12 June 2011

Little Angels and Angry Mummies

As a fan of Richard Hughes' 1929 A High Wind In Jamaica and Robert Musil's 1906 Die Verwirrungen des Zöglings Törleß (with a rather bleak view of childhood innocence and by extension the construction of 'childhood') and current Australian debate about content regulation - in particular the current ALRC review - I'm fascinated by Letting Children be Children - Report of an Independent Review of the Commercialisation and Sexualisation of Childhood (aka Bailey Report) under the auspices of the UK Department of Education.

The report deals with several 'themes' in a nice example of angsty mummies, wishlists and avoidance of parental responsibility. (Heaven forbid that some people actually turn off the television occasionally or influence marketers by voting with their credit card.)

Under The 'Wallpaper' of Children's Lives it comments that -
We are all living in an increasingly sexual and sexualised culture, although it is far from clear how we arrived at this point.

Many parents feel that this culture is often inappropriate for their children and they want more power to say 'no'.

Some parts of the business world and sections of the media seem to have lost their connection to parents and this is compounded in some new media where there is limited regulation.

Where regulation does exist, regulators need to connect better with parents and encourage businesses to comply with the 'spirit of the regulation'. Where regulation does not exist, businesses need to behave more responsibly.
Under the label What we would like to see the report wishes that "sexualised images used in public places and on television, the internet, music videos, magazines, newspapers and other places are more in line with what parents find acceptable, and that public space becomes more family-friendly.

Consequent recommendations are -
1. Ensuring that magazines and newspapers with sexualised images on their covers are not in easy sight of children. Retail associations in the news industry should do more to encourage observance of the voluntary code of practice on the display of magazines and newspapers with sexualised images on their covers. Publishers and distributors should provide such magazines in modesty sleeves, or make modesty boards available, to all outlets they supply and strongly encourage the appropriate display of their publications. Retailers should be open and transparent to show that they welcome and will act on customer feedback regarding magazine displays.

2. Reducing the amount of on-street advertising containing sexualised imagery in locations where children are likely to see it. The advertising industry should take into account the social responsibility clause of the Committee of Advertising Practice (CAP) code when considering placement of advertisements with sexualised imagery near schools, in the same way as they already do for alcohol advertisements. The Advertising Standards Authority (ASA) should place stronger emphasis on the location of an advertisement, and the number of children likely to be exposed to it, when considering whether an on-street advertisement is compliant with the CAP code. The testing of standards that the ASA undertakes with parents (see R7) should also cover parental views on location of advertising in public spaces.

3. Ensuring the content of pre-watershed television programming better meets parents’ expectations. There are concerns among parents about the content of certain programmes shown before the watershed. The watershed was introduced to protect children, and pre-watershed programming should therefore be developed and regulated with a greater weight towards the attitudes and views of parents, rather than ‘viewers’ as a whole. In addition, broadcasters should involve parents on an ongoing basis in testing the standards by which family viewing on television is assessed and the Office of Communications (Ofcom) should extend its existing research into the views of parents on the watershed. Broadcasters and Ofcom should report annually on how they have specifically engaged parents over the previous year, what they have learnt and what they are doing differently as a result.

4. Introducing Age Rating for Music Videos. Government should consult as a matter of priority on whether music videos should continue to be treated differently from other genres, and whether the exemption from the Video Recordings Act 1984 and 2010, which allows them to be sold without a rating or certificate, should be removed. As well as ensuring hard copy sales are only made on an age-appropriate basis, removal of the exemption would assist broadcasters and internet companies in ensuring that the content is made available responsibly.

5. Making it easier for parents to block adult and age-restricted material from the internet: To provide a consistent level of protection across all media, as a matter of urgency, the internet industry should ensure that customers must make an active choice over what sort of content they want to allow their children to access. To facilitate this, the internet industry must act decisively to develop and introduce effective parental controls, with Government regulation if voluntary action is not forthcoming within a reasonable timescale. In addition, those providing content which is age-restricted, whether by law or company policy, should seek robust means of age verification as well as making it easy for parents to block underage access.
The second theme is Clothing, Products and Services for Children, with the authors commenting -
Sexualised and gender-stereotyped clothing, products and services for children are the biggest areas of concern for parents and many non-commercial organisations contributing to the Review, with interest fanned by a sometimes prurient press. The issues are rarely clear-cut, with a fine balance on a number of points – taste, preference, choice, affordability, fashion and gender preferences.

