

• involve the industry and others with aninterest (through the media literacyresearch forum) in developing ourresearch methods;

• make a priority of research areas whichcan be of real practical value to us andothers in the industry;

• respond to emerging issues; and

• monitor all relevant research from othersources.


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We aim to promote media literacy in everyway we can. This includes strengtheningother people’s existing activities, stimulatingnew work and promoting and directingpeople to advice and guidance on types oftechnology. In this area of work, we canhave an immediate effect in raising theprofile of media literacy and making theissues a priority for everyone involved.

Connecting

Our main role in this area is to bringtogether interested organisations and maketheir efforts as productive as possible inincreasing media literacy.

There are many projects, in education andelsewhere, designed to raise theunderstanding of media literacy. This isparticularly true in relation to ‘criticalviewing’. We will get behind these plansand encourage people to work together.

For example, we know that teachers haveproblems gaining access and rights to usecertain visual materials in their teaching.We are in an ideal position to get togetherwith a range of stakeholders to find ways ofmaking resources available for education.

Partnering

If research shows that people’s needs arenot being met, we will be in a position tojoin forces with others with an interest tomake a difference.

In particular, we will support plans toencourage elderly, and socially or physicallydisadvantaged people, to try newcommunications technology for themselves.

Signposting

There’s a lot going on in the area of medialiteracy; so much so, it’s hard to keep tabson the full range of activities and where tofind them. We aim to raise the awareness ofthose plans.

We will also direct people to advice andguidance on a range of issues related tocommunications technology.

For example, research tells us that althoughthere is plenty of good internet safetyadvice available, many parents don’t knowhow to manage their children’s experiencesonline (see note 2 below). Ofcom willencourage providers of those services togive guidance to their customers on safetyand good practice.

We said in the consultation that creating aseparate place on the internet whereinformation can be found, or using part ofour own website, will help us in this area.

Connecting, partnering and signposting

2 Assessing Internet Content Rating and Filtering Tool Effectiveness. I2 media research and Opta, December2003, ITC

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There was wide support for this area ofwork. In fact, we’ve already received severaloffers of partnership, some arising duringthe consultation, from organisationsranging from Media Smart to Learndirect.

BSkyB suggests that we should only takethis further when we have the results of themedia literacy research. They also want usto review activity that has already beencarried out.

Our response

We have a firm aim to put media literacy atthe front of everyone’s minds. This meanscreating our own projects, and contributingto other people’s, to raise awareness andstimulate debate of the central issuesthroughout the UK and in Europe. We willactively look for opportunities to encouragedebate, including conferences and events.

In May 2005, we will be working closelywith the National Institute of AdultContinuing Education (NIACE) and itspartners in Adult Learners’ Week (ALW).Media literacy will be a central themeduring the week, and in the run-up to theevent we’ll be supporting a number ofactivities including a series of workshopsthroughout England and Wales.

The UK takes over the presidency of theEU in the second half of 2005. We havebegun discussions with the Department of

Culture, Media and Sport (DCMS )on ajoint initiative during the presidency tohighlight the importance of focusing onmedia literacy across Europe.

In terms of advice and guidance, researchhas shown that if families aren’t usingsoftware to manage their children’s onlineactivity, it is likely that the parents see it ashard to install and not user-friendly. Weand the Home Office have begun workwith the industry to create a BritishStandard (Kite Mark) for domestic-filteringsoftware. The standard will encourageproviders to make their products moreeffective and easier to use. The kitemarkwill also help give users confidence, andincrease the number using it. The standardwill be published in 2005.

Older people are also likely to need help.As a result, we have got together with Helpthe Aged to plan a series of workshops attheir Speaking Up for Our Age forums.Members at the workshops will then passon their learning and experiencethroughout the membership of the 350groups in the UK.

We will continue to work with centralpartners, and find new ones in all sectors ofthe communications industry, as well asother relevant stakeholders. Our researchwill help us to guide stakeholder plans topromote media literacy, and we’ll lend oursupport to make best use of their work.


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We will also offer money to support newprojects where we have seen a clear need,and where the project would not go aheadwithout our support.

The consultation suggested creating aseparate place on the internet (a medialiteracy portal) to direct people to helpfulmaterial. We have decided to develop thiswork as part of our own website(www.ofcom.org.uk).

The portal will include:

• information for children and parents onhow to use communications technologysafely;

• consumer information, such asinformation on digital television andradio, and guidance on online shoppingand so on. (‘e-commerce’);

• information for teachers and othereducation professionals on media literacy;and

• links to relevant websites and researchinto issues on media literacy.

We are considering publishing a medialiteracy newsletter (online), to spreadinformation and raise the profile of ourwork in this area.


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In future, viewers and listeners will be ableto get their ‘content’ by satellite, cable,digital terrestrial television or digital audiobroadcast. It may be by subscription, free toair, encrypted or PIN-protected. You maybe able to access online content throughpremium-rate phone lines, over the internetor by broadband connection. We can watchand hear programmes on television andradios, on PCs or on 3G mobiles.Programmes may be available on demandat any time, or recorded to watch later bypersonal video recorders. Content will alsocome to us on VHS, CD, MP3 and DVD.Some of this content will be regulated,some not. As you can imagine, there’s hugepotential here for confusion, frustration andoffence.

