Memorandum submitted by the Internet Watch
Foundation (IWF)
ABOUT THE
INTERNET WATCH
FOUNDATION (IWF)
1. IWF was formed in 1996 and became a registered
charity in 2005 with the following company objects:
— The promotion of the care and protection
of the health and welfare of the public, in particular children
and young people, by working to minimise the availability of potentially
illegal or otherwise harmful content on the Internet.
— The prevention of crimes relating
to offences involving exposure to illegal content on the Internet
in particular by:
— operating a hotline enabling the
public to report such instances;
— operating a notice and takedown service
to alert hosting service providers of such criminal content found
on their servers; and
— alerting relevant law enforcement
agencies to the content.
— To further such purposes as are recognised
as exclusively charitable under the law of England and Wales.
2. We are a self-regulatory body, funded
by the EU and the wider online industry. This includes internet
service providers (ISPs), mobile operators and manufacturers,
content service providers, telecommunications and filtering companies,
search providers and the financial sector as well as blue-chip
and other organisations who support us for corporate social responsibility
reasons.
3. The IWF is the only recognised organisation
in the UK operating an internet "Hotline" for the public
and IT professionals to report their exposure to potentially illegal
content online.
4. The Board of IWF has approved a remit
which aims to minimise the availability of potentially illegal
internet content, specifically:
— child sexual abuse images hosted
anywhere in the world;
— criminally obscene content hosted
in the UK; and
— incitement to racial hatred content
hosted in the UK.
5. We work in partnership with UK Government
departments including the Home Office, the Ministry of Justice
and the Department for Business, Enterprise and Regulatory Reform
to influence initiatives and programmes developed to combat online
abuse. This dialogue goes beyond the UK and Europe to ensure greater
awareness of global issues and responsibilities.
6. Through the "Hotline" reporting
system, we help ISPs to combat abuse of their services through
a "notice and take-down" service by alerting them to
any potentially illegal content, within our remit, on their systems
and inviting the police to investigate the publisher. As a result,
less than 1% of potentially illegal content has apparently been
hosted in the UK since 2003, down from 18% in 1997.
7. In partnership with many organisations,
we strive to create continued awareness of the role and purpose
of the IWF and aim to foster trust and reassurance in the internet
for current and future users.
HARMFUL CONTENT
ON THE
INTERNET
8. IWF has responded only to internet issues
associated with content hosted online.
9. We believe the issues that we raised
in our response to the Byron Review remain relevant to the Select
Committee's terms of reference and the IWF response to the Byron
questions is attached at appendix 1.
10. In appendix 1 we refer specifically
to:
— User-generated content in appendix
1, paragraphs 33 to 36.
— Personal data and social networking
sites in appendix 1, paragraphs 33 to 36.
— Incitement to racial hatred in appendix
1, paragraph 15.
11. We have achieved remarkable internationally
recognised success. Since 2003 less than 1% of reports of online
child sexual abuse content, which have been processed by the IWF,
have been traced to content hosted in the UK. This is down from
18% in 1997.
12. Working in partnership with the online
industry, government, police and the public, we are recognised
as an exemplary and highly effective model of self-regulation
around the world. Our positive and effective links with the wider
online industry and the inclusive nature of our work with diverse
stakeholders and partners have all contributed to this success.
Our partnership model is explained more fully at appendix 2.
13. With regard to Extreme Pornography,
in December 2005 IWF made the following points as part of its
response to the government's proposals to criminalise the possession
of extreme pornographic images:
— The IWF has not identified any criminally
obscene content that might fail the Obscene Publications Act threshold
hosted on UK servers in the last two years. Our current remit
with regard to obscenity is restricted to UK hosted content only.
— It is almost impossible to estimate
how this statistic might change with the introduction of a possession
offence because it seems that little attention has hitherto been
given to content published in the UK that appears to have no underlying
commercial motive.
— Most criminally obscene reports (not
child abuse content) that we process relate to content hosted
abroad but 12% of all those content allegations would fail the
current UK test of criminally obscene if hosted in the UK and
would fail the simple "possession" offence proposed.
— There are no reciprocal arrangements
with any other country to exchange information on criminally obscene
content.
— There is no UK national police unit
currently dealing with obscenity issues.
— A search on the internet using the
word "bestiality" and with filters turned off returns
thousands of hits; the top one is a website of humans engaged
in sex acts with animals which is hosted in Denmark. A similar
search for images with filters turned off returns hundreds of
pictures depicting bestiality.
14. In 2007, IWF received around 36,000
reports of online content which reporters judged to be within
our remit. There were 75,000 visitors to the IWF online reporting
page and a further 30,000 visits to our FAQs. On a daily basis
we receive telephone calls from the public about content which
has caused concern. These figures indicate that there is public
concern about content outside IWF's remit.
