Memorandum submitted by Orange UK
1.1 Orange welcomes the House of Commons
Culture, Media & Sport Select Committee's inquiry into Harmful
content on the Internet and in video games. We are happy to provide
any assistance or further information to the Committee in its
inquiry, including oral evidence.
1.2 Despite the recent political and media
attention on this particular issue, it is important to point out
that this is not a new issue. For many years now Orange has been
working closely with the Government, law enforcement agencies,
children's charities and the rest of the mobile and Internet industry
examining issues relating to new technology and the protection
of consumers, in particular children. Orange is a member of the
Internet Watch Foundation (IWF), the Home Office Taskforce on
the Protection of Children on the Internet (HOTF) and the Department
for Children, Schools and Families' Cyberbullying Taskforce.
1.3 Orange is a key brand of the France
Telecom Group, providing mobile, broadband, fixed, business and
entertainment services across Europe. It is one of the world's
leading telecommunications operators with more than 168 million
customers on five continents. In June 2006, Orange merged with
Wanadoo, a leading Internet Service Provider (ISP) and now, under
a single brand, offers mobile, broadband and multi-play offers,
including digital television and home phone services.
2.1 Orange believes the industry's self-regulatory
approach in protecting consumers in this area has been a success.
We therefore advocate continuing with this approach to improve
consumer protection measures without stifling innovation and investment
in new services.
2.2 Orange offers a wide range of technical
safeguards to its Internet and mobile customers, including a free
privacy service with parental controls for Internet customers
and a "safeguard" filter for mobile customers, based
upon the Independent Mobile Classification Board's system, which
prevents access to inappropriate commercial and wider Internet
content for those under the age of 18 years. We also offer users
of our Internet search service a "safe search" function
to control results.
2.3 Orange operates a "notice and take
down" procedure for reported inappropriate content on our
web portal and provides clear links from various services to enable
users to report abuse of any sort.
2.4 Orange uses the Internet Watch Foundation
(IWF) list of illegal child abuse websites to prevent inadvertent
access to such images on both our fixed and mobile platforms.
Whilst Orange is not responsible for generating this list, this
type of model could be extended to other types of material (eg
extreme violent pornography, terrorism, suicide sites etc) if
government deems it appropriate and provided a list can be made
available to ISPs.
2.5 Orange's "teen chat rooms"
(which are restricted to children aged between 16-18 years) are
professionally moderated with all moderators having undergone
2.6 At the heart of Orange's approach to
online safety is making customersparticularly children,
parents and carersaware of the potential pitfalls of using
the Internet and other technologies and how best to protect themselves.
This includes advice online and in our UK retail stores. We are
also developing several educational projects to enhance awareness
amongst consumers, such as an "Internet Years" campaign
specifically designed to address gaps in technology knowledge
and understanding between parents and their children.
2.7 Orange believes more can be done to
help, inform and protect consumers in this area. Orange supports
an industry kite marking scheme for family friendly Internet access,
such as the IIA "Family Friendly ISP" Ladybird scheme
developed in Australia, based upon an agreed industry Code of
Practice. This will build upon the PAS 74 kite mark currently
being developed for content filtering solutions.
2.8 We strongly recommend that the Government
embarks upon a high-profile campaign to shift existing attitudes
to Internet safety. We also believe there is a need to bridge
the "understanding gap" between children and parents/carers.
As part of its e-Safety teaching, we suggest that the Government
considers recommending "Internet Parent Evenings" to
schools and would be happy to lend our resources and expertise
to such a programme.
3. BENEFITS AND
3.1 The Internet is changing our lives.
Access to the Internet has become an invaluable communication
tool for almost everyone, whether in business, at school or college,
in the home or on the move. For work, learning or entertainment
it is changing the way we do thingssuch as buying goods
or services, banking, seeking information, listening to the radio,
watching television or chatting/interacting with friendsand
challenging our traditional cultures, such as enabling more flexible
work patterns, enhancing consumer choice and transforming consumers
into producers (such as via social-networking websites).
3.2 Broadband Internet is at the centre
of the Government's drive to modernise public service delivery,
such as health services and education. For example, Information
Communications Technology (ICT) in educationincluding the
wide use of the Internet and other technologies, such as interactive
whiteboards, in the class roomis helping to deliver more
personalised learning services to young people, meaning more ways
to learn, more flexible ways to study, a greater choice in subjects,
better teaching facilities and an increase in distance-learning
(ie from home). For example, the Government is committed to providing
an online learning space enabling learners to store, organise
and share information/work and around 79% of secondary schools
encourage the use of e-portfolios.
