Subtitles and Captioning – Regulatory requirements update part 2 and adding business value

As a follow-up to my previous post, I am going to discuss recent reports specific to UK broadcasters which are regulated by Ofcom.

Last month the charity Action on Hearing Loss published the results of a survey carried out at the request of Ofcom to investigate the quality of subtitles seen on UK linear television. The results for me were not that surprising:

The highest percentage of problems experienced with subtitles were in relation to news programmes, with nearly half of respondents reporting this as a problem in our survey. Entertainment programmes received 18% of complaints and drama programmes received 16%. Around one eighth of respondents complained about subtitles during a sports programme. A high proportion of these programmes are likely to have at least some live subtitling.

SOURCE: Action On Hearing Loss – Research – Getting The Full Picture

Of the live subtitling more than half the complaints were about delay and time lag between speech audio and the subtitles on screen. Again, not surprising. If you want to make subtitles completely unusable – being out of sync with the audio is the way to do it! What the survey does not cover and what I would be interested to see is how Ofcom as a regulatory body could measure the quality of subtitles that broadcasters provide on a regular basis. I have written about this in more detail in CSI User Experience Conference 2012 Part 2 – Live Subtitles & measuring quality.

Ofcom have published the full year 2012 TV Access Report. The table illustrates the percentage of programmes certain channels are required to subtitle. The good news is that with the exception of ESPN, channels have met their required quota and some have done even better and exceeded it.

The percentage of content that Ofcom require broadcasters to subtitle is based on the individual channels total audience share. This means that smaller channels are not legally required to provide subtitling and therefore those channels don’t even appear in the report. Is this right? I recently had a conversation via twitter with a TV viewer unhappy that the SyFy channel has not subtitled a brand new and exclusive show called Defiance. Take a look at the tweets I collated at Storify: UK broadcasters linear and VOD TV channels not subtitled.

In response to a complaint about lack of subtitles SyFy wrote:

Under current Ofcom regulations channels are obligated to provide access services according to their size. The bigger the channel, the more they must provide. On this basis we are not currently required to provided subtitles on SyFy, and unfortunately as the costs involved in creating those versions are high, we therefore cannot do so at this time.

SOURCE: @topofthetree

First off, it is good that SyFy sent a reply to the query (some channels don’t even bother with that). The answer is of course not what those of us who require subtitles to follow a programme want to hear. Whilst SyFy are correct with regards to regulations it the last sentence I question. The costs are high. Well yes there is a cost to subtitle a programme, but cost is relative. How expensive is creating subtitles for viewers compared to the costs spent on the UK marketing campaign promoting the series? I for one haven’t failed to notice the billboard posters promoting the series – the money was found for that. So here is my opinion:

Really what SyFy is saying is that they have not chosen to budget the cost because it’s not legally required. This is a real shame SyFy because you can spend as much money as you want on promoting the show but having chosen to not provide subtitles, you’ve lost potential audience members before you’ve even began. How silly is that? It’s a kick in the teeth to see the publicity and the posters knowing full well you can’t tune into the premiere even if you wanted to because no subtitles are available! And here’s another thing, the value added by providing subtitles stays with that programme throughout its run on the TV channel. The marketing does not! Once this series has premiered, all that money spent on publicity, done, finished. If you choose to also spend money on providing subtitles, they can be used again and again and again every time the programme airs (and lets face it almost every linear TV channel out there has an awful lot of repeats) that is surely value for money right there? SyFy state they hope to provide subtitles in the future. Given the points I have made in this article, I ask SyFy and similar smaller channels, what are you waiting for?

Going back to Storify: UK broadcasters linear and VOD TV channels not subtitled and a response from Sky with regards to no subtitles being provided on their VOD (Video On Demand) service:

The technology used in providing subtitles for TV broadcasts is different for On Demand. Unfortunately it is not possible to just transfer these over as different versions have to be created…We are investigating options at the moment to increase the availability of subtitles On Demand but we cannot at this point confirm when this will be available.

SOURCE: @Shelle02

Unlike linear TV channels, VOD is regulated by ATVOD (Authority for Television On Demand) in the UK (except for BBC iPlayer), and unlike Ofcom they currently have no power to compel VOD channels to provide subtitles. I have written about this in more detail in CSI User Experience Conference 2012 Part 1 – Subtitling & Video On Demand Services.

VOD is growing, in size and complexity. And with that comes technological challenges in providing the service, and access services. But here’s the thing, the content provider who solves the access issue in working out how to provide subtitles for VOD services, much like the SyFy example will be adding business value. According to an article by Red Bee Media, there are four ways add value to VOD:


In my view, value for Video On Demand is added in four areas:

1) Of course, the majority of the value is in the content creation and is generated when the item is first made. This, after all, is the reason content is purchased, watched, saved, shared and rewatched. This value drives all other values.
2) Additional value can be added during content manipulation. For example when a French movie is translated and localised for German audiences.
3) Content transcoding adds value by ensuring content will play on an end device like a tablet.
4) The last value-add is the ability to return consumption, demographic and interaction data to content and platform owners to generate additional value, which includes simple upselling like “if you like this, you’ll like that…”. Also, given that 64% of Generation X and 74% of Generation Y use a second screen while watching TV, metadata gives us the ability to synchronise second-screen content with first-screen action.

SOURCE: Red Bee Media – How Do We Handle The Growing Complexity In VOD

Looking at (2) above, content manipulation includes adding subtitles for the deaf and hard of hearing, not just translation surely? Looking at (4) subtitles can be used as a metadata source to assist a broadcaster with its workflows. Subtitle files are a data source – it contains valuable editorial information (i.e. all of the spoken dialogue) for that programme with a time stamp. This data could be used for search functionality to pinpoint exact parts of a programme where ‘x’ might be mentioned, potentially saving hours of time for a human to manually look for such instances. For more information on metadata’s use in VOD read An Introduction to Video Metadata and CSI User Experience Conference – Part 4 – Access business models. For VOD channels operating online there is also the added benefit that subtitles and captions give to video SEO. I have written about examples of this in Captioning, subtitling and SEO and the second screen and if you want more information on this subject taken a look at 3 Play Media blog series on Video SEO.

In conclusion then, adding subtitles provides access benefits and business value to broadcasters. Providing access is not a punishment because you’ve reached a certain audience percentage (linear TV), it’s a way to increase audience reach in the first place. Why wait until Ofcom tell you it is a legal requirement? And for VOD, it is no different. The quicker solutions are found for the technological issues in adding subtitles the quicker you can add business value and extend audience reach. The VOD service that does this, is the one that will get my money and customer loyalty.