Select Committee on Culture, Media and Sport Written Evidence

Memorandum submitted by the Interactive Software Federation of Europe (ISFE)


  1.  The Interactive Software Federation of Europe (ISFE) represents the European interactive software industry,[19] which produces entertainment and educational software for use on personal computers, consoles and portable devices including mobile phones and is the fastest growing "content" sector in Europe.

  2.  Due to the nature of their products European publishers of computer and video games have a tradition of caring about the protection of minors. This is exemplified by the Pan-European Game Information (PEGI) system (see the objective of which is to provide consumers with independently generated, trustworthy age recommendations likely to help parents make informed buying decisions. As online games now represent a growing share of our business, we want to shield minors from unsuitable content in that area too. We have therefore developed the PEGI Online project with the support of the European Commission ( Both PEGI and PEGI Online were launched, and are supported by, DG Information Society Commissioner Viviane Reding and her team.


  3.  Videogames are playing a growing role in the lives of people of all ages from all walks of life. They carry benefits and opportunities as they provide a playful way to hone ICT skills and, beyond, to acquire traditional knowledge (it is becoming widely accepted that they are unparalleled when it comes to stimulating the imagination or "making you think").

  4.  Videogames also have economic benefits: generations trained on consoles that encapsulate leading-edge digital technology cannot but enhance the competitiveness of Europe's ICT industries if they take a job in that sector. In addition, a number of today's online gamers are bound to become tomorrow's developers of online games because games, in essence, are all about creating your own content and gamers that prove particularly adept at this skill have no problem in subsequently making a business out of it.

  5.  As would hold true for any leisure pastime, however, there are risks attached. Some say that too much time is spent experiencing game content which the player finds so "riveting", as with other sports, that it is hard to resist yet another crack at improving your performance; others would point to an alleged, (albeit completely undocumented), spillover of violence in games to violent behaviour in real life. The EU-wide PEGI system was also developed by this industry to address such risks, and together with PEGI Online, it provides European parents with independently generated and reliable age recommendations aimed to help them make informed buying decisions. The parental control tools developed by game console manufacturers only make PEGI/PEGI Online more effective in this regard.


  6.  There has been growing recognition that games—owing to their interactive nature—may provide useful tools for training and education. In light of the enduring success of interactive software at getting generations of children excited by ICT and at endowing them with the right ICT skills, late and early adopters alike can benefit from this unique "learn as you play" training scheme so paving the way for full digital literacy.

  7.  In 2003 the OECD's Programme for International Student Assessment (PISA) collected data to explore the impact of ICT on the learning patterns of young students.[20] The results show that ICT availability and use are strongly associated with good student performance. Further the evidence also confirms previous studies indicating the particularly strong association of performance with home access to, and usage of, technology. OECD also convened a major conference on "videogames and education" in Santiago last year (see all presentations at Closer to home, the EU-supported Mediappro initiative ( concluded that the technological development brought about by the internet and ICT plays a leading role, in encouraging innovation, especially by young users.

  8.  Playing videogames has also other potential benefits for young players. These include providing children with the opportunity to negotiate society's rules and roles, allowing children to experiment with aggression in a safe setting without real world consequences, facilitating children's development of self-regulation of arousal, and serving as an effective tool in clinical settings. Moreover, interactive software confronts users with problem-solving tasks that have an inherent intellectual value, unlike the more passive forms of entertainment provided by traditional content. Whether members of the target population find it reminiscent of their schooldays or appreciate more the standard challenge of games to "think on one's feet", what matters is that they will take up this challenge and develop a taste for more of the same rewarding experience. As basic psychology would have it, enjoying a stream of rewarding experiences with ICT is the best way to build up confidence in one's own ICT skills and to shore up self-esteem.

