Select Committee on Culture, Media and Sport Written Evidence


Memorandum submitted by Big Game TV Ltd

INTRODUCTION

  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.

PROCEDURES FOR HANDLING CALLS FROM VIEWERS

  3.  Big Game's call handling procedures vary according to the type of competition.

"Conventional" competitions

  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 Big Game);

  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. [1]

  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 message:

    "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.

  All Play

  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 callers—successful or not—derive 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 play along.

  7.  Calls are treated as follows:

  All calls—greeting message and invitation to answer each question.

  All calls—acknowledgement of each answer given.

  If a caller does not give an answer—instruction 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 correctly—message 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 correct—message 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 studio—message 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 studio—message 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 landline—other 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 screen—the 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 callers—so 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 variable—it 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 inaccurate—any `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 makes—some 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 other—if 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[2] 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 this—or 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 for broadcasters

  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 revenues—the primary means of funding for the vast majority of broadcasters—have 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 on viewers

  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 us—and our viewers—in 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[3].

  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 below—the 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. [4]But where Call TV does not amount to gambling, there is no justification for additional consumer protection beyond that which Ofcom and ICSTIS deem appropriate—Parliament 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 that—despite a widespread disdain for Call TV amongst the media—the 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 viewers—rather 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 has—and continues to operate—a 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.

WHETHER FURTHER REGULATION OF CALL TV QUIZ SHOWS IS REQUIRED

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.

OFCOMa

  25.  In April 2006, Ofcom published a Broadcasting Code Guidance Update[5] (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 Services"[6] (the "Statement of Expectations") and included the following statement:

  "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. [7]

  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 TV—ICSTIS, 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 protection—the 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 output.

  If viewers feel that they have been misled by TV programmes, they can complain to Ofcom—the 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 being misled.

  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.

  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 states:

    "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." [8]

  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[9] (a paper which itself made a number of helpful points on behalf of the Call TV industry, and which Big Game invites the Committee to read).

  32.  In its half-year statement published on 24 October 2006, [10]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 regulatory cracks.

GAMBLING COMMISSIONpa

  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.

SUMMARY—OFCOM, ICSTIS AND THE GAMBLING COMMISSION

  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 of attention.

  36.  Big Game does not deny that it is legitimate for the Committee to take an interest in Call TV through this inquiry—it is part and parcel of democratic debate—but 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 that—unless the Committee is to propose new legislation—regulatory decisions must remain the absolute domain of the relevant independent regulators, notably Ofcom and ICSTIS.

Is more stringent regulation needed?

  38.  In terms of whether Ofcom and ICSTIS should impose more stringent regulation, Big Game has three main points.

  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 on request;

  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 services—so 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

CONCLUDING REMARKS

  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 taking part.

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

2   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

3   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

4   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 1(c)). Back

5   Available at pages 4-6 of http://www.ofcome.org.uk/tv/obb/prog cb/pcb37/issue58.pdf Back

6   Available at http://www.ictis.org.uk/pdf news/QuizTVExpectations06./pdf Back

7   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

8   Ofcom duly did this by way of the Update (see paragraph 0 above). Back

9   Available at http://www.icstis.org.uk/pdfs consult/ConsultResp GamblingComm Oct06.pdf Back

10   Available at http://www.icstis.org.uk/pdfs news/1stHalfYearStatement0607.pdf Back


 
previous page contents next page

House of Commons home page Parliament home page House of Lords home page search page enquiries index

© Parliamentary copyright 2007
Prepared 25 January 2007