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Undressing Room

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Chetra Sinnathamby, Arts Entertainment Licensing Officer at Infocomm Media Development Authority (IMDA).
(Completed on 27th March 2017, Singapore)

1) Can you share about the work that IMDA does, and what is its role in relation to the promotion of arts in Singapore?
The Info-communications Media Development Authority (IMDA) was formed on 1 October 2016, with the restructuring of the Media Development Authority (MDA) and Infocomm Development Authority (IDA). It develops and regulates the converging infocomm and media sectors in a holistic way to create a dynamic and exciting sector, safeguard the interests of consumers and foster pro-enterprise regulations. More information about the work that the IMDA does can be found at the IMDA’s website (www.imda.gov.sg). 

The National Arts Council is the key agency responsible for the promotion of arts in Singapore. IMDA too takes the view that the arts is important and valuable for Singapore and Singaporeans. 

As a regulator, the IMDA is responsible for classifying content according to its suitability for different age groups. Classification serves to protect the young, while allowing adults to make informed viewing choices on a wider range of arts content. In making our classification decisions for arts entertainment events, the IMDA aims to strike a balance between reflecting generally accepted social norms, while giving due consideration to the event’s artistic and educational merits; and in doing so, the IMDA complements NAC’s work in promoting the arts.  Based on surveys conducted by the IMDA between 2013 to 2015, about two-thirds of consumers were satisfied with the content classification standards for arts entertainment events in Singapore.

2) What are the difficulties IMDA has to deal with when trying to classify performances?
Unlike other forms of content that the IMDA classifies, arts entertainment events submitted for classification may not necessarily always be in their complete, final forms with all the necessary materials available at the outset. While we do understand that artists may need time to complete and refine their works which may evolve constantly, it remains important for artists to submit complete materials in a timely manner to IMDA so that we will have sufficient time to classify their arts entertainment events. The IMDA may also need to seek clarifications from the applicants on how the content is staged and depicted, as there could be different interpretations and portrayals of the submitted materials. 

The IMDA also frequently receives late Arts Entertainment Licence applications, which present operational challenges given the high daily volume of licence applications. Late applications also create additional stresses and pressures on the applicants, as they have shorter turnaround times to provide the IMDA with the necessary information for classification. 

3) How does the classification system work?
Classification enables content to be made accessible to mature audiences while protecting the young from content unsuitable for them. The classification rating issued takes into account the theme, message, context, content and its overall impact. 

Specifically for arts entertainment events, the IMDA classifies them according to the Arts Entertainment Classification Code (AECC). Content suitable for a general audience, including children, will be given the General rating, while those that are targeted at a more mature audience can either be given an Advisory, Advisory 16 or Restricted 18 rating.  Content which goes beyond the Restricted 18 rating, for example those which may undermine national interest, likely to cause feelings of ill-will between different racial or religious groups or is excessive and/or exploitative in its depictions, will be disallowed. 

The IMDA also regularly consults the Arts Consultative Panel (ACP), which comprises members of various professions (including those in the arts field) from the community, for additional views on the classification of arts entertainment events and for feedback on IMDA’s classification guidelines and standards.

4) Can you share about IMDA’s assessment and classification of Undressing Room. What were the content concerns?
The Arts Entertainment Licence application for Undressing Room was submitted by The Necessary Stage, the organisers of the M1 Singapore Fringe Festival 2017. Based on the information submitted in the licence application, the performance involves the performer and an audience-participant potentially undressing each other completely, before proceeding to touching each other. 

IMDA assessed it as exceeding the R18 guidelines in the AECC. IMDA also consulted the ACP on the performance, and the ACP shared the same view as IMDA. 

5) How were the content concerns conveyed to the organisers of the M1 Singapore Fringe Festival 2017?
Throughout the licence application process, the IMDA proactively engaged The Necessary Stage and communicated our considerations and assessment clearly to them. Although the original performance would have exceeded the AECC guidelines, the IMDA was prepared to consider modifications by the artist if the modified performance could be contained within a Restricted 18 rating or lower. However, The Necessary Stage decided to withdraw the entire performance from the M1 Singapore Fringe Festival.

6) IMDA has denied Undressing Room a classification, on the grounds that it contained ‘excessive nudity’. What constitutes ‘excessive nudity’? What are the criteria used to determine whether a performance contains ‘excessive nudity’?
Please refer to the response given in Question 4.

7) There are people who think that the non-classification for Undressing Room was a result of public complaints. What role do public complaints play in shaping IMDA’s decision and how does IMDA respond to them?
All Arts Entertainment Licence applications are objectively assessed, in accordance with the AECC guidelines. IMDA may consult the ACP to seek additional views. 

While the IMDA does look into feedback from members of the public, our assessment itself is not dependent or influenced by public complaints or feedback. For Undressing Room, all public complaints that the IMDA received were anonymised and shared with the Festival organisers as well, so that they would also be aware of public sentiments towards the performance. In responding to feedback or complaints about arts entertainment events from members of public, the IMDA will generally explain the rationale behind our classification decisions.

8) As you probably know, I am doing a documentation on Undressing Room. It is an independent, closed-doors, non-ticketed and by-invitation-only project. 17 participants have taken part in the work, in its original format without any changes to it. Why is it allowed to take place? Why is IMDA’s classification no longer applicable to it?
Private events are not considered as Public Entertainment under the Public Entertainments and Meetings Act and therefore are not regulated by the IMDA.

7) Forms, modes of production and modes of operation of artworks are evolving very rapidly. Some of them are very cutting-edge and therefore fall outside of any pre-established format or category. Faced with the diversity and complexity of artworks, how does IMDA hope to remain relevant to the evolving art landscape?
The IMDA is cognisant that the forms and substances of arts entertainment are not static and will continue to evolve. We keep up to date with the developments through engaging our stakeholders, such as our Arts Consultative Panel, the National Arts Council, arts groups and the arts community. From time to time, we review the AECC guidelines as well as our interpretation and application of the guidelines in consultation with our stakeholders to ensure that we keep up with changes and developments in artistic trends and community standards.

8) Many Singaporean artists see IMDA as monolithic and its decision as top-down. What is your perspective on this?
Typically the IMDA engages arts groups in the process of assessing their Arts Entertainment Licence applications. This ensures that we better understand the content and depictions of their works, so that we can give appropriate classification ratings, taking into consideration any artistic or educational merits of their works. 

We would also reach out to the relevant stakeholders when formulating new policies or reviewing the classification guidelines. IMDA has always welcomed and is open to engagements and discussions with the arts groups and the arts community. On occasions, IMDA has also facilitated dialogues and discussions between the Arts Consultative Panel and the arts groups on the latter’s works.

9) Will there be a day when IMDA is no longer needed? Under what conditions would that happen?
The key reason for arts entertainment licensing and classification is to protect the young from content unsuitable for them while enabling adults to make informed viewing choices. We also play a key role in developing content guidelines and classifying content to ensure that these are in line with community norms and do not denigrate any race or religion, or are contrary to the national interest. These responsibilities will remain an important cornerstone of our regulatory framework.