Memorandum submitted by Big Game TV Ltd
1. Big Game Television Limited ("Big
Game") welcomes the opportunity to provide this written submission
in response to the inquiry of the Culture, Media and Sport Committee
(the "Committee") into Call TV quiz shows.
2. Big Game operates both as a dedicated
Call TV quiz channel (currently broadcasting on the Sky platform
on channel 849), and as a production company for Call TV quiz
programming broadcast on our broadcasting partners' own channels.
Big Game was launched in May 2005 and has been at the forefront
of this exciting new area of television ever since, having produced
programming for ITV, ntl and (on an ongoing basis) the Hallmark
Channel. Big Game therefore believes that it is well placed to
provide relevant evidence and commentary in relation to this inquiry.
3. Big Game's call handling procedures vary
according to the type of competition.
4. By "conventional" competitions,
Big Game means the common Call TV competition whereby:
4.1. participants call a premium rate number
(or, if they have entered via the website, they are called by
4.2. calls are randomly selected by Big
Game's telephony system;
4.3. all calls are charged whether successful
or not; and
4.4. successful callers are put through
to the television studio and given the opportunity to answer the
on screen question and, if correct, to win a prize. 
5. Big Game's viewers may participate in
its conventional competitions by two methods:
5.1. Premium rate number
Participants may call Big Game's premium rate
telephone number, in which case they will be charged 75p from
a BT landline (other networks may vary).
Big Game sets its telephony systems to randomly
select a particular proportion of callers, the proportion depending
on a number of factors, but primarily based on the ratio between
the number of callers that are to be put through to the studio
and the total number of entries. The unsuccessful callers will
hear the following message:
"Welcome to Big Game and thanks for playing
along today. Sorry you haven't been selected this time, but please
feel free to try again. Calls cost 75p from a BT landline; other
networks may vary."
Callers who are selected at this first stage
hear the following message:
"Congratulations! You are now through to
the next stage. Please hold the line to see whether it's YOU who
goes through to the Big Game studio to play for a BIG cash prize
live on air..."
Callers are put on hold for two rings, and if
they are selected at this stage, they will be put through to the
studio for the chance to answer the question and win a prize.
If the caller is not selected within that time (whether because
no call is taken within that time, or because a call is taken
but another caller is selected), then the caller hears the following
"Sorry, you haven't been successful this
time, but please feel free to call Big Game TV again. Calls cost
75p from a BT landline; other networks may vary."
Big Game also has systems in place for identifying
frequent callers, who (in addition to the above messages) will
hear the following announcement:
"This is Big Game TV. Our records show
that you are a frequent caller. Please remember that you are charged
75p every time you call. Please hold the line to see whether you've
been selected to go through to our studio to play for a BIG cash
prize live on air..."
5.2. Free web entry
Participants may submit entries via the Big
Game website, in which case no charge is made.
A set proportion of web entries are randomly
selected as successful, and Big Game telephones the successful
entrants using the phone number supplied by the entrant when (s)he
submitted the online entry. The proportion of successful web entrants
is calculated so that the chance of being successful as a web
entrant is the same as the chance of being successful as a premium
number caller, ie the system for selecting contestants does not
distinguish between (paying) calling and (non-paying) web entrants.
6. All Play is an example of a new type
of competition that is often not considered by those examining
the Call TV industry. In this competition, each and every caller
is given the opportunity to answer a series of factual questions,
by using the buttons on their telephone to select the correct
answer to each in a series of multiple choice questions. Only
once the time allotted to the competition has ended is random
selection used to pick a winner (from the pool of all contestants
who answered every question correctly). As a result, all callerssuccessful
or notderive value from the competition, because they have
had the enjoyment of answering the questions. Save in the event
of technical difficulties, all callers have a chance to
7. Calls are treated as follows:
All callsgreeting message and
invitation to answer each question.
All callsacknowledgement of each
If a caller does not give an answerinstruction
to answer the questions now.
