Joint Committee on The Draft Communications Bill Appendices to the Minutes of Evidence


APPENDIX 69

Memorandum submitted by The UK Campaign for LOGO FREE TV

INTRODUCTION

  The UK Campaign for LOGO FREE TV (web site http://www.logofreetv.org.uk/) is a new UK Viewers Group with more than 1,000 UK members. We have assembled to lobby for and oppose problems specifically to do with "permanent on-screen logos", in-programme-time advertising, unsolicited interactive advertising, and in effect anything that effects the visual quality of service to the viewer. As a functional viewer's lobby group, we take an interest in and respond to all consultations that effect the service received by viewers.

WHAT ARE THE PROBLEMS WITH BROADCASTING AT PRESENT

  Accountability, Reporting, and "Checks and Balances" seem to be PR exercises conducted "end of term" report style. The issues that we encounter day-to-day NEVER get covered.

  White papers, Explanations of Policy, and Executive comment, are at best conducted at controlled Press Conferences. Detailed policy documentation, even from the BBC and Must-Carry broadcasters are NOT available to the public. We cannot get Broadcast Executives to comment first-hand, even with the help from our MPs.

  Regulation is explicitly "light touch" and industry lead. Enforcement is typical based on an "after-the-event" basis if a large enough number of people respond.

  There is NO requirement for broadcasters to disclose viewer complaint logs, statistics, or summaries to the public. Therefore, when TV viewers complain, these complaints disappear into a void. (We have established the first public duty office service on our own web site.) Can corporations with commercial interests really be trusted to disclose the truth if it is not in their interests?

  The ITC regulator assumes that viewers can make choices by simply switching off. But, the ITC ignores that channels are allocated on a "bundled" basis, and consumers are subject to minimum contracts. (At the very least, every time a consumer shops or buys a product, they are paying for TV services through advertising.)

  Regarding "on-screen logos", Interactive Solicitations, and "In-programme Cross Promotions", the BBC Governors have NEVER documented the issue, the BBC Executive leaves numerous questions unanswered in spite of a minuscule amount of viewers, the ITC will not rule for or against, and Sky has an agenda of making £50 ARPU.

  The Chairman of the BBC and BBC Board of Governors have so far refused and failed to investigate the issue of permanent on-screen branding.

WHAT WOULD WE LIKE TO SEE LEGISLATED FOR IN THE COMMUNICATIONS ACT 2002

  1.  Minutes of Board Meetings of the BBC (Governors and Executive), Must-Carry Broadcasters, and Subscription Operators should be openly published (as with Parliament or the MPC), since the decisions of these boards weighs upon their stakeholders, shareholders, customers, viewers and the public interest.

  2.  Viewer's Correspondence should be publicly categorised, and summaries published. Internet technology makes it feasible for the establishment of a collectively financed National Duty Office.

  3.  The Establishment of a National Duty Office would allow broadcasters to share costs, enjoy economy of scale, and by use of web technology, would allow new and instant visibility of issues as they occur. More, a consistent National Standard of Correspondence Handling could be established setting Britain as a world leader in this field.

  4.  The BBC should be aggressively included under OFCOM regulation.

  5.  The BBC itself SHOULD NOT be fined, but for the BBC and Channel Four Corporation, the regulator should have powers to fine broadcast executives, as a percentage of the broadcaster's Executive Directors Salaries inclusive of bonuses, and without financial fudge. There is no point in fining the viewers, advertisers, or producers. The most effective form of fines (as with the H & S Executive) are ones that "hurt" the Directors responsible.

  6.  "Subscription Bundling", the practice of forcing a large package of more expensive channels on consumers, should be investigated and loosened to provide more choice to more consumers. The packages are too expensive which excludes viewers from the market.

  7.  Adult content opt-out in the Digital Set-Top-Box, should be compulsory for ALL platform operators, on all channels.

WHAT WOULD WE LIKE TO SEE ADDED TO BROADCAST REGULATION

  1.  We would like to see a ban on the routine use of permanently on-screen BUGs, DOGs, LOGOs, Corporate Brandings, Emblems, or Channel Identifiers on British mainstream TV. (Full practical details are published on our web site).

  2.  We also believe broadcasters that employ permanently on-screen branding should give full and accurate explanations to their viewers. They should clearly state what the purpose of the "branding" is for, explain how (or whether) they consulted the public, accurately report any opposition they receive to on-screen branding, and periodically review the effectiveness and necessity of their branding policies.

  3.  When advertising and promoting LOGO-ised channels, we believe the promotional material should consistently and accurately show the branding found in the final product. We believe that consumers should be informed before they commit themselves to a purchase or contract.

  4.  With the new phenomena of Interactive Icons (particularly as found on the BSkyB satellite platform), we believe that consumers should have a menu option enabling them to opt out of the interactive services promotion. An option allowing the icons to time-out and disappear after 10 seconds should also be made available.

  5.  We are greatly concerned about the lack of parental lock-out on some commercial Interactive dial-up Services, and the unsolicited nature of the interactive icon "adverts" (of dubious benefit to the user) mid-programme. We want to see "parental lock-out" controls added to Digital Set-Top boxes preventing unauthorised use of inappropriate or expensive Interactive Services.

  6.  We would like to see safety warnings labelled on the front of Plasma and Rear-Projection TV sets in retail outlets, warning consumers that the equipment could be permanently and irreparable damaged if LOGOed channels are display on it. (Details of the risk of permanent damage are thoroughly documented on our web site).

  7.  We would like the regulator to take an aggressive and tough stance against in-programme advertising, promotion, and cross-promotion. We think it is appalling how youth TV shows, and even Sky News, can be allowed to promote premium rate telephone services (whether "Interactive" or not).

  8.  We think that there must be urgent research and analysis conducted into the effects of "branding", particularly on very young children. The appearance of BBC characters on adverts for commercial products (McDonalds, Burger King, Heinz) is detestable, and an insidious betrayal of the license fee and BBC values.

  9.  We can not see how BBC CHOICE or BBC FOUR serves the public interest, by running a "disfigured" picture that is watched by only a few thousand viewers at vast public expense. Some of our members resent being forced to subscribe by law to non-public interest channels that are clones of commercial channels, and in the case of BBC CHOICE feature heavily in "garbage and filth".

June 2002


 
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