Common classification criteria for all media content

9.50 Many submissions favoured common classification criteria for application to all media content regardless of the type of media. As suggested by the Arts Law Centre of Australia:

It would also be useful to consolidate the various codes and guidelines so there was one set of rules or guidelines that applied to classifiable content, regardless of the platform by which it was delivered.[56]

9.51 The Classification Board also questioned whether the existing separate and media-specific classification guidelines are the best system for the future,

with new technology, formats and platforms to see/hear/read material (digital ebooks, digital magazines, downloads of movies direct from the internet to mobile phone, ipad, TV, computer), and material no longer being confined to being a physical product.[57]

9.52 One set of guidelines for all media content removes the current anomaly whereby a webpage is classified under the film and computer game guidelines.

9.53 Importantly, classification guidelines need to adequately guide decision makers in their consideration of the unique features of an item of media content such as text, moving images, interactivity, sound, still images. Dane Armour submitted that:

The classification scheme should be consistent across all media formats and as such should take into account any themes, concepts or imagery which may be depicted more vibrantly in any given media format. For example, in literature, violence is described through descriptive language as opposed to the visual imagery of violence and gore found in film.[58]

9.54 In the context of media convergence, it is essential that classification guidelines account for features of content regardless of the form it may take. For example, e-books now may contain video content and computer games often incorporate film sequences. As MLCS Management contended, if there is a concern that ‘some aspects of computer game content (such as interactivity) need special consideration, that matter should be emphasised for all media types’.[59]

9.55 One combined set of guidelines that refer to the features of media content is therefore also an effective way to keep pace with technological advances, including media convergence. A new classification system must be capable of responding to new forms of media content and new features used to enhance content, quickly and efficiently. MLCS Management argued, for example, for the need to ‘future proof the guidelines against technological and content change’:

The combined guidelines for films and computer games have been a useful tool for their users—the Classification Board and industry assessors. Their lack of detail provides flexibility that the Classification Board needs to make decisions that reflect constantly changing community standards. It also serves to make them applicable to different media types.[60]

9.56 Platform-neutral guidelines also provide for the same thresholds and limits on content permitted at each classification category across media content. For example, if strong coarse language is permitted at the MA 15+ classification, then this should be the same threshold for language at MA 15+ for television programs, a computer game or online content. It is the role of the classifier, having regard to the features of the media content and the classification criteria and guidelines, to determine whether an item exceeds the stated limits of the category and therefore should be assigned a higher classification.

9.57 In the ALRC’s view, the same classification criteria and guidelines should be applied to any type of media content. It is neither practical nor meaningful to make classification decisions using multiple sets of guidelines for multiple types of media content with different thresholds and limits for the same classification category. Accordingly the separate tables in the Code should be consolidated to reflect one set of criteria for all media content.

9.58 This logic was the basis for the introduction of common classification categories and markings and combined classification guidelines for films and computer games in 2005. As Dr Jeffrey Brand foreshadowed in his report on the draft combined classification guidelines, convergence issues would necessitate combined classification guidelines for different media forms in the very near future.[61]

9.59 The existing guidelines for the classification of films and computer games could usefully be revised to incorporate criteria that provide guidance to classifiers in considering text and still images (currently outlined in the classification guidelines for publications). The guidelines for the classification of films and computer games provide a suitable template as they were developed following a comprehensive review process.[62] The guidelines were significantly re-engineered including layout, presentation, language and structure with input from academics, classification experts and the public.

[56] The Arts Law Centre of Australia, Submission CI 1299, 19 July 2011.

[57] Letter from Donald McDonald, Director Classification Board to ALRC, 6 May 2011.

[58] Confidential, Submission CI 1980, 14 July 2011.

[59] MLCS Management, Submission CI 1241, 16 July 2011.

[60] Ibid.

[61]A Review of the Classification Guidelines for Films and Computer Games: Assessment of Public Submissions on the Discussion Paper and Draft Revised Guidelines, (2002), prepared by J Brand for the Office of Film and Literature Classification. See also the Explanatory Statement, Classification (Markings for Films and Computer Games) Determination 2005, that noted that the new combined classification symbols address the ‘outdated nature of the previous determinations in respect of the marking of emerging technologies which blur the distinction between “films” and “computer games”, new storage devices and current marketing techniques’.

[62] Ibid.