If a caller makes an invalid entry (e.g.
presses the wrong button) message telling the caller
of this fact.
If a caller has answered all questions correctlymessage
telling the caller of this fact and instructing them to stay on
the line for a chance to go through to the studio.
If a caller has answered all questions, but
not all answers are correctmessage telling the caller
of this fact, and that the caller is free to try again provided
that there is still time on the on-screen clock.
If a caller has answered all questions correctly
and has been selected as the winner who goes through to the studiomessage
telling the caller of this fact.
If a caller has answered all questions correctly
but has not been selected as the winner who goes through to the
studiomessage telling the caller of this fact.
Information provided to viewers on the costs
of calls and their chances of participating and winning
Costs of calls
8. In order to ensure compliance with the
Ofcom Broadcasting Code and (in particular) the ICSTIS Code and
Statement of Expectations in relation to the cost of participating
(as well as best practice), Big Game operates the following procedures:
8.1. the presenter explains the rules of
the competition regularly and frequently, several times an hour
(including every time a new game is played)this includes
(among other things) the following details:
8.1.1. that all calls cost 75p (from a BT
landlineother networks may vary) whether the caller is
selected or not;
8.1.2. that callers must be aged 18 or over;
8.1.3. that callers must have the telephone
bill payer's permission before calling;
8.1.4. that terms and conditions are available
online or by writing to our PO Box address; and
8.1.5. that free web entry is available.
8.2. the following information is clearly
displayed on screen in a banner at the bottom of the screenthe
banner repeats each piece of information frequently (at present
on a cycle of 45 seconds, with each piece of information on screen
for approximately 6½ seconds at a time):
Callers must be 18 or over
Every call is 75p from a BT landline
whether you are selected or not
other networks may vary
Terms and conditions at
PO Box 5372, London W1A 8WN
Free web entry available
Big Game believes its on screen banner to meet
best practice as it is clearer and easier to read than that of
many of its competitors.
9. In addition to the above on screen information,
each time a caller calls (s)he is informed of the costs by means
of the telephone messages set out in paragraph 0 above.
10. Big Game is not convinced that there
is much more that it could do to bring pricing information to
the attention of its viewers and callers, at least without cluttering
the on screen graphics (which would likely have the result that
any individual piece of information would be crowded out and therefore
on the whole less noticeable to viewers). From watching
and listening to the programme (and no one is likely to enter
a competition without doing that), all viewers should be aware
of the costs. Even if some are not, they are clearly informed
by the messages that are played to all callersso no mistake
should be made more than once.
Chances of participating and winning
11. In terms of informing viewers of "their
chances of participating and winning", Big Game does
not attempt to provide such information, partly because it is
not practicable to do so and partly because it would, in our opinion,
prove misleading. Although Big Game is committed to best practice
and is very willing, where appropriate, to implement compliance-related
policies that are not strictly required by Ofcom or ICSTIS (as
indeed it has already done), Big Game does not consider that providing
information on participants' chances of participating and winning
would be appropriate. Big Game says this despite the fact that
if it were a regulatory requirement to provide information on
the odds of getting through to the studio, it would undoubtedly
gain a competitive advantage in comparison with its main rivals.
The chances of getting through to Big Game, with its relatively
small audiences, must be significantly greater than the chances
of getting through to (say) The Mint, a show broadcast
on a major terrestrial channel with bigger prizes than Big Game
is able to offer.
12. By the very way that Call TV operates,
not every entrant can win a prize and (in `conventional' Call
TV) not every entrant can answer the question(s). The number of
calls that are taken depends on a number of factors, including
the editorial and presentational needs of the show (i.e. putting
enough callers through to keep the show entertaining) and the
volume of calls received (i.e. whether or not enough calls have
been received to justify, in simple economic terms, giving a participant
a chance to win a prize). This varies from show to show: in some
cases there will be relatively long periods between calls, and
on other shows (including one particular two-hour show that Big
Game produces every weekday) the number of calls taken will be
close to the maximum physically possible in the time available.
