Culture, Media and Sport CommitteeWritten evidence submitted by Ukie

About Us

The Association for UK Interactive Entertainment (Ukie) is the trade association that represents a wide range of businesses and organisations involved in the games and interactive entertainment industry in the UK.

Ukie exists to make the UK the best place in the world to develop and publish games and interactive entertainment. Ukie’s membership includes games publishers, developers and the academic institutions that support the industry. We represent the majority of the UK video games industry; in 2011 Ukie members were responsible for 97% of the games sold as physical products in the UK. Ukie is the only trade body in the UK to represent all the major games console manufacturers (Nintendo, Microsoft and Sony).

We are an Executive Board Member of UKCCIS and sponsored the hugely successful UKCCIS Summit in 2011. The video games industry has taken a leading role in the field of child safety, both online and offline, and continues to do so, as we outline in detail below.

Key Points

The UK games industry has taken a leading role in protecting minors from adult content, most importantly through the PEGI age-rating system. Ukie led the successful campaign for PEGI’s adoption into UK law and constantly promotes safe and sensible gaming to parents, particularly through www.askaboutgames.com

All the major games consoles have parental controls in place. As well as enforcing the age rating of a game, these controls can be used to limit or prevent children’s access to online content through the console.

PEGI has expanded into the online games world through PEGI Online, setting the same high standard for protection of children from inappropriate conduct. Ukie also work with our members to discuss and share best practice in keeping children safe in online games, particularly through our Online Games sub-group.

We are concerned about the impact of the government’s internet filters plan. There is a potential for this to do significant collateral damage to the UK games industry.

Protecting Minors from Adult ContentOur Track Record of Responsibility

The games industry has a long record of taking a responsible approach to child safety, by giving parents the tools to control what games their children play, and how and when they play them. Our most important tool has been the PEGI1 (Pan-European Games Information) age rating system. PEGI operates through a principles based code of practice, against which content providers across the EU self-declare their practice. A content rating is given by designated national games rating authorities (NICAM and the UK’s Video Standards Council), who independently review and monitor self-declaration. The PEGI system itself is also overseen by a number of independent bodies.

PEGI has been in place in the UK on a voluntary industry basis since 2003, when it replaced an earlier UK-only system. It operated alongside BBFC ratings, but having two systems was confusing for consumers. So in July 2012 PEGI became the sole legally-enforceable UK age rating system for games. As a result it is now a punishable offence to sell a game rated 12, 16 or 18 to a child below that age.

All major games consoles incorporate robust parental controls to ensure that these age ratings can be easily enforced in the home. Different manufacturers offer different degrees of control and functionality, but generally they all have the ability to:

Block the playing of games based on their age rating.

Block the playback of nonlinear audio-visual content (ie films) based on their rating.

Disable or restrict access to network functionality including web browsing and messaging.

Disable voice chat.

These parental controls are password protected and usually offered on an “active choice” basis when the console is first booted up.

At the launch of PEGI as the legal UK age-rating system in July 2012, Ukie’s members funded a major awareness-raising campaign, under the title Control.Collaborate.Create, educating parents both about the PEGI system, parental controls and about wider issues around children and video games.

Our Control.Collaborate.Create. campaign covered the following key themes:

Control—ensuring that consumers have the knowledge of the tools that they can use to control game content (including PEGI, parental controls and the need to take regular rest breaks).

Collaborate—encouraging parents to engage with and understand the games that their children are playing.

Create—promoting games as a creative, fun and worthwhile activity for everyone.

At the heart of this campaign was the re-launched website www.askaboutgames.com, which is designed primarily to help families understand games. This website prominently features a section linking parents to advice on setting up parental controls for all commonly-available gaming devices, including all major consoles, hand-held devices, and mobile platforms.

The askaboutgames site also plays an integral part in delivering the wider campaign’s messages with information and tips for consumers, and showcases of how playing video games is a collaborative and creative experience.

Our campaign had 300 significant media hits, across the BBC, ITV, C4, C5, Sky, national print, games press, regional papers and radio and national online outlets.

