Select Committee on Culture, Media and Sport Minutes of Evidence

Memorandum submitted by T-Mobile UK

  T-Mobile UK welcomes the opportunity to respond to the Committee's inquiry, "Harmful content on the Internet and in video games."

  T-Mobile is one of the world's largest mobile communications companies with more than 112 million customers worldwide and in the UK it is the network of choice for over 17 million customers. T-Mobile was the first company to offer access to the open mobile internet when Web "n" Walk was launched in 2005.

  T-Mobile UK is the UK mobile network of T-Mobile International which is a wholly owned subsidiary of Deutsche Telekom AG.


    —  As the technology capability of mobile moves beyond voice and text consumers can access a rich variety of content including mobile internet browsing, mobile games, mobile TV, music downloads, and increasingly user generated content.

    —  Social networking and interactive sites are at the forefront of driving mobile internet usage. Consumers value the ability to generate their own content and update their personal social networks wherever and whenever they choose.

    —  Ensuring appropriate child and consumer protection measures are in place for accessing such services is a priority for T-Mobile. As content services develop T-Mobile is committed to ensuring child safety protection and risks are carefully considered as part of new product development or partnerships.

    —  T-Mobile has worked to develop a number of robust self-regulatory initiatives to ensure best practice for customer protection. The Code of Practice for Self-regulation of New Forms of Content on Mobiles protects children from inappropriate content and ensures parents have access to information to educate their children on how to use mobile devices responsibly.

    —  T-Mobile's Content Lock solution only allows access to 18 rated content to customers who prove they are over 18 irrespective of whether the content is accessed via own portal services, the mobile internet or mobile short codes.

    —  The proper harnessing of technology increases the standards of customer protection, responsible access to internet services, and robust action against offenders. However technical solutions can only provide part of the solution. There is a shared responsibility with other stakeholders, including parents, to develop children's ability to use new services responsibly and safely thereby mitigating potential risks.

    —  Consumer protection measures should be evidence based, proportionate and targeted at those areas of most risk.


  1. Three social trends are having a sustained impact on the telecommunications market: mobile technology offers customers new information, communication and entertainment products; changing patterns of how people use communications technology for maintaining contacts; and the growth in forums and platforms for self-expression.

  2. The combination of highly advanced mobile devices and growing UK wide access to faster mobile broadband speeds is enabling customers to access to a rich variety of content including mobile internet browsing, mobile TV, music downloads, and increasingly user generated content.[1]

  3. The growing personalisation of digital technology, usage and applications is allowing customers to determine the type of content they access, when and how they access it and enabling the user to generate their own content.

  4. As mobile technology offers customers new services T-Mobile recognises that parents and carers may have concerns about children coming into contact with unsuitable communication and content. Ensuring appropriate safeguards are in place for children accessing our services is a top priority. Moreover we are committed to ensuring that safety features are included in new services.


  5. The development of new content services poses challenges for content standards regulation. With increased choice of content and consumption options, new standards and approaches to the protection of the consumer are being introduced. Providers are applying voluntary content protection measures and consumers are using available information and tools, taking greater responsibility for protecting themselves and their children from accessing inappropriate content will be more effective.

  6. T-Mobile is setting new standards in probity in the access to new information and content. T-Mobile has been closely involved in developing a number of self-regulatory initiatives to ensure best practice for customer protection including the Code of Practice for Self-regulation of New Forms of Content on Mobiles ("Content Code").[2] It is also a signatory to the European Commission's Framework on Child Safety. T-Mobile is a member of the Home Office Taskforce for Child Protection on the Internet, the Cyberbullying Taskforce and the Internet Watch Foundation.

  7. Technology makes possible a range of safety features and customer verification measures. This aids the integrity of accessing such content services and is a demonstration of providing a safer and more transparent environment for our customers. Such self-regulation offers a number of benefits in meeting public policy objectives for consumer protection through implementation of appropriate and proportionate measures. The benefits of self-regulation include gaining industry buy-in, being quicker to agree and implement than formal regulation, and offering greater flexibility and responsiveness to market changes.


  8. T-Mobile pioneered open mobile internet access with the launch of our Web "n" Walk service in November 2005. Unlike a walled garden approach, T-Mobile customers are able to gain unlimited access to the whole internet via a mobile device. This strategic decision to enable a true internet experience reflects customer insights that show very low acceptance of limited access.

  9. Over 1 million customers are actively using Web "n" Walk services in the UK and the trend in most popular websites has shifted dramatically in the last 12 months. Analysis of our traffic data shows that eight of the twenty most visited sites from T-Mobile devices are social networking sites.