Each of these factors is a variableit changes from show
to show, from hour to hour and from minute to minute. Any information
that Big Game were to give viewers would inevitably be inaccurateany
`odds' of getting through would be approximations based on previous
shows, that would not necessarily bear any resemblance to the
current competition. Calls received fluctuate wildly between shows
and within shows. There would be no point in providing information
that was not accurate.
13. Moreover, Big Game believes that it
would be wrong in principle to offer such information, even on
a "best guess from previous competitions" basis, for
the following reasons:
13.1. Providing incorrect information is
worse than providing no information at all. Viewers can legitimately
expect that any information a broadcaster provides to them is
accurate. This would not be possible with information about the
chances of getting through to the studio, as this is so dependent
on rapidly changing variables. We should not attempt to do something
that we have no prospect of doing properly, particularly where
the likely result would be to mislead our viewers.
13.2. Part of the skill involved in these
competitions is anticipating when is the best time to enter. Big
Game has contestants who have more success at being put through
to the studio than others. This is not purely about the number
of entries each contestant makessome contestants are undoubtedly
more savvy than others about calling at the correct time to boost
their chances of being selected (i.e. when there are fewer rivals).
If viewers were provided with information on odds of getting though,
it would remove an important skill element from the game.
13.3. Big Game does not believe that a significant
number of entrants misunderstand the costs of participating or
the chances of getting through. Although of course many play a
few times only, there is also a large number who play regularly.
Call TV is a consumer dependent business like any otherif
viewers feel misled, or believe that the proposition reflects
poor value for money, they will stop playing. However, Big Game
understands that complaints have levelled off after an early peak
which suggests to us that although some consumers did not understand
Call TV when it first appeared, there is now a much more widespread
understanding of how it operates.
13.4. Furthermore, if information on odds
were provided to viewers of Call TV, it would create an anomaly
whereby competitions were regulated differently on television
in comparison with all other formats of competition. Thousands
of competitions are run every day, for example in newspapers,
in magazines and online. In each case it is an unavoidable function
of the nature of the competition that the chances of winning depend
on unknown factors, most notably the number of people who try
to enter that same competition. Everybody knows thisor
should know it. It would be inappropriate to make Call TV a special
case. Parliament has decided not to regulate prize competitions
and free draws in this way, and that policy decision must be respected
unless and until Parliament chooses to reverse it.
The role of Call TV quiz shows in raising income
14. Big Game cannot speak for other broadcasters,
but at present the entirety of Big Game's income is derived from
premium rate telephony revenues generated by Call TV quiz shows.
15. It is worth noting that although the
media has commonly stated that broadcasters take 60p or 75p (or
whatever the cost of entry is in that particular case), in fact
Big Game receives significantly less than its 75p entry price.
From the starting 75p one must take away a wide range of costs,
including the telephony partner's share, overheads, prize money
and 17.5% to the Exchequer in the form of VAT.
16. In general terms, Big Game notes that
advertising revenuesthe primary means of funding for the
vast majority of broadcastershave declined significantly
in recent years, and show no prospect of ever returning to historic
levels (not least because of the proliferation of multiple new
channels and alternative advertising media, such as the internet).
The major broadcasters and television production companies are
all examining alternative ways of generating the revenues that
are desperately needed to enable the continuation of quality programming
and, ultimately, the survival of each channel. In Big Game's experience
as a production company for other broadcasters, Call TV programmes
are often used to generate revenues that have been lost due to
the downturn in advertising income, which enables those broadcasters
to maintain standards of programming across the board. Big Game
cannot comment further as the details are not within its knowledge,
but no doubt evidence on this matter will be supplied by other
broadcasters and by Ofcom.
The impact, financial or otherwise, of participation
17. This is not something about which Big
Game can discuss extensively, as it is viewers themselves who
can vouch for the impact of participation for them. It is possible,
however, to make the following comments.
