Memorandum submitted by the Interactive
Software Federation of Europe (ISFE)
PRELIMINARY REMARKS
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 www.pegi.info) 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 (www.pegionline.eu).
Both PEGI and PEGI Online were launched, and are supported by,
DG Information Society Commissioner Viviane Reding and her team.
EXECUTIVE SUMMARY
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.
BENEFITS AND
OPPORTUNITIES
6. There has been growing recognition that
gamesowing to their interactive naturemay 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
www.enlaces.cl/seminariovideojuegos. Closer to home, the EU-supported
Mediappro initiative (www.mediappro.org) 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.
POTENTIAL AND
ACTUAL RISKS
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 extremealbeit
extremely rarecases 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 (http://www.foruminternet.org
) (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]
THE TOOLS
AVAILABLE TO
PROTECT PEOPLE
FROM POTENTIALLY
HARMFUL CONTENT
16. In 2002, the European Interactive Software
industry has set up the PEGI system (see www.pegi.info) 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 www.pegionline.eu). 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 (http://www.educaunet.org/), a European
project to foster critical awareness in media education, or EuroMediaLiteracy,
a network of organizations dedicated to enhance media literacy
(www.euromedialiteracy.eu)
EFFECTIVENESS OF
THE EXISTING
REGULATORY REGIME
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: cmars@essex.ac.uk. 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 www.isfe.eu Back
21
See www.isfe.eu 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). http://ec.europa.eu/information_society/activities/sip/eurobarometer/index_en.htm 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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