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Media Literacy

Media literacy in the Online Security Act: Sacrificing citizenship for resilience?


The UK’s online safety bill, published by the Department for Digital, Culture, Media and Sport in May 2021 and currently under scrutiny by a parliamentary special committee, aims to create a new legal framework to combat harmful online content. Here, Professor Lee Edwards of the LSE analyzes how media literacy is portrayed in the bill and suggests how the proposals in the bill could be strengthened.

In the Online Safety Act, media literacy is an important place to develop public awareness of harmful content and possibly to provide users of online services with strategies to identify and combat misinformation. Although questions have been raised about its representation in the bill and the assumptions it makes about Ofcom’s capabilities, the provisions expand Ofcom’s media literacy obligations – previously set out in the Communications Act 2003 – in three important ways . These new commitments are:

  • Promote the development of technologies that enable users to identify misinformation and control the information received;
  • “To implement, commission or promote educational initiatives” that support media literacy;
  • Develop guidelines for evaluating media literacy initiatives.

The new commitments help to clarify some of the more general provisions of the previous law (e.g. by clarifying how to interpret “nature and characteristics” of content and how to interpret the concept of awareness and understanding). These commitments give Ofcom more power to influence both organizational governance and media literacy investments, as well as shaping media literacy educational curricula. As such, they strengthen the regulator’s potential to assert the value of media literacy in both media producers and those who support user engagement with media.

However, the new bill also includes a subtle but decisive change to the wording, from a requirement to increase awareness and understanding of the media in the “public” to an increase in awareness for “members of the public”. The first obliges Ofcom to improve our collective media literacy and critical engagement with media content, while the second obligation is to improve individual media literacy.

The change in wording is in line with the focus on individual harm throughout the bill and certainly eases the obligation to assess media literacy – it is easier to measure outcomes related to individual behaviors and skills than to identify collective empowerment. Adaptation risks, however, sacrificing one of the main advantages of media literacy: its ability to support an informed, engaged citizenship willing to participate in deliberations and debates within our democratic processes. While that is not the intent behind the change, the effect is inevitable when media literacy is included in a bill that primarily focuses on regulating platforms and providers.

In addition, the more specific interpretations of “technologies and systems” that enhance media literacy focus on facilitating users’ ability to identify types of content, determine its reliability and accuracy, and have control over how information is presented obtain. These priorities place an emphasis on the ability to spot misinformation, rather than the ability to critically engage with media in a broader sense. However, media literacy interventions that can contribute to critical thinking and evaluation tend to take a systemic approach: They include learning to produce and consume media, understanding the media industry and its institutional power and priorities, criticizing media representations and developing the ability to create media. Promoting this type of media literacy can have a positive impact on our ability to actively engage with online information and media power, and to recognize our own voice as citizens. The draft law carries the risk that this competence building competence will be transformed into an exercise of informed consumption. If media literacy is only used to protect oneself from exploitation or harm, its potential to support our deliberative and democratic capacities could be severely weakened.

Both points point to a more fundamental problem with the bill: its emphasis on users rather than citizens and on mitigating individual rather than collective harm. However, the bill focuses on issues that directly affect our collective wellbeing. Living in a society in which information and knowledge remain balanced, reliable and accessible to all, or in which our desire to communicate our experiences is not dampened by fear of hatred and intolerance, is in everyone’s best interests. Harm occurs not only when individuals are harmed through interactions on the Internet, but also when those same interactions increase, ultimately reducing our critical skills and generating antagonistic arguments rather than agonistic debates in society. We have already seen the consequences of this polarization in increasing nationalism, the reification of misinformation and the dismissal of experts, as well as a gradual weakening of democratic structures that depend on committed, informed citizens.

Nonetheless, the bill presents users primarily as atomized individuals and not as social beings who live in relation to one another. The consequence of media literacy proposed by the draft law is that collective benefits are subordinate to individual resilience. If this framing of media literacy becomes the predominant form of delivery, there is a risk that the perception of its broader value to society will gradually dissolve. While a critical analysis of the power of platforms is urgently needed by all citizens, the instrumentalization of media literacy is worrying at best and dangerous at worst – potentially leading to greater political polarization and even less resilience to misinformation than we currently have.

There are ways to reduce this risk:

  • The wording of the draft law could be changed, for example to switch back to “public” instead of “members of the public”.
  • The specifications in the bill could be expanded to include the broader critical capacities that are so fundamental to our deliberative engagement.

However, claims about the need to support collective well-being and media literacy would be most strongly asserted in the context of digital rights, and the lack of such rights is a more fundamental issue of the bill.

During our summer round table, Professor Sonia Livingstone and Chi Onwurah MP both strongly advocated the inclusion of an explicit statement on digital rights in the bill as the basis for online security. Even if such rights are not included in the final version, they are clearly necessary. The intense discussions about citizenship, media literacy, due diligence and the need to protect freedom of expression arose in part because we lack a frame of reference for these issues in a digital world. Existing statements on human rights are difficult to transfer unchanged into digital contexts due to the changed environment in which they exist. Digital rights have to deal with the different architectures, actors and networked dynamics of digital spaces and are not easy to regulate – as the long development process of the UN General Comment 25 on children’s rights in relation to the digital environment has shown. But our digital rights must be addressed by both civil society and politics if initiatives such as the Online Safety Bill are to be implemented legitimately, future-proof and ultimately successfully and the social value of media literacy is to be preserved.

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.


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