18. First, Big Game encourages its viewers
to set a budget with which to play the game, and to stick to it.
Presenters frequently tell the audience to do this. It is not
in our interests for viewers to spend beyond their means on our
competitions, because they will not be able to sustain it and
in all likelihood they will stop playing fairly quickly. We would
always prefer our viewers to spend "a little every so often",
because we believe that that will be most profitable for usand
our viewersin the long term. It is important to highlight
that unlike gambling services, the motivation for participating
with Call TV services is, in our opinion, not limited to the prospect
of winning money. Callers enjoy the chance to be on TV talking
live on air to a presenter, and many enjoy reminding the gallery
staff of recent successful calls they have made.
19. Secondly, it should not be forgotten
that the financial impact for our winners is a positive one. For
example, we had a letter from a couple who were able to go away
on their first holiday for many years on the back of winning on
Big Game. Our viewers enjoy our competitions partly for their
own sake, but also because winning can make a real difference
to their lives.
20. Thirdly, and perhaps most importantly,
Big Game's participants must be aged 18 or over, and are therefore
consenting adults who are free to choose what to do with their
own money. This is the basis for Ofcom's regulatory approach (see
paragraph 0 belowthe two main regulatory concepts are harm
and offence)and in Big Game's view it is a sound one. In
any case where Call TV amounts to gambling in any form, additional
regulation will be imposed by the Gambling Act 2005 (enforced
by the Gambling Commission). In such cases, it is appropriate
that additional measures apply to protect participants. But
where Call TV does not amount to gambling, there is no justification
for additional consumer protection beyond that which Ofcom and
ICSTIS deem appropriateParliament has considered the matter
and decided to draw a distinction for such purposes between gambling
and non-gambling offerings.
21. In terms of non-financial impacts on
viewers, it is worth noting thatdespite a widespread disdain
for Call TV amongst the mediathe format is hugely popular
with a significant proportion of the population. Big Game receives
a significant number of communications from viewers who love our
shows. Furthermore, we have a large number of callers who participate
in our shows over the long term. It is not unreasonable to conclude,
therefore, that one "impact" on viewers is a significant
amount of entertainment value. The genre may not be the most "high
brow" television in the world, but it is popular. If it were
not, broadcasters would stop showing it. That itself is arguably
the main restriction on Call TV and the main reason why sensible
broadcasters will not use Call TV to unfairly treat their viewersrather
than any rules imposed from the outside by the regulators.
22. Finally, and for the record, in cases
where we believe that viewers have genuinely misunderstood the
gameplay mechanic or pricing structure (eg that every call would
be charged), Big Game hasand continues to operatea
policy of reimbursing the viewer's phone bill (including, at our
own expense, the VAT), where we believe that it would be fair
for us to do so.
CALL TV QUIZ
Whose decision is it?
23. The Committee's Chairman, John Whittingdale
MP, appeared on BBC Radio 4 on 25 October and stated that:
"...part of the problem is that this
seems to fall between the remit of a number of different regulators,
so we're going to have them all together and put it to them that
between them they've got to sort this out."
24. It is not Big Game's experience that
Call TV somehow "falls between the cracks" in regulation.
Nor do we believe that it is the view of Ofcom, ICSTIS or the
Gambling Commission. To help explain this comment, we consider
below the position and activities of Ofcom, ICSTIS and the Gambling
Commission, and the ways in which each cooperates with the others.
25. In April 2006, Ofcom published a Broadcasting
Code Guidance Update
(the "Update") in which it issued guidance concerning
Ofcom's role in the area of Call TV. The Update refers repeatedly
to the ICSTIS "Statement of Expectations for Call TV Quiz
(the "Statement of Expectations") and included the following
"Complaints to Ofcom alleging the broadcast
of misleading information about premium rate charges and/or line
availability will normally be referred to ICSTIS, since they are
considered to be complaints about promotional material concerning
the premium rate service (PRS) itself. ICSTIS has issued A Statement
of Expectations on Call TV Quiz Services ... [which], where relevant,
should be considered alongside its Code of Practice.
