Tuesday, 7 June 2011

Complaints procedure

Among the key recommendations of Reg Bailey's review into the "sexualisation and commercialisation of childhood" is that it should be easier for parents to complain about things they deem inappropriate for their children to see or hear.

Broadcasters and companies "need to be more proactive in encouraging feedback and complaints." Industry and regulators should work together "to promote parental awareness... of complaints procedures." There should be a website where regulators such as Ofcom and the Advertising Standards Authority provide a "one-stop shop" aimed at parents who want to complain. Company websites should have user-friendly complaint buttons.

It's all part of "empowering parents". Instead of muttering to themselves or neighbours about the inappropriate thing that they've seen, or merely switching the TV off when something upsets them, they should be doing something more decisive. Bailey seems disturbed, even puzzled, by what he sees as "the low level of complaint" - and convinced that a complicated complaints process must be to blame:


Despite some good practice, notably from the Advertising Standards Authority (ASA), the consumer complaints landscape is complex, confusing and inconsistent and certainly does not encourage parents to voice their concerns or make complaints. Our omnibus survey showed that the majority of parents (92 per cent) have never complained about things (for example, products and adverts) whether in public places, on television, on the internet, in a newspaper or magazine that they felt were inappropriate for children because of sexual content. This was because they have never needed to (43 per cent), they didn’t think anything would be done (22 per cent), didn’t know who to complain to (15 per cent) or didn’t get round to it (13 per cent).


The most relevant figure here is the 15% who didn't know who to complain to - but it's unlikely that ignorance alone frustrated their complaint. If they had been motivated, it's likely that they would have found out. In any case, it's a low proportion of the total. Most people are aware of who they might complain to, but either have nothing to complain about or do not see it as much of a priority. Perhaps they just weren't angry enough.

Bailey suggests that "the true extent of parental concern is not currently reflected in complaints statistics". But is this really a problem? Only if no-one is complaining about genuinely offensive material would there be a good case for encouraging more complaints, but the report provides no evidence that that is the case.

At present, the Review states, "the numbers of complaints to the ASA regarding children and advertising are relatively low." About 5% of ads complained of involved children. This might well reflect that advertisers generally obey the rules. Yet these same ads attracted 10% of the complaints. A questionable advert relating to a children's product or involving a child is already, it seems, twice as likely to be complained about as "complaint-worthy" adverts in general. That would suggest that parents are already well-motivated (perhaps over-motivated) when it comes to making complaints.

What would be the effect, then, of making it even easier for parents to complain? Most obviously, perhaps, more complaints - something that Bailey seems to approve off even if the complaints themselves are groundless:

We understand that complainants are going to be disappointed if their complaint is rejected. But a timely and personalised response will make such disappointment easier to accept, and provide reassurance that someone has listened to one’s views.

Last week at the Cambridge Skeptics, Simon Perry was talking about his ongoing campaign against the dubious claims made by some alternative medicine practitioners. Basically, it involves making multiple complaints to the ASA, Trading Standards and other regulators whenever he or his comrades in arms spotted anything unscientific. The campaign's biggest triumph came in the wake of the British Chiropractic Association's misconceived (© David Allen Green) libel claim against Simon Singh. Since then, Perry has developed a plug-in for Google Chrome to make submitting a formal complaint as easy as clicking on a few links.

Perry recently met representatives from the ASA, who expressed some slight misgivings about the sheer quantity of complaints they were now receiving about alternative therapists. There were, after all, other complaints that had to be dealt with. More importantly, the ASA stressed that all complaints were investigated. It was the substance of the complaint that mattered, not the volume of complaints about any particular issue. A complaint might be upheld if only one person had complained, or rejected if a thousand had done so.

Yet Bailey implies that volume matters; that it is not enough that some people complain - everyone who sees something they disagree with has a duty to go straight to the ASA or Ofcom. This suggests both a woeful misunderstanding of how these bodies operate and some lack of consideration for their overburdened staff.

Won't somebody think of the regulators?