Memorandum submitted by Bebo
1. As one of the world's leading social
media networks, Bebo is at the forefront of the revolution taking
place in new technology. We welcome the opportunity to offer our
experience and understanding of this exciting new world to this
2. We strongly believe that the internet,
including social media and other web 2.0 services (i) such as
Bebo, contributes positively to the lives of consumer-citizens
and the broader socio-economic landscape in the UK. In particular
social media networks allow users to develop digital literacy
skills (critical to both individuals and national prosperity in
a global knowledge economy), and improve their social capital
(the benefits that are derived from being part of a "network"
3. However, we are fully cognisant of the
risks that do exist online and the safety of our users is therefore
of utmost importance. We have consequently developed a robust
approach to safety, which is grounded in sound academic understanding,
and which provides users with tools and education to enable them
to be safe and responsible when online. As Bebo's primary audience
is 16-24, our safety strategy, and therefore our submission to
this inquiry, focuses mostly on issues related to this age group.
4. Bebo's approach to safety is led by forensic
psychologist Dr Rachel O'Connell, who has a 12 year career in
researching how end-users use new and emerging technologies. She
has also been involved in multi-stakeholder dialogues, such as
the Home Office Task Force.
5. Within the traditional "media effects"
research paradigm, young people were regarded as passive recipients
in relation to media and it was assumed that it was possible to
measure the potential negative effects on young peoples' psychological,
emotional, social and ideological well-being. In a web 2.0 world
young people are active participants in the creation, dissemination
and moderation of content. Harm can be derived not just from content,
but also from conduct; and users can be the creators as well as
the victims of harm. This significant alteration in young peoples'
relationship with media presents a whole new set of issues that
challenges traditional conceptualisations not only of how we define
harm but also how we consider measuring and mitigating its effects.
6. Cognisant of these new configurations
of harm Bebo takes a three-pronged holistic approach to risk management
(a) Securing our service: implementing industry-agreed
good practice guidelines and other self-regulation approaches;
embedding a series of safety features into the site to reduce
exposure to risk; and operating a robust Report Abuse system.
(b) Supporting users: working with organisations,
such as the Samaritans, via the Be Well part of the site to reach
out and support those users who have been the victim of harm and
those who are at risk of doing so.
(c) Implementing pro-active and reactive
harm reduction strategies, including but not limited to, developing
programmes of education, deploying the latest filtering technologies
on our service, safety check in new product development cycle,
operating an effective abuse management team and by working closely
with various stakeholders including young people, teachers, parents,
industry partners and law enforcement agencies.
7. Bebo believes that the most effective
way to address harm in a web 2.0 environment is through a combination
of individual companies employing robust safety features, the
implementation of industry self-regulation, and the encouragement
of digital literacy. We acknowledge that these approaches will
need to evolve alongside the rapidly changing marketplace (indeed
that evolution is already underway), but we firmly believe that
a multi-stakeholder approach, exemplified by the Home Office Internet
Task Force is an effective driver of industry self-regulation.
The latest product of the work of the Task Force is the "Good
practice guidelines for social networking and user interactive
services" which will be launched in the coming weeks. Bebo
has been an active participant in the discussions around the good
practice guidelines and we have been both thought leaders, (eg
all profiles private by default) and ensured that we are in compliance
with the guidelines as they were agreed.
8. Bebo is one of the world's most popular
social networking sites (SNS). It was founded in 2005 as an online
community where users could post pictures, write blogs and send
messages to one another via their User Profile.
9. Today, Bebo has evolved to become a global
Social Media Network, a radical new vision for online media which
combines community, self-expression and entertainment. It has
a membership of more than 40 million individuals worldwide, with
its primary membership coming from the UK (where Bebo is the number
two SNS, with more than 11.2 million users), Ireland, New Zealand,
Australia, and the US and Canada (ii). Bebo has also recently
launched a Polish version of the site.
10. The service is geared towards an audience
aged under 30, with the core of 16-24-year-olds spending 2.14
billion minutes on the site per month (more than MySpace, Facebook
and YouTube combined). The average Bebo user spends almost 40
minutes on the site each day, viewing an average of 92 pages.