3.3 Demand for broadband connectivity continues
to grow offering richer and higher-bandwidth services, such as
interactive entertainment and communication. Nine out of 10 Internet
connections (88.4%) are now broadband.
However, this figure does not include mobile Internet figures.
Accessing the Internet whilst on the move is available via high-speed
Third Generation (3G) mobile networks, allowing people to retrieve
services when on the move rather than at a fixed place, such as
a desk or in the home. 5.7 million people in the UK used a mobile
device to access the Internet during January 2007 and this figure
is set to grow.
3.5 The Internet is increasingly becoming
embedded in our lives, driven by broadband speeds. "Web 2.0"
features now offer consumers greater interaction and user experiences
whereas before the Internet was viewed as an "information
silo". This is leading to a fundamental shift in human behaviour.
The rise of social networking sites and user-generated content
is evidence of this change. UK participation in social networking
usage proves to be the highest in Europe, with 24.9 million unique
visitors78% of the total UK online populationnow
belonging to the country's social networking community.
3.6 The Internet is set to become further
embedded in our lives as access becomes increasingly available
on the move (via mobile devices and Wi-Fi hot-spots). This offers
further opportunities and has the potential to reach out to those
who traditionally have been disenfranchised. For example, most
mobile phones/devices today are Internet-enabled and, with over
80% of the UK population now owning a mobile phone or device and
increasing speeds and services becoming more prevalent, the potential
to bring Internet access to all regardless of age, geography or
social class is enormous.
4.1 There are a number of risks to children
and young people who use the Internet. These can be categorised
into contact and content and include being "groomed"
in chat rooms, becoming a victim of online abuse or bullying,
revealing personal details or photographs via a social networking
site or being exposed to inappropriate content. Inappropriate
content on the Internet can be age-inappropriate: for example
content that is age-restricted in other media (eg pornography,
gambling or violence). One big issue is that people are not always
who they say they are, with adults and children alike using the
apparent anonymity of the Internet to behave in ways that may
put them or others at risk.
4.2 The risks have increased in the area
of content with the advent of web 2.0 where the role of content
producer has passed from service provider to the users of the
Internet. Orange believes it is essential to strike a balance
between allowing freedom of speech whilst maintaining standards
of acceptable behaviour and community standards of taste and decency.
It is challenging for a service provider to set policies for these
standards. However, at Orange we believe that it is important
that our brand reflects what content we offer and we use various
measures to manage what is published by users on our web portal,
www.orange.co.uk. This varies according to risk assessments that
we conduct on the platform and the nature of the service.
4.3 Orange is unable to control what is
available on the wider Internet although we encourage the use
of parental controls. While ISPs have well established "notice
and takedown" procedures and are in line with industry best
practice, the speed of innovation and new market entrants means
that inappropriate content may be appearing on media or websites
that are not yet fully equipped to deal with such abuse. The wider
industry, working together with parental control software manufacturers
and age verification schemes, should study how to ensure that
such tools are equipped to deal with such a fast-evolving sector.
5. TOOLS AVAILABLE
5.1 Orange offers a range of technical mechanisms
to provide customers with a choice as to what content they are
able to see when accessing the Internet, whether using a personal
computer in a fixed place, a mobile handset/phone when on the
move or accessing Internet content via a digital television service.
5.2 All our fixed Internet customers are
offered a free McAfee privacy service with parental controls to
protect minors from harmful or inappropriate material. The parental
controls function lets parents or carers choose what children
can do and see online and offers a facility to manually block
or allow websites enabling greater control over the standard service.
5.3 Orange operates a "notice and take
down" procedure for reported inappropriate content on our
web portal, www.orange.co.uk. This procedure is in line with the
good practice models put forward by the HOTF.
We provide a link on our Chat and Forum services to enable users
and guests alike to report abuse of any sort. This link goes to
a general page where there is information that provides advice
about ways to use the tools in the product to manage abuse (eg
using the ignore button in Chat) together with a link to enable
reporting direct to VGT/CEOP.
Our "teen chat rooms" (which are restricted to children
aged between 16-18 years) are professionally moderated with all
moderators having undergone CRB checks and other safeguarding
measures as recommended by the HOTF.
