Policy, Production and Public Service in the UK – Taking Children Seriously

By Professor Jeanette Steemers

After the May publication of the damning Dyson inquiry report into the BBC’s handling of Martin Bashir’s Panorama interview with Diana, Princess of Wales in 1995, all sides are gearing up for the mid-term Review of the BBC’s Royal Charter in 2022. It promises to be a bruising encounter. Issues of governance, following a shift towards external regulation of the BBC by UK regulator, Ofcom in 2017, might seem tangential to how the BBC serves the UK’s children. However, taken as a whole, it all contributes to the slow and steady drip-feed of ideological arguments on three fronts around: the future of the BBC, the ethos of public service broadcasting generally, and how public service content should be funded. All three issues are relevant to children and young people, reflecting widely held assumptions about the BBC. As Home Secretary, Priti Patel stated in an interview on the BBC’s Andrew Marr Show on 23 May in response to the Bashir case, “This is the Netflix generation….How relevant is the BBC?”

The politicisation of debates around the BBC tend to push any consideration of children’s needs to the margins, minimising the Corporation’s contributions as a significant curator and funder of UK content for children and young people over many years. Within this febrile atmosphere, the Children’s Media Foundation’s campaign crucially goes to the crux of the issue, addressing Patel’s query directly when it asks whether public service media still matters for children. And unlike other policy consultations, it does put children at the centre of the debate. The CMF’s contribution is welcome because it offers a more comprehensive review of issues around content and children’s developing experiences, addressing recurring dilemmas about funding, but also pressing for a future vision that extends beyond constantly rehearsed, but stopgap arguments about broadcast provision by the BBC and commercial PSBs (ITV, C4, Five).

Who is framing the agenda?

One problem which constantly holds back the case for children’s public service media is the nature of the policy consultation process, namely – who gets to frame the agenda, who gets to respond, and who gets listened to. This has led to plenty of tinkering around the edges in recent years, but few interventions that deal with transformations and risk in the children’s market. The drawbacks of endless consultations from Ofcom, the DCMS or parliamentary inquiries by the House of Lords and the House of Commons, is that matters relating to children are rarely specifically addressed, and they rarely consult children. Consultation responses usually come from the same stakeholders including children’s advocacy groups like the Children’s Media Foundation: public service advocacy groups like the Voice of the Listener and Viewer; industry groups like Animation UK, Pact, COBA; broadcasters and other media players, who quite naturally represent their members or business interests rather than children’s interests. Most rely on evidence gleaned from Ofcom’s annual surveys of public service performance, which year after year show a decline in UK-originated hours (640 hours in 2019 compared to 1584 hours in 2006) and expenditure (from £99m to £79m between 2013-19) on UK children’s content by UK PSBs, but rarely reveal much qualitative depth about what parents and children really value about public service content made in the UK, whether they recognise it and whether they want more. What we do know is that a significant minority of children (pp. 20-21 also backed up by YACF research) don’t feel that TV shows people that look like them or that represent their localities.

There is also a constant failure to recognise the diversity of children and young people, lumping them all together when the needs of a 4-year old are clearly very different from a 10 year old or a 14 year old. By contrast those consultations that do focus on children for example, Ofcom’s Children’s Content Review (2017-18) and its 2019 consultation on BBC Children’s News and first-run UK originations are either so narrowly drawn, that they offer limited scope to move forward; or as was the case with BBC children’s news, pre-determined before the consultation was even concluded. The BBC asked for a reduction in originated Newsround hours from 85 to 35 a year, and Ofcom simply conceded, with little detail about how the BBC intended to cater for children’s news and engage them on other platforms.

Tackling inequalities

With all children supposedly able to access boundless services, experiences and content online this begs the question "Why should we care about public service media for children?” And indeed, there sometimes seems to be an apathy amongst policymakers towards this issue. But these assumptions about children as “digital natives”, who are uniformly engaging with online content and seeking out new experiences, is distorting the policy process. It’s true that many children are moving away from linear TV. But these arguments largely ignore deep inequalities in UK society, inequalities brought into sharp relief when Covid revealed the extent to which a significant minority of children and families have limited access to electronic devices and WIFI, let alone Netflix or Disney+, hindering their participation not only in essential education, but also essential communication. The pandemic has reminded us of the value of public interventions, the importance of public service values of universal access, quality and diversity, particularly for those children and families who do not have access to the necessities of life, including food, but extending to laptops and mobile phones. The BBC showed its worth with initiatives for educational content during the pandemic; but will it continue educational engagement if other more pressing priorities take over?