11. In addition to allowing users to find
and communicate with friends, Bebo enables users to discover,
experience and share user-generated and professional content such
as video, music, books and other forms of entertainment. The professional
content aspect of Bebo is an increasingly central feature of our
service and we provide access to a line-up of high quality programmes
and entertainment from professional broadcasters, independent
producers and other rights owners and gives users a simple set
of tools to create their online media collection and communicate
their tastes to everyone in their network:
(a) Bebo's KateModern, the UK's first interactive
web series, has received more than 25 million views since it first
aired. Another interactive series, Sofia's Diary, is planned for
(b) In October 2007, Bebo launched The Gap
Year, the first ever truly interactive reality series created
by Endemol which will follow six Bebo users on unforgettable adventures
around the globe.
(c) Also in October 2007, Bebo launched Open
Media, a new vision for social media and entertainment that gives
media companies free and open access to the Bebo community and
the Bebo community free and open access to thousands of hours
of premium entertainment content from some of the world's best
known media brands.
12. The combination of SNS functions plus
original entertainment creates a rich social media network experience
for our users, making Bebo one of the most innovative Web 2.0
companies in the world.
13. Before moving on to talk about the potential
risks that exist online, it is worth reminding the Committee of
the overwhelming good that the internet has brought to society
in terms of education, communication, commerce, financial services,
information and entertainment, as well as increased economic productivity,
innovation and competitiveness in the global market.
14. Web 2.0 services have their own particular
set of benefits: never before has so much power to create, communicate,
publish and moderate content been in the hands of the general
public. The associated abundance of "user generated content"
is fuelling an information revolution typified by the growth of
a number of new activities, including for example, citizen journalism.
The resultant paradigm shift in people's relationship with media,
its creation and exchange presents new challenges in terms of
mitigating risks associated with harmful content.
15. Web 2.0 services also provide a forum
to develop one of the most essential skill sets for the modern
age: digital literacy, the ability to express yourself online,
make informed choices, access, share and retrieve content, and
keep yourself and others safe. As well as being essential for
employment and for living a fully enfranchised life as a consumer
and a citizen, these skills also empower users to protect themselves
online. Bebo has consequently developed a number of ways to encourage
digital literacy as an integral part of our safety approach, as
we will explain later in the submission.
16. Another potential benefit of web 2.0
services is the creation of "social capital". Interaction
through networks enables people to build communities, to commit
themselves to each other, and to knit the social fabric. However,
it has been argued (iii) that in the real world active membership
in community groups is decreasing. This vacuum in community engagement
in the real world is being filled, at least in part, by the community
building activities that occur in online social networking environments,
which can act as an invaluable glue through which people can maintain
contact with one another and continue to build friendships. Furthermore,
having access to support networks has been found to buffer the
effects of stress and improve resilience. (iv)
17. As the Byron review has acknowledged
in its consultation, "risks are a reality of life" in
online world, just as it is in the offline world. The aim therefore
of public and private company policy should be to minimize that
risk and to provide citizen-consumers with the knowledge and tools
they need to address potential harm if and when they encounter
18. The starting point for an effective
company approach to risk management is solid understanding of
those risks. Consequently, Bebo's approach is led by forensic
psychologist Dr Rachel O'Connell, Chief Safety Officer, whose
experience includes more than twelve years of research into how
end-users use new and emerging technologies. Dr O'Connell has
been a key contributor to policy development with respect to internet-related
issues in the UK, both in her previous role as the Director of
the Cyberspace Research Unit at the University of Central Lancashire
chairing the Public Awareness Group of the Home Secretary's Internet
Task Force on Child Protection, where she facilitated a partnership
approach across the mobile and fixed internet industry, child
welfare organizations, government, parent and teachers' organizations
to develop a number of web-based programmes of education on internet
safety. Dr O'Connell has also co-ordinated pan-European projects
designed to address internet safety related issues, funded by
the European Commission. At Bebo she leads a safety team of three,
and is supported by a safety engineer, a graphic design team and
an abuse management team, who are based in Austin, Texas, who
work together to understand the landscape we are working in and
develop appropriate responses.
19. Concerns about the harmful effects and
negative influences on the public, and in particular young people's
well-being, with respect to media consumption are not new. In
the context of literature, film, TV and games these concerns have
traditionally been addressed through (often) statutory media content
regulatory policies, such as the broadcasting code. There is scope
to extend into the online world both the lessons learned from
the traditional media landscape with respect to mitigating harm
and updated versions of regulatory policy. However, as discussed
earlier the notion of "harm and offence", and therefore
the resulting measures employed to address it, needs to be reassessed
for today's internet environment. Further, in order to arrive
at an entirely contemporary definition, we need to consider web
2.0 services, where one of the central features is the increasingly
active role of users as producers, publishers and disseminators
of textual and visual content through their digital social spaces.