Protection from potentially harmful content

  10. In anticipation of the widespread availability and take up of new content by consumers, including under 18s, T-Mobile was a driving force in developing the Content Code. The Code protects children from inappropriate content and contact and ensures parents have access to information to show their children how to use mobile devices responsibly. The Mobile Broadband Group submission provides more detail on the provisions of the Code.

  11. T-Mobile has developed a system called Content Lock which helps protect children from inappropriate material. Content Lock places 18-rated content behind age verified access controls preventing access to inappropriate internet content or commercial content including gambling, open chatrooms, and games. Customers trying to access a website or a service on the internet via their mobile phone which is 18-rated will see a message that it is blocked.

  12. Content is classified as "18-rated" or "unclassified" against a framework developed by the Independent Mobile Classification Body (IMCB). This classification framework is based on existing standards in other media such as films.

  13. Content Lock incorporates an internet filter using Surfcontrol categories. These are matched against the IMCB framework to ensure a consistent customer experience. Customers expect the same level of protection from content regardless of how it is delivered.

  14. Content Lock is one of the industry's most advanced filtering tools and provides a safe and secure solution which is easy for parents to understand. T-Mobile applies Content Lock by default to all our accounts (pre and post pay) to provide maximum protection. Customers wanting to remove Content Lock have to prove they are over 18. To date a majority of active data customers have not lifted Content Lock.

Effectiveness of Content Code

  15. T-Mobile's experience is that the Content Code has led to the implementation of appropriate and proportionate measures which have been successful in restricting the viewing of inappropriate content by children and ensuring only adults access 18 rated content. In three years there have been no official complaints upheld by the IMCB; the classification framework is well understood by mobile content providers, aggregators and operators; and obligations to meet the requirements of the Code are contained in all service contracts. This has been achieved at a reasonable cost.

  16. Ofcom has announced its intention to review the operation of Content Code. T-Mobile, and the other signatories, will contribute to that review.

User Generated Content

  17. The growing popularity of social networking and interactive sites is driving mobile internet usage. Consumers value the ability to generate their own content and update their personal social networks wherever and whenever they choose.

  18. Social networking and interactive services can provide users with tremendous benefits. However, T-Mobile recognises concerns over potential access to inappropriate content, bullying and grooming. New interactive services, such as video sharing sites, pose particular challenges due to the number of postings and subscribers.

  19. Nonetheless, in developing such new services T-Mobile is committed to ensuring that adequate safeguards are in place. Customers expect companies to adopt a responsible approach to allowing access to such sites.

  20. To enhance the safety of children and young people T-Mobile has been involved in producing the Good Practice Guidance for the Providers of Social Networking Sites and User Interactive Services through the Home Office Taskforce. These are expected to be published shortly and make recommendations for good practice on key issues such as safety information awareness, editorial responsibility, registration, user profiles and controls, search, and reporting abuse.

  21. T-Mobile applies rigorous content protection safeguards for customers accessing interactive sites hosted on its own portal T-Zones:

    (a)  In November 2007 T-Mobile launched My Social Sites which provides access to four social networking sites. To provide a secure environment it has risk based safety features including: moderation of all uploaded images (within two hours); alarms and blocks on key words; no profiles with specific locations; a report abuse button on every content screen and the ability to block or restrict access to offending material.

        However T-Mobile can only control mobile uploads to these sites. The majority of uploads will be from fixed PC users but only social networking providers can implement these controls.

    (b)  All other interactive services on T-Zones, such as BeOn TV where customers upload video clips are fully moderated. All chatrooms and blogs in T-Zones are fully moderated. This results in very low levels of complaints. Sites not fully moderated are placed behind Content Lock and therefore only accessible to over 18s.

  22.  Where T-Mobile is contracting with providers to provide access its ability to influence applicable standards is restricted to that of commercial negotiation. As a minimum standard it requires that all social networking providers should meet the Home Office guidance.

  23.  However, although providers may be signatories to best practice guidance in practice it is often difficult to negotiate safeguards in a contract or to fully understand what safeguards are operational or even to include a specific notice and takedown provision.

  24.  If providers meet T-Mobile's higher child safety standards and moderate content themselves (or use an aggregator) it would directly connect to them. If providers do not meet these criteria their services will be placed behind Content Lock and only be available to over 18s.


  25.  T-Mobile takes the protection of its customers very seriously and recognises that new technology offers the potential for misuse. Receiving malicious calls or unpleasant texts or pictures can be very distressing. "Happy slapping" where videos and footage of physical assaults or distressing events are illegally distributed has attracted significant attention.

  26.  Whilst "cyber-bullying" is a form of bullying which schools will be largely equipped to deal with through existing anti-bullying policies it poses particular challenges. T-Mobile believes there is no easy technological solution to what is fundamentally a behavioural issue. Rather young people need to be educated how to use technology safely and responsibly. To provide information and advice to teachers and parents T-Mobile contributed to the DCSF Cyberbullying guidance.[3] It also supported an accompanying promotional campaign aimed at challenging young people's views about bullying. T-Mobile is supporting the European Schoolnet project to develop a hub of information for teachers and providers.

