Response to consultation on Ofcom’s strategy and priorities for the promotion of media literacy

General points

MeCCSA welcomes the increasing recognition of the importance
of the role of the media in all its forms in modern societies
and in particular the emphasis on the concept of media literacy
and Ofcom’s role in promoting it. We endorse the evidence-based
approach to policy and recommend partnership with media experts
in the higher education sector as a cost-effective way of
identifying research already in the public domain and areas
where more research is required to address fully the complex
of issues, problems and practice-based solutions to media

The Communications Act proposes more deregulation of the
media, promising access to increasing layers of mediated
information and entertainment and shifting responsibility
for media content from the government to the home. MeCCSA
acknowledges that the role of Ofcom is to attempt to ensure
that this shift is as inclusive as possible while also equipping
people with the skills to filter content where it is perceived
necessary. This is a crucial and complex aspect of Ofcom’s
responsibilities since educating consumers to become literate
involves more than labelling, guidelines and warnings about
problematic content. We appreciate also that the Communications
Act emphasises the importance of competition but would stress
that an ever increasing amount of mediated information and
entertainment from similar sources for similar ends (financial
profit) does not amount to increased choice and can act as
a block to understanding. Our response is built on the premise
that media literacy should not be defined from a consumerist
position wherein the ‘buyer’ is given full responsibility
for consuming the goods on offer but be a genuinely democratic
concept which involves a broad definition of education in
a variety of contexts, one of which is higher education.

Question 1: What is your view of Ofcom’s proposed
definition of media literacy?

The definition of media literacy is broad but focuses heavily
on access, technical abilities and labelling and rating. While
MeCCSA would agree these are necessary tools to facilitate
media use they offer the least ambitious interpretation of
media literacy; such an approach runs the risk that an opportunity
to truly engage and empower people through the media would
be forfeited. Although MeCCSA acknowledges that gaining access
and connecting to the media is a crucial entry point, developing
media literacy involves far more than the acquisition of
technical skills and know-how. MeCCSA would like to see more
emphasis put on the notion of critical engagement and active
participation with the media. To fully understand,
navigate and gain access to a whole range of opportunities
provided by the media requires the critical abilities to
understand and evaluate the content and processes therein.
Extending critical capacity in relation to the media will
also benefit those who take advantage of the opportunities
in new media in particular to become cultural producers.
As creators of media content themselves the likelihood is
that they will appreciate the nature and practice of mediation
more thoroughly while being aware of the potential impact
any media product may have.

Any definition adopted needs to be flexible, in order that
the definition can change as we learn more about media literacy.
The definition should also be able to take on board what
the public understand as media literacy. We will know more
about what media literacy is when more empirical research
is available on the way children and adults understand and
define the concept of media literacy for themselves.

Ofcom’s definition of media literacy over emphasises
children. Given good opportunities, children often learn
quickly the skills associated with media literacy and research
shows that they have firm views about what is produced for
them. Many adults, with fewer learning opportunities, find
it difficult to develop confidence and skills. In our view
it would be a mistake to prioritise children in Ofcom’s

Question 2: What do you consider to be the key role/s of
media literacy in the UK?

This question needs to be preceded by another: why do we
want media literacy? Is it so that everyone has equal ability
to become an effective consumer? Is it so that we can all
be creative and self expressive people? Or rather, as MeCCSA
would prefer to enable an informed citizenry to participate
fully in society. Social and political participation need
not of course exclude creative expression or cultural appreciation
but we would argue that the critical capacity to understand
and evaluate the media and cultural industries is the prerequisite
for all other skills relating to the media. We would like
to reverse the order of importance that is implied in the
consultation papers and place the ability to critically engage
with the media as a means of social participation in a wider
democracy at the very top of the agenda.

Question 3: Do you agree that each of the 3 proposed strands
of work (Research, Connecting, Partnering and Signposting
and Labelling) address an important element of the media
literacy landscape?

