When Dr Tanya Byron published her investigation into the use of videogames and the Internet by children on March 27, it was hailed as a decisive moment in the battle of perceptions between the gaming industry and its detractors. Here at last was a comprehensive, thoroughly-researched report on the potential risks of interactive entertainment – on and offline – from a creditable source.
While most of the Byron Review’s conclusions – in particular, that videogames could have a beneficial effect on young minds if managed accordingly – were welcomed by the industry at large, there was disagreement over some of its recommendations. Dr Byron’s suggestion that the British Board of Film Classification continue to play a dominant role in age classification has prompted outcry in many quarters – not least from the Entertainment and Leisure Software Publishers Association, who argue that their Pan-European Game Information system is better equipped to tackle the unique possibilities of interactive entertainment.
As managing director of the ELSPA, Michael Rawlinson has played a headline role in the debate. Strategy Informer caught up with him earlier this week to chat about the Byron Review, PEGI and the problems of classification in an online-enabled market.
Strategy Informer: You welcomed Dr Byron’s conclusions on videogame classification in April. What do you think of the response to her review – on the one hand from the UK government, and on the other from the videogame industry itself?
Michael Rawlinson: I’d just like to qualify that we welcomed the overarching response of Dr Tanya Byron’s report: the research that she undertook into child development and the potential and actual risks to children that may be encountered through the internet and videogames, and the very positive way in which she spoke about the benefits of videogames alongside the relatively limited risk potential that exist around games.
Specifically around the classification issue we were perplexed by her response, in that throughout her report she talked about the need for a number of things in a classification system: that it should be clear and easily communicated to consumers; that it should cover both the physical product and online gaming, whether that be a downloadable game or interaction in massively multiplayer worlds…
And then at the end of all those very clear principles and very clear guidance that we agree with, she came out with something that was a bit of a dog’s breakfast to say the least: a hybrid between the two existing systems and bodies rating videogames – the BBFC and PEGI. So it’s the sharp end that we disagree with – on the principles that she was recommending, the structures that she was outlining, we think she got it right.
Strategy Informer: We suppose the BBFC’s major advantage in the eyes of some consumers will be that it’s a British institution, subject to a British government. Do you think that in proposing this hybrid scheme, Dr Byron was trying to appease all parties to the debate – to take into account both national and global priorities?
Michael Rawlinson: Yeah I think that’s absolutely right. I think there was this desire to try and please everybody, and in the end she probably didn’t please anybody. From a cursory glance or even a casual viewpoint – we get this when we talk to… I was going to say ‘lay people’ – if you just talk to the ordinary man in the street about videogames classification and say “Do you want the BBFC that you’ve known and loved for years, that have been rating cinema films since time immemorial – they started in 1917, something like that – and then more recently rated videos in the 1980s – do you want that body, or do you want the body that started rating videogames in 2003?” And I guess if you phrase the question that way, you’re likely to get a response like “Well, the BBFC – that seems to make sense.”
The other thing of course is that the way the law is structured and the legislation is fulfilled at the moment, the BBFC are the designated body – [they’re] the one who’ve been given the responsibility under the Video Recordings Act to implement that piece of legislation, to classify video works and the small number of games that require classification. They have those powers – currently.
And I guess given that landscape, Tanya Byron wanted to continue that process. But at the same time she recognised I think the future of where the industry was going, in that more and more games are being played online, are being downloaded from online, have an online element in all sorts of shapes and ways, and that means it’s outside of the national boundaries of the UK and therefore some system that is broader and wider than the UK makes a lot of sense. And that’s what the PEGI system is.
So I think she was trying to bring the elements together. We’ve looked at this, and we think that there’s a better way to protect children, and the reason why we are being so vociferous about this debate is because we want the right solution for child safety both today and in the future, and we just don’t think that the hybrid she’s recommended gives us that.
Strategy Informer: In many ways games still occupy the same cultural ‘space’ as films for more casual consumers – if nothing else, game boxes on the shelf resemble DVD boxes. What would you say are the key challenges in classifying videogame content as against film content? What really distinguishes the two mediums for the consumer?
Michael Rawlinson: I guess something your readers will almost certainly appreciate, because they are hardcore gamers, is that as consumers of the products it is a totally different experience to sitting down and watching a film. Playing a game over a large number of hours, days, weeks, months is a completely different experience to sitting down and watching a film for one, two, three hours start to finish: an experience that’s been prepared and laid down by the director of that movie… you receive and experience the way that it was set out for you.
And I think for me there are three elements that Tanya Byron recognised and highlighted that are covered by a game-specific system that are not covered – two of the three are not covered by the BBFC. Dr Byron talked about content, contact and conduct. The BBFC can rate content – that’s what they do with a film – and because it is a passive medium – whether I’ve watched it on the telly, watched it on the big screen at the cinema [or] download it as a video on demand – however I watch that piece of entertainment I interact with its content. That’s all I do.
