The Salvation Army Australia

     

The   Salvation Army Australia

Submission made on behalf of The Salvation Army Australia Eastern   Territory and The Salvation Army Southern Territory       Response to

FreeTV Australia’s invitation for  public comment on the   Review of the Commercial Television Industry Code of   Practice            

For further contact:    Kelvin Alley (Lieut‐Colonel)  National Secretary  The Salvation Army National Secretariat  2 Brisbane Avenue  Barton, ACT 2600    Phone: (02) 6273 3055  Email: [email protected] 

3 April 2015

Introduction The Salvation Army Australia welcomes the opportunity to comment on Free TV Australia’s review of the Commercial Television Industry Code of Practice. The Salvation Army understands that with the advent and increase in information and communication of technologies and digital media delivery, media consumption is changing across Australia. As a result, free to air television content delivery and programming will change as well. We understand that new and existing television programming has benefits for the Australian community. Indeed television consumption is an integral part of Australian culture. However we are concerned that some aspects of television programming and the proposed changes to the Commercial Television Industry Code of Practice will have negative effects on some in our community. Despite claims that the new Code regulates commercial television to “…uphold community standards and ensure appropriate viewer safeguards and …ensures commercial television remains Australia’s safest and most heavily regulated platform…”, The Salvation Army is deeply concerned about the proposed Classification Changes to programing timeslots, and the subsequent alcohol and gambling advertising that these proposed time changes will attract. While The Salvation Army accepts the social and cultural contexts in which television programming operates, we are concerned that changes in programming times will change viewing consumption for children, with a subsequent increase in availability of inappropriate content. Consequently this will normalise lower community standards as to what is considered appropriate viewing content for children across Australia.

Classification Changes and Inappropriate content Under new proposals to change the Code, various timeslots of television programming are to be changed. These are:    

M-rated: Currently: 8.30pm, proposed: 7.30pm MA-rated: Currently: 9pm, proposed: 8.30pm PG-rating: All day, all channels – removal of G-rated programming slabs AV-rating: Removed, reclassified to M and MA

The Salvation Army is concerned with the bringing forward by an hour of M & MA Rated programs and the subsequent availability of content within these programs that may be viewed by children. Additionally, we are concerned about the removal of G-Rated programing slabs, and the introduction of ‘PG – all day, all channels’ provisions.

 1 The Salvation Army submission to Free TV Australia

Recent ACMA data shows that children aged 0-14 spent an average of 1 hour 54 minutes watching television per day.1 The Salvation Army is not concerned by the fact that children watch television and recognizes that children learn through watching television. Research suggests that television is a beneficial educational and socialisation medium when used appropriately, surpassing all other media by far in its influence on children.2 3 Nevertheless, The Salvation Army is concerned that these changes in programming times will increase greater availability of inappropriate and anti-social content that is not appropriate for children. An increase in the exposure of inappropriate content will further impact on the psycho- social elements of this demographic. The Salvation Army is deeply concerned that an increase in negative media consumption will have a detrimental impact on children through the viewing of harmful, violent and inappropriate programs originally placed in a time slot that restricted the viewing by children. Exposure to violent media, particularly through video games and television, shows consistent associations with subsequent aggressive behaviour in children. Theorists believe this relationship occurs as children become desensitized to violent content and perceive aggressive and violent acts to be more normative. Furthermore, greater exposure leads to a greater number of aggressive emotions, thoughts and actions in children4 5 As a result, any intervention to reduce exposure to screen violence and increase exposure to pro-social programming can positively impact child behaviour.6

Parents and families at risk The Salvation Army is not only concerned with the type of content available at these times, but also the difficulties that families we represent face in regulating the viewing of this content by their children. The Salvation Army acknowledges that parental responsibility must be a significant factor in what children watch on television. However, the parents and families which The Salvation Army represents – often families from lower socio-economic locations and backgrounds, single parent families, families affected by alcohol or drug use or domestic violence, or those facing severe disadvantage, unemployment and poverty - do not always have the resources, education, support or time to regulate television consumption.                                                              1

Australian Communications and Media Authority 2015, Children’s television viewing, ACMA, Commonwealth of Australia. Gonzalez-Mena, J. 2010, The Media as an Influence on Socialization. Available at http://www.education.com/reference/article/media-as-influence-socialization/ 3 Ibid. 4 Anderson, C. A., & Bushman, B. J. (2001.) Effects of violent video games on aggressive behaviour, aggressive cognition, aggressive affect, physiological arousal, and pro-social behaviour: a meta-analytic review of the scientific literature. Psychological Science, 12, 353-359. 5 Ibid. 6 Christakis, D.A. et al, 2013, Modifying Media Content for Preschool Children: A Randomized Controlled Trial, Pediatrics, Volume 131, Number 3, March 2013. 2

 

 2 The Salvation Army submission to Free TV Australia

Free to air television is cited as being the greatest viewed platform of all media content for these parents and families. Indeed, research has found that children of low socio-economic backgrounds are spending greater time engaged with television and less time on the internet, compared to children from middle and higher socio-economic backgrounds. 7 Disturbingly, research shows that this cohort consistently demonstrates lower regulation, concern, technological literacy and awareness of the potential harms of unhealthy television viewing. Parental regulation exacerbates or protects children from the harms of inappropriate content, yet evidence suggests that parents from low socioeconomic backgrounds are poorer content regulators of their children’s activity. Therefore, children from disadvantaged socioeconomic families may be experiencing the dangers of inappropriate content in an unfavourable proportion compared to children from middle and higher socio-economic backgrounds8. This fact alone therefore renders these children especially vulnerable.