Research: MeCCSA believes that good quality research is
the key to understanding and addressing media literacy and
more research will be needed as policies are rolled out.
However, there is a lot of research already in the public
domain that addresses issues such as access and the digital
divide A critical first step in any commissioning of research
must be to gather together and evaluate relevant data and
analysis that already exists. Beyond questions of access
the research becomes far more complex, addressing issues
such as how to track access, how to investigate levels of
media literacy, when and how those levels have increased
or decreased and understanding meaning-making in relation
to the media. This is true across all forms of media not
just new media consumption as assumed in the consultation
papers. Research needs to draw on all the strengths and understanding
of scholars in the field and to cover all aspects of mass
and minor media with a focus on social participation.

Connecting and partnering will be vital to gain and sustain
any impetus created through the Communications Act. We would
strongly suggest that departments in higher education institutions
that have an interest in media and media literacy are included
in the partnering and connecting activities. Any research
undertaken in Higher Education Institutions into this area
would benefit from contact with other interested parties.
And importantly, other bodies and agencies involved in media
literacy would be able to keep up to date with the latest
research and thinking in the field.

Labelling and Signposting need to avoid patronising and
paternalistic approaches and be underpinned by UK-wide research
that seeks to identify areas of disagreement and difference
as well as possible areas of consensus in respect of taste
and values. Research is also required to investigate how
labelling and signposting can aid or inhibit people’s
understanding of media content. On their own labelling and
signposting as substitutes for positive content regulation
will not deliver media literacy even in its most limited

Question 4: Are there any specific areas which you consider
to be a priority that we have not considered here as part
of our early media literacy work?

From a media studies point of view, it makes little sense
to study only what people do with the media and not the media
content or the nature and practice of the media and cultural
industries. The problem of media literacy may well lie in
the type of mediated information and entertainment that is
available for consumption not in the skills of the consumer
per se. Media literacy should also extend to the media industries – are
they literate in the sense of offering or opening up
rational critical debate? Do they provide a range of information
and entertainment that affords people the opportunity to
make informed decisions and participate fully in their societies?

Adult media literacy has been addressed in a previous ITC/BSC
publication although this was only a review of existing literature
on adult media literacy. Programmes aimed at improving media
literacy need to call on a body of empirical evidence on
adult media literacy. Adults are the main media consumers
in Britain and we know relatively little about their experience
of media literacy over a period of time.

Question 5: What do you think are the types and levels of
media literacy skills necessary to enable citizen-consumers
to effectively manage and enjoy the opportunities offered
by new communication technologies? How do these differ for
particular sections of society?

The assessment of research in the consultation papers assumes
that only research in to new media consumption is relevant
to understanding media literacy. This is clearly not the
case. Research into the use of new communication technologies
has shown that they become embedded into existing media use
and that peoples’ social, political and domestic
lives are intertwined with media consumption at all levels
and across all media over time. Media literacy cannot and
should not be limited to new media. In a world of media convergence
it is critical to appreciate the complex interplay between
all forms of media as well as taking account of social and
political context in any consideration of media literacy.

The ITC conducted initial research in Personal Video Recorders
(PVRs), and Electronic Programme Guides (EPGs). This research
needs to continue in relation to media literacy. The more
children and adults have access to PVRs and EPGs the more
important it is to continue ongoing empirical research in
an emergent area of media literacy skills relating to access
and labelling, but also to critical engagement and evaluation
of television programmes.

The desire to participate creatively in media activity is
strong in many of those whom we teach. Social participation,
creative expression and cultural appreciation can be promoted
through cultural production. New technologies in particular,
open up new possibilities for user empowerment through production.
But there is still also plentiful unexplored potential in
more traditional media for increased user creativity, participation
and production. Work in these areas needs to be underpinned
by a much broader understanding of the possibilities of interactivity
and cultural production than that displayed by many commercial

Question 6: What do you see as being the key barriers to
achieving appropriate levels of media literacy in the UK?

One barrier to increased media literacy for children, and
in particular, adults, is the media itself. The social stigmatization
of the media as harmful, for example, the common assumption
that ‘watching television is bad for you’, creates
a negative environment in which audiences/users are nervous
about learning from the media, in particular popular media,
such as soap operas, or reality television. If we want to
understand how literate children and adults are, then we
need to understand the social stigmatization of the media,
by the media, and the role of the media in influencing people’s
attitudes towards and understanding of media literacy.

