Agency Information Collection Activities; Submission for OMB Review; Comment Request; FTC File No. P994511 #00003

Submission Number:
00003
Commenter:
Patricia Vance
Organization:
Entertainment Software Rating Board (ESRB)
Initiative Name:
Agency Information Collection Activities; Submission for OMB Review; Comment Request; FTC File No. P994511
Matter Number:

P994511

Hi Keith,Thank you so much for sharing the draft survey instrument, and my apologies for the delay in getting our feedback to you. The attached version includes more detailed comments but the top-line issues from our perspective are: 1. We’re guessing it’s due to reading comprehension, but limiting to kids age 8+ can substantially impact the results as far as parental restriction. Parents of younger kids tend to be that much more engaged in restricting access to media, and kids under 8 are highly likely to be using these types of devices. I think this runs the risk of under-reporting the actual levels to which parents overall are restricting access to content. 2. Having the parent “assist” the child or, worse yet, answer as if they’re the child, can compromise the validity of the results – either by kids under-reporting access or parents over-reporting restriction. We’re not sure what the right answer is but we feel it’s important to find a way to alleviate this potential for biased responses. At a minimum there shouldn’t be different instructions for different respondents. 3. There are inconsistencies in the way games and their ratings are asked about versus other media like movies and music. If the objective is to compare the levels of kids’ access to these media and parents’ awareness and use of tools with which to restrict such access, these need to be brought into line so comparisons are valid. 4. We strongly suggest removing the ESRB icons from D5. This survey focuses on users of Apple or Google devices and neither of their storefronts use our system, let alone our icons. We’re afraid this will be confusing. 5. The survey is a bit unclear in spots. For example, downloaded media are sometimes lumped in with streaming services, which function very differently. App store ratings and parental controls apply to purchased/downloaded media but not necessarily to streaming media accessed from within an app. To that point, there is some potential confusion around inputting passwords for access and whose account is used to do so. I hope this is useful feedback. As always, if you have any questions or there is any other way we can be helpful please let me know. All the best, Pat