This isn’t an argument for a return to the days of afternoon children’s slots on mainstream channels, but it is an argument for the need to recognise that regulated and universal access to information and communications is a child’s essential right as laid down in the United Nations Charter on the Rights of the Child. Without regulation and public funding, the market alone is wanting in respect of diverse provision for diverse children, and current debates about online regulation and online harms suggest that similar mistakes are set to be made with little attention paid to positive interventions that ensure that public service content is freely available. As Ofcom concludes its Small Screen: Big Debate consultation about the future of public service media, and with the mid-term review of the BBC’s Charter next year, there is a danger that children’s issues will again drop down the agenda. This needs to be resisted, because if we don’t engage children and young people in trusted spaces with public service media content and experiences now, then we could be heading for a less cohesive and dysfunctional society further down the road.

Disappointment, again?

In its recent 2021 Small Screen: Big Debate consultation on the future of public service media, Ofcom only mentioned children under sixteen infrequently (on 6 pages), and they were not a focus of consultation events. To echo the newly appointed children’s commissioner on 16^th March “society and political structures often short-change children” and there is a high risk that policy-makers will ‘short-change’ children again.

Consultation of children, as distinct from undertaking market research in media trackers, has been lacking in previous inquiries. The current Ofcom overview of PSB does not take enough account of the future impact of technological transformations on children’s lives or offer to explore their views. Over time this has reinforced an almost laissez faire approach to children’s media and communications needs, which does little to engage with why public service is important for the under-18s, who are marginalised in many other aspects of policy as well. In respect of public service, we only have a partial picture of what they watch, how they find content, and how they interact with it.

The erosion of public service for children since 2003 tells us that arguments in favour of it need to be constantly reformulated and articulated, because serving children is often trumped by other short-term considerations - financial and commercial priorities, and more lucrative adult audiences. The current system, of which freely available public service broadcasting is a key part, has contributed to a cohesive democratic society, to which children also belong and in which they participate, engage and learn. It underpins children’s communications rights including ‘access to information and material from a diversity of national and international sources’ (Art.17), and the right to require states to give ‘due weight’ to the views of children, and to provide them with an opportunity ‘to be heard’ (see UN Convention on the Rights of the Child). Updated in 2021 to take account of children’s rights in the digital world, the UN convention underlines that states need to ensure equitable access, that children’s rights outweigh commercial interests, and that governments and businesses must take children’s views into account, including in matters around the digital world. Current consultations in the UK suggest that this is not happening.

Bring out the public service positives

Ideally an independent public service for children should include impartial news, educational content, information, drama and entertainment in new formats which reflect the diverse backgrounds of children living in all parts of the UK. It should be universally accessible, easy to find, prominent on any freely available platforms. It should be accessible in a platform-neutral way on-demand and online, so that all children can access it. It should be regulated in ways that protect children from harm.

Children’s content is part of the UK’s overall PSM offer, because commercial providers, many of whom are foreign-owned and minimally regulated, have never supported the full range of UK content, that fulfils children’s communicative rights in the place where they live. It’s disappointing therefore that the UK government’s most interesting response to market failure in recent years, namely the establishment in 2019 of the British Film Institute’s Young Audience Content Fund (YACF) had its funding cut from £57m to £44.2m in May, leaving £10.7m to spend in its final year.

