BBC response to the Byron review consultation
"We aim to provide children with challenging,
educative, enjoyable and interesting content to help them make
sense of the world in which they live. But, at the same time,
we must safeguard the welfare of children and young people both
as contributors and consumers of content"
Section 9BBC Online Services Guidelines
The Byron Review has asked the BBC specifically
to provide details of how the BBC protects children and young
people online from potentially harmful and offensive content.
So, in submitting this evidence, we have concentrated mainly on:
the aspects of connectivity
that we feel pose the most threat to the safety and wellbeing
of these audiences as they grow up, and
on what the BBC does to minimise
We support the Byron Review's belief in the
importance of adopting an evidence-based approach to policy making.
However, we have not attempted to respond to the full range of
attitudinal or behavioural questions posed by the consultation
paper as we feel these are best answered by academic or quantitative
research. Where we have relevant, specific information, we have
referred to it.
We do feature online games on our sites but
we apply the BBC Editorial Guidelines to online games as we do
to any other online content (text, audio or video). We have therefore
treated games as a subset of our internet response. Similarly,
at the end of this document we make a brief mention of our mobile
activities and how the BBC is responding to security issues involved.
This paper is written from the point of view
of the BBC public service although the same principles normally
apply to BBC Worldwide.
2. OUTLINE OF
The BBC has a very clear strategy of supporting
children from birth through to early adulthood, with three sites
that reflect the varying levels of protection, computer literacy,
independence and maturity as they grow up, as well as specific
educational services offered by BBC Learning.
1. The CBeebies (www.bbc.co.uk/cbeebies)
and CBBC (www.bbc.co.uk/cbbc ) websites enable children and their
parents or carers to interact with us and each other in a safe,
trusted and accessible environment. The sites provide high quality,
engaging and relevant interactive content and experiences for
children, as well as acting as a springboard to the best appropriate
external websites for the under-12s.
2. The focus is on empowering children and
giving them the opportunity to gain a deeper relationship with
the BBC, the brands and characters, increasing the value they
receive, the ownership they feel, and the impact they have on
CBeebies and CBBC. To achieve this, the sites offer a range of
innovative interactive tools and creative opportunities aimed
at all British children, of every ability and background, giving
them the space to publish their own content, thoughts and opinions.
We also provide a dedicated 24/7 news service for children online
as part of Newsround and through the Press Pack section we can
actively engage children in the topical issues that matter to
3. BBC Switch provides an online space for
all teenagers, with content aimed at engaging young people, addressing
their interests, and encouraging interaction. The site contains
both supporting TV and radio programmes and free-standing content.
4. BBC Learning provides output for school-aged
children across a broad range of subjects and skills. The following
are linked to curriculum or specific skills:
and recap service for all major subjects for children aged 5-16
development for teenagers, currently focused on creative arts,
including partnership with youth arts organisations (www.bbc.co.uk/blast).
Some services are designed for use in the classroom;
others are increasingly used directly by learners at home or at
school, without the need for tutor mediation.
Whether designed for relaxation or to deliver
specific learning outcomes, all our sites share a philosophy to
empower and engage young people in line with the BBC's public
They have a dual role to;
(a) build on the BBC's reputation as a strong
public service media brand in the UK (on TV and radio)providing
deeper, stickier, enriched, and engaging experiences around our
existing contentby harnessing the known benefits of interactive
and on-demand functionality, and
(b) extend reach (and relevance) to an increasingly
digitally aware audience who are spending more and more of their
dedicated "media time" on the web and other digital
All BBC online services are subject to the BBC
Editorial Guidelines (http://www.bbc.co.uk/guidelines/editorialguidelines/edguide)
and the BBC Online Services Guidelines (http://www.bbc.co.uk/guidelines/editorialguidelines/onguide
3. HOW AND
INAPPROPRIATE BBC MATERIAL
The BBC divides its online audience into distinct
age categories with different content rules.
|7 to 12s|
|12 to 16s|
|16 to 18s|
|18s and over|
The majority of content is designed to be appropriate for
general family consumption, acceptable for all ages (although
not necessarily targeted at a younger age range). Thus, a complex
science documentary strand might be deemed acceptable for a minor,
although not necessarily likely to appeal to them (complexity
of language, explanation etc). To address this online, we have
specific services designed for different audiences and we take
account of the expectations of the likely audience.
