Further supplementary memorandum submitted
by the BBFC
1. How many examiners does the BBFC have
to examine video games?
The BBFC has around 30 examiners, and currently
up to a dozen of those may be called upon to examine games. This
dozen, together with a senior examiner, constitute our digital
media team. All have had extensive training, and all have a cutting
edge knowledge of both physical and online games. Indeed, some
have been recruited from the games industry, and all have particular
areas of expertise in games classification and policy.
2. Do the examiners play the whole of the
game? ie: how long do they spend playing the game?
A typical current BBFC game will be examined
for around five hours. Some games need much greater time [...]
Manhunt 2 took up a total of over 100 examining hours. Other games
may be suitable for examination taking less than five hours. No
classifier anywhere in the world plays games all through [...]
some games may have hundreds of hours of gameplay, and each playthrough
may give a different gaming experience. Instead, the onus is put
on the publisher to draw attention to material which may affect
the classification, and to provide all necessary supporting material
such as cheat codes, DVD playthroughs and documentary material
such as scripts. However, in terms of the fees that we charge,
we would expect to charge for up to five hours of play plus an
3. What are the ramifications if shopkeepers
sell age-inappropriate games to children?
It is a criminal offence under the terms of
the VRA to supply a work classified by the BBFC to anyone under
that age. The offence applies to the person doing the selling
and not the retail outlet, so every shop assistant is answerable
under the law. You can be fined up to £5,000, though in practice
it is usually several hundred pounds for first offences and I
doubt there are many second offences and or sent to prison, but
you would have to be a serious recidivist to get sent to prison.
4. Has the BBFC ever given a game an R18
No. R 18 is the category reserved for pornography
which is real sex and only available for sale in Licensed Sex
Shops. While some 18 rated games do have sexual activity in themGrand
Theft Auto and prostituteswe have not seen an "R18"
level game. Not least because of the limited outlets for sales.
5. What are the BBFC's powers in relation
to downloadable vido games? What incentives are there for games
publishers to submit dowloadable games to the BBFC?
I understand that the BBFC does not rate games
which can be played online because of the fact they can alter
over time, but why do you not rate fixed format downloadable games
as a matter of course? Is it because it is easy for consumers
to access downloadable games from other countries, therefore the
BBFC classification system becomes irrelevant? Or is it because
since there is no actual physical "shop keeper", therefore
no one can be prosecuted for selling someone an age-inappropriate
game? Why would games publishers buy BBFC Online classification?
What is in it for them?
Our powers come from the Video Recordings Act
which does not, as far as our best legal advice goes, cover the
Internet. So there is no legal requirement for the online distributors
to send their games to us. The reason BBFC.online is appealing
to both film and games distributors is that the public knows and
understands the BBFC system. We have carried out research which
very clearly says that the public actually expect the BBFC to
classify the same sort of material online that we already have
for cinema and DVD. In addition they said that they would trust
a website selling downloadable material if it was clear that it
was part of a BBFC scheme. It also assures them that they are
buying legitimate material. What they get is a lot of information
about why the work was rated as it was and this stays with the
work once it has been downloaded. This means that parents can
keep track of what their children are downloading. We also require
efficient gatekeeping systems in place so no one can access inappropriate
material. We will monitor this and websites risk being thrown
out of the scheme if their systems do not work. The distributors
are buying our reputation. This clearly does not have the same
weight in other countries and there is nothing to stop someone
in the UK downloading material from foreign websites. But most
people are very conservative in their online "shopping"
and like to have the assurances of a recognised brand protecting