November 9, 2023
Ofcom has duties under the Communications Act 2003 to promote media literacy which have been extended under the Online Safety Act 2023 (“OSA”). In addition, the OSA requires Ofcom to draw up, and from time to time review and revise, a statement recommending ways in which others, including providers of regulated services, might develop, pursue and evaluate activities or initiatives relevant to media literacy in relation to services covered by the OSA.
In its Call for Input, published on 31 October 2023, Ofcom seeks feedback from online platforms and services to help expand its understanding of what media literacy “by design” should look like. For Ofcom, what happens on online platforms, such as social media, search, video-sharing and gaming services, must be part of the solution to media literacy challenges in the UK, in particular as online platforms are able to engage with users “in the moment”. The response to the Call for Input is intended to contribute to the preparation of the statement Ofcom is required to make under the OSA.
Ofcom defines “media literacy” as “the ability to use, understand and create media and communications in a variety of contexts”. Ofcom refers to concepts such as prompting critical thinking, challenging unwelcome behaviour and enhancing user experiences.
On-platform interventions, including by means of pop-ups, labels, overlaps, notifications and resources, are used by service providers to intervene in their users’ experience to provide additional context or information to support informed decisions, to enable users to reflect on their behaviour and to develop resilience. Evidence shows that these interventions are initiated in response to a particular event (e.g. pandemic or a war), sometimes prompted by an external organisation or user, and evaluation of the impact of the interventions is not routinely conducted. Users have found interventions broadly helpful for highlighting sensitive or harmful content, although all agreed that repeated exposure became both irritating and counterproductive over time.
Specifically, Ofcom seeks input into a number of (non-exhaustive, voluntary) best practice principles for media literacy interventions. These include the creation by online services of a media literacy by design policy to promote critical and informed use of their product, publishing the impact that media literacy interventions have had, ensuring designs serve the broadest range of user needs by engaging a diverse range of users in the research stage of development, providing specific support to those with disabilities or accessibility needs, determining at the outset how the effectiveness of interventions will be measured (e.g. behaviour change), and monitoring interventions for effectiveness and impact and then iterating them to maintain and improve effectiveness.
Ofcom is seeking answers to nine specific questions, which include a request for case studies as well as feedback on the proposed best practice principles and other aspects of how online services currently support, or could support, media literacy. It does not specify or appear to seek input on what the content of the interventions should be.