APPENDIX 1
IWF RESPONSES TO THE BYRON REVIEW
UNDERSTANDING THE
POTENTIAL RISKS
What are the potential and actual risks to children
and young people who use the internet and how should the Review
approach defining and measuring those risks?
15. It is evident from our work that there
is a huge number of web site "landing pages"[38]
and web pages from around the world which are accessible to the
UK consumer and host content which may be considered potentially
illegal, harmful or inappropriate for children. Within our remit,
such content may include:
— Potentially illegal child sexual
abuse content—In 2007, IWF processed 35,656 reports of which
9,053 URLs were confirmed to contain child sexual abuse content
and would have failed the UK legal definition had the content
been found on a defendant's electronic device.[39]
— UK hosted R18 adult pornographic
content, accessible to all users (including children) and on landing
pages without access controls such as age verification systems
or credit card requirements, which could be interpreted as potentially
illegal under the Obscene Publications Act (as likely to deprave
a child seeing the content).
— Potentially illegal content likely
to incite racial hatred—In 2007, IWF processed 847 such
reports and assessed 203 of these to be content likely to incite
racial hatred. However, only one report identified content which
could be traced to a UK host and could therefore be forwarded
to the appropriate UK authorities.[40]
16. A web search using unambiguous and explicitly
adult terms and with search filters switched off,[41]
returned 10,100,000 web pages. In this particular test, all of
the links on the first three pages of the search linked directly
to content which might be considered as potentially illegal under
UK law if hosted in the UK and almost certainly could be construed
as inappropriate for children to view. If the links are accessed
without a "pop up blocker" on the web browser, then
a number of sexually explicit images also appear as "pop
ups". The same search query with filters on returned 1,660,000
web pages; mostly online discussions or news items and no direct
links to sexually explicit content were found. Searching for images
without filters applied and using a common term such as "teen",
returns a number of sexually explicit images which are not potentially
illegal child sexual abuse images but are likely to be considered
inappropriate content for children. The images are hosted on web
pages which are accessible to anyone without any search filters
or access controls. Repeating the search with filters on returned
no sexually explicit images or inappropriate content for children
within the sample viewed.
17. In November 2005, the Home Office Task
Force on Child Protection on the Internet published the "Good
Practice guide for search providers and advice to the public on
how to search safely". The guidance and advice contained
in the publication can help protect young people.
18. In June 2007, IWF responded to a government
consultation on criminalising possession of non-photographic visual
depictions of child sexual abuse. In order to estimate the volume
of such content, a search of the web on various "cartoon
fantasy" terms known to refer to pre-pubescent children was
carried out. The search returned a total 68,600 web pages and
a sample indicated that the percentage of the search results,
which contained child sexual abuse depictions assessed to be at
level 3 or above, was 7.5%. Such content is likely to be considered
potentially harmful or inappropriate for children. None of the
content appeared to be hosted in the UK but would be available
to UK consumers.
19. IWF also receives reports about "mutilation"
sites which depict extreme violence or bodily mutilation of people
or animals and are particularly graphic. The web sites are rarely,
if ever, hosted in the UK, but are available to UK consumers and
may be considered inappropriate content for children to view.
20. IWF research suggests that as many as
one in 20 UK adult internet users (or 1.5 million people) stumble
across child sexual abuse content on the internet. Furthermore,
our research would suggest that those seeking legal online adult
pornography are almost twice as likely to stumble across indecent
images of children. Whilst this cannot add specifically to an
understanding of young people's online behaviour, it can inform
understanding of how illegal online content may be inadvertently
accessed. The UK industry has agreed to reduce instances of "stumbling
across" child sexual abuse content by blocking third party
websites which have been reviewed by the IWF and found to be containing
child sexual abuse images.[42]
The IWF and the UK have been seen as a great success in promoting
self-regulation around child sexual abuse images.
What do a) children and young people and b) parents
already know about the potential and actual risks of using the
internet?
21. IWF industry members, many of the UK's
major online brands, joined forces in their efforts to raise awareness
of our organisation and the first IWF Awareness Day, held in October
2007, was a culmination of such efforts.
22. Our industry members and stakeholders
provided fantastic support of the Awareness Day by running adverts
on their websites and intranets and other communications channels,
and by emailing their customers and staff with information about
our work. The aim of the day was to reach out to the UK's vast
online population to raise awareness of our "Hotline"
and let them know that the IWF is dedicated to getting potentially
illegal online content removed.
The media coverage we received for the day was
very impressive with almost 300 articles, including 70 radio and
TV broadcast features—regional, national and international.