  27.  Where bullying does take place we provide practical advice such as not replying to unwanted messages, not deleting messages as this can help track an offender, and suggesting parents involving the school. If the bullying is serious or involves offensive content, then we ask customers to refer such complaints to the police for investigation, so that the most appropriate action can be taken. If bullying does not stop then the most immediate help T-Mobile can offer is to change a phone number.

Shared responsibility

  28. There is a shared responsibility for interested stakeholders, including parents, to develop children's media literacy to understand the potential risks associated with new services and how to behave responsibly. Technical safeguards can only provide part of the solution.

  29.  In June 2007 T-Mobile launched a dedicated website covering the issue of mobile safety for children, with input and advice from the NSPCC.[4] It provides advice for parents on the safeguards T-Mobile has and offers advice to help educate children on the potential risks and how to mitigate them. Areas covered range from protecting children from inappropriate content to dealing with bullying.

  30. To achieve the most effective management of potential risks requires a twin approach of industry implementing consumer protection measures and consumers taking on more responsibility for protecting themselves and their children from inappropriate content.

  31. T-Mobile has been involved with the Broadband Stakeholder Group initiative to develop a common set of principles for providers who are committed to promoting and enabling media literacy. By offering content information users are empowered to make informed choices about the content that they and their families access/consume/watch.

Illegal Content

  32.  T-Mobile recognises the need for effective partnerships in delivering child protection. It has developed very constructive working relationships with relevant law enforcement agencies to provide appropriate assistance in the reporting and tackling of illegal activity.

  33.  T-Mobile is a long-standing member of the Internet Watch Foundation (IWF). The IWF remit covers illegal content including child abuse images, criminally obscene content and incitement to racial hatred content. It operates a hotline for the public to report such content. T-Mobile blocks access to sites listed in the IWF database as containing illegal content. This applies regardless of whether Content Lock is enabled or not.

  34.  The IWF is an excellent example of an effective self-regulatory model which has resulted in the percentage of online child abuse content apparently hosted in the UK falling from 18% in 1997 to less than 1% in 2003.

Video games

  35.  Mobile gaming is a small but growing market providing clear benefits to users—in addition to entertainment—including developing educational, language, and problem solving skills. Unlike consoles, where the more popular titles tend to be complex real-time action games, research shows that mobile gamers tend to play arcade puzzle and strategy games.[5]

  36. To protect customers games purchased via a mobile phone are covered by the Mobile Content Code. Any game that contains 18 content is placed behind Content Lock. Mobile operators also provide warnings of game content.

  37. Mobile games generally contain lower levels of violence than console games. This is because the smaller screen size means that graphics are more limited and the games providers do not want to restrict their games to over 18 audiences.

  38. With respect to location based gaming, the mobile operators published a Code of Practice for Passive Location Services (where one person can find the mobile device of another using GSM network supplied data) in September 2005. The Code forms part of the commercial terms and the location feed can be turned off if the service provider does not follow the Code.


  39.  T-Mobile has adopted best practice to maximise consumer protection, to protect young people, and ensure confidence for all consumers accessing new online content services.

  40.  Policy applied to how customers access online services should address public concern that the service being sought adheres to standards that provide suitable customer protection and probity in the service.

  41. In particular, T-Mobile recommends the following steps would help address public concern and provide greater child protection from inappropriate content:

  42. A risk based approach should be adopted by all providers—whilst pre-moderation of all content is not achievable it is possible for social networking providers to undertake risk based moderation of some content. Such moderation should be targeted at areas of most potential harm including for example, profiles and pictures, specific takedown timescales which currently vary greatly, blocking facilities and trigger words. Our experience shows that this requires resource but can be achieved without negative operational impact.

  43. Sign up to and implement Home Office guidance—all social networking site providers should implement the Home Office guidance, referred to above, including that default settings for under 18s profiles are private and non-searchable. Providers should ensure a consistent approach to protection with mobile applications including the same level of safety as applications for fixed access.

  44. Achieve a step change in consumer literacy—in combination with customer protection measures concern about potential harm can be addressed through improving parental understanding to enable them to communicate with their children on how to use the Internet and by educating children how to use technology responsibly and safely. Educational initiatives on online safety should reflect that the age at which children use mobile devices is becoming younger. All stakeholders—government, regulators, industry, schools, charities etc.—have a role to play.

January 2008

1   T-Mobile's mobile broadband network offers speeds of up to 1.8 Mbps. Back

2 Back

3 Back

4 Back

5   Ofcom Communications Market 2007, p. 29-30. Back

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