Memorandum submitted by O2
EXECUTIVE SUMMARY
O2 welcomes the Committee's inquiry. Preventing
children and other customers from harm or inappropriate experiences
when using new media technology is an important public policy
issue. We recognise that if society is to enjoy the full benefits
of new technology, it is crucial that we retain public confidence
about the benefits as well as the safety of new media technology
and related products and services.
The UK mobile operators have a voluntary agreement
not to promote the use of mobile phones by under 16s. Despite
this most secondary school children own mobiles, and ownership
is growing among under 11s.
Our research indicates this is because parents
believe the benefits of their child using a mobile phone out weigh
the downsides, although they still have very real concerns about
children accessing inappropriate content, being contacted by strangers,
or being bullied online or by mobile phones.
O2 works hard to offer parents more control
and children more protection. This includes working with our competitors
on a common approach to protect children and other customers from
the mis-use of mobile phones and the Internet.
In 2004 the UK mobile operators published a
voluntary code of practice to regulate the provision of new forms
of content over mobile phones. It was a world first and has been
widely recognised as a model of best practice. Following the launch
in the UK it has been adopted by mobile operators in a number
of other countries and forms the basis of the EU's new framework
for Safer Mobile Use.
We believe the best way to offer protection
is through partnership with parents. So we either provide technological
safeguards or awareness raising education material to give parents
the tools and knowledge to protect their children.
Self-regulation has proven to be a highly effective
way of protecting customers and maintaining public confidence.
There's more that industry can and will do, but unfortunately
business does not have the ability to solve or address all of
the problems associated with the mis-use of the Internet or mobile
phones.
WHO IS
O2
1. O2 is a leading provider of mobile and
broadband services to consumers and businesses in the UK. These
services include voice calls, text messages, media messages, games,
music and video, as well as always on data connections via GPRS,
3G, ASDL+ and WLAN.
2. O2 has 17.9 million customers in the
UK and is part of Telefonica O2 Europe which comprises mobile
network operators in the UK, Ireland and Slovakia along with integrated
fixed/mobile businesses in Germany and the Czech Republic.
INTRODUCTION
3. We welcome the Committee's inquiry into
harmful content on the Internet and in video games. Mobile phones
and the Internet have changed the way we live and work for the
better, delivering considerable benefits, which vastly outweigh
the problems associated with the mis-use of the technology. In
the UK there are currently more than 70 million mobile phone subscribers,
and O2 customers send more than 1 billion text messages every
month. Research conducted by the Centre for Economic and Business
Research (CEBR)—and commissioned by O2—in 2004 estimated
that the mobile sector contributes 2.3% of GDP, as much as the
total oil and gas extraction industry.
4. As with all forms of technology there
is scope for mis-use. It is, therefore, essential for industry,
Government and its agencies, to maintain public confidence in
the technology by working together to protect the public against
abuse and mis-use.
5. Equally, it is crucial to ensure that
the regulatory and legislative framework strikes the correct balance
between protecting the public and encouraging innovation and investment
in products and services.
PROTECTING CUSTOMERS
IN AN
UNPREDICTABLE WORLD
6. We take our role in protecting the vulnerable
very seriously, but we also respect our customers' rights to make
informed choices about the legal content and services they access
across our network.
7. O2 was the first mobile operator to join
the Internet Watch Foundation and the Home Secretary's Task Force
on Internet Safety. We work hard to give parents more control
and children more protection.
8. Content that is inappropriate for children
includes some commercially produced entertainment, but also misleading
and harmful content published by adults and even other children.
9. Prevention is always better than cure and
so our approach has been to seek to predict and pre-empt problems.
Perhaps the best example of this was the introduction in 2004
by the five UK Mobile Operators of the UK Code of Practice on
New Forms of Content.
10. This self-regulatory code was developed
between 2001 and 2003 (in consultation with the children's charities,
police and Home Office) long before the majority of mobile phones
had colour screens or web browsing capability, and was a world
first. (See para 26 for more on the Code)
11. But part of the appeal and excitement
of new media technology is its versatility and unpredictability.
It is not always possible to anticipate new forms of mis-use.
For example in 2003 we published a series of leaflets including
advice to customers about the appropriate use of camera phones.
This included advice on "think before you send or post photos";
"guarding your privacy"; "Respecting others";
and "what to do about bullying". In 2007, O2 updated
the series to ensure up to date information was provided.
12. The series of leaflets were well received
by a broad cross-section of stakeholders, and yet we did not anticipate
that 18 months later people would be using their phones to take
picture of themselves assaulting other members of the public,
the so-called practice of "happy slapping".