Askaboutgames.com has 20,000 visitors a week since its re-launch in July last year. We also distributed more than 50,000 leaflets promoting our safe and sensible gaming messages via Game and HMV stores.

A survey of over a thousand parents was conducted in July 2012 for the start of our campaign to support PEGI. This found that 35.9% of parents who own games consoles use parental controls, either regularly or occasionally, whilst 40% of parents know that parental controls exist for video games but do not use them because they already supervise their children’s game-playing and do not allow their children to own or play inappropriate games.

In total, 92.5% of parents whose children played games were aware of the parental controls that existed for those games on the consoles on which they are played.

We do not have previous data on these questions, so we cannot claim to know any trends. However, it is clear that at least three quarters of parents know about the availability of parental controls for games and feel informed enough to have confidence in deciding whether to use them.

This makes intuitive sense—many of today’s parents themselves grew up playing games, and have a strong understanding of the medium itself. It also indicates that, although education efforts should of course continue, there is already a strong understanding of the dangers of games both online and offline.

As a result of this strong experience with parental controls and age ratings, Ukie took a leading role in the UKCCIS Parental Controls work-stream and was part of the strong push for an active choice approach, reflecting the good track record such an approach has on games consoles.

Protecting Children in Online and Mobile Environments

PEGI has been recognised by the UK government as a leading example of an industry taking a responsible approach in keeping children away from unsuitable content, and also has strong recognition amongst UK parents. It has now expanded into the online games market through PEGI Online. As part of the rating process online game providers must indicate if their gaming environments fulfil rigorous PEGI Online requirements which are set out in article 9 of the PEGI Code of Conduct. These are:

Ukie work closely with PEGI to ensure that this system works for games companies, and to continue strengthening and improving it.

Ukie members offer many different types of online game and work to implement tailored safety controls that are appropriate for the different experiences and audiences those games provide. Those may include, among other things, information on safe gameplay, such as taking breaks, or tools to set time limits, chat filters, codes of conduct. See, for example, https://eu.battle.net/account/parental-controls/index.html.

Publishers of game worlds aimed at younger children regularly tailor controls to account for that audience’s unique needs. An excellent example is “Moshi Monsters”, the global success created by UK developers Mind Candy.

Children playing Moshi Monsters can post content on pin-boards, which is automatically filtered for inappropriate content. Furthermore, children can only see the pin-boards of the people they invite into their network, which can only be done if the other child’s username is known. This helps to ensure that children are only in contact with people they already know.

These are just examples of the ways in which online game providers are leading the way in allowing children and young adults to interact safely online, while having lots of fun.

Mobile Games—PEGI for APPS and IARC

The rise of smartphones and tablets as gaming platforms has been a vital part of the evolution of the games industry in recent years.

PEGI for APPS, a rating procedure specifically designed for small software applications, including but not limited to games, was launched in 2012 to address this important market shift. It is designed to cater specifically to the needs of app developers and digital platform operators. It is not a new rating system, it is a more flexible and tailor-made procedure that allows mobile or digital platforms to use the classic PEGI rating system as it is known from boxed products and online titles. On top of that, it adds new feature descriptors that inform a consumer about certain types of functionality in an app. Currently, PEGI for Apps is used by Microsoft on Windows 8 and Windows Mobile platforms.

Although app platforms still have local storefronts for customers it has become clear that publishers are in need of a one-stop-shop to get all age classifications for their products in one streamlined process. Therefore, an international working group, including rating boards from Europe, US, Australia, Brazil and others, is working on a global solution under the name of IARC (International Alliance for Rating Content): a list of questions that combines all the criteria of the different rating boards across the globe into one big flowchart.

PEGI for Apps has been part of this project from the start. The IARC program will provide for a streamlined submission process in order to produce classifications for all participating regions at the same time. Although depending on cultural differences, these ratings may vary the system provides a publisher with a single, robust solution and takes away a lot of hassle. IARC is expected to be launched at the end of 2013.

Internet FiltersSignificant Risk of Over-blocking

We have particular concerns about the potential for unintended consequences from the universal internet filtering that was announced by the Prime Minister in July.

Ukie have always supported an “active choice” approach to parental internet controls, as emphasised in our response to the DCMS consultation on the issue last year. The approach being proposed, where controls will be switched on by default, goes a step beyond this.