When the YACF launched it certainly felt like a meaningful positive policy intervention to halt the decline in public service commissioning of UK children’s content. Admittedly, the condition of free-to-air distribution has largely limited awards to commissions by commercial PSBs (ITV, Five and Channel 4), in effect a public subsidy. But it has opened opportunities to explore alternative paths with new voices among the production community, such as Sky News (FYI Investigates with First News), and for regional representation and indigenous languages (S4C, BBC Alba). The YACF rekindled investment by commercial PSBs (the BBC did not participate) with the prospect of YACF financial support - combined with industry-targeted incentives of tax credits for animation and children’s live action. As a different model it does offer a starting point to think about new ways of defining and measuring the value of public service media to children, criteria that are not always open to scrutiny from PSBs. If one key lesson needs to be learned from the YACF, it should be how to extend its effectiveness beyond broadcast-type material largely from mainstream PSBs, to facilitating the distribution and promotion of a wider range of public service material on other platforms.

The Government’s decision to cut back on the YACF is indicative of a constant refrain since 2003 when the UK’s deregulatory Communications Act removed origination quotas for UK children’s content by commercial PSBs (ITV, Five, Channel 5). Restrictions in 2007 on advertising food high in fat, sugar and salt around children’s broadcast content led to radical reductions in commissioning, particularly by ITV which had been a key investor in quality UK children’s content. The BBC’s emergence as the UK’s dominant commissioner of children’s content, arguably proved detrimental for children’s choices and the production sector as BBC commissioning declined as part of a “fewer, bigger, better” initiative after 2007. In hindsight, it’s no surprise that children shifted their attention swiftly to online offerings, because PSBs have increasingly failed to provide them with enough of what they really want to watch or engage with. The removal of regulatory quotas and the failure of broadcasters to respond swiftly to new platforms, offers a cautionary tale of policy-makers failing to provide necessary safeguards, and the uphill battle to win those children back.

What next?

The CMF campaign is keen to establish new future-proof models for public service children’s media, which will continue to provide children with a rich diverse range of media experiences that will enhance their lives and address market failure. Looking over the contributions to this submission, several themes emerge on which to build more coherent approaches. They don’t provide all the answers, but they offer a start in four key areas, that learn from past failings and look further into the future.

BUILD PARTNERSHIPS WITH CHILDREN

Public service providers , governments and regulators should be less “top-down” and work harder to reach out to and engage with young people across the UK. This means more flexibility by the likes of the BBC, Ofcom and others to build collaborative relationships and new definitions of public service across multiple platforms with children and young people, rather than simply deciding for them. It could mean working with other publicly-funded cultural and educational institutions that engage with children – including crucially schools and film institutes as happens in Scandinavia and the Netherlands.

Building partnerships means engaging children and young people seamlessly across the platforms that appeal to them and taking greater account of the significance of gaming, friendship and content creation as markers of their identity, that could contribute to more inclusive definitions of public service. Could public service providers, funders and producers do more to recognise what children and young people can contribute as co-commissioners, co-creators and co-curators, filling the gap between the subscriber, data-driven experiences of Netflix and Disney Plus and the unregulated attractions of YouTube. It should mean listening to children, not just about how they create and share content, but also about what they value to ensure that the digital universe is not simply shaped by adults, and that adults take proper account of what different platforms mean to them and what is missing from their media experiences. Respecting and taking children’s opinions into account as ratified by the UN Convention on the Rights of the Child would go some way to tackling the public service dilemma of not connecting with children on their terms and in the digital world.

INVEST IN MEDIA LITERACY

Closely linked to better partnerships with children in decisions that affect them, is the need to invest in media literacy. As others argue elsewhere there needs to be improved development of critical digital literacy skills, that children need to assess what is being reported, how, why and in whose interests to become active, informed citizens in a socially cohesive and tolerant society. This is something which Ofcom has chosen to downplay as part of its statutory duties on media literacy. Yet this is precisely where those entrusted with public service obligations (regulators, broadcasters, funding bodies) can and should exercise leadership, working closely with schools and families to help children navigate the digital space and clearly distinguish between information sources. We know that older children (12-15) trust broadcast news (84%) more than social media (39%) (pp.16-17), and this needs investment to protect that space which represents a core public service priority. This is where regulatory intervention can ensure that children and young people as citizens continue to have access to trusted news and information.