We were particularly pleased with the positive messaging around
the industry's responsible approach and IWF support and the UK
success. Our website statistics show we had a 320% increase in
visitors on Awareness Day and the day after and a comparison of
the same two day period with the previous month shows a 67% increase
in reports to the Hotline about child sexual abuse content online.
HELPING CHILDREN,
YOUNG PEOPLE
AND PARENTS
MANAGE RISKS
What are the range of mechanisms that exist to
help children, young people and parents manage the potential or
actual risks of engaging with the internet?
23. IWF operates a self-regulatory partnership
with the UK online industry, government departments, law enforcement
agencies and the public, whilst ensuring effective consultation
and coordination with wider stakeholders. The success of this
approach is clear, particularly that of ensuring UK networks are
some of the most hostile spaces in the world to the hosting of
potentially illegal online content within our remit. Confirmed
reports of child sexual abuse content apparently hosted in the
UK has reduced from 18% in 1997 to less than 1% since 2003. On
the rare occasion it is hosted in the UK, the quick and effective
partnership with the online industry means it is removed within
hours. A more detailed description of the IWF model is shown at
appendix 2.
24. In addition, many UK internet access
providers, and all major search engines, licence the IWF's list
of child sexual abuse URLs hosted outside the UK and block users'
access to this content.[43]
This helps prevent users of all ages inadvertently stumbling upon
such criminal content online.
Are children, young people and parents aware of
the tools available and to what extent do they use them?
25. IWF has found that there is a low level
of consumer awareness about potentially illegal online content
issues within our remit and the processes and mechanisms for dealing
with or reporting such content. Although IWF was formed in 1996,
consumer awareness of us and our role remained low for many years—1%
awareness in 2005—and only recently, following investment
in awareness raising campaigns, do we believe public awareness
of IWF has increased to around 19%.
26. IWF awareness work to increase the visibility
of the IWF "Hotline" around the UK as well as raise
the profile of our successful model around the world is ongoing.
We consistently target law enforcement agencies, IT professionals,
parliamentarians and policymakers as well as child protection
workers, teachers and other relevant professionals. This year
we completed a campaign aimed at men, particularly young men,
following research into their online habits. Crucially, our industry
members, many of the UK's major online brands, joined forces in
their efforts to raise awareness of our organisation and the first
IWF Awareness Day, held in October 2007, was a culmination of
such efforts.
27. Our industry members and stakeholders
provided fantastic support of the Awareness Day by running adverts
on their websites and intranets and other communications channels,
and by emailing their customers and staff with information about
our work. The aim of the day was to reach out to the UK's vast
online population to raise awareness of our "Hotline"
and let them know that the IWF is dedicated to getting potentially
illegal online content removed.
28. The media coverage we received for the
day was very impressive with almost 300 articles, including 70
radio and TV broadcast features—regional, national and international.
We were particularly pleased with the positive messaging around
the industry's responsible approach and IWF support and the UK
success. Our website statistics show we had a 320% increase in
visitors on Awareness Day and the day after and a comparison of
the same two day period with the previous month shows a 67% increase
in reports to the Hotline about child sexual abuse content online.
29. It is important that all adult internet
users are aware of our "Hotline" reporting mechanism
and know what to do if they stumble across online illegal content
so that we can continue our work getting this content removed.
It is also necessary in order to foster trust and reassurance
in the internet, that UK consumers are aware of the actions, support
and funding from a mature and responsible UK online industry.
30. The IWF has also published a list of
providers who have committed to using the IWF's URL list to block
users' access to known child sexual abuse images hosted outside
the UK. This can help concerned consumers make an informed choice.
What opportunities exist for children, young people
and parents to learn about safe, responsible and fulfilling internet
use—and do they help?
31. IWF has invited child protection professionals,
police, teachers, policy makers and other interested professionals
to various awareness raising events and sign-posts interested
parties to similar events and sources of important information,
such as CEOP.
GENERAL
What impact will new ways of accessing media have
on the questions being considered in this review?
Mobile
32. In Japan there is more access to the
internet via mobile technologies than from fixed access points.
There is every reason to think that this trend will apply to the
UK as more and more portable electronic devices come on stream.
Therefore the old adage that a single family computer should be
placed in a family room for parents and carers to supervise their
children's use of the internet is being overtaken by smaller and
portable devices being used by many young people.
Social networking services
33. IWF are aware of concerns about user-generated
content of under-18s posting provocative and indecent images of
themselves, which may constitute child sexual abuse content, and
place them at risk of inappropriate contact from adults (through
their online profile and image which becomes widely available
to the internet community). Currently the IWF has received few
reports about user-generated content of this type but there is
concern that this may change if young users take risks with the
types of images they post.
34. At this stage we are unable to quantify
the extent of the issue or the risk to children and young people.