No matter what the source, young andvulnerable people need protection frominappropriate and harmful content andservices. Our codes will continue to givethem protection in the areas we regulate.The industry will also take someresponsibility. But all of us will have to takemore responsibility for what we, and ourfamilies, watch and listen to.

We have to become ‘active’ viewers andlisteners, and some more than others.Families with young children, for example,may need particular help.

We need to know more about the nature ofprogrammes and how they come to be onour screens and radios. We need to knowhow to get the programmes we want, and

how to stop those we don’t. In short, wewill have to take more control of ourviewing and listening.

We think that viewers and listeners canonly make informed choices with clear,accurate and timely advice about content.To provide this, we need a framework tolabel the content.

We challenged the industry to create andapply this framework to all electronicaudiovisual material, no matter how it isdistributed. With industry agreement, weproposed that we should set up, as a firststep, a working group on labelling fromacross the media (including the BBC,commercial public service bradcasters ,BSkyB, the British Board of FilmClassification (BBFC), the mobile industry,the Internet Service Providers’ Association(ISPA), the Entertainment and LeisureSoftware Publishers’ Association (ELSPA),and others).

We propose the following definitions.

• Label – a word or phrase to describe thenature of the content (for example,‘contains strong language’).

• Rating – a judgement of the nature ofthe content (for example, ‘suitable forfamily viewing’), also known as a‘classification’.

• Audiovisual material – any content thatuses a combination of sight and sound topresent information (for example, video,but not still images).

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The Netherlands was the first country tointroduce a single classification system forthe audiovisual industry. Research by theNetherlands Broadcasting Corporationsuggests that over 80% of parents ofchildren aged between four and 15 wantsome sort of classification of audiovisualproducts (see note 3 below). A similarpercentage said that if a classificationsystem was available, they’d use it. Inparticular, parents want to know ifproductions contain violence,discrimination, drug abuse, frighteningscenes, strong language and sex. Researchby the BBFC confirms these findings andsuggests these categories should go further,to include an idea of how often or howstrong (see note 4 below).

The BBC has also found that TV viewersprefer information about programmes to bedelivered to them as clear messages in text,describing any content which may causeoffence.

In the digital age, viewers and listeners willrely more and more on programme makersand broadcasters to tell them what’s beingprovided. While some information includedin labels may help in searching, our mainconcern is to make sure the information ispresented in a consistent way. Only thencan young and vulnerable people beproperly protected from possible harmful oroffensive content.

However, already different sectors anddifferent rules are leading to a messy rangeof labels and information. Unless everyonestarts to work together, this could be arecipe for real confusion.

We have a critical role to play, to make surethat viewers and listeners in the digital agehave consistent, accurate information theycan trust.


This proposal was supported by consumergroups, many non-industry organisations(film, education, academics, libraries andchild-protection agencies) and privateindividuals.

However, most television broadcasters(apart from the BBC, Scottish MediaGroup (SMG) and The CommunityChannel) were against the idea of acommon labelling scheme – at least fornow. The commercial public servicebroadcasting (PSB) channels (ITV, Channel4 and Five) do not believe there’s enoughevidence of potential harm to justify thepossible cost. They are also not convincedthat different labelling schemes meanthey’re confusing, or that a single labellingsystem will guarantee informed choices.They also argue that viewers haveparticular expectations according to thechannel or brand they’re watching

3 http://www.kijkwijzer.nl/engels/ekijkwijzer.html

4 Sense & Sensibilities: Public Opinion & the BBFC Guidelines, September 2000


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(especially with the PSBs). Since the viewer‘understands’ a channel, it reduces the needfor a common framework which, theyargue, could actually weaken their brands.

The Internet Service Providers’ Association(ISPA) and various other web-publishingstakeholders (The Newspaper Society andothers) also expressed their concern, as didthe Mobile Broadband Group (MBG).

A general worry was the basic differencesbetween broadcast material (which isregulated) and online material (which isn’t),and the feeling that a common labellingframework could just be regulation usinganother name (ISPA and Yahoo).

Many also thought it would be difficult toput a common framework in place fordifferent types of media. However, theInternet Content Rating Association(ICRA) showed how their own labellingsystem for internet content could bedeveloped for all media.

THUS pointed out that a commonframework, even if it could be applied toweb material created in the UK, mightconfuse or even cause a false sense ofsecurity if foreign material was not labelledin a similar way.

A number of important issues related tolabelling were discussed at a consultationmeeting in July. Members of the MediaLiteracy team were there to hear thecomments.

Our response

Our view is still firm. Viewers and listenersneed enough information about content, tomake informed choices about what theywatch and listen to. We realise the likelyeffect that changing viewing habits willhave on the industry. However, the soonerwe recognise and begin to prepare for thesechanges, the less of an effect they are likelyto have on viewers and the industry.

We recognise the concerns expressed in theconsultation responses, and without thesupport of broadcasters and internetservice providers the initiative will notsucceed. For this reason, we consider thatthe first task of the working group is tocarry out more research.