Recommendation The Salvation Army does not support the Code’s argument that “time zones were not one of the top three methods used by parents/carers to manage their children’s viewing” as justification for changes to classification timeslots. The Salvation Army opposes this justification as evidence suggests that such parental regulation is low in families from lower socioeconomic backgrounds. Changing the timeslots will create a greater burden on these families, who already struggle to regulate children’s viewing patterns by creating further availability of inappropriate content to children in these situations.

Alcohol & Gambling Advertising The Salvation Army is concerned by the fact that the changes in programing timeslots will attract an increase in alcohol and gambling advertising. The proposed changes to the Code have implications on the times at which alcohol advertising can be shown on commercial, free-to-air television. As the changes state, “under the new Code, alcohol advertising is only permitted during the M or MA classification zones or as an accompaniment to a sports broadcast on a weekend or public holiday”, Therefore, if the time at which an M rated program can be shown is brought forward from 8:30 to 7:30, alcohol advertising is also brought forward to 7:30pm.                                                              7  Australian Communications and Media Authority (ACMA) 2007, Media and communications in Australian families 2007, Report of the Media and Society Research Project, Sydney. Available at www.acma.gov.au/mediareports 8 Ibid.

 3 The Salvation Army submission to Free TV Australia

This is deeply concerning to The Salvation Army as there is strong evidence that alcohol advertising has a detrimental effect on children. The connection between alcohol advertising and underage drinking has been clearly demonstrated in much research9. Indeed, there are numerous studies that show that greater recall of alcohol advertising by children is significantly related to more positive beliefs about alcohol use, which in turn is associated with greater future intentions to drink alcohol among children and adolescents.10 Every day, The Salvation Army comes face to face with the very real and damaging consequences of alcohol abuse and violence on individuals, young people, families and communities. Alcohol is a harmful drug yet is legal, widely available and relatively inexpensive. The recent Australian Institute of Health and Welfare (AIHW) report Alcohol and other drug treatment services in Australia: 2012-1311 confirms that that alcohol continues to be the most common principal drug of concern for people seeking treatment for addiction. Our internal data supports this finding, with alcohol being the primary drug of choice for 50% of persons admitted for rehabilitation in the year July 1, 2013 to June 30, 2014. If these changes to the Code proceed, alcohol advertising will inevitably change in nature to target a younger audience, which will in turn change the nature of alcohol advertising societally. The obvious implication of this is the fact that our addictions services will see an alreadydecreasing-age of addictions becoming even younger. Additionally, The Salvation Army is concerned about the effect that the removal of G-rated Programing Slabs will have on gambling advertising restrictions. Under the proposed changes to the Code, PG-rated shows can be shown at any time of day, on any channel. The ‘gambling advertising’ restrictions in the new Code state that “the new Code does not allow commercials relating to betting and gambling during a Program that is classified G or lower, and screened between 6:00am and 8:30am; or 4:00pm and 7:00pm”. Obviously, if a PG-rated program can be shown at any time of day, a gambling or betting related advertisement can also be shown at any time of day. We are deeply concerned about the impact that an increased level of gambling and betting advertising will have on children. Similarly to alcohol advertising, an increase in viewing leads to a normalisation of gambling to a child. Like with alcohol addiction, a normalisation of an action can open up the possibility of addiction to that action. The Salvation Army is deeply concerned by the destructive impact gambling has on a significant number of people. We regularly encounter these individuals and the families affected in our homelessness, community service and addiction treatment programs. We believe that every opportunity possible should be taken to protect Australia’s children and youth from the normalisation of gambling and betting.

                                                            

http://www.camy.org/factsheets/sheets/Alcohol_Advertising_and_Youth.html  Chen, M.J. Grube, J.W. Bersamin, M. Waiters, E. Keefe, D.B , 2005 . Alcohol advertising: what makes it attractive to youth? In Journal of Health Communication, 10:553–565, 2005 Routledge, California, USA. 9

10

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AIHW 2014. Alcohol and other drug treatment services in Australia 2012-13. Drug treatment series no. 24. Canberra: AIHW. 

 4 The Salvation Army submission to Free TV Australia

Recommendation The proposed changes to the Code state that “commercial free-to-air television is the only platform where alcohol advertising is restricted”, and reiterates that despite changes to timeslots in which gambling advertising can be shown, “commercial free-to-air television is still the most heavily regulated platform regarding gambling advertising”. The Salvation Army believes that these are standards that commercial free-to-air television should maintain in order to protect our children, especially those who are most vulnerable in our society. Therefore The Salvation Army recommends no changes to classification timeslots, and as a result, no change to the timeslots in which alcohol and gambling advertising is allowed.

The Salvation Army has been providing a wide range of support services to the Australian community for over 130 years. We operate in more than 900 locations across Australia, delivering 1000 programs and support to more than 200,000 people each year. Our mission, as part of the universal Christian Church is to meet human needs without discrimination. To achieve this we provide a wide range of services and practical support designed to meet the social, emotional, material and spiritual needs of people who are disadvantaged. We work with some of the most marginalised, disadvantaged and vulnerable individuals, families and communities across our nation. We see the effects and consequences of family breakdown, domestic violence and alcohol and drug misuse and recognise that myriad circumstances contribute to the complexity of social need we encounter daily in our work.

 5 The Salvation Army submission to Free TV Australia