Under 7sCbeebies online
This is a "walled garden" site designed for use
by children with their parents or carers. All content is specifically
targeted at the designated age range, and the only links off the
site are from the Grown-ups support area to similar support sites,
and to specifically approved third party sites maintained by the
TV Independents responsible for the programmes. These are pre-vetted
by BBC staff to conform to Editorial Guidelines.
In addition, users can link off to the main BBC homepages
via our global navigation where all content is designed for family
consumption unless otherwise stated.
Similar to Cbeebies, CBBC is a walled garden site with links
off only to specifically approved sites (See section 4). The only
other permanent links are via the BBC global navigation (via the
main homepages again), to Cbeebies and to Bitesize Primary which
is aimed at the same age group.
12-16sBBC Switch online
BBC Switch is our third age-specific offer which launched
earlier this year to aggregate all the BBC online content currently
targeted at a Teens audience. All material is checked to make
sure it is age-appropriate and external links are pre-vetted.
This service is not promoted to younger children on Cbeebies and
BBC Learning (Schools, Blast and Bitesize)
These sites follow similar rules and are targeted at curriculum
learning. All external links are vetted for their appropriateness.
Many of the games and other interactive offers like message
boards on bbc.co.uk require an extra level of security based on
our registration service (Single Sign On) which distinguishes
access according to the user's age.
All sites also encourage an active understanding of the Internet
and potential hazards for parents and children alike.
4. HOW WE
BBC MATERIAL IN
The advent of video-on-demand on the web has brought new
challenges. We can no longer simply rely on the TV transmission
time of a programme to ring-fence material that is deemed unsuitable
for children by using the 9 pm Watershed and we have adapted our
online services accordingly.
The BBC has led the way in considering how to provide parents
with information to complement the Watershed when programmes are
increasingly being consumed in an On Demand environment.
Our research indicates that parents want to know about the
types of content that may cause concern (such as strong language
or violence) rather than being presented with simple age ratings.
Because of this, the BBC developed the "G" for Guidance
labelling system where a "G" is displayed when a piece
of content contains challenging material and the nature of the
content is spelt out in text alongside the programme synopsis.
The presence of the "G" is used to trigger parental
PIN control systems,if enabled, as outlined below.
On the current BBC iPlayer, installation is restricted to
those aged 16 and over. Users are also told about PIN protection
during the registration process and have to make a decision about
whether to enable it there and then. If they choose not to, they
are told how they can enable it later. Where a programme carries
guidance, the "G" and text label are displayed at the
point the user decides to download the content. At the point of
viewing, the text label is also displayed and the user has to
enter their PIN number, if enabled, before they can view the content.
Anyone using the iPlayer without the correct PIN code receives
an explanatory message that they don't have permission access
to the "G" rated content.
As we introduce streamed content to the iPlayer shortly,
we will also display the "G" and text label before content
can be viewed. A PIN protection system will be available from
launch which we will look to make more robust as streaming and
downloading are integrated into one system.
The BBC's "G" for Guidance system has also been
adopted by ITV, Channel Four and FIVE for their On Demand offers.
We have worked closely with Ofcom and a number of broadcasters
and platform providers to promote best practice on labelling and
have been an active participant in the BSG Content Information
Group. The BBC is also an associate member of the Association
for Television on Demand (ATVOD), the self-regulatory body for
On Demand services.
The current iPlayer is not promoted on the BBC's Children's
services and in the near future we hope to release a junior version
of the player, specifically designed for children and teens, which
will block any material that is not appropriate for a family audience.