The working group will investigate howviewers in the digital age want to receiveinformation about the nature ofchallenging content, as they sit down tomake their choices. We will inviterepresentatives of the PSB broadcasters,BSkyB, BBFC, ISPA, ICRA, the children’scharities, the Mobile Broadband Group,Voice of the Listener and Viewer (VLV)and others to form a working group. Themission will be to look at how viewing andlistening habits may change in a digitalworld, where multi-channel broadcast,personal video recorders and on-demandservices may become routine. The groupwill be able to look at the experiences ofother countries, where similar labellingschemes are up and running. The outcomeof this research will show what we need todo to allow people to make informedchoices in the digital age.


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Regulatory impact assessment (RIA)

A number of people who replied disagreedwith our proposal not to carry out aregulatory impact assessment (RIA). Wesaid in the consultation that since we wereworking with the approval of stakeholders,and we were not proposing detailed plans,we did not believe this kind of assessmentwas necessary. The purpose of theconsultation was simply to gather people’sviews on ways to promote media literacy.

However, BSkyB argued that any ‘proposal’we made could have a significant effect onthose involved, within the meaning ofSection 7 of the Communications Act. Inparticular, it argued that our decision thatwe need a common labelling system shouldonly apply if we have an RIA.

The Internet Service Providers’ Association(ISPA) commented that any attempt toforce content labelling onto internet serviceproviders would need an RIA. If this iswhat we were planning to do, we would ofcourse fully consider the need for an RIA.However, our consultation was notproposing a compulsory labelling system.

Andrea Millwood Hargrave and SoniaLivingstone argued that media literacy willhave a significant effect on the generalpublic - and that a media-literate publicwill, in turn, have a significant effect onbusinesses in the UK.

Our response

As we said in our original consultation,these initiatives (such as a working groupconsidering a possible scheme for labellingcontent) should only stimulate discussionamong those involved. The consultationwas not proposing options we should put inplace.

We understand the industry’s concern that,even if a proposal is not for regulatoryaction, it should be thoroughly analysedagainst the range of options available.

However, we do not believe the challengemade to the industry - to consider creatinga common scheme for labelling content -was advanced enough to merit an RIA.

We still strongly support the idea thatviewers and listeners should haveinformation about the nature of content,allowing them to make informed choicesover what they watch and listen to. Weinvite the industry to take part in a workinggroup on labelling content. We will ask thisgroup to look at further research into theissue, and we would expect them toconsider a number of different options.

We believe that media literacy as a wholewill have an effect on the general public.However, the other areas of work we haveidentified - research, and connecting,partnering and signposting - are tools tohelp us understand what else needs tohappen to increase levels of media literacy.

Other issues raised in the consultationSection


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For example, our research work may wellhighlight issues or concerns that couldneed further action, but it would only be atthat stage that we would ask whether anRIA was appropriate. It’s too early in theprocess to consider that question now.

Regulating the internet

CHIS (the Children’s Charities’ Coalitionon Internet Safety) commented that“implicit in the discussions on theCommunications Bill in Parliament wasthe notion that, should Ofcom becomeconvinced that the internet industry wasfailing to make reasonable and timelyprogress in terms facilitating effectiveparental controls in relation to internetaccess, or in terms of developing greatermedia literacy in relation to the internetamong parents, that you [Ofcom] could goback to ask the Secretary of State to giveyou new powers or directions”.

Our response

In the Communications Act, Parliamentmade a clear distinction between broadcastcontent (which we must regulate), andinternet content (which is outside ourresponsibility). Our board believes this was

the right approach. However, over timeand as new technology means that contentcan be broadcast over the internet, thedifference between ‘broadcast’ and‘internet’ content will blur. The debatehasn’t yet begun – in society, in industry orin Parliament – on whether the rulesregulating broadcasting should also beapplied to the internet.

Greater self-regulation will undoubtedlyplay a role. Internet users have far morepowerful tools, such as filtering softwareand parental controls, than televisionviewers or radio listeners. However, theremay also be specific areas where relying onthe good sense of providers, and theabilities of media-literate users - is notenough. Where those areas are and what,if anything, could or should be done aboutthem are questions that should be centralin the debate ahead.

Regulating the press online

The Newspaper Society (NS), NewsInternational (NI), the PeriodicalPublishers Association (PPA) and othersexpressed concern about the possibility ofus regulating online content that is alsopublished in print (‘online print material’).The NS and PPA were concerned aboutthe possibility of ‘creeping regulation’.


www.ofcom.org.uk

News International (NI) shares thisconcern but was more explicit: “Weurgently seek a more explicit statementfrom Ofcom that its work in the area ofmedia literacy will not include the printmedia in any form – either offline oronline.”

Our response

We do not plan to regulate online content,whether it is published just online, or alsoin print.

However, material published online (in theterms set out in Section 11 of theCommunications Act 2003), falls withinthe scope of our duties. However, we donot plan any specific activity in this area.

Riverside House2a Southwark Bridge RoadLondon SE1 9HASwitchboard +44 (0)20 7981 3000Facsimile +44 (0)20 7981 3333www.ofcom.org.uk

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