5.4 Orange uses the IWF list of child abuse
images to prevent inadvertent access to such images on our fixed
Internet and mobile platforms. The HOTF guidance also provides
that Hosting Providers supply the IWF with a point of contact
for notifications about illegal content held on their systems.
The IWF is thus able to operate a service of "notice and
take down" to alert hosting service providers to criminal
content found on their servers. Whilst Orange is not responsible
for generating this list, this type of model could be extended
to other types of material (eg extreme violent pornography, terrorism,
suicide sites etc) if government deems it appropriate and provided
a list can be made available to ISPs.
5.5 Orange offers free anti-spam and virus
filtering to help block harmful content sent via Orange e-mail.
Our Internet search service has a "Safe Search" function
enabling users to control search results. The service is set to
"moderate" by default and is clearly displayed at the
top of the search results page in line with the good practice
models put forward by the HOTF along with advice to the public
on how to search safely. The user can set the Safe Search filter
according to their preferred choice:
Strictalways filter explicit websites/pictures
Moderatedisplay warning consent
page before displaying adult content
Offdisplay adult content without
showing a warning page
5.6 Along with the other mobile network
operators, Orange recognised the potential dangers of widening
access to the Internet (ie from the living room to the back of
the bike sheds) by making it available on a mobile phone or device.
In January 2004, operators published a Code of Practice for the
self-regulation of new forms of content on mobiles including the
use of Internet services.
The Code included a commitment to classify and restrict adult
content to those over the age of 18 years. Content is classified
according to the Independent Mobile Classification Body (IMCB)
framework which was published in February 2005.
All mobile operators' commercial content providers are required
to self-classify as "18" all content unsuitable for
customers under the age of 18 years, adhering to the IMCB's framework.
The Code (and framework) is currently under review and any modifications
will be made in 2008.
5.7 Accordingly Orange has placed all adult
content (whether on our mobile Internet portal or the wider mobile
Internet) behind access controls. The Orange "Safeguard"
service prevents anyone using a mobile handset from accessing
adult content (including games), whatever its source, while enabling
them to surf the rest of the mobile Internet. An additional benefit
is that all customers are prevented from accessing sites with
illegal content as defined by the IWF. All Orange pay-as-you-go
mobiles and SIM cards are supplied with Safeguard on by default
and customers need to prove that they are 18 years of age in order
to view "adult" content otherwise our safeguard filter
blocks their access. Pay monthly customers are assumed to be over
18 years of age having been through the credit reference process.
However parents wishing to give a pay monthly handset to a minor
can request the filter to be applied.
5.8 Prior to the recent launch of our mobile
service for Bebo users, we worked closely with Bebo to introduce
measures to make children as safe as they are on a computer in
the home (outside parental supervision). Registration and other
activities, such as accepting new friends or changing the privacy
settings, can only be done on a computer where a parent or carer
can supervise. We are awaiting the review of the content Code
of Practice to give guidance on whether some social networking
sitesa phenomenon which has come about since the development
of the Codethat are unsuitable for children should be placed
behind access controls as unmoderated chat sites currently are.
5.9 Orange is committed to applying the
good practice models put forward by the HOTF. Additional child
protection measures for the removal of unsuitable material applies
to websites aimed at children. These measures provide guidance
to the Internet industry for the establishment of mechanisms for
reporting abuse and procedures for the identification and removal
of content that is illegal (or in breach of our terms and conditions).
5.10 Orange has a dedicated Malicious Calls
Bureau to support customers receiving abusive communications,
including offering advice and a free change of mobile phone number
if requested. If the customer wishes the Bureau can investigate
a report and provide evidence of text messages, voicemails and
call records to law enforcement.
5.11 In addition to the above technical
measures, Orange places consumer awareness and safety advice at
the heart of its approach. We try to make the information as accessible
as possible using a range of media and to engage with busy or
5.12 Orange's UK website includes a newly
redesigned safety advice area for parents, carers and children.
The site includes a wide range of safety advice on using the Internet
and mobile phones, including using social networking sites, chat
rooms and the technical options to filter out inappropriate content.
The website also includes talking points for parents to use with
children, user polls and links to interesting related media articles.
The site also provides tools for customers to report potential
online abuse. The website also promotes the Parent's Guide to
the Internet, produced by the NCH, which seeks to educate parents
about the Internet and how to help their children enjoy a safe
and productive environment.
5.13 Orange has also produced a short guide
on mobile phones (and the Internet) entitled "What parents
need to know".
