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.
SUMMARY
— 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.
INTRODUCTION
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.
Self-regulation
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.
Internet
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.
Bullying
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.
Conclusion
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
http://www.mobilebroadbandgroup.com/content-code.pdf Back
3
www.teachernet.gov.uk/wholeschool/behaviour/tacklingbullying Back
4
www.t-mobile.co.uk/adviceforparents Back
5
Ofcom Communications Market 2007, p. 29-30. Back
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