However, protecting children from harmful content is not
just about the systems broadcasters and service providers can
put in place. This is why the BBC plays an active role in the
promotion of Media Literacy. Through our own work, and in partnership
with Ofcom, the Council of Europe and the Industry Taskforce,
we aim to ensure that parents and children are made aware of both
the benefits and potential dangers which new On Demand technologies
can bring. (See also s 11)
5. HOW WE
All external content linked to via Cbeebies and CBBC is pre-approved
by an editorial expert and put on a "green" list which
can then be searched via our Search services.
Cbeebies specifically searches out content on the Cbeebies
site and approved sub sites created by Independent producers supporting
their own Cbeebies programming.
The CBBC Search tool is a more complex resource to help users
find the best CBBC and Newsround content, as well as carefully
selected sites from around the BBC and the wider web. All the
sites must be editorially valuable and relevant to our seven to
12 year old UK audience and must not:
carry, link to or advertise pornographic
material or other sexually explicit material (unless it forms
part of tailored sexual education for this audience group);
carry, link to or advertise explicit violence
or content inciting violent behaviour (including online games
and game reviews with fighting, shoot `em ups or other use of
incite anything illegal;
include discrimination of any kind;
promote poor health/poor eating;
use unsuitable language;
exist solely to sell products or services;
restrict features to paying subscribers.
We do not allow linking to any social networking sites from
CBBC. If any external sites include message boards, they must
be pre-moderated at all times. We never link to live chat rooms
from BBC children's sites.
The CBBC search database is constantly checked with an automated
tool which "sweeps" all the sites in the database, looking
for changes according to key words eg "message boards"
or "chat room". If such changes are detected, the site
is flagged to a researcher, who checks the site again for suitability,
and removes it from the database if necessary.
Similarly, BBC Switch operates a rigorous policy when it
comes to protecting our users from inappropriate content online.
Whilst Switch's presence on third party sites is a key part of
our offer to teenagers, allowing Switch to reach out to an audience
that may not always be very familiar with the BBC offer, all our
ventures in this space are fully moderated and carefully monitored.
We include prominent links to features about online safety wherever
possible and never link to live chat rooms from Switch.
6. HOW WE
To ensure that inappropriate content isn't published on the
CBBC message boards, we have a number of procedures in place.
(a) Automatic filterinappropriate words
are blocked from user names and messages at the point of posting.
This filter includes swearing, sexual terms and racist or homophobic
language. Non-CBBC or Newsround urls are also blocked, along with
(b) Pre-moderationall our message boards
are pre-moderated by a team of specialised children's moderators
against the published House Rules. Each message is checked before
it is published, and moderators will also spot and flag suspicious
users, as well as users in distress.
(c) HostingIn addition to the moderation
team, there is a team of four community hosts. The hosts manage
the message boards from the public facing side, and are the first
point of contact for the moderators when they have concerns about
All CBBC and Newsround moderation is performed by an office-based
team of advanced CRB checked staff from a single external agency.
Working from home is not permitted in order
to ensure that nobody else has access to children's information.
Moderation is team-based so that moderators
are able to share concerns about posts or users, and build up
their knowledge of users' behaviour as a group.
Moderation is performed to our strict moderation
guidelines, built up over the last seven years.
Moderators work from 9 am to 9 pm, and message
boards are only open within those hours. Therefore, when the boards
are open for posting, there is always a moderator on duty.
However, this is a very labour-intensive process and the
more popular and successful the community, the more resources
it takes to moderate.
The ultimate sanction is to block those who persistently
disregard the published House Rules but in the future we want
to move towards a more "trust and "reputation"
based system so as to harness good behaviour and enable peers
to teach best practice to each other, by example. Those who are
key and central to the community would be rewarded for their good
behaviour and disruptive members would have privileges removed.
For BBC Switch, all submitted user generated content is pre-moderated
before it can go livealthough Switch also plans to move
towards a more "trust and reputation" based system.
Exclusive pre-moderated public chat sessions with, for example,
children's favourite authors and presenters are an incentive we
already use for the target age group to participate in the CBBC
communities. Offering these exclusive events and other premium
content discourages users from lying about their age and registering
for services aimed at older users.