The guide is available in our retail stores across the UK and
provides parents and carers with a greater insight into how children
use the Internet and mobile handsets. It includes talking points
which we believe offer parents a useful means to engage with their
children on subjects which they may feel the children know more
than they do. It also provides simple advice on how to reduce
potential risks. We will be updating the guide in 2008.
5.14 Orange is a member of the Department
for Children, Schools and Families' Taskforce on Cyberbullying
which published specific guidance for schools on tackling cyberbullying
in September 2007.
The guidance includes practical tips on preventing cyberbullying
such as not responding to malicious text messages or emails and
not giving out personal details such as mobile phone numbers over
the Internet. Our Malicious Calls Bureau has for many years delivered
presentations in schools in collaboration with Police and NGOs
to warn children about the dangers of phone misuse, such as cyberbullying.
This programme is due to be extended in 2008 via our Orange Ambassadors
programme whereby training volunteer members of staff will help
deliver messages about safe and responsible use of mobiles and
5.15 We have produced a DVD in response
to demand from schools specifically designed for and incorporated
into the national curriculum to alert children to the dangers
of cyberbullying. Our cyberbullying DVD, Incoming Message has
been introduced in 40% of UK schools since its launch in June
2007. We will shortly launch a DVD specifically on the potential
risks of social networking sites, a copy of which we are happy
to provide to the Committee.
6. FURTHER ACTION
6.1 Orange believes more can be done to
make parents and children aware of the dangers of using the Internet.
We have commissioned specific research by Dr Jo Bryce from the
University of Lancashire's Cyberspace Research Unit into the public's
awareness of the risks associated with the use of the Internet
and the results will be published in the spring of 2008. This
will aim to address gaps in understanding between children and
parents and will be the focal point of our "Internet Years"
campaign in the Spring of 2008.
6.2 In addition to various industry customer
initiatives, we recommend that the Government embarks upon a high-profile
campaign to help bridge the understanding gap between parents
and children. There is evidence to suggest that this approach
does help to change culture and habits in society, such as the
wearing of seat belts in vehicles, drink driving or the practising
of safer sexual habits to reduce the risk of AIDS. The public's
response to the BBC's recent "One Click from Danger"
Panorama programme shows that parents would greatly benefit from
high-profile advice on these issues.
6.3 Orange recommends that schools could
do more to help parents and carers to better understand how young
people are using the Internet and the potential dangers in doing
so. Many schools and colleges across the UK are already doing
this but we suggest, as part of its e-Safety teaching, the Government
considers recommending "Internet Parent Evenings". Orange
would be happy to support this by enabling our Orange Ambassadors
to deliver presentations for this purpose.
6.4 Orange supports an industry kitemarking
scheme for family friendly Internet access, such as the IIA "Family
Friendly ISP" Ladybird scheme developed in Australia, based
upon an agreed industry Code of Practice. This would build upon
the PAS 74 kite mark currently being developed for content filtering
7. The effectiveness of the existing regulatory
regime in helping manage the potential risks from harmful content
on the Internet and in video games
7.1 The Internet is constantly evolving
and one of the largest changes we expect to see in the future
is its increasing mobility. Internet usage is no longer going
to be restricted to communal areas, such as the living room at
home, which means parents will not always be able to supervise
their children when using the Internet. It is therefore imperative
that the regulatory regime is adequate to meet these challenges
to ensure services are designed with safety inbuilt and that the
technical mechanisms are in place to respond to these changes.
7.2 Orange believes the self-regulatory
regimethrough various bodies and via industry guidelines
and Code of Practicehas been successful in achieving this
to date. We therefore believe it is vital that we continue with
this approach. We strongly believe the way to meet the challenges,
potential risks with existing and new technologies and changing
consumer behaviours is by working in partnership with key stakeholders.
In this way we can ensure that new technologies and services deliver
the enormous benefits they are designed to do, but are matched
with adequate safeguards to protect consumers, particularly children.
7.3 The mobile content code is evidence
of this success. It was developed prior to many of the services
it sought to regulate became widely prevalent in society and its
review shows the importance of "future proofing". In
addition to this, as a member of the HOTF, Orange is actively
involved in developing good practice guidance on a range of matters
including moderation, safe search, interactive services and social
networking. Orange supports the recommendations and has implemented
the good practice models in so far as is technically practical.
New Orange services are developed with safety in mind and this
guidance, coupled with collaboration with industry, law enforcement,
academics and children's charities, provides excellent resources
for doing so.
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