Complaints concerning potential unfairness
surrounding the conduct of a competition, or its solution and/or
methodology, will normally be investigated by Ofcom."
26. In this way Ofcom and ICSTIS have set
out a clear distinction between the matters for investigation
by Ofcom, and matters for investigation by ICSTIS. 
27. At a conference on Transactional Television
on 28 September 2006, Ofcom Director of Standards Chris Banatvala
gave a presentation:
27.1. repeating Ofcom's acknowledgement
that there are a number of different regulators involved in Call
TVICSTIS, the Gambling Commission, Ofcom;
27.2. setting out Ofcom's approach in relation
to TV content standards, i.e. that consenting adults should be
permitted to make informed choices, but that the under
eighteens merit additional protectionthe slide dealing
with this issue concluded that "we [Ofcom] have therefore
aimed to put in place that necessary information to ensure transparency";
27.3. indicating that Ofcom will continue
to regulate in its two traditional areas, i.e. where there is
actual or threatened harm, and where there is actual or threatened
offence. In relation to quizzes, the presentation highlighted
Rule 2.11 of Ofcom's Broadcasting Code and referred to the Update,
and the slide concluded (in bold type) that "we are keeping
this under review and will put out new rules/guidance if necessary";
27.4. stated that Ofcom was currently looking
at the boundary between advertising and editorial content, and
whether Call TV should be classified as advertising (and so subject
to a more stringent regulatory regime).
The above confirms that (1) Ofcom is not allowing
Call TV to fall between its remit and that of ICSTIS or the Gambling
Commission; (2) Ofcom has already given detailed consideration
to the sector and has published guidance that it considers appropriate;
(3) Ofcom is keeping Call TV under review and is open to the possibility
of further rules if that proves necessary; and (4) in fact there
is an active review into the regulation of this type of broadcasting
If viewers feel that they have been misled by
TV programmes, they can complain to Ofcomthe public has
a direct route to the regulator if there is a problem (actual
or perceived). That is important for two reasons: first, it shows
that adequate remedies already exist where programmes mislead
viewers; and secondly, it means that Ofcom is the body best placed
to consider the need for further regulation, because it is the
body that has the best knowledge of whether viewers really are
Ofcom is an independent regulator, with regulatory
duties that are enshrined in law. While Big Game expects that
Ofcom will value the Committee's input, Big Game considers that
it would be wrong for the Committee to seek to bypass the regulatory
regime set up by the Communications Act 2003 by regarding the
decision to regulate Call TV further as one for anyone other than
Ofcom and ICSTIS.
28. As noted above, ICSTIS published a Statement
of Expectations on Call TV Quiz Services, to indicate how the
ICSTIS Code would apply in the specific case of these services.
29. In the Statement of Expectations, ICSTIS
"This Statement of Expectations is being
released due to the increased number of complaints and enquiries
that ICSTIS and other bodies have received about Call TV Quiz
Services. In particular, some consumers have misunderstood the
nature of the service or the charges levied regardless of whether
they are successful in getting through to the studio ... "
In the response to the consultation that prompted
the Statement of Expectations to be published, ICSTIS also acknowledges
Ofcom's role in the area of Call TV:
"We appreciate ... that some of the issues
complained about are also matters for the broadcasting regulator,
Ofcom, to consider and our purpose here was not to duplicate regulation.
The responsibility for regulating premium rate services rests
with ICSTIS and provisions for this and Ofcom's responsibilities
are set out in the Communications Act 2003. Accordingly, ICSTIS
and Ofcom continue to pursue a joint approach to these issues.
Ofcom will publish guidance for broadcasters on these services
to support the requirements of the Ofcom Broadcasting Code."