We have received just over 150 reports since social networking
sites started to become popular in 2005. No potentially illegal
content has been found although we have passed on six Police Intelligence
reports (usually where profiles were requesting meetings with
children or looking to exchange potentially illegal images).
Photo sharing services
35. Around 18 months ago, we noted a growth
in the number of reports about potentially illegal child sexual
abuse content being hosted in photo-sharing sites including some
which support social networking services. Recently, in the larger
companies, abuse of these sites has reduced significantly, probably
due to improvements in security and abuse management. However
new photo-sharing sites are constantly appearing and newer companies,
unaware of the risks, have their services abused by the posting
of potentially illegal content. When the content is reported to
the IWF and assessed to be potentially illegal child sexual abuse
which is hosted outside the UK, it will be added the URL list
and blocked to UK consumers.
Personal data
36. It is important for parents and carers
to understand that the presence of online personal information
about children and their pictures can result in unrestricted availability
and place them at risk. Images can be used and altered to produce
potentially offensive, inappropriate, abusive or illegal pseudo-images.
The popularity of social networking sites amongst
young people, and Web 2.0 developments and virtual world websites,
present new challenges for parents and carers to keep up with
the pace of technological change. The developments present new
challenges with regard to potentially illegal and inappropriate
online content which may put children at risk.
APPENDIX 2
THE IWF MODEL
37. The Internet Watch Foundation (IWF)
was established in 1996 following agreement between Government,
police and the internet industry that a self-regulatory approach
was necessary to combat the growing problem of child sexual abuse
content on the internet. The IWF is funded by the UK online industry
and receives a grant from the EU Safer Internet Plan. The IWF
now operates the only recognised non statutory UK internet "Hotline"
for the public to report their exposure to online child sexual
abuse content hosted anywhere in the world and criminally obscene
and incitement to racial hatred content hosted in the UK. Working
in partnership with the online industry, Government, police and
the public, we are recognised as an exemplary and highly effective
model of self-regulation around the world. As a result of our
positive and effective links with the wider online industry and
the inclusive nature of our work with diverse stakeholders with
different philosophies, we have achieved remarkable, internationally
recognised success, not least, that less than 1% of online child
sexual abuse content reports processed has resulted in traces
to content hosted in the UK since 2003, down from 18% in 1997.
38. In order to fulfil our role and remit
we deploy a range of approaches and offer various services to
our members, these include: the Hotline reporting service, notice
and takedown, a code of practice for members, Usenet newsgroup
policies, the provision of keywords, a child abuse spam alert
service and blocking. To facilitate blocking the IWF produces
a list of URLs containing potentially illegal child sexual abuse
content hosted overseas and this unique list is made available
to IWF members under licence so that they can develop technical
solutions to prevent their users from being inadvertently exposed
to this type of content.
39. Our industry members have grown from
9 in 1999 to nearly 80 in 2007. We were a founding member of INHOPE,
the association of Hotlines around the world, and we make a significant
contribution to the Home Secretary's Task Force on the Protection
of Children on the Internet. Importantly, we are consistently
referenced as a national and international model of effective
self- and co-regulation and are commited to sharing our best practice
around the world.
40. The IWF is recognised as an influential
and relevant authority by many sectors, from commercial and media
to charities and policymakers. We maintain the high standard we
have set in this country as we raise awareness of our work and
focus global attention on those challenges still to be addressed;
particularly those issues requiring an international approach
which transcend country borders, to which we can add expertise.
41. Our governance structures are based
on consultation; with the online industry and with key stakeholders,
ensuring our response to new challenges in the constantly evolving
field of online criminal content within our remit is responsible,
informed, effective and widely supported. Our industry members
have put aside market-place rivalry in their united support of
our important work and aims.
42. We work to foster trust and confidence
in the internet for current and future users, working to ensure
they are aware of our "Hotline" reporting mechanism
and that there is a body combating potentially illegal online
content. The online industry is acting responsibly by funding
our work, supporting our aims and volunteering to block their
customers access to child sexual abuse content hosted outside
the UK.
January 2008
38 A landing page is the web page on which a visitor
arrives after clicking on a link or advertisement. Back
39
The figures have been updated since the submission to the Byron
Review to include the latest 2007 information. Back
40
The figures have been updated since the submission to the Byron
Review to include the latest 2007 information. Back
41
Some search services will have filtering defaults set to "moderate"
which filters out explicitly adult results. Users may choose to
switch off the filter altogether or choose a higher setting. With
some search companies parents can also opt to lock safe search
to "on" for a particular computer so that no-one in
the household using that computer can change the settings. Back
42
See http://www.iwf.org.uk/public/page.148.htm Back
43
See http://www.iwf.org.uk/public/page.148.438.htm Back
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