Any contact that I have may be with the people I’m sitting in the room with, watching it at the same time as me, but the contact we’re having is only in the context of discussing what we are watching, and reacting to it, but not through that film. Whereas with a piece of interactive content, an interactive experience, I not only am a contender, influencing and receiving the images, the sound – the experience of the game, the content – but I’m having contact with other players, I’m interacting with other players more and more, and this is how the game has changed.
You go back to the old consoles, the old PC games – I used to interact with the artificial intelligence that was already pre-programmed, and though it was an interactive experience and I would affect the way the game played out, I wasn’t interacting or having contact with other people.
But now I am. It’s just as easy for me to be playing via an online connection with somebody who’s sitting next to me, sitting in their room down the street or on the other side of town, or in another country. So the contact that I’m having goes across borders, and I am potentially influenced [by] and have contact with other people. And the way in which they conduct themselves in that world can have an effect on me – particularly when we think about voice communication or text communication, or indeed user generated content within the game.
So there are other elements that will change the gaming experience, and it’s very important that I’m aware of and – it can’t be rated, you can’t rate what someone’s going to say. Nobody can rate this conversation unless it’s on a five second delay and someone’s sitting there listening with a beeper button to remove anything that might cause offence to you. All you can do is listen and react and potentially report me if it were a gaming situation for inappropriate behaviour, inappropriate conduct – [for example] if I was trying to groom someone within the game.
And therefore what we need is a comprehensive solution [for] which the two elements of PEGI – PEGI classification and PEGI online safety code – together provide the framework… nobody’s saying it’s perfect, but it’s a starting point that will be developed and advanced and rolled out and communicated to consumers - both to players of the game and particularly in relation to children, those who are guardians and have responsibility for the children. These things will be communicated out over time, so that those who don’t play the games in particular understand what’s happening.
And this is why it’s so critical for us that we don’t label games with the BBFC label – we try to differentiate the products on the shelf, so that parents, grandparents and others do recognise that this is not a film. This is something different.
Strategy Informer: You’ve identified the online component of contemporary videogames as posing problems for classification. What do you think of the BBFC’s recently launched online ratings system?
Michael Rawlinson: I can summarise BBFC Online as effectively being BBFC offline put online… In other words they are classifying content and they’re using all of their tools, their logos, consumer information, advice and so forth [for] that online content, so that if you go into a shop and pick up a DVD, turn it over and it says “contains moderate violence” or “mild sexual references” or whatever it might be on the back, so now if you go onto a website to download a film, as you go through the purchasing process you’ll see the BBFC logo - when you hold your mouse over a particular film, up will pop a little window that will say all those things it said on the back of the box, just informing consumers all about it, and then you click to buy or download and off you go.
So it all it does is translate their offline offering to an online offering. Where PEGI is different is that the content continues to be rated, and is rated under the PEGI criteria…. I think the important thing about the PEGI criteria is that it’s an international standard of rules and regulations and different levels of classification that has been prepared by experts from a European perspective, so it works across borders and it’s uniform.
I liken it to a shop having an entrance on two streets – if you come in from one street, you want to know that the shop you’re entering from street A is the same shop you’re entering from street B. So if you go in from the UK you want to know what content classification it’s got, and if that content classification says it’s suitable for twelve-year-olds and up, or is not suitable for children under twelve… you don’t want to find on the other side of the street that it says this is only suitable for adults.
Because otherwise if you’re a British consumer entering thinking it’s suitable for twelve-year-olds and upwards and you find that it’s full of adults, and those adults think that they’re entering an adult world and therefore have their conversations in an adult sense, then there will be a misjudgement and mis-selling of that world, and that’s why it’s very important to have consistency of rating across Europe.
So PEGI gives that, and then PEGI online is about how do we deal with those contact and conduct issues, so that there is a big sign outside that says there may be contact through voice or text, and there may be user-generated content in this world – almost “buyer beware”… be aware Mr Consumer that the operator of this site stands by a serious code of conduct that means the site will be monitored and moderated in accordance with certain rules and regulations, and those will vary by operator, by site, by age classification, but you the user should be able to look it up and see what it is before you decide to enter or not…
That’s a lot more advanced and a lot more detailed than just putting a rating online, which is what the BBFC is looking to do. Again, as regards a film or linear content BBFC online works, I have no issues with that at all, but in terms of gaming I don’t think it meets the requirements of the consumer at all. I think it misses the mark completely.
And indeed Dr Byron notes in her report that PEGI Online has been in development already for 18 months, and that it is supported and endorsed by the European Commission – they part-funded the creation of that scheme, and have backed it – whereas she reports that BBFC online is just setting out on its journey. So they’re way behind the times anyway, and more specifically any online safety code that operates only from the UK perspective, is not going to protect the consumer in any online game world that we’re seeing…
Strategy Informer: But do you think the adoption of legally enforceable PEGI criteria would be construed as unwanted foreign intervention by UK consumers?
Michael Rawlinson: I think there’s a lot of talk around that, but I think actually if you took the PEGI criteria to consumers and showed them the classification criteria and asked “do you agree with this?” I don’t think there would be much concern about it. There was a lot of talk about how the BBFC was in touch with UK consumers and rated content as we wanted it, and it won’t have escaped your notice I’m sure the very vociferous debate that’s been going over the past two or three weeks about Dark Knight.