  9.  This is starkly supported by the results of the latest Nielsen EU Consumer survey which clearly show that games fare ahead of TV and movies as tools to stimulate imagination and make people think.[21] Findings from "Interactive Australia 2007" show that this is a worldwide phenomenon:[22]

    —    Parents in game households estimate that the positive outcomes from game play includes more than just enjoyment and happiness: 73% say games help their children learn about technology, 68% say games help their children learn maths, 64% say games help children learn to plan.

    —    Gamers are more than twice as likely as non-gamers to say interactivity enhances the educational nature of a media experience.

  10.  The European videogame industry is in a position to make a unique contribution to delivering on the objectives of the EU's Lisbon Agenda in two ways:

    —    it is a transformational industry with a proven record of strongly influencing adjacent sectors whether upstream (hardcore gamers provide the test bed for high-performance micro-chips for instance) or downstream (capacity-hungry MMOGs are known to foster the uptake of broadband in Europe);[23]

    —    Dr Jason Rutter at Manchester University estimates that "playing games acts as an effective training ground for entry into the games development industry. It allows the development of skills, experimentation with innovative ideas and the development of a games portfolio for entry into paid work". (Postino, H 2003 From Pong to Planet Quake: post-industrial transitions from leisure to work, Information and Society, 6(4), pp 593-606). In other words, today's online gamers with specific skills at generating new content will manage the game development studios of tomorrow.


  11.  A number of PC and videogames include violent content. In particular, 90% of PEGI 18+ games carry the violence descriptor. However, only 5% of all games awarded PEGI licenses are rated as 18+. It is worth noting that violence in a 7+ game is radically different to violence in a 16+ game as evidenced by the strict requirements of the PEGI questionnaire.

  12.  Any risk is more theoretical than real, however, as global research is divided as to identifying any causal link between playing violent games and physical aggression:

    —    researchers in Japan and in the US believe they have ascertained this link. Professor Sakamoto: "Videogames play promotes aggressive behaviour. Influence was the strongest when games had both high rewarding and realistic qualities".[24] Even in the US, the link allegedly found by research is often queried:

    "We seem to want to believe that kids are more violent than they are. Some respected news outlets have been caught distorting the facts in order to play on our anxieties about out-of-control kids. A flurry of stories from the major networks and wire services in 1996 reported, in the words of one AP entry, `though crime rates in general are going down, rates of juvenile crime appear to be rising'. Subsequent media studies found that the stories came from a cobbling together of two very different sets of data from the Justice Department showing that the opposite was true. The truth in fact was quite dramatically opposite: from 1980 to 1996, serious crime among American children 17 and younger dropped by 15%; among young adults, 18 to 29, it dropped by 11%. But among adults in their thirties, serious crime increased by a staggering 36%. Even among adults in their forties, serious crime increased by 20%."[25]

    —    In Europe, Professor Wassilis Kassis (University of Basel) is positive: "There is no linear combination between violent games and the violence of teenagers in reality".[26] In 2007, Professor Kassis admitted to extreme social environments being potentially conducive to such a link.[27]

    —    More generally, most of the European research points to social factors as cause for aggressiveness which inflicts an interest for more violent media but it is also worth noting that some European researchers would consider that lab or in vitro research is flawed.[28]

  13.  Some research points to videogames being overly addictive. World researchers are divided on this topic too. Again, Japan and Korea seem to have identified extreme—albeit extremely rare—cases of gamers becoming so obsessed with in gaming that they lose sight of real life: they are dubbed "No Life". In Europe, Mark Griffiths, an addiction luminary, said: "A lot of people confuse excessive behaviour with addictive behaviour". At the same event Guy Cumberbatch, another expert from the UK, stated that "the prevalence of true videogame addiction, say in the UK population, is probably less than 0.0001%, to be compared with just under 1% for gambling".[29]