Increasingly, we are encouraging our users to send us photos
and videos as well as text. All these are pre-checked to make
sure that the material is suitable for publication on CBBC and
to check that children do not publish sensitive personal information
about themselves or others eg. school signs, road names, door
numbers which could put them at risk, for example through "jigsaw
In particular, when videos are submitted we normally require
the telephone number of a guardian or parent, to get formal adult
consent before publication. (This is in line with our TV policies
and protects for example against children being traced by estranged
parents who may have court orders against them).
7. DATA PROTECTION
AND CRB CLEARANCE
The BBC's approach to data protection is based on the principle
of ensuring that the child is protected, their data is protected,
but that the burden of parental approval is relevant to the level
of risk to the child.
The Data Protection Act 1998 does not differentiate by age.
All organisations are therefore forced to rely on contract law,
which means that in theory no one under the age of 18 can supply
any personal data, or agree to a website's terms and conditions
without parental consent. If this was taken to its logical extreme,
we would need express parental validation before allowing a child
(under 18) to register for any BBC service. The BBC therefore
takes a pragmatic approach ensuring that the level of parental
approval is both legally justifiable and appropriate to the child
and its involvement with the BBC.
The BBC Data Protection approval system is based on two principles:
Children under 16 must obtain a parent or
guardian's permission before sending the BBC any personal details.
Verification of parental consent depends
on the level of a child's involvement with the BBC. (Four levels,
from very low level to high level).
For a very low level of interaction, for example playing
a game online using a BBC registration system that does not hold
any personal data, we will only require a check box stating that
the child has the parent's approval. Whereas for a high level
interaction, for example an appearance by a child on a TV programme,
explicit verified parental consent on a variety of forms is required.
The BBC is presently engaged in a range of trials to review
the use of parental consent by email, and by a registration system
that would allow parents to decide what activities their children
could engage in on BBC websites and what level of reporting they
would receive. The BBC is also reviewing what rules should apply
for teenagers up to 16, and whether they should have access to
greater levels of interaction before they need to ask for parental
Children's data is always regarded as sensitive and is treated
as the highest priority in information security terms. It is never
supplied to third parties without consent and is not used for
to all children's sites, although they sometimes add additional
terms and conditions in order to increase specific provisions
or to highlight key issues.
For all children's services, we also insist that anyone with
access to personal data is pre-cleared with the Criminal Records
The BBC will only contact children:
in relation to the functioning of a service
to which they have signed up, to ensure effective delivery;
where they have opted to receive further
in relation to any contribution they have
made to bbc.co.uk, eg on the BBC message boards;
to invite them to participate in surveys
about BBC services (participation is always voluntary and involves
parental permission), and
for BBC promotional purposes (eg programme
alerts and newsletters) where they have specifically agreed to
All staff at BBC Children's and BBC Switch who would initiate
such contact are again pre-checked for CRB clearance.
8. ONLINE BULLYING/PEER
The automatic word filter and the pre-moderation of all user
content before it can be published offer significant protection
against online bullying. However, our hosts (see s 6 above) also
play an important role in the prevention of cyber bullying in
the CBBC communities. They are alert to signs of bullying behaviour,
and work to ensure that the communities are welcoming and inclusive,
discouraging exclusive clubs and cliques. It can sometimes be
difficult to spot a subtle pattern of bullying when looking at
individual messages, out of context, in the moderation system,
as the moderators do. So it is the hosts who play a vital part
in being across all the various discussions and consequently being
able to identify troublemakers as well as users who are in danger
of being isolated.
We also encourage our audiences to make sure they are open
and honest with their parents or guardians when communicating
online. We reinforce our advice to children with the following
information as part of our media literacy support:
"Make sure a parent, teacher or guardian knows when you're
surfing the net. If you get an e-mail with rude or unpleasant
things, you MUST tell a responsible adult straight away and DON'T
reply to it! Remember that it's not your fault that someone has
sent you this."
9. STRANGER DANGER
By keeping our message boards restricted by age, reverting
to limited text functionality in games where moderation isn't
available and keeping our moderators aware of the latest grooming
techniques, we aim to minimise the potential for grooming online.
