Dear Mr Vaizey

Thank you for your letter of 1 September in reply to ours of 15 August to Rt Hon Jeremy Hunt MP about violent video games and violent content in the media.

You mentioned the Communications Review for the Digital Age which will inform the Green Paper to be produced at the end of the year. Unfortunately we had not heard about this in time to meet the deadline of 30 June to respond to Mr Hunt’s Open Letter. Nevertheless, as a body representing the interests of consumers and citizens, we very much hope that our comments contained in this letter can still be taken into consideration.

Growth, Innovation and deregulation

May we open with this rationale behind Jacques Ellul’s book, The Technological Society: ‘He was concerned about how to maintain moral values in a technological society’.

We also note the comments made by Dr Richard House in the Daily Telegraph 24 September 2011, ‘The inexorable momentum of modern technological life is such that despite awareness raised through the September 2006 Telegraph open letter on ‘toxic childhood’, matters have improved very little.’

These epitomise Safermedia’s own concern about the rapid technological changes in communications technology. Fiercely competitive global markets have driven growth at break neck speed and the independent research on the negative effects this is having on children and society is not being taken sufficiently seriously.

Please see the attached paper, ‘Where Lunatics Prosper’ by Jeanine Connor.

Principle of independent regulation

1. We note that PEGI system for classification for video games will be under the authority of the Video Standards Council (VSC) which your letter states is independent from the games industry. However the VSC is funded from its membership who pay fees based on their annual turnover, and all are trade, retailers, suppliers and games companies. Not one single category of membership is consumer-based. The VSC says it represents the interests of video and games industries at the highest levels. Therefore, we do not see how the VSC is independent from the vested interests of the industry.

In your letter you say you believe the PEGI system is right for video games classification but it is interesting to note that the VSC website admits that at certain levels the material could ‘encourage’ activities such as drug taking and gambling.

2. British Board of Film Classification (BBFC) – the same applies to the BBFC which is funded from the fees it charges the industry to classify their films. While it provides consumer advice, few busy parents check their website, and this does not allow for illiteracy among a vulnerable section of the population or inability to speak English. Providing information in the hope people will read it AND act on it is unrealistic, putting too much responsibility on consumers.

We have written to the BBFC in the past about our concerns but this has proved futile. We don’t believe the BBFC is mindful of current sensibilities regarding knife and other violent crime; in 2005 the BBFC dropped its ban on knife fights in films deemed suitable for 15 year olds. Since then we have seen knife crime escalate. For the Guidelines at ‘15’ to state that “easily accessible weapons should not be glamorised” raises two questions immediately: what does ‘easily accessible’ mean, and what does ‘glamorised’ mean?

We disagree that research suggests they (BBFC) are generally perceived as awarding

the appropriate classification. If the research referred to is the BBFC’s own research, which is mainly focus group based, asking its own questions, then it is not valid. We remain of the opinion that the BBFC needs to be made properly accountable to Parliament.

3. Ofcom – Ofcom is partly funded from the fees it receives for granting licences to broadcasters, of which we now have an over abundance resulting in lower standards of content. Light touch regulation has provided Ofcom with the means to be extremely elastic in its adjudications (X Factor is an obvious recent example). We understand that businesses need to have confidence in the regulatory system but the desire for market growth must be balanced by effective regulation of content for the public good.

In 2007 following the murder of Rhys Jones by a young person, Mr Cameron said, “We have had a spate of children killing children. What is going wrong?”.

In January 2010 in Edlington, two boys aged 10 and 11, subjected two other boys of the same age to a prolonged and violent attack, shocking the nation. Kevin Browne, Professor of Forensic Psychology at Nottingham University commented: “The chances of these boys committing such a horrendous crime of violent and sexual assault were definitely increased by watching violent and pornographic films at home.”

In 2008 Judge David Rennie called for a Government inquiry into violent videos on the internet after a 40 year old man was left paralysed and blind in his right eye after a gang of youths beat him with a metal wheel brace and stamped on his head. Judge Rennie said the attack was inspired by graphic scenes of violence which can be found easily on the web.

May we ask if a Government inquiry was set up?

In 2009 a headline read ‘7 year-olds carrying knives in ‘arms race’, and on 10 September 2011 an almost identical headline, ‘Seven-year-olds armed with knives’.

Tax breaks for games industry

We suggest that only those games companies who are able to produce ethical games which do not need to carry warnings for violent content etc should be granted a tax break. They should also carry a warning of potential addictive behaviour.

We understand the stunning artistic creativity and skill that go into their production. Surely if manufacturers want to be truly ‘innovative’ they can avoid violence, sexual violence etc, for example, this and further comments from a games player (mature adult):

“I'm playing a delightful game called Syberia at the moment. There is no violence - it's a puzzle game, heavily centred on mechanical devices.”

“It's sad that games, like movies, are so often in a race to the bottom; they have the capacity to expand kids' ethical awareness…..
While playing an adventure (genre) game this week, I found myself stuck – an

Impasse – so decided to cheat by consulting a walk-thru, and was horrified to read that the recommended solution was to take the person causing the problem somewhere out of sight and kill him. [Later I came up with a more creative solution.] I decided to stop playing, perhaps because I am silly enough to apply ethics in a virtual world (or at least wish to play a consistent character). I was somewhat concerned that the game might be a bad influence on young players (ie teaching ruthlessness). This is a generally non-violent game – if you count wiping out most of the wildlife non-violent.”

We are breeding a lost generation of angry young men, many who come under the heading ‘neets’, who spend their days alone in front of a screen and playing violent computer games and who are prey to those anarchic elements who wish to stir up hatred and cause mayhem as witnessed in the riots recently. We need to heed Baroness Greenfield and other scientists who argue that screen-based modern technology is changing the way our brains function.

On 22 July, following the NewsCorps scandal, in David Cameron’s statement to Parliament he said this was a “once in a lifetime opportunity to try and get media regulation right.” We hope that the inquiry led by Lord Justice Leveson together with the review of the regulatory framework supporting the UK communications sector will indeed ensure the wider public interest and safety is paramount.