  14.  It is worth noting that the risk of addiction is deemed to be higher with online games, particularly MMOGs (see Michael Stora's concerns about World of Warcraft).[30] However the same Michael Stora is quoted in the Recommendation of the Forum des Droits sur l'Internet ( ) (page 31) as saying: "The game is more a tell tale of deeper problems, not the root cause of the dependence". "Videogames have a knack for putting parents' authority to the test", he comments. This being said, parents cannot deny that there are ways of keeping a check on "addiction" at home: as one panelist commented at a session on parental control,[31] "however user-friendly or unfriendly parental control software is felt, there is always a basic tool at hand, ie to pull the plug".[32]

  15.  The Eurobarometer's qualitative survey which interviewed children of 9-10 and 12-14 years old from all 27 EU Member States plus Norway and Iceland asked about how they use online technologies, and how they would react to problems and risks when using the internet and mobile phones. The results show that children are globally well aware of the potential online risks, such as security, viruses, access to unwanted content, identity theft and potential dangerous contact with strangers. Many of them are also well aware of the necessary precautions they need to take. Some children nevertheless admitted that they have engaged in risky behaviour, and some acknowledged that they have been victims of bullying and had contacts with strangers.[33]


  16.  In 2002, the European Interactive Software industry has set up the PEGI system (see a now very successful classification system for video games to help parents make informed buying decisions and prevent minors from being exposed to content unsuitable for their age. These recommendations are meant to help guide the choice of parents and other "gatekeepers". In addition the industry has now designed a system to make this protection more effective in the online gaming environment PEGI Online is a new initiative funded by the European Commission under the Safer Internet programme (see It is based on a code of practice, the PEGI Online Safety Code, a licensing system managed by an independent administrator, and a distinctive "PEGI Online" label intended as a "trust mark" and independent supervisory bodies aimed to provide advice and to settle disputes.

  17.  Given the above emphasis on the paramount role of parents and educators, Communication is instrumental in making PEGI effective. Familiarity with the existence of PEGI is the highest in the UK (43%) 98% of interviewees in the UK recognize the PEGI symbols when prompted with them, 74% deem the system to be "quite" to "extremely" useful, 58% recognize PEGI descriptors and 67% think they provide useful assistance in their buying decisions.

  18.  Playing together is the best insurance against potential risk as it affords parents opportunities to talk and explain. As French psychologist Serge Tisseron put it in plain terms at the ISFE 2006 Experts Conference "When children speak with their parents, the risk is lower". Incidentally this holds true for other content, movie, TV, drama, etc. A good practice on the part of parents also consists of being involved in the choice of games. In this respect, the Nielsen survey of 2005 found that 81% of parents interviewed check their children's games (although this finding has to be qualified in light of no interviewee being older than 34).

  19.  Filtering is the next best alternative: parents who do not have time to share entertainment with their children have an opportunity to control the suitability of interactive software played at home in accordance with their own children's age and maturity. It is worth noting that filtering software offers a safety net in case retailers do not exercise their responsibility in full. However, betting one's children's safety on automation is not something to be encouraged. Indeed, the publicity materials associated with PEGI Online do quite the opposite by calling on the vigilance of parents in making the system work.

  20.  Age verification or filtering systems can be said to achieve one of two extremes: building trust with parents or misleading them. The reality is somewhere in between. Any parent who ascertains that a virtual environment is secured by efficient technology and infers from it that this environment is absolutely `safe' runs the risk of experiencing a false sense of security. Just as no playground in real life is absolutely safe nor can any online equivalent ever be totally secure. Accordingly, age verification or filtering systems can never be totally free of weak spots which clever children can use to bypass the system. As with other technologically advanced automated processes, these systems tend to reduce parents' appetite to learn about what their children do on the internet. This could be said to be "the dark side" of over reliance on automation.

  21. The Insafe network of national nodes interacts with industry, schools and families with a view to empower individuals to use the internet safely and bridge the digital divide between home and school and between generations. In many countries these Insafe nodes cooperate with national helplines to address the questions and concerns of young people linked to their experiences online or the harmful or illegal online content they encounter. Other examples are Educaunet (, a European project to foster critical awareness in media education, or EuroMediaLiteracy, a network of organizations dedicated to enhance media literacy (


  22.  As a general observation, the European Commission has tasked Rand Europe with suggesting methodologies to evaluate self- and co-regulation of the Internet. Chris Marsden is leading this research: The report, scheduled to be delivered in early 2008, will include a vast outlook of existing self- and co-regulations. It may therefore be of interest to this inquiry.