However, we believe there are a number of ways we can improve
upon this with greater industry collaboration.
When children sign up to the message boards, they are asked
to provide their correct date of birth. They are not able to change
this at a later date. As there is no accessible national database
we can use to check identity and age against, we are unable to
confirm these ages, but we do all we can to keep the boards safe
and age relevant.
One way we do this is to ensure the communities are very
much aimed at the target age (seven-12) thus putting off older
users, who will find more engaging content and conversation for
their age range in other BBC communities. Our strict rules regarding
the publication of personal information ensure that it would be
extremely difficult for an adult masquerading as a child to access
the personal details of other users on the site. We block any
attempts to swap direct contact information or suggestions to
redirect online conversations to sites with less stringent security
measures and we constantly monitor for other behaviours associated
with online grooming.
In some cases we also add a maximum age for entry, based
on the Single Sign On registration data.
However, in spite of all these measures, the BBC would welcome
a pan-industry initiative to explore the feasibility of developing
an age verification system that could "talk" to a secure
and reliable database containing relevant children's personal
When creating a user account, children are advised to ask
their parents' permission, and make sure that their parents are
aware that they will be using the message boards. The terms of
use also make it clear that children should have a parent or guardian's
permission before using the message boards.
If a child posts a message which suggests that their parents
don't know or don't want them to use our communities, we will
message the user making it clear that they must have parental/guardian
permission to use the message boards.
Some organisations require parental verification by return
email for added security. However, our own user testing suggests
that many children share their parents' email addresses which
would undermine the efficacy of the system, and that a proportion
of our audience only access CBBC through after school clubs, either
because they don't get that support at home or because they don't
have access to the Internet.
Therefore, a tick-box solution or email verification is not
sufficient to acknowledge that an informed parent/guardian/teacher
is actually monitoring the child's activities and doesn't help
children who fall the wrong side of the digital divide.
We would again welcome some pan-industry exploration into
more robust parental consent procedures that are socially inclusive
and not open to abuse.
10. OUR DUTY
Occasionally, we do receive messages from children in distress.
Our team of trained moderators read every message before it is
published. They refer any messages which ask for help, or which
hint at a situation where the child may be at risk, to the CBBC
staff Community Team.
Such situations include: extreme bullying, eating disorders,
self harm, domestic violence, depression, sexual or physical abuse
or potential grooming.
When a child posts a message directly asking for help, or
is troubled, a BBC staff host will post a reply using one of a
list of "distress responses", which cover scenarios
ranging from having an eating disorder to domestic violence.
These responses have been developed with leading children's
charities such as ChildLine and Childnet International and were
revised with the help of trained counsellors. We also work closely
with a children's psychologist and counsellor who gives public
(and, where necessary, private) in-depth help to children who
The host response will typically urge the child to talk to
an adult they know and trust (parent, teacher) and offer them
helplines such as ChildLine,Young Mind, the NSPCC or Samaritans
in case there is nobody they feel they can talk to. If the content
of the message is graphic or particularly distressing, it won't
We also provide a number of direct links for children to
self-report to different agencies. These are also searchable under
the CBBC search system. They include a link to CEOP for children
who may wish to report criminal abuse or grooming direct, rather
than using our single integrated "complain about this post"
We also assess whether the child would appear to be in immediate
danger or serious distress. In the majority of cases, this is
not the case but if a message is more serious, we follow the escalation/referral
procedure described in s 13 below.
BBC Switch also follows a clearly defined escalation policy,
the team pre-moderate all comments before publication and they
refer any worrying ones up. Switch uses "distress response"
emails which are adapted from CBBC ones. Switch also believes
in defining expectations about what level of response a distressed
teen can expect from the team and makes it clear that not every
email can be published. The site offers direct links to dedicated
resources such as Samaritans and ChildLine.
