Dear Mr. Webb,
RE: ONLINE SERVICES INVESTIGATION
Thank you for the opportunity to comment on the issues paper released by the Australian Broadcasting Authority about the content of online information services and entertainment services. I have been asked to repond for the University of Canberra on behalf of Professor Don Aitkin.
The University of Canberra would like to comment on the purpose of the issues paper, the approach taken and the principles put forward.
The University of Canberra has an interest in the matter of online services. The University has been making online information services accessible to the University's community for many years including via the Internet for the past six years. The University has developed an information policy, an information and communication resources development strategy and an information technology policy to provide a context for the management of networked access to information. All policies and strategies are intended to foster the empowerment of members of the University's community.
Our experience leads us to make the following comments:
1. YOUR PURPOSE
Your stated purpose is "to identify concerns within the community about on-line services and to consider options for addressing these concerns" (see page 6). The paper provides a list of concerns but presents only one option for addressing them, namely regulation of online services. We would like to see research undertaken to validate the oncerns, to provide data on the problems giving rise to the concerns and to identify a range of options for addressing the problems which may include regulation.
We would also like to see the Australian Broadcasting Authority present a balanced discussion of online communication and online services.
The paper is dominated by concerns without any attempt to highlight the positive attributes. Without adequate data on the nature of the problems underlying the concerns and without a balanced perspective, it will be difficult for the Australian Broadcasting Authority to claim that its investigation has done what it was designed to do, namely "to identify the nature of on-line content, its current relationship to community standards and the appropriateness of developing codes of practice..." (see page 18).
2. YOUR APPROACH
The approach followed in the Australian Broadcasting Authority's issues paper assumes that there is an online industry which can be modelled and that responsibilities can be allocated to each participant. The model identifies the participants as content providers, network infrastructure providers, online access providers and users (see page 12).
Our experience is that networking has radically changed and blurred the roles found in the traditional market system as exemplified by your model. This makes it difficult to identify an online industry. For example, using your model, the University plays the following roles simultaneously:
The paradigm upon which you base your case for regulation does not reflect adequately our reality and the new dynamic of a networked community which transcends established views of the information industry and traditional market channels.
3. YOUR PRINCIPLES
While we commend the inclusion of a set of principles in the issues paper, there is an inherent tension within your principles. On the one hand the issues paper promotes the empowerment of the community and freedom of expression while at the same time proposing mechanisms for classifying information, controlling access and even refusing access to information. Censorship and regulation of the kind suggested are not conducive to the empowerment of people, the right of the individual to access information and the preservation of a democratic society.
The University of Canberra would like the Australian Broadcasting Authority to re-visit its purpose, approach and principles. While the issues paper is a valuable starting point for discussion, it needs to take account of a fuller range of options to resolve problems and to be open to new models to explain the phenomenon of a networked society and electronic patterns of communication, access and delivery. It is important to develop a policy position for the evolving needs of a networked community based on knowledge and not on fear of the unknown.
Lois Jennings----------------------------------------------------------------------------- Lois Jennings | Email: email@example.com Manager, Information Services | Division and Librarian, | Telephone: +61 6 201 5092 University of Canberra | Fax: +61 6 201 5068 PO Box 1, Belconnen ACT 2616 |