30. ICSTIS also used the Statement of Expectations
as an opportunity to remind Call TV operators that they require
prior permission before launching any live Call TV service. Broadcasters
must complete a specially designed form, which provides ICSTIS
with the information it requires to decide whether or not the
service should be permitted to go ahead. This means that ICSTIS
knows about all existing Call TV services and that no new services
may be launched without its say so.
31. ICSTIS also invited the Deputy Chief
Executive of the Gambling Commission, Tom Kavanagh, to its annual
Forum on 10 October 2006, so that Mr Kavanagh could discuss with
representatives of the premium rate industry the implications
of the Gambling Commission's Issues Paper. This is indicative
of a certain level of cooperation between ICSTIS and the Gambling
Commission, which is further supported by the fact that ICSTIS
submitted its own response to the Gambling Commission's consultation
(a paper which itself made a number of helpful points on behalf
of the Call TV industry, and which Big Game invites the Committee
32. In its half-year statement published
on 24 October 2006, ICSTIS
stated that one of its aims for the next six months is to "complete
a review of the quiz TV sector and implement any necessary new
consumer protection measures". This was one of just eight
stated aims. Call TV is therefore very much on ICSTIS's agenda.
33. As a result, Big Game considers that
ICSTIS, too, has demonstrated a "joined up" approach
to regulation; has imposed rules it considers to be appropriate
for the sector; and is keeping the sector under close scrutiny
with a view to further regulation as and when appropriate. As
a result, Big Game again doubts that Call TV is falling between
34. The extent of the Gambling Commission's
involvement in Call TV quiz programming is at present somewhat
uncertain, the question being whether current offerings will fall
within the legal definition of `complex lotteries' when the Gambling
Act 2005 comes into force (in September 2007). The Gambling Commission's
consultation on the subject was published on 3 August 2006 and
the deadline for responses was 31 October 2006. The consultation
made explicit reference to the Call TV genre and indicated that
some programmes might need to change to comply with the new law.
This shows that Call TV is very much on the Gambling Commission's
radar and it is not clear what would be achieved by any further
regulatory involvement, beyond what the Gambling Commission anyway
plans to do as a follow up to its consultation.
ICSTIS AND THE
35. Big Game considers that the above facts
are inconsistent with the notion that Call TV is being forgotten
by the regulators because each thinks it is somehow another regulator's
problem. If anything, the overlap between the regulators means
that Call TV receives a disproportionately great amount
36. Big Game does not deny that it is legitimate
for the Committee to take an interest in Call TV through this
inquiryit is part and parcel of democratic debatebut
it does consider that it would be illegitimate for the Committee
to seek to do anything that would undermine the role of Ofcom,
ICSTIS and the Gambling Commission in their respective capacities
as the appointed regulators. The regulators are independent bodies,
which means that the Committee can be no more than an influential
participant in the existing industry-wide debate.
37. In summary, Big Game welcomes the Committee's
input but considers thatunless the Committee is to propose
new legislationregulatory decisions must remain the absolute
domain of the relevant independent regulators, notably Ofcom and
Is more stringent regulation needed?
38. In terms of whether Ofcom and ICSTIS
should impose more stringent regulation, Big Game has three main
39. First, it is a fact that viewers complain
about television with which they are not happy. More stringent
regulation is only needed if a large number of viewers complain
about Call TV (although even then the problem is less likely to
be about what rules exist but whether compliance with those rules
is enforced). Big Game understands the number of complaints to
be relatively low, in particular in comparison with complaint
levels when Call TV was in its infancy. Ofcom and ICSTIS will
no doubt provide the relevant statistics to the Committee.
