Memorandum submitted by The UK Campaign
for LOGO FREE TV
The UK Campaign for LOGO FREE TV (web site
http://www.logofreetv.org.uk/) is a new UK Viewers Group with
more than 1,000 UK members. We have assembled to lobby for and
oppose problems specifically to do with "permanent on-screen
logos", in-programme-time advertising, unsolicited interactive
advertising, and in effect anything that effects the visual
quality of service to the viewer. As a functional viewer's lobby
group, we take an interest in and respond to all consultations
that effect the service received by viewers.
Accountability, Reporting, and "Checks
and Balances" seem to be PR exercises conducted "end
of term" report style. The issues that we encounter day-to-day
NEVER get covered.
White papers, Explanations of Policy, and Executive
comment, are at best conducted at controlled Press Conferences.
Detailed policy documentation, even from the BBC and Must-Carry
broadcasters are NOT available to the public. We cannot get Broadcast
Executives to comment first-hand, even with the help from our
Regulation is explicitly "light touch"
and industry lead. Enforcement is typical based on an "after-the-event"
basis if a large enough number of people respond.
There is NO requirement for broadcasters to
disclose viewer complaint logs, statistics, or summaries to the
public. Therefore, when TV viewers complain, these complaints
disappear into a void. (We have established the first public duty
office service on our own web site.) Can corporations with commercial
interests really be trusted to disclose the truth if it is not
in their interests?
The ITC regulator assumes that viewers can make
choices by simply switching off. But, the ITC ignores that channels
are allocated on a "bundled" basis, and consumers are
subject to minimum contracts. (At the very least, every time a
consumer shops or buys a product, they are paying for TV services
Regarding "on-screen logos", Interactive
Solicitations, and "In-programme Cross Promotions",
the BBC Governors have NEVER documented the issue, the BBC Executive
leaves numerous questions unanswered in spite of a minuscule amount
of viewers, the ITC will not rule for or against, and Sky has
an agenda of making £50 ARPU.
The Chairman of the BBC and BBC Board of Governors
have so far refused and failed to investigate the issue of permanent
1. Minutes of Board Meetings of the BBC
(Governors and Executive), Must-Carry Broadcasters, and Subscription
Operators should be openly published (as with Parliament or the
MPC), since the decisions of these boards weighs upon their stakeholders,
shareholders, customers, viewers and the public interest.
2. Viewer's Correspondence should be publicly
categorised, and summaries published. Internet technology makes
it feasible for the establishment of a collectively financed National
3. The Establishment of a National Duty
Office would allow broadcasters to share costs, enjoy economy
of scale, and by use of web technology, would allow new and instant
visibility of issues as they occur. More, a consistent National
Standard of Correspondence Handling could be established setting
Britain as a world leader in this field.
4. The BBC should be aggressively included
under OFCOM regulation.
5. The BBC itself SHOULD NOT be fined, but
for the BBC and Channel Four Corporation, the regulator should
have powers to fine broadcast executives, as a percentage of the
broadcaster's Executive Directors Salaries inclusive of bonuses,
and without financial fudge. There is no point in fining the viewers,
advertisers, or producers. The most effective form of fines (as
with the H & S Executive) are ones that "hurt" the
6. "Subscription Bundling", the
practice of forcing a large package of more expensive channels
on consumers, should be investigated and loosened to provide more
choice to more consumers. The packages are too expensive which
excludes viewers from the market.
7. Adult content opt-out in the Digital
Set-Top-Box, should be compulsory for ALL platform operators,
on all channels.
1. We would like to see a ban on the routine
use of permanently on-screen BUGs, DOGs, LOGOs, Corporate Brandings,
Emblems, or Channel Identifiers on British mainstream TV. (Full
practical details are published on our web site).
2. We also believe broadcasters that employ
permanently on-screen branding should give full and accurate explanations
to their viewers. They should clearly state what the purpose of
the "branding" is for, explain how (or whether) they
consulted the public, accurately report any opposition they receive
to on-screen branding, and periodically review the effectiveness
and necessity of their branding policies.
3. When advertising and promoting LOGO-ised
channels, we believe the promotional material should consistently
and accurately show the branding found in the final product. We
believe that consumers should be informed before they commit themselves
to a purchase or contract.
4. With the new phenomena of Interactive
Icons (particularly as found on the BSkyB satellite platform),
we believe that consumers should have a menu option enabling them
to opt out of the interactive services promotion. An option allowing
the icons to time-out and disappear after 10 seconds should also
be made available.
5. We are greatly concerned about the lack
of parental lock-out on some commercial Interactive dial-up Services,
and the unsolicited nature of the interactive icon "adverts"
(of dubious benefit to the user) mid-programme. We want to see
"parental lock-out" controls added to Digital Set-Top
boxes preventing unauthorised use of inappropriate or expensive
6. We would like to see safety warnings
labelled on the front of Plasma and Rear-Projection TV sets in
retail outlets, warning consumers that the equipment could be
permanently and irreparable damaged if LOGOed channels are display
on it. (Details of the risk of permanent damage are thoroughly
documented on our web site).
7. We would like the regulator to take an
aggressive and tough stance against in-programme advertising,
promotion, and cross-promotion. We think it is appalling how youth
TV shows, and even Sky News, can be allowed to promote premium
rate telephone services (whether "Interactive" or not).
8. We think that there must be urgent research
and analysis conducted into the effects of "branding",
particularly on very young children. The appearance of BBC characters
on adverts for commercial products (McDonalds, Burger King, Heinz)
is detestable, and an insidious betrayal of the license fee and
9. We can not see how BBC CHOICE or BBC
FOUR serves the public interest, by running a "disfigured"
picture that is watched by only a few thousand viewers at vast
public expense. Some of our members resent being forced to subscribe
by law to non-public interest channels that are clones of commercial
channels, and in the case of BBC CHOICE feature heavily in "garbage