  23.  Retail has a potential ability to help make PEGI more effective if they commit to avoiding that adult games end up in the hands of minors. The UK retail is well briefed and regularly trained by the VSC and has a flawless record in this respect.

  24.  Given the above emphasis on the paramount role of parents and educators, communication is instrumental to making PEGI effective. Familiarity with the existence of PEGI is the highest in the UK (43%) (Nielsen 2007 survey p 38).[34] 98% of interviewees in the UK recognize the PEGI symbols when prompted with them, 74% deem the system to be quite to extremely useful, 58% recognize PEGI descriptors and 67% think they provide a useful assistance to their buying decisions.

  25.  It could be argued that PEGI has done pretty well from the very start. On comparing the uptake of PEGI after 15 months in culturally diverse Europe with the uptake of the OFLC game classification over three years in culturally homogeneous Australia,[35] PEGI came out a clear winner:

    —    42% of parents, 35% of non-parents were aware of a classification system in Australia. This ratio reached 74% with young people.

    —    In Europe, close to 60% of respondents to the PEGI questionnaire admitted to being aware of the system. While unaided awareness was considerably lower (20%), recognition reached 72% when respondents were shown PEGI symbols.

    —    Only 38% of adults, 45% of young people would use the Australian system. Almost 40% of respondents to the Nielsen study (42% of parents, PEGI's key target) found the system "quite useful". 73% would find it quite or very or extremely useful.

    —    40% of adult respondents, 20% of young people who said they were aware of the Australian system proved unable to nominate specific classification levels. In Europe, 40% of Nielsen respondents reported spotting the PEGI descriptors, vs 52% reporting they had not noticed.

January 2008

19   ISFE Membership consists of the following: Associations-AESVI (Italy), ADESE (Spain), BIU (Germany), BLISA (Belgium), ELSPA (UK), FIGMA (Finland), MDTS (Sweden), MUF (Denmark), NVPI (The Netherlands), NSM (Norway), OVUS (Austria), SELL (France), SIEA (Swizerland). Companies-Activision, Atari,, Eidos, Electronic Arts, Konami, Microsoft, Nintendo, SCEE (Sony Computer Entertainment Europe), Take 2, THQ, UbiSoft, VUG (Vivendi Universal Games), The Walt Disney Company France. Back

20   The full PISA study is available for download at our website Back

21   See Back

22   Interactive Australia 2007, Facts about the Australian Computer and Video Game Industry, Bond University. Back

23   Massively Multiplayer Online Games. Back

24   Present State of Videogames and Learning Games-Use and Effects, presentation by Professor Takashi Sakamoto at OECD conference on video games and education. Back

25   Gerard Jones in Killing Monsters, Basic Books, p 126. Back

26   ISFE Experts Conference Videogames; Friends of Foes Brussels July 2006. Back

27   ISFE Experts Conference The Challenge of Online Gaming Brussels June 2007. Back

28   Review of research on the impact of violent computer games on young people, Boyle and Hibberd, 2005. Back

29   ISFE Experts Conference Videogames; Friends of Foes Brussels July 2006. Back

30   ISFE Experts Conference The Challenge of Online Gaming Brussels June 2007. Back

31   Conference on videogames, France's National Assembly, Paris, 11 September 2006. Back

32   ISFE Experts Conference The Challenge of Online Gaming Brussels June 2007. Back

33   See detailed statistics at (Nielsen 2007 survey p 38). Back

34   Nielsen Videogame Consumer Survey 2007 p 38. Back

35   Interactive Australia 2007, Facts about the Australian Computer and Video game industry, Bond University. Back

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Prepared 31 July 2008