A personal response to Communications Consumer Panel consultation of 25 April 2019

Bill Dutton

12 May 2019

I was a former member and Chair of the Advisory Committee for England, and have followed the Consumer Forum for Communications (CFC) for years. Having returned from working in the US for four years, I’ve also attended the last several meetings of the CFC as an unaffiliated individual. My major involvement in communication has been as an academic, involved in teaching and research on the social implications of the Internet and related media, communication and information technologies. 

I am pleased to learn of Ofcom’s decision to increase support for the Communication Consumer Panel (CCP), particularly in light of diminished support for the Consumer Forum for Communications (CFC). I have been impressed with the breadth of expertise and exceptional commitment of members of both organizations. However, I have comments on how the work of the CCP might be improved in the coming years.

Let me preface this by noting that the various schemes for organizing committees and individuals outlined in the consultation document on ‘strengthening the consumer voice in the communications sector’ appear to be wedded to a previous era of communication in which there were clear demarcations between the telecommunications industry and its consumers. This distinction is less meaningful today as the general public acts in a variety of roles, such as in producing, providing, sharing, using content, and more—and not just as consumers. 

The mission of the CCP recognizes this in part when saying the body is designed “to protect and promote the interests of consumers, citizens and small businesses in the communications sector by giving advice to Ofcom, the EU, Government, industry and others.” For example, people are increasingly talking about ‘digital citizens’ and using other broad terms that go beyond ‘consumer’. Clearly, the interests of consumers are a huge aspect of the public interest, but serving the public interest in communication is no longer limited to meeting the needs of consumers. And the regulation of communication is increasingly tied to multiple agencies and public officials. Is there a way to move away from this overly simplistic and dated dichotomy between industry and consumer, while also broadening the scope of our definitions of communication? I have a suggestion. 

Instead of creating an ‘industry forum’ and/or creating ‘focused, direct engagement with consumers’, why not create a truly broad communication forum, open to all actors in the design, production, and use of media, communication and information technologies and services, from the post and phones to the Internet of Things? There are tools available today for organizing collective intelligence across the nations of the UK on any topics that actors in this increasingly complex ecology wish to address. If well moderated from the outset, with clear rules of order, such as not posting anonymous comments, and supported by Ofcom, then there is no reason not to have it open to everyone interested in how communication can better serve the public interest. 

An open communication forum – not simply a blog or website – would enable direct involvement with the entire ecology of actors, surface issues before they become problems, and create a source of insights for the CCP that it would never otherwise be able to have at its service. As a forum of Ofcom, this would have the ability to attract input from key actors, and be able to translate what is learned into meaningful discussions at Ofcom and other appropriate agencies with the potential for effecting policy and practice. Given the growing number of industries, companies, SMEs, consumers, and other individuals playing multiple roles in our new communication ecology, why would you not want to exploit new communication technologies to tap the wisdom of civil society to identify and discuss contemporary communication issues in the public interest? 

An open communication forum would not replace the various advisory committees of Ofcom, but complement and inform all of them, and also the officers of the regulator and related agencies and ministries involved with communication, broadly defined. It is possible that state of the practice, off-the-shelf software could be purposed for this role. However, an open forum would need the engagement and leadership of the CCP to enable a national forum for communication in the public interest to thrive.