20. Before the mainstream arrival of web
2.0 services, there were three categories of online harm: "Commerce",
(which relates to misleading product placements and exposure to
advertising); "Contact" (which relates to inappropriate
contact being made between adults with a sexual interest in children
or young people, who solicit young people to engage in cybersex
and/or to meet in the real world); and "Content", which
relates to pornography, violence, racist content, misinformation
and propaganda. In today's world we need to reconsider existing
categories to acknowledge that users can be both victims and perpetrators
of harm and we also need to add a fourth categoryConduct.
21. There are two sub-categories of potentially
(a) Bullying or victimization, which has
been described as the repeated exposure over time to negative
actions on the part of one or others. (v) In an online context
bullying, harassment, defamation can be perpetrated by a young
person to victimize another young person or an adult such as a
teacher. These include behaviours such as spreading rumours, excluding
peers from one's social group, and withdrawing friendship or acceptance.
(b) Risk-seeking behaviours, which include
divulging personal information, posting sexually provocative photographs,
lying about real age or arranging to meet face-to-face with people
only ever previously met online.
22. As such, it can be argued that "harm
and offence" should be expanded to "Risk of Harm from
Online and Related Offline Activities" (RHOOA), to more accurately
encapsulate users' opportunities to harness the capabilities of
interactive technologies as creators, producers and disseminators
of both content and communications. These potential risks include
harm to the physical, psychological and social well-being of users
and recognizes the ability of users people to be active initiators
of, and participants in, deviant or criminal online activities
such as cyberbullying, cyberstalking, creation and dissemination
23. A further consideration in this new
web 2.0 context is the complexity of the construct of "risk
of harm". For example, a vulnerable young person who is seeking
information about self-harm online may be at an increased risk
of harm to their psychological and physical well being if they
become participants in online forums where self-injurious behaviours
are legitimized, sanitized and normalized. Alternatively, other
users may derive positive benefits from engagement with similar
online communities since communicating with others may have a
cathartic effect by providing support and an opportunity to discuss
problematic emotions, cognitions or behaviours.
24. Again, while the concept of social capital
was introduced earlier in this submission as a potential benefit
associated with online social networking, it is important to recognize
that these communities can sometimes be characterized by negative
aspects of human interaction and social organization, including
delinquent and sometimes criminal conduct.
25. In summary, while it is possible to
identify new formats of potential online harm, sufficient programmes
of research have not yet been undertaken which focus on how web
2.0 communities address anti-social, deviant or other inappropriate
behaviours. As our knowledge base is not fully formed, it is important
to ensure that appropriate programmes of research are commissioned
to better understand the issues in advance of any proposals regarding
"formal regulation" of these issues.
26. Given this understanding of risk of
harm, Bebo takes a three-pronged holistic approach to the minimising
risk of harm (both content and conduct) on its site.
Securing our service
27. Bebo is an active participant on the
Home Office Internet Task Force's sub group, which has developed
Good Practice Guidelines for Social Networking and User Interactive
Services. Bebo adheres to the good practice guidelines laid
out in the social networking guidance and it is worth noting that
many of the safety features on Bebo pre-date the guidance. The
following are examples of Bebo's safety features; however this
list is not exhaustive.
(a) Since its inception all profiles on Bebo
are Private by default and safety messages on Bebo are continually
updatedsee www.bebo.com/safety. Bebo's aim is to have programmes
of education designed for parents, teachers and young people easily
accessible on the sitesee www.bebo.com/safety. Bebo places
context specific safety messages in areas where young people make
decisions about how to interact with the community, eg, when users
register they are strongly advised to keep their profile Private
if they are under 21. When users sign in to use the service their
IP address is visible with messaging which details that they are
not anonymous online.
(b) As part of Bebo's schools engagement
strategy Bebo has created http://safesocialnetworking.com for
use by teachers in schools where access to the Bebo site is banned.
The materials have been mapped to the school curriculum and include
(c) Bebo has had a robust Report Abuse system
in operation since its inception. Every profile page contains
a Report Abuse link located underneath the profile picture which
when used allows our abuse management team to quickly view both
the sender and the subject of the report and to issue conduct
warnings, remove content or delete accounts as appropriate.
