When UK trade group TIGA announced its Five Principles for Safeguarding Players yesterday, my first impression was that it was a defensive PR measure, a shield to point to whenever governments started to scrutinize the business a bit too closely.
After all, that's what I've come to expect from the trade groups in this industry. And at a glance, these five principles would not be out of place coming from a group interested in empty posturing without the need to actually make substantive changes to anything the industry is currently doing:
- Protecting Children
- Treating Consumers Fairly
- Safeguarding Online Communities
- Respecting Personal Data
- Spending and Time Management
However, upon reading through TIGA's explanation of each point, it quickly becomes clear this is not a list of things the industry already does so much as it is a list of things it should be doing. Some of those "Positive Practices" (as TIGA labels them) were embraced by the industry years ago. Others feel like they are years away from becoming standard. Virtually all of them would likely strike outside observers as the sort of thing one would assume a reputable industry would be doing anyway.
TIGA's Five Principles represent a more critical discussion of common industry practices than I can envision coming from any of its fellow trade organizations
Taken together, they feel bizarrely revolutionary at this particular moment in time. TIGA is not the first trade organization to release best practices -- the IGDA has done so on a variety of subjects for years -- but its five principles represent a more critical discussion of common industry practices than I can envision coming from any of its fellow trade organizations.
While TIGA specifically acknowledges that not every guideline will be appropriate for every business, it doesn't leave much wiggle room for companies to outright ignore them.
"While it may be possible to achieve compliance with the Principles without complying with all of the following Positive Practices, this is likely to be difficult," TIGA says. "Equally, there may be other actions required to comply with the Principles that are not included in the Positive Practices."
These are exactly the kind of steps a group concerned with the long-term health and sustainability of the games industry should be talking about, but sadly they are also the least likely to be undertaken by the people who in theory would care about that that most.
For example, I would be shocked if the Entertainment Software Association in its current form suggested that companies should issue a refund when a child makes unauthorized purchases on their parents' credit cards (Positive Practice 3 under "Treating Consumers Fairly"). And while complying with a prohibition on misleading advertising (Positive Practice 6 under "Treating Consumers Fairly") doesn't sound like a big ask, platforms and publishers alike clearly haven't been too fussed about running blatantly misleading mobile ads on games.
Similarly, it would be out-of-character for many of the biggest players in the industry to adopt Positive Practice 7 under "Respecting Personal Data," which says players should be informed when their data is used to weight purchasing-related variables in-game, like what the odds are of getting a rare loot box reward. After all, it was only last August that Nintendo, Sony, and Microsoft agreed to mandate loot box odds disclosure. Not only was that already years after Apple started mandating it for iOS apps, but the console makers only committed to implementing odds disclosures by the start of 2021. This industry has an allergic reaction to transparency, and its trade groups have traditionally reflected that.
I would also be beyond shocked to see another trade group suggest its members publicize Common Sense Media the way TIGA does (Positive Practice 6 in "Protecting Children"). After all, Common Sense Media is an outfit with a lengthy history of criticizing the industry. It advocated for the California law against selling violent games to children that eventually went before the Supreme Court. It cautions parents that exposure to violent games can desensitize children. When the Newtown elementary school shooting brought game violence into the spotlight again in December of 2012, Common Sense Media commissioned and released a study on parental concerns around violent games within weeks.
Embracing TIGA's principles would help show the industry's genuine interest in serving its customers' needs rather than exploiting them
That said, if you're a parent and you want a resource to tell you not just about the sex, violence, and profanity in a game but about whether it portrays positive role models, how aggressive it is about pushing in-game purchases, or if its reason for existence seems to be marketing a companion toy line -- all entirely valid concerns not fully served by the standard rating systems -- then Common Sense Media's site is legitimately helpful.
It's exactly the sort of resource the industry should be working to make parents aware of: informative, invaluable, and (most importantly) independent. TIGA's willingness to include it under the best practices for protecting children despite the group's past criticism reads to me as evidence that this is an exercise embarked on in good faith by a trade group more concerned about living up to its responsibilities than who's on which side.
The Positive Practices for "Spending and Time Management" are further evidence of good faith on TIGA's part. While there are various tools and features across every platform to accomplish the general goals of limiting spending or play time, TIGA's guidelines incorporate a number of features industry critics have called for that would produce genuinely robust support for users. Many of them are prefaced "where proportionate and technically practical" in a nod to the fact that these would be harder to incorporate for some studios and games than others, but they would all help show the industry's genuine interest in serving its customers' needs rather than exploiting them.
TIGA called for developers to allow players to set daily, weekly, or monthly spending caps, or to remove their ability to make new purchases for a set amount of time. Furthermore, when players exhibit atypical patterns of spending, the trade group says companies should consider an automated system to let the players know, or to impose a "cooling-off" period where they can't spend any more.
From the outside, many of the games industry's biggest titles are a black box of revenue generation, and that will always be terrifying to skeptical outsiders
There's also one best practice that doesn't carry the "where proportionate and technically practical" qualifier, and rightfully so. Regardless of constraints, TIGA wants developers to let players track spending on in-game purchases, "including lifetime spending on the game and by providing the option for periodic emails or other communications to remind players what they have spent."
Finally, there's one point that comes up twice. Positive Practice 5 under "Treating Consumers Fairly" is compliance with the Competition and Markets Authority's principles regarding online games, which specify that costs of in-game purchases need to be provided clearly and prominently up front before a player downloads or signs up for a game. Reiterating that point, Positive Practice 8 under "Spending and Time Management" calls for companies to disclose the use of loot boxes and other chance systems up front.
I think this part is crucial in a way the industry doesn't readily comprehend. In this job, I am semi-regularly required to write about the monetization systems of games I don't actually play. Let me tell you, it can be an incredible pain trying to understand how an in-game monetization system works unless you have first-hand experience with it. Generally speaking, these games don't have online stores that detail what is being offered to people or for how much. Often the best you can get is an app store list of the most popular in-game purchases. But just knowing how much a bundle of virtual currency is doesn't tell you how that currency is spent in the game, what players can and can't do with it, which features of the game mandate the use of it, are built around it, or have light interactions with it.
I'm not saying this to complain about how in-game monetization makes my job harder. (Well, not just that.) I'm saying this to emphasize that from the outside, many of the games industry's biggest titles are a black box of revenue generation, and that will always be terrifying to outsiders already skeptical of the industry's ability to behave itself. Giving people who aren't already immersed in a game the opportunity to scrutinize how it makes money would be a gesture made in good faith to anyone beyond the player base, be it potential customers or watchdogs. It's the sort of transparency this industry badly needs, but has traditionally fought against at every turn.
Adopting these standards and adopting them proactively -- before legislators spell out for the industry exactly what they want to see happen, as they did back when the Entertainment Software Rating Board was formed -- would be a good first step for an industry beset by criticism. It would show that game makers don't have to be dragged kicking and screaming into doing the right thing, that they might just mean it when they say they won't ignore their customers' interests in favor of their own.