13. This illustrates not only the challenge
of predicting all forms of mis-use but also that mobile operators
do not have the controls or answers to every problem. We can introduce
filtering and age verification to restrict children's access to
adult content, but we are not able to control how our customers
use the cameras on their phones.
CHILDREN AND
MOBILE PHONES
14. In 2000 Professor William Stewart conducted
an independent review for the Government into the health and safety
of mobiles. Stewart found no evidence of adverse health effects
for adults or children from the use of mobile phones. However,
as a precaution Stewart recommended that the mobile operators
should refrain from promoting the use of mobile phones by children.
15. O2 and the other mobile operators accepted
this recommendation. And therefore O2 does not target its advertising
at children. For example we only advertise in magazines where
the majority of the audience is over 16.
16. Despite this more and more children
own mobile phones. The most recent figures show that 50% of 10-year-olds
and 90% of 12-year-olds have mobile phones.[6]
Our view is that this is largely because parents believe the benefits
outweigh the risks. We also believe it is a decision for parents,
and it is right that they should have the choice of whether to
give a phone to their child.
17. A MORI poll commissioned by O2 in January
2006 found that parents believe by three to one that the advantages
of a child owning a mobile outweigh the disadvantages. http://www.ipsos-mori.com/polls/2006/disneyo2.shtml
And many young people see their mobiles as a way of life, important
for staying in touch, helping to ensure safety and security and
for having fun.
18. Of course that does not mean parents do
not have concerns about the mis-use of mobiles. Parents are worried
about bullying by mobile phone; mobile phone crime; access to
inappropriate content such as adult material; excessive spend;
and grooming by paedophiles in chatrooms. And so we work with
parents to make phones safer.
19. We believe the best way to offer protection
is through partnership with parents. So we either provide technological
safeguards or awareness raising education material to give parents
the tools and knowledge to protect their kids. (See paragraph
35)
BENEFITS OF
CHILDREN USING
MOBILE PHONES
20. For many parents the main reasons for
giving a phone to their child is the reassurance that they can
contact each other in the event of a problem. Texting in particular
is an ideal way for parents to keep in touch with their teenage
children without embarrassing them. In the past O2 worked with
the parents of Milly Dowler, the murdered school girl, on a joint
campaign called Teach Your Mum To Text campaign. For more see
http://www.livelifesafe.org.uk/content.asp?PageID=1604
21. Many children use their mobiles to access
help and support about child abuse. More than 80% of calls to
Childline are from mobile phones. And all calls to Childline from
O2 mobiles are free and do not appear on bills to protect the
child's anonymity.
BULLYING
22. Bullying—whether it is malicious
text messages or mis-use of camera phones is an especially unpleasant
and challenging issue. O2 has a dedicated nuisance call bureau
which can take a number of steps to help customers who are receiving
nuisance or malicious calls or texts.
23. This includes offering a change of phone
number free of charge. For many customers this will provide immediate
resolution of the problem but a change of number will not be suitable
or practical for everyone.
24. Other measures are tracing the culprit and
sending a warning by text message; assisting police in prosecutions;
and cutting off O2 customers found to be mis-using their phones.
25. The Nuisance Call Bureau also visit schools
as part of the Prison Me No Way programme to explain how upsetting
text bullying can be and to provide advice on what to do if someone
receives a malicious message.
THE EFFECTIVENESS
OF THE
EXISTING REGULATORY
REGIME
26. Content accessed over mobile phone networks
is regulated by a self-regulatory code, The Code of Practice on
New Forms of Content. The Code of Practice was developed by the
five UK mobile operators in partnership with the children's charities,
police and Home Office.
27. It was a world first when launched in
2004 and has been widely recognised as a model of best practice.
Following the launch in the UK it has been adopted by mobile operators
in a number of other countries and forms the basis of the EU's
new framework for Safer Mobile Use.
The Code covers:
— Classifying commercial content;
— Introducing age verification &
access controls for 18 rated content;
— Introducing Internet parental controls;
— Taking down illegal Internet content;
— Taking action against unsolicited
bulk communications and malicious communications;
— Providing customers with information
and advice.
CONTENT CLASSIFICATION
28. The Independent Mobile Classification
Body (IMCB) http://www.imcb.org.uk was appointed by the UK mobile
phone operators in October 2004 to oversee the self-classification
of new forms of commercial content on mobile phones. IMCB is a
subsidiary company of PhonePayPlus (formerly ICSTIS, the Independent
Committee for the Supervision of Standards of Telephone Information
Services), the regulatory body for all premium rate charged telecommunications
services.