REGULATE FOR DISCOVERY

Policy needs to be more radically focused on where young people access media, making sure there is space for non-commercial content and experiences that are inclusive, diverse and which don’t marginalise children in hard to reach minority or poorer communities. This means as much emphasis on positive interventions to achieve good outcomes such as beneficial cultural, social or developmental impacts, as negative regulatory interventions that counter the negative effects of violent, sexual or over-commercialised content. Ideally this should mean prominence for public service content and players on those platforms where screen-based public service content is most easily and frequently accessed and/or watched by children. It means negotiating with commercial providers to ensure that children can easily find it. This will need clear guidance from regulators about how the concept of public service can be reflected, recalibrated and reinvented for social media and algorithmic recommendation. Where previous regulatory interventions focused on levels of investment and production quotas, future regulatory work needs to focus much more on how public service content and experiences can be accessed easily, and fairly through regulatory interventions around prominence and algorithms.

BEWARE OF UNINTENDED CONSEQUENCES ON FUNDING

Funding public service represents a huge challenge. Public seed-funding for UK content is still a crucial part of today’s funding of UK children’s content, but it doesn’t go far. It is largely locked up in the licence fee, from which the BBC chose to spend 83m or just over 5% in 2020 on children’s  (p. 50) out of £1609m on TV services by genre, and in £57m over three years for the YACF, which was originally top-sliced exceptionally from the licence fee.

As others have argued, this may be time to explore levies on global media companies and platforms who enjoy unparalleled access to UK markets including production tax credits and low tax rates. But these are powerful companies, backed by a powerful US government, which is hostile to these type of interventions as other countries have found out. Nevertheless, levies could be used in different ways to support UK-originated children’s productions, but also in persuading global players to invest in promotion and discovery through public service algorithms; levies could also make the YACF a permanent fixture.

Alternatives to the licence fee, include a household fee (as in Germany), progressive tax-based systems (predominantly in Scandinavia) which involve smaller or larger payments based on personal income, and even collection through utility payments, which dramatically reduced evasion in Italy. All these systems have drawbacks and do not answer the fundamental issue of whether one institution should still receive the bulk of licence fee income, and whether a new approach is needed to serve children and young people across different funders and different platforms, disaggregating children’s content from institutions that are finding it harder to reach younger audiences. This could open a new plurality of providers as a truly contestable system, but evidence of how this operates in other countries (e.g., New Zealand), does not necessarily show a better fulfilment of the public service mission for children, and it would require a radical overhaul of the BBC.

Furthermore, for many projects, public funding forms only one part of the budget, and deficit funding from multiple sources, means that investment in originations is often shaped by the commercial considerations of others including international rollouts, which may diminish cultural distinctiveness, but also blur public service and commercial priorities. These tensions have been around for many years; but are also relevant for how publicly-funded or non-commercial public service content can sit comfortably online alongside commercial brands, or whether public service brands need to carve out a distinctive portal or landing page to create a public service space on digital platforms (see David Kleeman’s contribution). These are all issues that still need to be addressed suggesting the future still needs thought and crucially thought by the most important stakeholders, children themselves.

A way forward

The answers to these issues are not straightforward, but a start would be for policymakers in government and regulatory bodies to sit up, take notice and start to look for solutions that recognise that universal access to quality information and cultural experiences in new formats across multiple platforms is what makes the UK a functioning democracy, where everyone including children are taken seriously.  This is not just an industry issue, but also a society issue, where media literate young people contribute to the future stability of a diverse and inclusive democracy; where public service media content and experiences enhance citizenship and active participation, rather than subjecting children to conspiracies, fake news, and hate speech delivered by untransparent algorithms driven by unaccountable digital companies. Yet this requires sustainable regulatory, financial and structural interventions in the digital sphere, that allow children to benefit from their communications rights, rather than having those rights curtailed by lack of adult care and communications practices that undermine society.

By Professor Jeanette Steemers

Jeanette Steemers is Professor of Culture, Media and Creative Industries, and Vice Dean of Research  in the Faculty of Arts and Humanities at King’s College London. She has published widely on distribution, public service broadcasting and the children’s media industry. Her work has been funded by the British Academy, the Leverhulme Trust and the Arts and Humanities Research Council.

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