Why is media literacy so important in the UK draft Online Safety Bill 2021?
The UK government recently released a bill on online safety in line with its commitment to “make the UK the safest place in the world to be online while defending freedom of expression”. Ahead of our LSE briefing on Thursday July 8th, Professor Sonia Livingstone reflects on the position of media literacy in the proposed bill.
The purpose of the bill is, as stated in the first sentence:
«To take precautions for and in connection with the regulation by OFCOM of certain Internet services; and to take precautions about and in connection with the functions of OFCOM with regard to media literacy. “
The importance given to media literacy in the Online Security Act is very welcome to anyone who has long advocated it. However, their treatment in the bill has not received much discussion compared to other aspects of the bill, although the bill suggests a particular and somewhat limited approach to media literacy that positions the public as consumers rather than citizens. This is important because the consumer’s need for media literacy can be limited to ensuring the instrumental use of technology and avoiding harm such as disinformation, and the critical understanding required to participate creatively or politically in a digital world as a citizen , comes up short.
Twenty years ago we had a highly controversial debate about the Communications Act 2003, which specified Ofcom’s promotion of media literacy in Section 11. How narrowly or ambitiously should it be designed, and for what purpose and by whom? For those of us who know the UK has long been a world leader in media education, the results have been disappointing.
Chapter 8 of the Online Safety Bill 2021 (“Media Literacy”) is now replacing the original Section 11 with a new and much longer text. Does this reflect an increasing importance of media literacy? I decided to track changes from the old to the new version to see exactly what was being said.
Several problems arise with the proposed approach to media literacy:
1. The role of critical evaluation. In the academic world, media literacy has long been defined as the ability to access, analyze, evaluate and create communication in any form. In 2003 Ofcom dropped the valuation dimension of that definition, a decision that now seems unwise in the face of the rise of disinformation. If only we had spent the last twenty years promoting the public’s ability to rate digital content!
The Online Safety Act reintroduced this dimension by defining media literacy as “an understanding of the nature and properties of material published using electronic media”. […and] an awareness and understanding of the processes by which such materials are selected or made available for publication. ”However, research suggests that teaching on these topics in schools is patchy at best, and few teachers are supported or trained to teach such teaching granted.
2. The role of communication and content creation. Research also suggests that creating communicators – as agents, citizens, communities, even future media producers – is an excellent way to develop media literacy. But the creative dimension of media literacy does not seem to be mentioned in the bill at all. There is not much of this to be seen in our schools either.
3. Media literacy depends on the readability of the digital environment. In other words, you cannot teach people to “read” a text, an interface, an ecology that is illegible, opaque, obscured or impossibly complex. In this context, it seems significant that the draft law proposes to drop the previous requirement in Section 11 that Ofcom should encourage “the development and use of technologies and systems to regulate access to” [electronic] Material.”
While other parts of the bill encourage this, the previous formulation recognized the link between media literacy and the delivery of digital content: systems that regulate access must, among other things, be designed to be legible so that people receive what they receive Understand digital services and must be given real and detailed choices so that they can act meaningfully on what they understand.
4. Promoting media literacy requires educational initiatives. Paragraph (3) of the Online Security Act states: “OFCOM must, in particular, carry out, commission or promote educational initiatives to improve the public’s media literacy.” This is a new and curious requirement for a market-oriented communications regulator. Education takes years, not hours. General Comment 25 on children’s rights in relation to the digital environment calls for media and digital literacy education to begin when they enter school and to continue throughout their schooling. How Ofcom will work with the Ministry of Education remains unclear. The Department of Education also has no track record of evaluating media education.
5. Promoting media literacy risks exacerbating previous inequalities. Although the bill conceptualizes online harm through risk assessment, it does not appear to extend that approach to media literacy. However, media literacy is particularly important for people in higher risk situations – for example marginalized groups who are more prone to disinformation or people with disabilities who need digital resources to participate in society. As with all educational initiatives, if we do not target the most needy, the overall effect will be to widen the knowledge gap, which will benefit the already beneficiaries more than those in disadvantaged situations.
Therefore, I am concerned that Chapter 8 of the Online Safety Act does not distinguish “members of the public” by age or other status. I am also concerned that children in higher risk situations or with disabilities or other forms of structural disadvantage are neglected in Ofcom research. Nor have I heard much about how the media literacy curriculum can be tailored to the “vulnerable” or “hard-to-reach” children who may need it most.
6. Media literacy initiatives need to be evaluated. I welcome paragraph (4), which requires Ofcom to prepare “guidelines” “for evaluating educational initiatives” by the providers – presumably the DfE, schools and also providers of regulated services. Getting this right will be crucial. It’s not about whether people enjoyed a media literacy campaign, liked the website colors, or thought they learned something.
The decisive factor is whether the actual harm as a result of a media literacy intervention is reduced (and the actual benefit increased). If this does not happen, attention must not only be directed to possible restrictions on media education in order to change the understanding of the public, but rather to Internet governance and the role of digital companies, which through their actions can cause problematic content, behavior, contact and contractual risks Make it accessible to children and the general public first.
Why is media literacy so important in the draft law?
It is worrying that the bill fails to provide a rationale for combining Ofcom’s regulation of Internet services and the provision of media literacy. Ten years ago I argued that media literacy, while a major force in the digital world, risks becoming a scapegoat for the difficulties of internet governance in a society divided over the form of such governance. When online harm occurs in practice, it often seems easier to conclude that it is the public’s understanding and behavior that is to blame, rather than that of regulators or digital providers.
These two points are related, especially when we consider the case that challenges internet governance the most: children. Instead, calls for regulation of the Internet in the interests of children are often met with calls for more media literacy. In addition, requests for media literacy for children are often translated into requests to teach children to be “good” online, thereby failing to address the bad actors on the internet, both individuals and businesses.
So it’s great that the bill calls for media literacy for children and the general public, but let’s be careful what kind of media literacy is provided and make sure we don’t shift responsibility from those who cause and aggravate online harm the victims. Especially when the debates about the regulation of digital providers get tricky.
Visit the Eventbrite page here to register for the LSE Online Safety Bill Briefing on July 8th. This article represents the views of the author and does not represent the position of the Media @ LSE blog or the London School of Economics and Political Science.