Whilst the protection of children is of course paramount, having controls in place by default greatly increases the importance of ensuring that they are well targeted and do not inadvertently block or restrict access to content that is not in fact inappropriate for children.

We understand that discussions are still taking place with ISPs, and that the final design of the filters is not in place. However, the only example already in place is the filtering that Talk Talk offer to all customers under the HomeSafe brand, and we have specific concerns about this system.

According to the Talk Talk website promoting their HomeSafe technology, parents are given a list of categories of “inappropriate websites” from which they can select which to block. These different categories are:

Dating.

Drugs, alcohol and tobacco.

File sharing sites.

Gambling.

Games.

Pornography.

Social networking.

Suicide and self-harm.

Weapons and violence.

The inclusion of “Games” in such a list is deeply troubling to our industry.

We recognise the value to parents of controls enabling them to restrict access to games that contain mature content (for example when they are PEGI age rated 18) if they choose to do so, as under existing parental controls systems, but simply filtering out all games is an extremely blunt approach that we believe is unnecessary and disproportionate, and could potentially have very adverse effects on the UK games industry. It should be noted that only a small proportion of games are age-rated 18. In 2012, for example, just 9.4% of PEGI-rated games received an 18 rating.2 Indeed, in the last ten years just 5.7% of games rated were PEGI 18.3

This proposal seems to ignore the difference between the content and the medium. It would be absurd to have an option for websites about “books” or “films” to be classed as inappropriate by their nature, without regard to the content, nature or rating of the individual products. It is equally wrong for the same to be applied to games.

We strongly disagree with this approach, and are discussing it actively with Talk Talk to learn how it is applied and what impact it is having.

We are very concerned that filtering “games” as a category of inappropriate websites could be held up as an example of best practice: it must not become government policy that this should be adopted by all ISPs. While the industry agrees that the protection of children is tantamount, the solution should be tailored appropriately to address the specific concern and not be so overly broad that it will have extreme and inappropriate consequences.

The potential commercial risk is clear: if a large portion of the UK population had all websites related to games blocked from their internet connection automatically, the impact on the games industry could be significant. More importantly, this filtering would block content that is well outside the scope of the adult material that this program seeks to address.

For example, application of a broad filter for all “games” will create a significant risk that games specifically intended for young people, including educational games, will be automatically blocked by filters targeting those issues.

The game industry does not believe this is in the best interest of UK children or something that parents want or need. This is evidenced in the statistic used earlier in the document that 40% of parents are aware of the parental controls that exist on their games consoles and choose not to use them, as they are already confident that they have sufficient control over their children’s habits. There are a large number of well-informed, technologically savvy parents in the UK, and blocking access to games websites without their consent would do great damage to the system’s credibility.

We strongly recommend that, as the government works with each ISP on implementation of the new filters, it does not promote the inclusion of “games” as a category of inappropriate websites.

Additionally, even filters that more specifically target content about “dating,” “drugs” or “alcohol,” may have unintended consequences that are detrimental to children. For example, a game teaching children about sexual health, drug addiction or other issues is likely to be caught by the filters and so inaccessible to the children it is designed to help. Many of these games can be discovered on sites which are not explicitly labelled as “education” or “charity”, in order to be discovered organically by the young people they are targeted towards, making it even more difficult for filters to intelligently detect and allow them.

Much greater information is needed on how the filters will work in practice, including how quickly incorrect blocks on websites can be reported and removed.

September 2013

1 The PEGI (Pan-European Game Information) system is a set of ethical standards in the format of a Code which reflect the industry’s commitment to act in a responsible manner towards children. The Code’s main aim is to provide parents with objective, intelligible and reliable information regarding the minimum age for which a given product is deemed suitable, but the Code also deals with related advertising and promotion, consumer redress & sanctions, commits members not to offend human decency and, after its merge with the PEGI Online Safety Code, now also aims to provide a safe online gaming environment for children.

2 http://www.pegi.info/en/index/id/1068/nid/media/pdf/390.pdf p13

3 Ibid.

Prepared 18th March 2014