Select Committee on Culture, Media and Sport Minutes of Evidence

Memorandum submitted by O2


  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.


  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.


  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.


  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.


  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. 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)


  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

  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.


  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.


  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.


  28.  The Independent Mobile Classification Body (IMCB) 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.


  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.


  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.


  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.


  33.  O2 has a dedicated Nuisance Call Bureau to help customers encountering problems with malicious calls or bullying. (see para 22 for more )


  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.


  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

  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:


  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.


  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.


  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

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