Similarly the constant devaluing of media studies as a legitimate
academic endeavour by policy makers and the media is not
only profoundly anti-intellectual but also damaging to the
way the media is perceived in general. If we want the issue
of media literacy to gain credibility and achieve increasing
and sustaining political relevance then the systematic study
of the media and cultural industries – those industries involved
in the production and circulation of social meaning – must
be taken seriously and be seen to be taken seriously.

Poverty of expectation by broadcasters is also a barrier
to developing media literacy. Ofcom will be aware that a
concept of media literacy based on the rights of consumer-citizens
will allow people to challenge some of the assumptions of
the current broadcasters. We hope that such challenges will
be encouraged.

To fulfil the requirements of the Communications Act demands
much more research in to the issues surrounding the concept
of media literacy. To date, lack of research funding for
such work has been a key barrier to developing evidence-based
policy on media literacy.

In general, we would question how Ofcom intend to assess
appropriate and/or inappropriate levels of media literacy;
what and who do these levels relate to? The key issue is
about how children and adults understand media literacy as
a means of increasing their social, political and cultural
participation in society. Much can be learned here from research
undertaken on citizen participation and social inclusion
particularly in reference to social class, poverty, disability,
race and ethnicity, and gender.

Question 7: Should any of the following groups with potentially
particular needs in relation to media literacy feature as
a priority for Ofcom’s work in media literacy and why?

  • Vulnerable children
  • Vulnerable adults
  • Disabled people
  • Elderly people
  • People on low income
  • People in different parts of UK
  • People from different ethnic communities
  • People living in Rural areas
  • People living in urban areas

This question contains an assumption that research is about
identifying who is at risk. Notions of protection and risk
that pivot around concerns of harm and offence are limiting
and overly constrictive. MeCCSA believe that it would be
counterproductive to prioritise any of the above groups when
the list of vulnerable groups in relation to the media is
potentially endless. A simplistic model that foregrounds
children who cannot use the internet critically or elderly
people not able to use an EPG is unhelpful. Focussing on
the technology denies the social and political factors that
create the circumstances that lead to the difficulties. Any
approach that extracts the media from its social context
is technocratic and bound to fail. Cultural consumption is
a social activity and an everyday practice that takes place
in political conditions and from cultural commodities produced
for most, for the most part from behind closed doors. Research
must begin from this premise – the answers to questions
of media literacy are unlikely to lie in the technology itself.

The ITC/BSC conducted previous research in the treatment
of non-professional actors in television programmes. It would
be good to see further research on the relationship between
participation in the media, in particular broadcast media,
and increasing media literacy skills.

Question 8: Are there any other areas in which you feel
that Ofcom should be conducting research in order to inform
its media literacy work?

In order to gain a full appreciation of the body of research
already available and the areas of investigation least explored
MeCCSA encourages Ofcom to have a preliminary research foray
either by means of a symposium or a commissioned review that
begins with as wide and as ambitious an interpretation of
media literacy as possible. This should be followed by a
free and open research tendering process.

Question 9: What are the key initiatives, projects or resources
that Ofcom should have regard to in promoting media literacy?

Labelling and access issues, although important, must not
be allowed to dominate Ofcom’s agenda. We would suggest
that Ofcom needs to: develop a programme of research which
builds on existing work in the area in collaboration with
HEIs; develop projects which acknowledge the work already
being done in the formal education sector; work with the
BBC as the main public service provider; ensure that an ambitious
standard of media literacy is an integral part of other areas
of Ofcom’s work (such as the review of public service broadcasting
or development of competition policies); encourage access,
critical engagement, active participation and cultural production
in creative and democratic ways; and challenge strongly broadcasters
and government on the role they have to play in relation
to media literacy.

Question 10: Do you support the need for a common labelling
system for audiovisual content?

MeCCSA believes that there needs to be more research on
what is meant by ‘common labelling’, what it
would entail, who would implement it, how it would apply
to a diverse range of media and media content, how it would
be interpreted by users and how it would impact on the statutory
obligations of service providers as well as investigating
other international experiences of common labelling before
any system can be devised and put in to practice.

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