My response to ABA media release

Peter Webb writes on behalf of the ABA:
> Firstly, the ABA has *not* proposed a mandatory or compulsory labelling 
> scheme. As we stated in our postings to the Link mailing list on 16 December 
> 1996, and 15 and 17 January this year, we have proposed a *voluntary* 
> labelling scheme in a _substantially self-regulatory regime for on-line 
> services in Australia_.

Two points.

Firstly, not having proposed a mandatory labelling scheme is not the same
as making a commitment not to introduce such a scheme.  Irene's favourite
quote is:

	"An obligation to utilise PICS-type systems ...
	might have to be enforced". 
	Peter Webb, Chairman, Australian Broadcasting Authority, June 1996. 
 
Can we take it that you have changed your mind since then?

Secondly, the ABA plans to approve ISP codes of conduct.  Can we have
an assurance that compelling the use of labelling schemes will NOT be
a criteria for deciding which codes are approved?  If the only Codes
approved by the ABA mandate labelling, that is just compulsory labelling
by indirect means.  (With the threat of prosecution under the laws of
individual States as the stick, and an offer of immunity as the carrot.)

> Further, in postings to the Link mailing list on 16 December and 15 January 
> we stated that the _ABA has proposed:
>        the development of voluntary Internet content labelling schemes
>        which will provide parents and supervisors with options to protect
>        minors from content which may be harmful to them_.

For reasons which I have expanded on before, I do not believe
that *self*-labelling can ever be much use in this regard.  I also
believe that the primary goal of any rating system used by parents and
schools should be *selection* of useful information, not *blocking* of
harmful information.  The blocking of pornography and similar materials
should be just an incidental byproduct of the selection of appropriate
educational materials.  (This parallels the CDA judgement's finding 
that inadvertent exposure to "offensive material" was a byproduct of
"irrelevant results" from search engines.)

The RSACi system is totally useless as a selection tool for educational
value.

> Secondly, the ABA has also been criticised for supporting the labelling
> scheme developed by the Recreational Software Advisory Council (RSAC). The 
> labelling scheme they have developed is known as RSACi, or RSAC for the 
> Internet. The ABA sees many benefits in the development of these schemes, 
> especially ones that are international in focus.

The last thing we need is an international rating scheme outside our
control.  Australian parents, schools, and service providers should build
their own system(s), so that they have a full say in what is decided.
It should be designed with the primary goal of selecting material
of educational value and the services that use it should be run by
libraries, schools, and other educational organisations.

Since when did the ABA (or the OECD, for that matter) play a significant 
role in selecting books to go in school libraries?

> A voluntary system, as proposed by the ABA, whereby content is labelled by 
> content providers or third parties will be of great benefit to parents and 
> supervisors. By using labelling schemes such as RSACi, parents and 
> supervisors will be able to filter out content they consider unsuitable for 
> either their children or themselves.
 
You have dodged the point.  Very specific criticisms have been levelled
at RSACi; you have not responded to any of them.  Instead you revert
to talking about "schemes _such as_ RSACi" (my emphasis).
 
> If parents are happy for their children to surf the Internet with no 
> restrictions, then that is their choice. However if they are concerned with 
> some forms of Internet content, such as sex, nudity, language and violence, 
> then they are able to restrict their children_s access to this content.

Only if they are concerned about sex, nudity, violence, and language *and*
their models for these things correspond to RSAC's.

For example, not a few Muslims consider any depiction of a woman's
shoulders as indecent, but unless people rating with RSACi take this into
account when deciding what 'a reasonable person' would consider sexually
suggestive, RSACi cannot be used by them to block access to such material.
On the other hand, some cultures consider nakedness normal, but will be
forced to label (or will have labelled for them) images of everyday life
in the same fashion as pornography.

> RSACi is, in general, is descriptive rather than evaluative in the way it 
> defines each category. 

No, it _is_ evaluative.  It makes radical assumptions about background
culture and personal attitudes in its very choice of definitions.  Its
descriptive surface just provides an illusion of objectivity.

A clearly subjective system such as Net Shepherd is far superior.
Everyone gets to rate material by the appropriate age for viewing it,
these are then used as "votes" to produce different ratings *for different
communities* and end users get to choose which community's ratings
they wish to use.

> The ABA agrees, as does RSAC itself, that there is 
> room for further improvement in the labelling scheme.

I'm glad to hear it.  My challenge to you - or anyone else - is to
produce a ratings system that which covers material offensive on
religious grounds and is appropriate for global use.  I am convinced
that no such system can exist (and am working on an impossibility proof
using algebraic theology :-).

> Currently RSACi is being reviewed with the aim of improving the labelling 
> scheme, making it more relevant to the Internet, and making it more relevant 
> to those outside the United States. To our knowledge this revised version of 
> RSACi will be available in a few weeks.

I look forward to seeing it.  The flaws in RSACi are, however,
fundamental, so unless they have changed their entire approach it will
be subject to the same criticisms as the current version.

> There have been proposals put forward for RSACi to be mirrored in Australia 
> and the UK, among others, and these mirror sites would be rewritten to 
> reflect the language of each country.

Either rewriting the definitions will make the ratings incommensurable
with US ratings or the changes will have no substantial effect.
 
> Currently the ABA_s manager of On-line Services, Ms Kaaren Koomen, is in 
> Europe meeting with officials from the EC, UNESCO, OECD, United Kingdom, 
> Germany and Brussels among others. While overseas Kaaren has been discussing 
> the role of labelling schemes which could meet international standards, 
> including the role of RSACi.

Another chance for the First World to impose its values on everyone else.
I hope the sub-committees spend the next fifty years arguing about it;
I'm sure at least some of the Europeans will be sensitive to issues
of cultural diversity and non-discrimination, even if the Australian
Broadcasting Authority is not.

Danny.

Labelling << Internet Censorship in Australia << Danny Yee