On 1st June 2004, the UK Office of Communications (Ofcom) published a consultation on its strategy and priorities for the promotion of media literacy. ICRA’s response is given below.
- The Internet Content Rating Association is an international, non-profit organisation whose mission is to protect children from potentially harmful material while protecting free speech on the internet. ICRA has offices in the UK and US and Points of Presence in both Germany and Hong Kong. The labelling questionnaire has been translated into the major European languages as well as Traditional Chinese. Increasingly, and with the expected Quatro project, we see our role as directing people to the content they want, to trust what they find and to block what they don’t want to see for themselves or for their children.
- We do this through a global content labelling scheme to allow publishers in all digital industries worldwide to label content and allow it to be identified and, where appropriate, filtered. ICRA has its origin in the internet environment, but can be extended to provide a common underlying labelling scheme for all digital content and platforms – mobile, TV, games and so on.
- We welcome the clear distinction made between the words label and rating in the document circulated at the recent Ofcom meeting on Media Literacy. We will use the definitions that Ofcom itself uses in our response so that a label is a word or phrase to describe the nature of content where as a rating is an appraisal of the nature of content – usually an age-based category, eg, 12 or 15. This is also commonly known as a classification. It must be said that Ofcom’s own consultation document dated 1 June 2004 uses these words interchangeably and this, we believe, has led to a good deal of confusion in the press and in the discussions with various media representatives.
- A further distinction needs to be made and that is the difference between a visual label (often an age-based rating!) that appears on an actual product, such as a movie rating before a film or on a poster; an age-based rating on a computer game, etc. and a machine-readable label that travels with the digital content, eg, an ICRA label that describes the content of an internet site or page read by a localised filter or blocking software. Once again, we feel there is considerable confusion in the minds of those in the industry, never mind the public, about this important distinction.
- Therefore, we believe that Ofcom’s perceived ambition to create a single means for rating media is highly ambitious. We believe the existing rating schemes in the entertainment industry are too far advanced and diverse to allow easy conversion into a single unified labelling scheme. Neither do we believe they need to be integrated, but rather, they do need to be normalised and based on a common foundation.
- ICRA has a unique role to play in this unifying process. ICRA can provide the underlying scheme for labelling content for all media, with each media sector then applying its own rating scheme based on its existing (or created) standards but related back to the ICRA labelling scheme. ICRA provides the objective description of what type of content is contained in the media in question, and the specific rating scheme determines what age classification mechanism is appropriate for its industry and where it draws the line for each age category of content.
- A parallel example may be drawn from the car insurance industry. Car manufacturers label their products with certain engine sizes and brake horse power levels. Then each national insurance industry translates this common set of information into a set of insurance Group ratings, based on the specific characteristics of the national car insurance market. The engine specification scheme can be common to all markets, yet is interpreted differently by each set of national standards.
- The fundamental benefit of ICRA’s approach is that the consumer rating standard is set independently from the ICRA labelling, meaning that:
- multiple parallel rating schemes (cinema, home video etc) can draw on the same common ICRA label but accommodate different consumer standards (see multi-layered approach model below)
- the content only needs to be ICRA labelled once – content providers can use a single label across all their markets worldwide – the rating for a particular piece of media can be changed between countries or as societal standards change
- content providers can do their own ICRA labelling so there is no bottleneck preventing scalability
- One way to visualise this is to use the chart below. The multi-layered approach model shows the different levels or layers involved in achieving Ofcom’s goal of greater media literacy among the public of all kinds of digital media. While the model looks complicated, the consumer would only be concerned with the top layer itself. Content providers would only be asked to fill out the common labelling scheme once and the various rating schemes would be asked to create a mapping between their systems and ICRA labels. Such a mapping may be quite sophisticated. For example, the presence of nudity, violence and potentially offensive language together may put content in a different category than any single content type would on their own.
- ICRA board members are currently leading two working groups to achieve this. Firstly, ICRA’s descriptive vocabulary is being reviewed to ensure that it can address the needs of the full range of digital content, not just websites. ICRA will publish recommended methods by which the vocabulary can be extended to meet further demands of, for example, as yet undefined media, content types, special interest groups or countries. Secondly, modern methods of labelling based on XML/RDF are being developed. This will make it significantly easier to add machine-readable labels to digital content than is possible using the present PICS system. That said, the two exist independently. ICRA’s descriptive vocabulary is technology-neutral and can
be used without reference to any specific encoding method.
- It would then be the job of filtering manufacturers, parental controls for televisions, mobile phones, etc, to create a consumer-friendly interface using an existing (age-based) classification or rating scheme to allow parents to easily and quickly choose what content they do and do not want their children (or themselves) to see.
- ICRA, therefore, recommends OFCOM to consider the introduction of the ICRA system (or a development of it) as the common underlying labelling scheme while working with a cross-industry group of experts to create
appropriate mappings between rating schemes and the revised ICRA vocabulary.
A multi-layered approach
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This model is presented to provide a pictorial view of what we are trying to convey using Ofcom’s own definitions:
Label – a word or phrase to describe the nature of content, eg, contains strong language
Rating – an appraisal of the nature of content, eg, suitable for family viewing (also referred to as a classification)
In this way, the existing rating schemes can flourish while working with the underlying labelling scheme offered by ICRA. This allows for the all important machine-readable labels (in PICS, RDF or any other future standard) to flow with the content and be read by filters based in TVs, PCs, PDAs, etc.
An example of this is seen in the recently enacted Internet Content Rating Regulation in Taiwan. Here, the four age-based film categories of the Taiwanese classification system have been mapped to the ICRA system. The content provider is urged to label using the ICRA system, and this is converted into an age-based rating logo based on their movie industry standards. Thus they have both a machine-readable label (in the PICS standard) and a visual logo or label based on their country-specific rating scheme.
Stephen BalkamInternet Content Rating Association
8 August, 2004
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