Response to Ofcom consultation

Ofcom has produced a set of recommendations that focus on giving people more control over their online experience.  It aims to do this by helping service providers understand how they can promote media literacy. 

The recommendations apply to all service providers that create, host and distribute content and media through broadcast, on-demand and online platforms, including social media and streaming services. They are not a set of mandatory rules. They are a statement of good practice.

Media literacy by design and accessible intuitive, practical tools

We welcome the regulator’s recommendation to embed media literacy by design and adopt inclusive design practices to address a broad spectrum of media literacy needs. We also welcome the recommendation to provide accessible, intuitive, practical tools for people to manage their experience during use of platforms and online content and offer clear meaningful choices and transparent information at key points in the service experience.

In addition, REPHRAIN advises that:

• Developers and service providers should be supported through media-literacy-style education to ensure that the people building these digital services have a good understanding of accessibility and inclusion.
• Capability Approach framework should be used to assess the individual needs of users to ensure they and their abilities and capabilities, as well as any environmental/contextual factors, are at the centre of the provision. This will enable the recommendations to cover a diverse range of users.
• A code of practice, or other guidance – similar to Beeban Kidron’s “Age-Appropriate Design: A Code of Practice for Online Services” – should be implemented to support service providers in adopting this approach  to media literacy.  

Support for media literacy skills development

We appreciate the recommendation for service providers to commit to funding of skills-building programmes in partnership with charities, educators and other bodies and to co-design and deliver media literacy interventions with third sector organisations, government bodies, Ofcom, and grassroots community groups.

The advice to publish an annual statement on these activities and an assessment of their impact may incentivise service providers to follow suit.

However, REPHRAIN proposes:

• Ensuring a balance is achieved between users’ media literacy skills and the accessibility of the systems and interfaces they interact with. There is a risk of victim blaming if interface design remains confusing and the focus is on users to develop better skills to cope with it. Literacy outcomes must be measured by ability to act on information, not exposure. Ofcom should highlight “usability of privacy” as a media literacy issue not just user knowledge, and system design that supports comprehension and control.
• Ofcom should consider providing centralised compliance toolkits and shared literacy resources to support the implementation of these media literacy measures by service providers and to level the playing field for SMEs. 

Supporting parents and children in age-appropriate and meaningful ways

We welcome the focus on stronger privacy and safety defaults for child accounts and profiles, and clear display of parental controls and transparency around commercial features and costs.

Service providers are also advised to work with expert third parties to provide tailored guidance to parents and caregivers, to enhance media literacy support. This specialised support will certainly be useful.

REPHRAIN recommends in addition to this that a culturally and linguistically inclusive approach to media literacy should be taken. This might include, for example:

• Co-designing educational resources with underrepresented communities, such as migrant parents, to ensure greater accessibility and inclusion.
• Introducing digital literacy initiatives, such as Privacy clinics or community-based programs, delivered in different languages for people of different cultural backgrounds.

Read the response to the Ofcom consultation for the full arguments and evidence.

Contact the REPHRAIN team if you have any queries of questions.