29. In January 2005 it published a classification
framework for content deemed to be suitable to those 18 and over.
Commercial content that is rated as 18 in accordance with the
Classification Framework will be restricted, through age verification
arrangements put in place by each mobile phone operator, to those
customers who are aged 18 or over.
ACCESS CONTROLS
30. O2 does not currently offer any 18 rated
services but we have put parental controls in place to prevent
children under the age of 18 from accessing 18 rated material
sold by third party providers over the O2 network. Customers attempting
to access 18 rated content are required to prove they are over
18 by submitting credit card details. Alternatively customers
can verify their age at their nearest O2 store by presenting a
passport or similar document. The access controls are lifted once
the customer's age has been verified.
INTERNET PARENTAL
CONTROLS
31. Since December 2004 customers have had
the option to turn on internet parental controls, which restrict
access to only a list of permitted sites that O2 believes are
suitable and interesting for children of 13 and under. Customers
can activate the controls by dialling 6 18 18 and then following
the IVR prompts.
BULK COMMUNICATIONS
32. The operators have established a "common
STOP" procedure to enable customers to quickly and easily
cancel subscriptions to premium rate text services. To do this
customers simply need to reply with the word STOP to the originating
short code.
MALICIOUS COMMUNICATIONS
33. O2 has a dedicated Nuisance Call Bureau
to help customers encountering problems with malicious calls or
bullying. (see para 22 for more )
ILLEGAL CONTENT
34. O2 was the first mobile operator to
join the Internet Watch Foundation and works closely with the
IWF and police to report, block access, and take down illegal
sites.
INFORMATION AND
ADVICE
35. Protection requires partnership with
parents. We have a programme of public education, awareness raising
and stakeholder dialogue. O2 has worked with Childnet International
to create a dedicated child protection web site for customers,
point of sale materials and a printed guide for parents. See http://protectourchildren.o2.co.uk/
36. O2 also published Childnet's checklist
for parents, a checklist designed to help parents know which questions
to ask when buying a mobile for a child, and is working with Childnet
to train its front line staff, so they are more able to offer
real, useful, honest, practical advice to parents about their
children's use of mobiles.
37. More than 100 Child Protection Champions
have been trained within O2's customer services department, and
this programme is now rolling out in the retail part of the business.
38. O2 also joined forces with other mobile
operators to create a new dedicated website for teachers, offering
information and advice on how they can best manage issues associated
with the mis-use of mobile phones.
39. O2 has also partnered with Childnet
International and the Personal Finance Education Group (pfeg)
to produce a short film on mobiles and child protection. The film
focuses on the dilemma many parents face, balancing parental preferences
against children's needs. What are the concerns of parents? What
is O2 doing? Where can I get help and advice? You can access the
film: http://www.o2.com/media/film_children_protection.asp
WHAT DOES
THE CODE
NOT COVER
40. A significant development since the
publication of the Code, has been the emergence of social networking
sites such as Facebook, Bebo and Myspace. These services are designed
to be accessible across a variety of platforms—home PC,
mobile or public Internet access points.
41. In order to promote good practice for
the operation of social networking sites, the mobile operators,
alongside, social networking providers, children's charities and
law enforcement agencies,[7]
have collaborated to develop Good Practice Guidelines for social
networking site providers. The Guidelines set down customer protections
that provide consistency across all platforms.
42. Ofcom is currently reviewing the effectiveness
of the industry code. Separately, the mobile operators will be
conducting a consultation exercise later this year on updating
the Code.
THE EFFECTIVENESS
OF THE
CODE
43. As mentioned earlier, the UK Code was
a world first when launched in 2004 and has been widely recognised
as a model of best practice. Ofcom itself is currently reviewing
the effectiveness of the industry Code and we very much welcome
this initiative. Separately, the mobile operators will conduct
a consultation exercise later this year on updating the Code.
CHATROOMS
44. O2 moderates the public chat forums
that it operates. When apparently dangerous situations, such as
grooming, are identified by moderators, they can act to block
user accounts and report the incident to O2's specialist team
at its Nuisance Call Bureau. O2's Nuisance Call Bureau has close
links with the police.
45. O2 Nuisance Call Bureau has established
a process of providing information including reports of grooming,
contact offences and distribution of indecent images to the Child
Exploitation and Online Protection Centre (CEOP). In the quarter
to September 2007 O2's contribution accounting for 2.7% of total
reports received by CEOP.
January 2008
6 Carphone Warehouse Mobile Youth Report, 2006. Back
7
Under the auspices of the Home Office Task Force for child protection
on the Internet. Back
| 