40. Secondly, the existing regulatory requirements
are already very stringent. Big Game invites the Committee to
review closely the Update (see paragraph 0 above) and the Statement
of Expectations (see paragraphs 0 and 0 above), which build on
the Ofcom Broadcasting Code and ICSTIS Code respectively and apply
those codes directly to Call TV. The Committee should study the
actual documents, but purely by way of example:
40.1. the Update requires significant competition
rules to be broadcast, and other terms and conditions to be available
40.2. the Update requires competition organisers
to be able to prove that answers have not been changed after the
competition started, to ensure that competitions are both run
fairly and are seen to be run fairly;
40.3. the Statement of Expectations points
out that broadcasters need prior permission before launching live
Call TV servicesso unless ICSTIS has approved the service,
it cannot be launched;
40.4. the Statement of Expectations stipulates
that pricing information must:
"be easily legible, prominent,
horizontal and not require close examination. If it crawls or
scrolls, it should never be off screen for more than 60 seconds";
"make clear that the charge
applies to all calls, regardless of whether the viewer is successful
in getting through";
"be spoken by a presenter
or voice-over at regular intervals"; and
be provided at the start of
each call as well as on screen, "making clear to consumers
that all calls are being charged".
As a result, if the existing rules are properly
observed, consumer protection levels should be very high already.
Big Game is committed to best practice and at present it believes
that the existing requirements do more than enough to make Call
TV fair to all who wish to participate.
41. Finally, Big Game considers that the
existing regulation provides a sufficient basis for any other
matters to be done by way of self-regulation and/or best practice.
As already noted, Call TV will not have a future if it does not
look after its viewers and it is in no one's interests for broadcasts
to unfairly treat those who choose to participate in their shows.
The best case scenario for the industry is to have a large number
of callers who enjoy playing a little every so often, and for
there to be a significant number of people who have the opportunity
to give an answer on air and win a prize. In our opinion, further
regulation is not necessary as the best interests of the industry
and the viewer are the same
42. As noted above, Big Game considers that
the regulation of the Call TV industry is primarily a matter for
Ofcom and ICSTIS. While we welcome debate, we are not sure that
the Committee has a clear remit other than as an influential voice
for Ofcom and ICSTIS to take into account. Having said that, if
we can assist the Committee in any way, either at the oral session
or outside it, then we would be very happy to do so.
43. In summary, we do not believe that further
regulation of Call TV is necessary, given that stringent rules
already exist, and we do not consider it either practical or appropriate
to provide viewers with details of the number of other competitors
14 November 2006
1 Unless they appear to be under 18 years of age,
are drunk/abusive, or if there is any other reason (eg compliance
with the Ofcom Broadcasting Code) why the caller should not be
permitted to go through to the studio-in which case the Big Game
telephonist will exclude that entrant. Back
TV quiz related complaints to ICSTIS have fallen from a peak
of 64/month in October 2005 to the 18/month in August 2006 (the
latest month for which we have data). Complaint levels have been
reasonably static since May 2006 (20 complaints), which 21 complaints
in each of June and July 2006. Source: ICSTIS-"Prize Competitions
and Free Draws: ICSTIS' response to a consultation document issued
by the Gambling Commission", 27 October 2006. Back
We should add that, in accordance with Ofcom's recommendation,
we have a written policy forbidding our presenters from presenting
our competitions as a possible solution to financial difficulties. Back
Indeed, one of the licensing objectives under the Gambling Act
2005 is "protecting children and other vulnerable persons
from being harmed or exploited by gambling" (section
Available at pages 4-6 of http://www.ofcome.org.uk/tv/obb/prog
Available at http://www.ictis.org.uk/pdf news/QuizTVExpectations06./pdf Back
It is also worth noting that Ofcom also makes reference, under
the heading "free entry route", to matters within the
remit of the Gambling Commission-which again indicates the extent
of "joined up thinking" between the regulators. Back
Ofcom duly did this by way of the Update (see paragraph 0 above). Back
Available at http://www.icstis.org.uk/pdfs consult/ConsultResp
GamblingComm Oct06.pdf Back
Available at http://www.icstis.org.uk/pdfs news/1stHalfYearStatement0607.pdf Back