11. MEDIA LITERACY
CBBC has a media literacy section called Stay Safe,
presented by an animated cartoon rabbit called Dongle. Research
has shown that children of primary school age respond very well
to the character. The section includes an interactive quiz, a
"pop video", and links to other resources such as "thinkuknow'"
The material covers online and mobile safety, and the content
is built around the Stay Safe smart rules:
S = Keep Safe
M = Don't Meet Up
A = Accepting emails can be dangerous
R = Reliable? People may not be who they say they are.
T = Tell an adult if you feel scared or uncomfortable
The Stay Safe section is linked to from all the community
pages, and these messages are reinforced by the hosts as they
encourage the right sort of behaviour from users. But it is important
to note that although the SMART rules are widely used and recognised,
several different versions of it are being used across the industry,
which is likely to confuse some children.
12. THE BBC'S
Through audience testing, we have found that the best approach
is to provide one single complaints system, as children seldom
distinguish between criminal abuse, bullying or simple differences
of opinion. Our trained staff then route messages as appropriate
according to our referrals process below.
We are cautious about adding external complaint functions
to this trusted "One-Stop-Shop" system as this may create
more confusion for our audience (for example, which button do
they press?), encourage misuse if directly routed to the police,
or risk overloading police and other agencies with a large number
of queries which their services are not designed or equipped to
deal with. We also tread a careful line between making children
aware of the potential threats of the online world and seeing
to it that younger children aren't overly intimidated by perceived
threats that actually don't relate to the activities they're involved
We need to maintain our reputation as a safe environment
but are aware from audience feedback that too many on-screen caveats
can be off-putting and could potentially drive some users to less
reputable, unregulated sites.
13. OUR INTERNAL
If we do receive a message from a user who requires further
help, the following rapid referral procedure is followed, and
a member of senior management is alerted on a formalised rota
The following are mandatory for instant referral:
if the user says they are going to kill themselves;
if they are reporting sexual abuse (online
or real life) or physical abuse;
if they are going to run away;
if they have been left alone at home, or
if they or a friend are going to meet someone
from the Internet.
Hosts can also escalate any other issue which poses an immediate
danger or which they are unsure how to treat.
The senior manager then decides the next steps, including
whether or not to refer the message to the NSPCC. (The hosts are
able to contact the on-call senior manager at any time when the
boards are open, between 9am and 9pm, seven days a week).
In the meantime, the host will post the appropriate distress
response, or the "seek urgent help" response, as advised
by their senior colleague.
When messages of concern relate to specific suspected criminal
activities or behaviour, they are then referred on immediately
14. COMPUTER GAMES
The BBC's public service activities in this sector are restricted
to games downloaded from the Internet for free; single player
online games and multiplayer games played on the Internet with
others across the UK or internationally. In this paper, we do
not refer to commercial games or franchises based on BBC brand
Our emphasis is on games which fulfill the BBC's public purposes
to encourage creativity, self-expression, social confidence, exploration
and learning. These games may have specific educational value
relating to the curriculum or supporting key developmental themes
according to the different age ranges. We also feel it is increasingly
important that they should reflect the lives of British children
in the global marketplace.
All our audience research and user testing suggest that children
retain more information through direct interaction. For the younger
age group, Cbeebies games can be used to encourage core dexterity
and cognitive functions; on CBBC, role-playing enables them to
ascertain boundaries in the real world. Increased connectivity
can, if given specific purpose and direction, encourage greater
collaboration and awareness of others.
Online communities are often at least partially self policing
and actually encourage social inclusion among those who may feel
disenfranchised in the world of the playground. As well as supporting
logic skills and empirical reasoning, we believe that, contrary
to common perception, games do also encourage language and conversations
skills either in-game or as part of playground chit-chat.
We also recognize specific societal benefits of role playing
gamesencouraging citizenship and establishing relevance
of "reputation" and appropriate behaviours within your
community (eg climate change games or "right vs wrong"
games); as well as economic benefits in the online space with
games such as Bamzooki which are actively encouraging core skills
that are important for the UK knowledge economy.
