TRAI tackles ratings

The Telecom Regulatory Authority of India (TRAI) takes its job seriously even if it has to contend with the Ministry of Information and Broadcasting which sometimes bats on the side of those it is seeking to regulate. And it also persists in telling the ministry what to do and how. It has now set out a framework and guidelines on the contentious issue of ratings agencies and suggested that the ministry notify guidelines for such agencies in two months. 

It has said that these should mandatorily cover registration, eligibility norms, cross-holding, methodology of rating, complaint redressal, sale & use of ratings, audit, disclosure, reporting requirements and penal provisions. The recommendations detail in particular ways to make audience sampling more representative, suggesting a minimum panel size of 20,000 to be implemented within 6 months of the guidelines coming into force. Thereafter, the panel size should be increased by 10,000 every year until it reaches the figure of 50,000.  It also says that geographic representation shall be provided in proportion to the TV viewing population. 

Excerpts from the recommendations published on September 11, 2013. 

III Methodology for Audience Measurement 

Viewing Platform
a. Ratings ought to be technology neutral and shall capture data across multiple viewing platforms viz. cable TV, DTH, Terrestrial TV etc.; online platforms to be covered wherever feasible. 

Panel selection
b. The panel homes for audience measurement to be drawn from the pool of households selected through an establishment survey. 

c. For selecting the pool of households, a large scale establishment survey shall be carried out. The household pool created through this survey shall be at least ten times the number of panel homes required for audience measurement. 

d. The establishment survey shall be carried out annually to reflect changes in growth of TV homes, changes in demographics, growth in new delivery platforms like internet, variations of growth across markets etc. 

e. The selection of panel homes, from the household pool created through establishment survey, shall be based on distribution of target viewership for a particular segment like age group, socio-economic class, gender, working status, multiple delivery platforms, all States and urban & rural markets.

f. 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. 

g. Geographic representation shall be provided in proportion to the TV viewing population. 

h. The rating agency shall not include any officer, employee or any other member, of broadcasters, advertisers and advertising agencies, in the audience measurement panel.  

i. The panel homes shall be updated periodically to reflect the developments taking place in the delivery platforms, growth in viewership etc. 

Secrecy and privacy
j. Secrecy and privacy of the panel homes must be maintained.

In this context the industry body will issue a voluntary code of conduct to be followed by all stakeholders, including penal provisions for breach of the code. 

k. 10% additional panel homes beyond the required panel size shall be deployed. The actual panel homes required for computation shall be randomly sampled from the total panel homes deployed. The rating agency will use necessary algorithms to detect outliers having unusual viewing behaviour and discard such data. 

l. 25% of the panel homes shall be rotated every year. The rotation shall be in such a manner that older panel homes are removed first while maintaining the representativeness of the panel. Such rotation will be achieved in a staggered manner by rotating panel homes every month. 

Data Analysis

All weighting or data adjustment procedures utilized by the rating agency in the process of converting basic raw measurement data to rating reports shall be based on systematic and logical procedure and applied consistently. 

Any shortcomings, deficiencies, limitations in the rating system shall be clearly disclosed in the rating reports and also brought to the notice of users of the rating system. In the event that a rating agency identifies an attempt to bias measurement results by a respondent’s submission of fabricated information, it shall eliminate such cases from analysis. In the event that such cases have been included in published data, the agency shall be required to assess the effect on results and notify users about the same along with indication of its practical significance. 

Transparency

p. The procedure adopted for selection of panel homes and the rotation of the panel homes shall be made transparent. 

q. The Rating agency shall submit the detailed methodology it uses to the Government and also publish it on its website.

IV Cross-holdings

a. Substantial equity shall mean equity of 10% or more of paid-up equity. Having a substantial equity holding in companies shall constitute a cross-holding. 

b. No single company/ legal entity, either directly or through its associates or inter-connected undertakings, shall have substantial equity holding in both rating agencies and broadcasters/advertisers/ advertising agencies. 

c. No single company/legal entity, either directly or through its associates or inter-connected undertakings, shall have substantial equity holding in more than one rating agency operating in the same area. 

d. The cross-holdings restriction will also be applicable in respect of individual promoters besides being applicable to legal entities. 

e. A promoter company/ member of the Board of Directors of the rating agency cannot have stakes in any broadcaster/ advertiser/advertising agency either directly or through its associates or inter-connected undertakings. 

Complaint Redressal

a. The rating agency shall have an effective complaint redressal system in place. 

b. The rating agency shall provide the options for registration of complaints online, by email, by post etc. and provide details pertaining to the same on its website. The rating agency shall ensure that complaints are addressed in a time-bound manner. 

c. The rating agency shall establish an Appellate Authority.

The procedure for filing an appeal shall be available on the rating agency’s website. Any complaint not addressed within the scheduled timeframe shall be automatically escalated to the Appellate Authority. 

d. Details of the complaints and their disposal shall be displayed on the website of the rating agency.