Select Committee on Culture, Media and Sport Minutes of Evidence

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 CRB checks.

  2.6  At the heart of Orange's approach to online safety is making customers—particularly children, parents and carers—aware 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.


  3.1  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 things—such as buying goods or services, banking, seeking information, listening to the radio, watching television or chatting/interacting with friends—and 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 education—including the wide use of the Internet and other technologies, such as interactive whiteboards, in the class room—is 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.[8]

  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.[9] 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.[10]

  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 visitors—78% of the total UK online population—now belonging to the country's social networking community.[11]

  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, 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.


  5.1  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, This procedure is in line with the good practice models put forward by the HOTF.[12] 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.[13] 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:

  Strict—always filter explicit websites/pictures

  Moderate—display warning consent page before displaying adult content

  Off—display 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.[14] 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.[15] 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 sites—a phenomenon which has come about since the development of the Code—that 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 disinterested parents.

  5.12  Orange's UK website includes a newly redesigned safety advice area for parents, carers and children.[16] 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".[17] 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.[18] 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 the Internet.

  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.


  6.1  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 solutions.

  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 regime—through various bodies and via industry guidelines and Code of Practice—has 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.

January 2008

8   Harnessing Technology Review 2007: Progress & Impact of Technology in Education-DCSF September 2007 Back

9   Office of National Statistics: 20 November 2007 Back

10   ComScore-14 May 2007 Back

11   ComScore - 10 October 2007 Back

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17<mv3>-<mv-3>affairs/guide<mv3>-<mv-3>for<mv3>-<mv-3>parents.pdf Back

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