In its response to the Ministry’s March 12 letter, TRAI has said that since installing a chip was not part of the initial reference from the Ministry, it was not discussed for the recommendations for new DTH licences that the regulator gave in 2014. In its response to the Ministry’s March 12 letter, TRAI has said that since installing a chip was not part of the initial reference from the Ministry, it was not discussed for the recommendations for new DTH licences that the regulator gave in 2014.

In a letter written to the Telecom Regulatory Authority of India (TRAI) regarding new licences for Direct-To-Home service providers last month, the Union Ministry of Information and Broadcasting said it was “proposed to ask DTH operators to install a chip in the new Set-Top-Boxes which can give data about channels watched and their duration”.

In its response to the Ministry’s March 12 letter, TRAI has said that since installing a chip was not part of the initial reference from the Ministry, it was not discussed for the recommendations for new DTH licences that the regulator gave in 2014. (It was on these recommendations that the Ministry had asked TRAI further questions.) A “new issue”, TRAI said, could not be part of a “back reference”, and if the Ministry “desires” the regulator’s recommendation on it, it must ask officially. The Ministry has not sent such a request yet.

What is this exchange about, and what is the background and relevance of the discussion between TRAI and the Ministry?

How is television viewership in India measured currently?

The Broadcast Audience Research Council (BARC), an industry body that is jointly owned by advertisers, ad agencies, and broadcasting companies, represented by The Indian Society of Advertisers, the Indian Broadcasting Foundation and the Advertising Agencies Association of India respectively, measures television viewership in the country, using television rating points, or TRPs.

BARC has installed “BAR-O-meters” in 33,000-odd empanelled households (as of September 2017) across the country. These households are classified into 12 categories under the New Consumer Classification System (NCCS), the so-called “new SEC” that was adopted by BARC in 2015, based on the education level of the main wage earner and the ownership of consumer durables from a predefined list of 11 items ranging from an electricity connection to a car.

While watching a show, the members of the household register their presence by pressing their viewer ID button, thus capturing the duration for which the channel was watched and by whom, and providing data on viewership habits across age and socio-economic groups. This data is one of the most important considerations for advertisers and agencies while choosing a channel to advertise their products.

It is important to note that like any good statistical survey, the panel used to capture TRPs must be representative of the country’s population, and the methodology must be economically viable for the industry.

So, why does the I&B Ministry need a chip-based activity log?

The Ministry, sources said, feels that a recorded activity log can lead to a more “accurate assessment of viewers”, which can be used by advertisers and advertising agencies. Also, the sources said, there were concerns within the Ministry that BARC was underreporting viewership numbers for Doordarshan. Finally, according to these sources, the data produced by BARC may not be accurate, and this could be impacting the advertising costs of the government — with some channels with low viewership being able to charge more for advertisements.

BARC, the sources said, was a “monopoly” which did not disclose its methodology in sufficient detail, and senior Ministry officials felt that installing the chip could capture more accurate viewership data for all DTH households.

A BARC spokesperson, however, said being the only agency that the industry subscribes to does not automatically make it a monopoly. “We operate strictly within government guidelines”, the spokesperson said, and BARC’s systems and processes are “periodically audited by global firms”.

When did these doubts first arise?

The integrity of viewership data has been controversial for a decade. In January 2008, the I&B Ministry sought TRAI’s recommendations on various issues relating to television audience measurement. In August 2008, TRAI recommended self-regulation through an industry-led BARC. The regulator also laid down how many households must be empanelled, how they should be rotated, who should own the television viewership assessment body, etc.

As issues persisted, however, the Ministry went back to TRAI in 2012. In 2013, the regulator reiterated most of its 2008 recommendations, adding, “A minimum panel size of 20,000 to be implemented within 6 months of the guidelines coming into force. Thereafter, the panel size shall be increased by 10,000 every year until it reaches the figure of 50,000. The panel of homes has to remain representative of all television households in the country.”

And will the proposed chip in set-top boxes produce better data?

The idea is still in a nascent stage, but a basic chip that passively records TV viewership data of all households that have set-top boxes will only be able to capture the duration of viewership for each channel — even though it will be able to potentially capture this data for a much larger TV-watching population. No information about the TV-watching habits of different age groups will be captured — unless every household that has a set-top box also has a system by which every member of the household is able to register her presence while watching a particular channel. Also, for the data to reflect viewership patterns of different socio-economic groups, each set-top box will have to have a unique marker that identifies the particular household.

Data from a basic chip, then, will be quantitatively richer, but not necessarily better qualitatively — which is essential for the advertising industry and, therefore, the broadcasting industry. Also, the proposal is only for set-top boxes of DTH customers, whereas TRAI recommends that TRP measurements should be platform-agnostic, i.e., it should reflect the viewership of cable TV and IPTV, etc., as well.

Are there any other concerns about a chip in set-top boxes?

As explained above, if the chip is to capture qualitative data across age groups and socio-economic segments, each set-top box will have to be equipped with a unique identifier, which is rather similar to inviting the government into living rooms to watch which households and family members are watching what at any given time. Concerns over privacy are bound to b e expressed.

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