The UK’s draft Online Safety Bill, published by the Department of Digital, Culture, Media and Sport in May 2021 and currently under the scrutiny of a parliamentary Select Committee, aims to establish a new regulatory framework to tackle harmful content online. Here, LSE’s Professor Lee Edwards analyses how media literacy is presented in the Bill and suggests how the Bill’s proposals could be strengthened.

In the Online Safety Bill, media literacy features as an important location for developing public awareness of harmful content, and potentially giving users of online services strategies for both recognising and tackling misinformation. While questions have been raised about its presentation in the Bill, and the assumptions it makes about Ofcom’s capabilities, the provisions do extend Ofcom’s obligations relating to media literacy – previously set out in the Communications Act 2003 – in three important ways. These new obligations are:

• To encourage the development of technologies that empower users to identify misinformation and control the information they receive;
• To ‘carry out, commission or encourage educational initiatives’ that support media literacy;
• To prepare guidance for evaluation of media literacy initiatives.

The new obligations help to specify some of the more general provisions in the previous Act (for example, by clarifying how to interpret the ‘nature and characteristics’ of content, and how the idea of awareness and understanding should be interpreted). They give Ofcom more power to influence both organisational governance and investments relating to media literacy, and also to shape educational curricula for media literacy. As such, they strengthen the regulator’s potential to assert the value of media literacy among both producers of media, and those who support users’ engagement with media.

However, the new Bill also includes a subtle but crucial change in wording, from an obligation to improve ‘public’ awareness and understanding of the media, to improving the awareness of ‘members of the public’. The first obliges Ofcom to improve our collective levels of media literacy and critical engagement with media content, while the second is an obligation to improve individual levels of media literacy.

The change in wording is consistent with the focus on individual harms throughout the Bill, and certainly facilitates the obligation to evaluate media literacy – it is more straightforward to measure outcomes in terms of individual behaviours and capacities than to identify collective empowerment. However, the adjustment risks sacrificing one of the main benefits of media literacy: its ability to support an informed, engaged citizenry, prepared to participate in deliberation and debate as part of our democratic processes. While this may not be the intent behind the change, the effect is inevitable when media literacy is incorporated into a Bill primarily focused on regulating platforms and providers.

Moreover, the more specific interpretations of ‘technologies and systems’ that improve media literacy focus on facilitating users’ ability to identify types of content, to determine its reliability and accuracy, and to have control over how they receive information.  These emphases prioritise the ability to detect misinformation, rather than the capacity to critically engage with media more broadly.  Yet, media literacy interventions that can contribute to critical thinking and evaluation most often take a systemic approach: they include learning about how media is produced and consumed, understanding media industries and their institutional power and priorities, critiquing media representations, and developing the ability to create media. Fostering this kind of media literacy can have a positive effect on our ability to actively engage with online information, media power, and recognise our own voices as citizens. The Bill runs the risk of transforming this capacity-building literacy into an exercise in informed consumption. If media literacy is deployed only as a mode of self-protection from exploitation or harm, its potential for supporting our deliberative and democratic capacities could be severely weakened.

Both these issues point to a more fundamental problem with the Bill: its emphasis on users rather than citizens, and on mitigating individual rather than collective harms. Yet, the Bill is focused on issues that directly affect our collective well-being. Living in a society where information and knowledge remain balanced, reliable and accessible to all, or where our desire to communicate our experiences is not tempered by fears of hate and intolerance, is in all our interests. Harm occurs not only when individuals are damaged by interactions online, but also when those same interactions scale up, ultimately reducing our critical capacities and generating antagonistic argument rather than agonistic debate across society. We have already seen the results of this kind of polarisation in increased nationalism, the reification of misinformation and the dismissal of experts, and a gradual weakening of democratic arrangements that rely on engaged, informed citizens.

Despite this, the Bill imagines users primarily as atomised individuals rather than social beings living in relationship with each other. The corollary in media literacy suggested by the Bill is that collective benefits are subordinate to individual resilience. If this framing of media literacy becomes the dominant mode of delivery, there is a danger that the perception of its broader value for society gradually dissipates. While critical analysis of platform power is desperately needed on the part of all citizens, the instrumentalization of media literacy is at best concerning, and at worst dangerous – potentially leading to more political polarisation and even lower resilience to misinformation than we have currently.

There are options to mitigate this danger:

• The wording of the Bill could be amended to revert to ‘public’ rather than ‘members of the public’, for example.
• The specifications in the Bill could be expanded to include the broader critical capacities that are so fundamental to our deliberative engagement.

However, claims about the need to support collective well-being and media literacy would be most strongly made within a framework of digital rights, and the lack of such rights is a more fundamental problem with the Bill.

During our summer roundtable, Professor Sonia Livingstone and Chi Onwurah MP both argued forcefully for the inclusion of an explicit statement of digital rights in the Bill, as a foundation for online safety. Even if such rights are not included in the final version, they are undoubtedly necessary. The intensive discussions around citizenship, media literacy, the duties of care, and the need to protect freedom of speech, have all arisen in part because we lack a framework against which these issues can be referenced in a digital world. Existing statements on human rights are difficult to transplant unaltered into digital contexts, because of the changed environment in which they exist. Digital rights must grapple with the different architectures, actors and networked dynamics of digital spaces, and are not easily settled – as the long process of developing the UN’s General Comment 25 on children’s rights in relation to the digital environment has shown. But our digital rights must be addressed by both civil society and politicians, if initiatives like the Online Safety Bill are to be legitimate, future proof, and ultimately, successfully implemented, and if the societal value of media literacy is to be preserved.

This article gives the views of the author and does not represent the position of the Media@LSE blog, nor of the London School of Economics and Political Science.