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Consultation titleHow to promote Media Literacy: Consultation on recommendations for online platforms, broad-casters and servicesFull nameStéphane GoldsteinContact phone numberRepresenting (delete as appropriate)OrganisationOrganisation nameMedia and Information Literacy Alliance - MILAEmail addressYour details: We will keep your contact number and email address confidential. Is there anything else you want to keep con-fidential? Delete as appropriate.NothingYour response: Please indicate how much of your response you want to keep confi-dential. Delete as appropriate.NoneFor confidential responses, can OfcomYespublish a reference to the contents of yourresponse?QuestionYour responseQuestion 1: Is it clear which types of organisations the 10 proposed recom-mendations are aimed at? Please pro-vide reasons and evidence to support your answer.Confidential? – N The four categories of organisations set out in chapter 3 are clear and seem to be comprehensive, although as with any fast-moving technology, it is important to en-sure that the list of types of services is regularly updated to ensure future proofing. We have two more specific comments/questions: Do the references to online games also include • gaming apps? We feel that the gaming ecosys-tem could be better described in the recommen-dations. We note that the recommendations make no • reference to mobile operators - yet these could be relevant because they provide device-level opportunities and levers to introduce friction into payment systems.Question 2: Do you have any com-ments on whether they should apply to all organisations, including those of different sizes and operating models? Please provide reasons and evidence to support your answer.Confidential? – N We understand that it is necessary for the recommenda-tions to apply to as wide a range of services as possible. But we also recognise the differences between large players and small organisations, such as micro-scale de-velopers of online games, which do not have the same resources, human and financial, as say PSBs. Moreover, PSBs in particular may have educational obligations, and therefore have a basis for developing appropriate poli-cies, in a way which is more difficult for say a start-up whose reach is also much more limited. But at the same time, smaller platforms can also be harmful, and they too need to adopt media literacy by design principles, provided these are clear just as they adopt accessibility designs.Question 3: Do you have any com-ments on the proposed recommenda-tions? Please provide comments in particular on their effectiveness, ap-plicability or risks. Please provide evi-dence to support your answer.Confidential? – N The thematic arrangement of the recommendations to follow the user journey is helpful, although we are sur-prised that only two of them are about product design, with the others being equipping users to deal with the consequences of that design. Designing good practices into services and platforms seems to be critical. But in allQuestionYour responsecases, the recommendations feel like no more than po-lite requests with little scope for compulsion or enforce-ment - all very sensible, but there is too much room for interpretation in them. Platforms could build laudable policies around these, or alternately a bare minimum with little actual impact. And while we recognise the im-portance of encouraging users to be proactive about tak-ing action - but in practice, harried users may not always have the time to do this, and service providers them-selves need to do more to encourage such proactivity and not simply pass the buck to users. Recommendations 1 and 2: these are well intentioned, but we wonder whether they are strong enough in push-ing platforms to be transparent about design intended to keep people (including children) online for longer. Help-ing users understand how their data is being used, why they see certain information in their feed and how they can control this is hugely important. The use of overly long/complex terms of use is not helpful as most people do not read these. Simple choices at the sign-up stage that are clear are vital. Recommendations 3 to 6: these rely on the user to rec-ognise their need for ‘training’ and could be seen as re-active approaches to media literacy, rather than pro-ac-tive. Some specific points: The crucial section (recommendation 4) on de-• veloping critical faculties, which lie at the heart of MIL, states that "it is vital that service provid-ers support people in developing the critical thinking skills needed to navigate today’s com-plex digital landscape", but it goes on to say that "how they empower their users and audiences will be a matter for them". Unfortunately, this leaves service providers with the option to do as little as they choose to help develop users' criti-cal faculties, and this may be insufficient. The document rightly says that “service providers [should] provide meaningful context about con-tent and sources”, but we feel that the recom-mendation should be stronger and clearer about how media literacy by design should include for instance prompting users before they re-shareQuestionYour responsecontent, notably asking them to check their sources. Moreover, and more broadly that the responsi-• bility of service providers (also recommendation 4), there is also the question of enabling the ‘pre-requisites’ for users being critical and em-powered, in terms of understanding for instance how algorithms work and the functional model design. This underlines the importance of educa-tion, including in