Danny Yee >> Internet Censorship in Australia >> Labelling

RSACi response

Recently there has been some discussion regarding the Australian 
Dear Irene Graham

Thank you for your recent e-mail.  I am sorry if you have received several
copies of my e-mail sent to all registered RSACi web sites. It was certainly
not our intention to annoy or upset people on the web.

Since receiving your message, I have read your piece entitled, "The Net
Labelling Delusion" which I found thought provoking.  I have also read
newspaper reports from Australia on Danny Yee's condemnation of RSACi.  I
would like to address a number of points you raise and put forward a few

I would like to begin with the current mission statement of RSAC: "We are an
independent, non-profit organization that empowers the public, especially
parents, to make informed decisions about electronic media by means of an
open, objective content advisory system."  Further, I would add the phrase
we often use to describe ourselves:  "We are pro free speech and pro
parental choice." In other words, we are strongly in favor of anyone's right
to express themselves while, at the same time, pragmatically responding to
the legitimate concerns of parents, teachers and others about what they or
their children experience on the Net.

We do not censor anyone's speech.  It is up to an individual parent whether
or not to use the parental controls within, say, Internet Explorer.  Further
it is up to them to set the levels in the four categories depending on what
they feel is appropriate.  And, it is up to them to allow access to unrated
sites or not.  We seek to empower people through the use of our system.
RSACi is a tool, however imperfect, to help parents and others to control
what their children experience on the Net.  It is not a substitute for
parental guidance and oversight.

I would like to address your many criticisms of the RSACi system.  Although
I may not agree with many of the conclusions that you reach in your e-mail
or in your article, I am, however, grateful for the time and critical energy
you have expended on raising these issues.  When we designed the RSACi
system, our first goal was to ensure that the system, questionnaire and
definitions were all open to public scrutiny and discussion and to periodic
review and improvement.  Another point to make at the outset is that we are
still in our first year of operation on the Net and we are learning quickly
what is and what is not working.

You are right to point out that the current RSACi system has many references
to terms used in computer games.  We do not deny that we have borrowed
heavily from our original RSAC system used for recreational software in the
current RSACi version.  Also, that the current definitions on profanity have
an entirely Christian bias and that we do not, currently, make distinctions
between material with scientific, educational or artistic value.  Over the
past two months, we have brought together the many comments, suggestions and
criticisms raised by users all over the world to conduct a thorough review
of the RSACi system.  This new version we hope, will be simpler to use, more
culturally sensitive and address a number of the points you raise.  We hope
to have the revised questionnaire and definitions up on our web site in the
next few weeks.

We have decided, for the meantime, not to expand from the four categories of
Nudity, Sex, Language and Violence.  It is conceivable that we could double
or even triple the number of categories we currently have.  We have tried to
maintain a balance of what we have perceived to be the core areas of concern
on the web, while keeping the system easy enough to use.  It is possible
that these categories could be increased in the future or that a third party
(say the Catholic Church) could provide an RSACi+ classification whereby
they use our labels and than add their own interpretation or recommendation. 

On the issue of objectivity I can only agree with you that there are
elements of subjectivity within the RSACi system.  That is inevitable.  We
are not dealing with absolutes.  What we are attempting to provide is a
framework which is as objective as possible while remaining open to
revisions and improvements.  We are also seeking to localize the RSACi
system in other countries.  We have had discussions with ISPs and others in
the UK, in Germany, in South Africa and in Australia about having mirrored
sites with the questionnaire translated into the local language using local
examples in the definitions.  We are very conscious of the charge of
American imperialism in this matter and that is why we have opened
discussions with others to localize the system and adapt it to local needs
while retaining its universal applicability.   (Having lived most of my life
in the UK, I am keenly aware of this particular concern.)

You are correct when you say that the RSACi labels are easy to fake.
Because of this, we have developed a bot that searches the Net 24 hours a
day looking for unauthorized usage of our labels.   You also correctly point
out that we use expiration tags on our labels, but your conclusion is
incorrect.  It is true that, at one point in the evolution of our business
model, we did consider charging web sites for rating with us, but this has
now been rejected.  We will not be charging for the service.  We will,
however, use the expiration dates as a way to check in with the registered
sites on a periodic basis to ensure they have kept an eye on the content
they are posting on their site and that it hasn't affected the original
rating.  We will, of course, continue to seek sponsorship and licensing
deals to allow us to provide this service free to the internet community.

As far as the personal information that is disclosed to us, we have not, do
not and will not disclose this to any other source for payment or otherwise
without the prior consent of those involved.  I have spoken with Lori Fena
of the Electronic Frontier Foundation about this issue and we are looking
into ways to participate in the EFF-sponsored eTRUST initiative.

The issue of the Australian government mandating the use of RSACi is, I
believe, one that is far from determined.  I understand the ABA is
undergoing a comprehensive review of the issue of content ratings and have
not yet reached any firm decisions on mandatory ratings.

On the reliability issue of self-ratings I can only say that we take very
seriously the issue of web sites willfully misrepresenting themselves. One
of our greatest resources in checking sites for misrepresentation (an
extremely rare occurrence over this first year) has been the feedback we get
from web users all over the world.  With the spot checks and audits we
conduct, we add the comments and alerts from other web users to track down
sites that have chosen to blatantly cheat the system.

The technical issues you raise regarding the sites incorrectly blocked by
Internet Explorer have been taken up with Microsoft and a fix is being
worked on.  We have also been in touch with the ABA regarding their site and
are working with them to overcome the difficulties they have been having
with their labels.

I'd just like to finish with a quote from Esther Dyson, editor of Release
1.0 and the Chairman of the Electronic Frontier Foundation in the US.

   "Many people would prefer to see traditional government stay out: 'We can
handle our own problems, thank you!'  Well we do need governance on the Net;
we just don't need the kind of governance we're likely to get if we don't
take action for ourselves.  Many libertarians would like absolute freedom,
but that doesn't work in real life and it won't work on the Net."  (from
Release 1.0, December 1996)

We agree with Esther's sentiments and we are doing our best to provide a
practical and pragmatic tool for those who agree with what we are trying to
achieve and who would like to work with us to make it better.

I would be more than happy to discuss these and other issues further with
you.  Please don't hesitate to contact me via e-mail or by phone at the
number below.


Stephen Balkam
Executive Director, RSAC
Tel: 617 860 9888
Fax 617 860 9604

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