In addition, we try not to encourage prolonged usagemuch
of our content is aimed at a casual gaming audience which is short
form and episodicand we often flag when kids should take
Evidence is anecdotal, but from our message boards, parents'
perception of risk is very mixed. In our experience, parents are
less proficient and sometimes unnecessarily fearful about the
risks. Feedback from parents also suggests they often divide up
their child's screen-time between TV/ web/ games and that parents
like to send their children to CBBC because it relieves them of
the pressure of checking that all material is appropriate.
For Cbeebies parents, we offer a specific site alerting them
to best ways to use the site as a developmental support.
BBC Switch uses quizzes, short form games and, increasingly,
new narrative formats that provide a distinct approach to casual
gamingmixing high quality audio visual storytelling with
interactive opportunities to solve puzzles, look for clues and
to learn more about yourself.
As a matter of corporate policy, the BBC does not offer "shoot-em
ups" or any games where children or teens can chat in private
through the BBC systems.
15. MOBILE PHONES
The BBC is currently reviewing its editorial position in
relation to mobile services for children but we believe mobiles
to be an important tool for social inclusion in a digital world.
Many families now have no fixed line telephone services at home
and penetration of mobiles amongst our older audience can help
us guarantee universal reach for our digital services.
However, we are acutely aware of the on-going debate about
potential health risks of mobile telephony.
The 2000 Stewart report concluded that mobile phones did
not appear to harm health, but recommended further research was
carried out. In 2005, Sir William added that mobile phone use
by children should be limited as a precautionand that under
eights should not use them at all.
Government guidance stresses that mobile phones should not
be over-used by young children.
We therefore take the view that mobile services around the
Cbeebies brand should be restricted to our Grown-ups service targeted
at providing adult support and that, on CBBC, the emphasis should
be on providing mobile content through other mechanisms (via Bluetooth
or side-loading from our own website) in preference to wireless
This is a precautionary approach and we welcome more detailed
scientific research into potential or perceived health risks.
We also believe we may need to increase our audience awareness
about children not putting themselves unnecessarily at risk from
traffic accidents or street crime based on current national statistics.
Again we would welcome pan-industry research about the best
way to communicate these messages.
16. ADDITIONAL COMMENTS
Online child protection filters
The BBC recognizes that online parental controls and filters
can provide valuable protection for children against harmful and
offensive content. The BBC's own iPlayer system offers PIN protection
for video downloads so that parents can control their children's
online access to challenging content.(See s 4 above)
But there appears to be a significant issue with over-blocking.
This not only limits freedom of expression and restricts older
children's ability to study online. It is also a safety issue.
One operator of online parental controls has reported that over-blocking
was the number one reason why parents turned off their parental
controls. Another has acknowledged that their filter products
sometimes block access to the BBC's own site for children, CBBC.
In order to stimulate a reduction in over-blocking and a
possible increase in use of parental controls, the BBC hopes that
the proposed BSI kite mark standard for online parental controls
will require demonstrably low levels of over-blocking before an
award is made and that reputable children's sites like CBBC will
be an essential part of the testing process.
Self regulation and legislation
The BBC is a long-standing, active and committed member of
the Home Office Task Force on Child Protection on the Internet.
Over the last six years, the Task Force has produced a range
of Good Practice Guidance for example on Chat, IM, web-based services,
Search and Moderation. The guidance relies on the knowledge of
experts from the children's charities, law enforcement, industry,
government, regulators and others. (While the core guidance is
aimed at reducing the risk of illegal behaviour, some areas also
cover harmful and offensive content.)
The BBC greatly values the Government's continuing support
for the Home Office Task Force and the self-regulatory principles
it embodies. In this area of rapid technological development,
where timely and flexible responses are likely to be most effective,
we believe that the voluntary collaborative approach, where service
providers take into account the particular nature of their own
services, has delivered real benefits. This is in part because
the collaborative process itself encourages providers to share
their own methods and practices with each other and with the relevant
group as a whole, which often acts as a stimulus for robust debate,
for self-examination and for improvement before the guidance is
However, we believe that there may be room for more work
on how the Good Practice Guidance is publicised and in the evaluation
of its practical effects.