schools, to develop people’s critical capacity and motivation. Yet the recom-mendations do not mention this important link with education, other than briefly (recommenda-tion 6) in the context of platforms building rela-tionships with third sector organisations. We feel that the recommendations would benefit from more reference to the role of formal education. Parental control at sign-up and 'other opportune • moments' seems to be weak (recommendation 5). What constitutes an 'opportune moment?' and parental control/ being informed at those points? There is a recognition (recommendation 5) of • the parallel between addictive online behaviour and gambling, but with only weak proposals around transparency and developing users’ un-derstanding of monetisation and commercial features. Why not treat the potential for online addictiveness with the same severity and regula-tion associated with gambling? It is a rather pious hope (recommendation 6) • that online platforms "explore ways to share timely links" (a rather vague and ill-defined no-tion) with reputable third sector organisations. It also leaves platforms to decide which organisa-tions to link to - a problem that has come up many times before and been kicked down the road. Recommendations 7 to 9: building trust is vital, and plat-forms need to work together to achieve consistency ra-ther than each try to do this separately. Regarding edu-cational content and skills-building (recommendations 7-QuestionYour response8), it is not sufficient to rely on what services and plat-forms themselves provide: their offerings are liable to be devised to suit their own agendas; and moreover, they could quite easily invest in educational programmes which, whilst sitting outside their products, still follow bad practice themselves. For us, this means a stronger recognition of long-term education independent of ser-vice providers and with no strings attached - which links to what we say above in response to recommendation 4. The recommendation recognises the distinct and historic educational role played by the BBC, but the Corporation has a charter that sets out its educational obligations (with media literacy inherent in those) and it is not clear whether that can serve as a model for other PSBs, let alone other players. Recommendation 10: we recognise the fundamental im-portance of evaluation, and we concur that standards across platforms and services should be agreed to and monitored and evaluated regularly. However, we have two remarks: We wonder whether evaluation might be better • conducted in association with neutral third par-ties so that there are some standard measures across platforms and services. Given the effort that Ofcom has been putting • into developing evaluative methods based around Theory of Change, it is bizarre that this does not feature at all in the recommendations or even in the entire document.Question 4: Are there any other addi-tional recommendations you think we should consider? If so, please provide evidence to support your comment.Confidential? – N We suggest three areas that would benefit from atten-tion. These are not necessarily additional recommenda-tions - they could be built into the proposed Ofcom rec-ommendations to boost their ambition and/or their clout. Enabling users to have higher expectations for • platforms, services and broadcasters to act ethi-cally and in the public interest: Encouraging users to act when they encounter • harmful content or exploitative practices, withQuestionYour responseservice providers to deploy mechanisms which make this easy to do for users. One aspect of media literacy where platforms al-• ready do quite a lot of work is around copyright education. Primarily this is to protect the plat-form from litigation and accusations of copyright infringement on platforms that allow users to upload content. However, this is an area where many services already have thought about some embedded support - so prompts about confirm-ing copyright ownership when users upload con-tent are common. Automated checks also take place on platforms like YouTube, Spotify to try to identify infringing content. A similar approach might be taken with prompting people to think before they share and to fact check misinfor-mation. In line with what we have stated above under recom-mendation 10, there is a strong case for recommending explicitly the deployment of Theory of Change to help evaluate reach and impact, building on the methodology and practice that Ofcom itself has developed over the past 2-3 years.Question 5: Do you have any exam-ples or suggestions of ways of encour-aging services to adopt these recom-mendations?Confidential? – N Under the heading of evaluating and reporting, we sug-gest the deployment of adapted forms of accreditation, perhaps involving kitemarks or badging, to indicate in a simple and intuitive way that services have met certain defined standards that address media literacy impera-tives. But we recognise too that this would be very chal-lenging. Moreover, accreditation would not be manda-tory, so there is a need to reflect on what might encour-age services to comply. There could be benefits to them through showcasing good practice, maybe also involving awards and commendations.Question 6: Do you have any com-Confidential? – N We have no comments to make under this heading.ments on our impact assessment,rights assessment, equality impact as-sessment and Welsh language assess-ment? Please provide evidence in sup-port your answer.
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Please complete this form in full and return to MSOM_SoR_Consultation@ofcom.org.uk.