(d) In accordance with Home Office good practice
guidance it is not possible to search for users under the age
of 16 using search engines.
Supporting young people
28. Sites like Bebo reflect what is happening
in young people's lives and the nature, scope and extent of harmful
behaviour between young people is a cause for concern. As above
Bebo addresses these issues through our abuse management team,
which deals with reports of abuse submitted by members of the
community and we also issue conduct warnings if necessary. However,
we also employ a more innovative approach to tackling potentially
harmful content/conduct on our site.
29. Research findings indicate that many
teenagers fall prey to abuse both offline and online without ever
having flouted laws or acted irresponsibly. For others, personal
attributes render them vulnerable both to law breaking and to
victimization. Bebo has therefore created a part of the site called
Be Well (www.bebo.com/bewell), a well-being centre, which allows
support providers to use the Bebo platform as a means to easily
access the young people who need their services. Currently, organizations
including the Samaritans, beatbullying and Mencap, harness Be
Well to reach out to and support not only those who have fallen
victim to abuse but to empower young people with the knowledge
to identify possible risks to their personal safety and well-being
and to seek appropriate help to mitigate the risk.
30. Be Well is just one of a number of initiatives
that Bebo is involved in with a growing number of partners focused
on empowering and supporting young people in areas as diverse
as motivational training, social entrepreneurship, careers advice
and using Bebo in an educational context as a Virtual Learning
Environment. For example, Bebo is also part of a multi-stakeholder
policy group called Technology for Well-Being, which brings together
providers of support services related to mental health, social
care and well-being who harness or are considering harnessing
online platforms (both fixed and mobile), in order to share learning
and develop good practice around the operation of support services
31. We believe that this innovative approach
to supporting and empowering our users offers a great opportunity
to mitigate potential harm on our site and offers scope to address
issues relating to conduct by educating young people to promote
tolerance, respect and inclusion in online communities.
Pro-active and reactive harm reduction and crime
31. Bebo's content standards policy is aimed
at ensuring that only content suitable for under 18's should be
accessible on its site. The majority of user-generated content
uploaded to Bebo.com meets Bebo's content standards policy, as
described to users in Bebo's Terms of Service.
32. Bebo ensures that, as a minimum, the
Bebo Terms of Service obtains the agreement of the users of the
Bebo Website not to post content that is harmful, obscene, indecent,
unlawful, libellous, profane, defamatory, infringing, inappropriate,
hateful or racially, ethnically or otherwise objectionable.
33. Bebo has a Member Media Review team
"MMR" that searches for inappropriate images and videos
on our service. Currently, the MMR team operates seven days a
week and typically inappropriate content is removed by the MMR
team within 24 hours after it is uploaded to Bebo. However, as
with any large social networking environment, it is impossible
to find all inappropriate content.
34. Bebo deploys various technologies to
intelligently filter content, which augment the efficacy of the
MMR team. Bebo is always looking at additional ways to: (i) monitor
and filter content that contravenes its standards policies and
aims to utilise the ever-increasing capabilities of new and emerging
technologies in order to fulfil this aim. Bebo aims to remove
inappropriate content within 24 hours of becoming aware of or
being notified of such content and its location on the Bebo Website.
35. Bebo monitors the patterns of evolution
in the use and misuse of various aspects of our service and reviews
new products from a number of perspectives including safety and
security. Whilst Bebo cannot be liable for unsuitable content
that is uploaded, or any sensitive content that is downloaded
or otherwise used as a result of or in connection with technological
advances, developed user practices, hacking, or any other illegal
and/or unforeseen activity, Bebo aims to address these issues
as and when they arise.
36. Bebo was the first social network to
implement an audio filtering solution (developed by Audible Magic),
which is designed to allow Bebo to filter any copyright material
owned by a third party on the Bebo Website.
37. Bebo enables users to moderate content
in the following ways;
(i) Pre-screen comments: Users have a facility
to pre-screen comments made by other users before they appear
on a users profile page.
(ii) Delete comments: a user can delete comments
that appear on his or her page but also each user has the ability
to delete comments posted by him /her to another user's page.
(iii) Default private setting for the profile.