Retailers are aware of the issues and sensitivities and are responding. They need to be explicitly and systematically family friendly, from design and buying through to display and marketing.
After indicating "What we would like to see" is that retailers do not sell or market inappropriate clothing, products or services for children, the report offers one recommendation -
6. Developing a retail code of good practice on retailing to children. Retailers, alongside their trade associations, should develop and comply with a voluntary code of good practice for all aspects of retailing to children. The British Retail Consortium (BRC) should continue its work in this area as a matter of urgency and encourage non-BRC members to sign up to its code.
Theme 3 concerns Children as Consumers -
We all live in a commercial world and children are under pressure from a range of sources to act as consumers.

We do not want to cut children off from the commercial world completely as we believe that it brings benefits and parents tell us that they want to manage the issue themselves, supported by proportionate regulation and responsible businesses.

While adults may understand that companies might look to ‘push the boundaries’ when
advertising to them, children are especially vulnerable and need to be given special
consideration.

Special measures already exist in advertising and marketing regulations to protect children but some gaps exist.

Regulators cannot realistically be expected to anticipate detailed developments in the new media. However, an absence of regulation does not absolve businesses from acting responsibly by themselves.
The report's parents would accordingly "like to see" that -
the regulations protecting children from excessive commercial pressures are comprehensive and effective across all media and in line with parental expectations. That marketers do not exploit any gaps in advertising regulation in order to unduly influence the choices children make as consumers. That parents and children have a sound awareness and understanding of marketing techniques and regulation.
The associated recommendations are -
7. Ensuring that the regulation of advertising reflects more closely parents’ and children’s views. The Advertising Standards Authority (ASA) should conduct research with parents and children on a regular basis in order to gauge their views on the ASA’s approach to regulation and on the ASA’s decisions, publishing the results and subsequent action taken in their annual report.

8. Prohibiting employment of children as brand ambassadors and in peer-to-peer marketing. The Committee of Advertising Practice and other advertising and marketing bodies should urgently explore whether, as many parents believe, the advertising selfregulatory codes should prohibit the employment of children under the age of 16 as brand ambassadors or in peer-to-peer marketing – where people are paid, or paid in kind, to promote products, brands or services.

9. Defining a child as under the age of 16 in all types of advertising regulation. The ASA should conduct research with parents, children and young people to determine whether the ASA should always define a child as a person under the age of 16, in line with the Committee of Advertising Practice and Broadcast Committee of Advertising Practice codes.

10. Raising parental awareness of marketing and advertising techniques. Industry and regulators should work together to improve parental awareness of marketing and advertising techniques and of advertising regulation and complaints processes and to promote industry best practice.

11. Quality assurance for media and commercial literacy resources and education for children. These resources should always include education to help children develop their emotional resilience to the commercial and sexual pressures that today’s world places on them. Providers should commission independent evaluation of their provision, not solely measuring take-up but, crucially, to assess its effectiveness. Those bodies with responsibilities for promoting media literacy, including Ofcom and the BBC, should encourage the development of minimum standards guidance for the content of media and commercial literacy education and resources to children.
Under Theme 4 – Making Parents’ Voices Heard - the report notes that -
Parents have told us that they feel they cannot make their voices heard, and that they often lack the confidence to speak out on sexualisation and commercialisation issues for fear of being labelled a prude or out of touch.

Business and industry sectors and their regulators need to make clear that they welcome, and take seriously, feedback on these subjects.

Given the technology available, regulators and businesses should be able to find more effective ways to encourage parents to tell them what they think, quickly and easily, and to be transparent in telling parents how they are responding to that feedback.

Once parents know that their views are being taken seriously, we would expect them to respond positively towards companies that listen to their concerns.
What we would like to see is "that parents find it easier to voice their concerns, are listened to more readily when they do, and have their concerns visibly acted on by businesses and regulators".

The recommendations are -
12. Ensuring greater transparency in the regulatory framework by creating a single website for regulators. There is a variety of co-, self- and statutory regulators across the media, communications and retail industries. Regulators should work together to create a single website to act as an interface between themselves and parents. This will set out simply and clearly what parents can do if they feel a programme, advertisement, product or service is inappropriate for their children; explain the legislation in simple terms; and provide links to quick and easy complaints forms on regulators’ own individual websites. This single website could also provide a way for parents to provide informal feedback and comments, with an option to do so anonymously, which regulators can use as an extra gauge of parental views. Results of regulators’ decisions, and their reactions to any informal feedback, should be published regularly on the single site.

13. Making it easier for parents to express their views to businesses about goods and services. All businesses that market goods or services to children should have a one-click link to their complaints service from their home page, clearly labelled ‘complaints’. Information provided as part of the complaints and feedback process should state explicitly that the business welcomes comments and complaints from parents about issues affecting children. Businesses should also provide timely feedback to customers in reaction to customer comment. For retail businesses this should form part of their code of good practice (see Theme 2, Recommendation 6), and should also cover how to make it