Everybody I’ve spoken to who’s seen the film - and I hold my hand up and say I haven’t seen the film so I can’t personally comment – but everybody I have spoken to has said “I can’t believe the BBFC rated this suitable for 12-year-olds.” They just really did not understand where they’re at. So if that is an organisation that is trying to be in contact with British sensibilities, I’m not sure they’ve got it right.
Now it’s easy to be critical on one particular issue… what we do have with the PEGI scheme is a set of criteria that any consumer can go and see on the PEGI website, and read the questions and understand what will make the game a 16, a 12 or a 7, and they can see it clear as day.
I’m not sure that it’s that transparent with the BBFC what makes a game a 12 or a 15, and indeed the sort of language that the BBFC was using when they were coming under criticism about the rating of Dark Knight was that “It was borderline – we weren’t sure whether it should be this or it should be that.” Well I guess there needs to be some discussion and debate but not too much, because otherwise people aren’t quite sure where you’ve drawn the line, and I think there is a sense these days that maybe the BBFC is trying to push public opinion rather than following it.
Strategy Informer: Do you think we can get by with a purely advisory system – consumers buying more violent or sexual content at their own discretion? Is it absolutely flat-out necessary that we make the ratings legally enforceable, or should it just be a question of consumer choice?
Michael Rawlinson: I don’t think we can get around the notion of a legal requirement at this moment for ratings in a retail environment, because that’s what the retailers want – that’s a consumer expectation unfortunately.
In an ideal world every consumer should understand what it is they’re buying and be able to make the decision as to whether that product is suitable for their children – unfortunately, parents, grandparents and others are saying “I haven’t got time to look into this stuff – anyway I’m not a gamer, I don’t know anything about this. Please help me, please make my life simple, please tell me whether I can buy this product for my child, whether it’s suitable or not suitable.” That’s the consumer demand at the moment.
I guess in another 10 or 15 years, maybe less, when today’s gamers – children, teenagers, twenty-somethings – become parents, they will be familiar with the format, with interactive products, and will say “I know what this is all about. It may be a new game, it may be a new genre, but I understand gaming.” And they will be able to make those decisions by playing the game, reading the reviews, watching the trailers, whatever it might be – there will be an understanding.
But as we stand today there is this consumer demand for legislation, and indeed for the retailer – and I think this is an unfortunately serious point – if a child goes into a shop and tries to buy something that is rated higher than their age, if it’s not legally enforceable and the retailer says “I’m sorry I don’t think this is suitable, I’m not selling it to you,” then the child will just keep going down the street till they find a shop that will sell it to them. And then the child will never go back to shop one because they’ll have had a bad experience.
Whereas if the retailer knows that… there’s a legal requirement to refuse the sale, they’ll have the confidence that every shop down the high street will also refuse the sale, and therefore they won’t be tarred with being out of step. In an ideal world I agree – I don’t think it should be a legal requirement. We have no evidence – Dr Byron said this – that computers and videogames cause harm.
That doesn’t mean there’s evidence of no harm, but I take the example of all the people that play videogames – and we sold over 70 million units last year in the UK alone, if you take the worldwide market you’re looking at hundreds of millions of units – and we don’t see children badly affected by their gaming experience. So I don’t think the evidence is there for harm – in some isolated cases with children of a certain background, social situation, there may be extenuating circumstances to which gaming may be a factor. But I don’t think it’s the cause.
Strategy Informer: Our readers seem to be a well-adjusted bunch, at least! On a lighter note, which games do you personally enjoy?
Michael Rawlinson: I’m not a hardcore gamer but I do love my Brain Training, I do love my Sight Training and I love racing games! That’s what touches me. I’m in my mid-to-late forties. I think I missed gaming first time round – my brother played games, and because he played games it put me off, I have to say, and therefore I didn’t go down that route, but I have come to it later in life, and those are the things that do for me.
I think the wonderful thing today is that there’s something for everybody, and there are many people who say “I don’t play games” but they do – they just don’t recognise it. There are things on Facebook I enjoy playing as well but they’re fairly casual and light-hearted and certainly don’t take up hours of my time, but for those who do dedicate hours to their gaming experience I think it’s fantastic as well.
Strategy Informer: It’s been fascinating talking to you. Thank you for your time.
Michael Rawlinson: You’re very welcome. I guess the final thing I would just say is that we’re keen for gamers – particularly gamers who are voters - to express sensible views – if they have sensible views, or actually to express their views whatever they might be - if they believe that gaming is a great pastime and they are not mass murderers and they aim to play their violent games without causing any negative actions, and they feel like expressing those views to politicians - that’s great.
Unfortunately so often these days people only pick up the pen to complain when they’re against something rather than when they’re for something, but politicians do react when they get a postbag – whichever way it goes. So if they get a postbag full of people saying “I’m a gamer and it’s really enhanced my life,” that could be very helpful to us.
For more info, check out the official PEGI and PEGI Online websites.
