Stating that “several concerns relating to neutrality and reliability of the existing rating system have been raised by stakeholders”, the Telecom Regulatory Authority of India (TRAI) has issued recommendations on Review of Television Audience Measurement and Rating System in India.
TRAI has released a 28-point agenda of guidelines that the Broadcast Audience Research Council (BARC) India must follow and implement to address what TRAI describes as the issues relating to the existing system. BARC India, remember, was accredited by MIB on 28th July 2015, to carry out the television ratings in India, which it started doing when it commenced its operations in 2015, and since then has been the sole provider of TV rating services on commercial basis.
TRAI had suo-motu issued a consultation paper on “Review of Television Audience Measurement and Ratings in India” on 3rd December 2018 for seeking comments of stakeholders on the issues related to review of existing system. The last date for submission of the comments was 15th February 2()19 and that of the counter-comments was 28th February 2019.
TRAI received 23 comments and 3 counter-comments.
Subsequently, Open House Discussions on the subject were held on 31st May 2019 at New Delhi and on 3rd July 2019 at Mumbai, to seek the views of the stakeholders on various issues.
A BARC India spokesperson says: ‘The TRAI recommendations have only just been received. BARC India is reviewing the same in consultation with its Board and stakeholders.. All Stakeholders from the Industry and the Government and related bodies are aware of the scientific, statistical and technical robustness of the data collated and released by BARC.
‘BARC truly represents all facets of the Industry comprising Advertisers, Agencies and Broadcasters regardless of size, as the Currency of What India Watches. We do not wish to comment at this very early stage’
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After considering all comments received from stakeholders during consultation process and further analysis of the issues, the Authority has finalised its recommendations.
The salient features of the recommendations are given below:
- Structural reforms are required in the Governance structure of BARC to mitigate the potential risk of conflict of interest, improve credibility, and bring transparency, and instill confidence of all stakeholders in the TRP measurement system.
- The composition of the Board of BARC India should be changed as part of the proposed structural reforms.
- The Board should have at least fifty percent independent members which should include one member as a measurement expert, one statistician of national repute from among the top institution(s) of the country and two representatives from the Government/ Regulator.
- Restructured Board of BARC India should provide for equal representation of the three constituent Industry Associations, namely, AAAI, ISA and IBF and with equal voting rights irrespective of their proportion of equity holding.
- Tenure of the members of the board shall be for two years.
- Active participation of representatives of the Advertisers and the advertising agency will bring more accuracy, transparency, credibility, and neutrality in the system, due to their inherent need of advertisers to reach viewers accurately.
- The constituent Industry Associations shall be entitled to nominate their representatives to the board membership subject to the condition that a cooling period of 4 years shall be applicable between two consecutive tenures, for any such nominee member.
- Tenure of the Chairman of the Board should not be more than two years. Chairmanship of the Board shall be rotated among the constituent industry associations in every two years.
- Number of members in the technical committee should be increased to 5 with addition of two external technical experts.
- An Oversight Committee should be formed to guide BARC India in the areas of research, design and analysis, constantly improving the rating system.
- The Oversight Committee should have representation from the National Council of Applied Economic Research, IIM, IIT, media research expert and demography expert, nominee from the Ministry of Information & Broadcasting, and TRAI.
- The Committee should also be responsible for nomination/ appointment of independent members of the Board as well as to give policy direction to BARC India, if it is so required.
- To create credible and accurate collection of data, multiple data collection agencies need to be encouraged.
- Competition and multiple agencies for data collection and processing would bring in new technologies, new research methodologies, new methods in analysis, new and better ways to ensure better data quality.
- BARC should be at an arm’s length from its own subsidiary, Meterology Data Pvt Ltd., which is the sole data collecting agency for BARC, as of now; so that the entire process of measurement is carried out independently to ensure inherent checks in data inconsistency.
- Efforts may be made to withhold the identity of the channel’s name and number while collecting and processing the data from the field, to bring more transparency in the complete process.
- BARC should also separate its functions in two units (a) one unit should be responsible for prescribing methodology of ratings/ validation of data, publishing the data and audit mechanism and (b) the other unit for processing the data, watermarking or any other such technical work including management of data collection agencies.
- Once multiple agencies come forward for rating, BARC should limit its role to publishing the ratings, and framing methodology and audit mechanism for the rating agencies, so that the number of agencies can develop multiple rating system leveraging new technologies.
- The rating agency should be mandated to increase the sample size from the existing 44,000 to 60,000 by the end of 2020, and by the end of 2022 using the existing techn010U.
- BARC shall immediately conduct a study in collaboration with the Indian Statistical Institute or any other institute of repute, to estimate the appropriate sample size, and to get the correct representation of the viewership including regional and niche channels. Sample size once increased; it will make the data tampering an arduous exercise. On the basis of the study conducted, BARC should reach the target of reaching the sample size in a time-bound manner.
- There should be some financial disincentives prescribed as penal provisions including the cancellation of registration, if the specified target is not met by BARC.
- MIB should amend the DTH License and MSO registration so as to mandate STBs capable of transferring viewership data and adoption of RPD technology. This transfer of data can be done by establishing a return path/ connection from STB to the remote servers of the Audience
- Anonymized viewership data should be transferred electronically to the Audience Measurement agency for statistical analysis and Television Rating purpose. No data from any STB should be transferred to Rating agency without explicit consent from the subscribers.
- DPOs should be allowed to mutually negotiate the terms andconditions for sharing the data with Measurement Rating agency within the overall framework prescribed by TRAI from time to time. Such framework shall be prescribed by TRAI once these recommendations are accepted by MIB.
- BARC should keep all relevant data such as original data (meter-level data) arising out of the household panel, the data deleted/ ignored/ not considered for ratings and the resultant processed data for TRP rating at least for one year in the same format and pattern as in the final ratings, declared to the subscribers including Broadcasters, advertising agencies, and advertisers.
- BARC should review/frame its outlier policy based on scientific study and market survey conducted from time to time. BARC should automate data processing in such a manner that no manual intervention is required before the final TRP rating is released. Any type of manual intervention in the meter level / raw data arising out of household panel must be avoided. Manual intervention, if any, in abnormal circumstances should be reported and informed to the auditors also.
- Adequate framework for grievance redressal may be made having nodal officers and Appellate body.
- BARC should get annual audit conducted by an independent agency to ensure conformance with TRP rating methodology, Sample size, and grievance redressal methodology and publish audit report on their website after board approval within three months after end of the financial year.