All user profiles are Private by default when a user sets up a
Bebo account. Users can remain private or opt to make their profiles
(iv) By editing their photo albums users
can control who can see individual photo albums and choose whether
to allow others to copy photos from individual photo albums.
(v) There is a link to a Report Abuse form
on every Profile page and adjacent to content, which augments
users ability to Report content that contravenes Bebo contents
standards or Terms of Service to Bebo.
(vi) Bebo members can choose to Block individual
members, which will prevent the blocked member from sending them
mail messages, posting to their White Board, and commenting on
their Blogs, Quizzes, Photos, Profile or Polls.
38. Bebo recognizes the importance of working
with law enforcement and we actively engage with the Home Office's
Single Point of Contact training program which is designed to
educate law enforcement officers about how to lawfully acquire
telecommunications data from Bebo under the Regulatory Investigatory
Powers Act (RIPA).
39. Bebo has a distinct reporting route
for users to report suspected paedophile behavior to us and includes
critical education material designed to help those unsure about
whether the behaviours they are concerned about constitute paedophilic
behaviours. Reports we receive via this route are dealt with as
a highest priority and reports are disseminated to the appropriate
law enforcement agency.
40. Bebo supports the work of the newly
formed Child Exploitation and Online Protection centre (CEOP)
and has worked with the both harm reduction team and the intelligence
How effective is the current regulatory regime
in managing potential risk?
41. The current regime for managing risk
from harmful content and conduct online can therefore be described
as: individual company safety policies + self-regulation via industry
good practice guidelines (developed with input from other stakeholders).
This approach recognises that traditional "command and control"
regulation, which has worked for passive media, is unlikely to
be effective in an environment where users are not just passive
but active, where the parameters are global and not national,
and where services and the use of those services are developing
and evolving at a lightning speed. This multi-stakeholder approach
has already demonstrated that it can work, as we have seen in
the response to illegal content, the establishment of the IWF,
which saw potentially illegal content hosted in the UK reduced
from 18% in 1997 to less than 1% by the end of 2003.
42. However, while we should have confidence
self-regulatory approaches, we do acknowledge that the rapidly
evolving nature of the market means that it is necessary for all
stakeholders to continually review and improve their response.
For example, Bebo's safety approach is in a continual cycle of
improvement, as we demonstrated when our move into the mobile
market, with the launch of a service with Orange in the UK and
O2 in Ireland, prompted a safety review prior to product launch
and the development of a Bebo Mobile safety animation which is
included on http://safesocialnetworking.com.
43. The wider multi-stakeholder response
also needs to evolve in order to be fit for purpose, and there
are currently many activities underway to do this. For example,
the Broadband Stakeholder Group, which has brought together a
range of audiovisual content providers, will shortly publish a
set of guidelines for labelling potentially harmful or offensive
content. Bebo hopes that these multi-stakeholder dialogues will
continue and that they are used proactively to discuss potential
problems as soon as concerns develop. We also believe that there
is the potential to extend dialogues and share good practice and
information across national boundariesthe UK is not in
isolation in dealing with these concerns.
44. However, while industry, with support
of government bodies and other stakeholders, is already evolving
practices to best address existing and upcoming harmful content/conduct
issues we do believe that a third element is vital in empowering
users to manage risk of harm online: digital literacy. As we have
demonstrated, Bebo strives to promote digital literacy, and we
have also committed to increase investment in educational and
other Corporate and Social Responsibility related activities which
raise awareness of the information and tools available. However,
adequate levels of digital literacy can only be achieved if recognized
educational institutions and other state-based organizations also
provide programmes of education.
45. We believe that internet safety needs
to be a mandatory part of the school curriculum, that it is informed
by research and that it looks at the many positive benefits of
networking with others online, as well as the potential risks
including for example, bullying, identity theft, harassment or
stalking. The curriculum must also recognize that young people
may also pose a risk of harm to other users, as well as themselves
and develop young peoples' understanding of their human rights,
roles and responsibilities.
46. Digital literacy also needs to go beyond
young people to the wider population, for the sake of both their
capacity as users, and as guardians for children's online activities.
In the case of teachers and other educational staff, we believe
that this education needs to take place both as part of initial
teaching training and as part of the rolling programme of continual
professional development (CPD). For the general public supplementary
support in the form of help lines, websites and awareness raising
initiatives are needed.
48. The existence of potentially harmful
content (and conduct) is taken extremely seriously by stakeholders
across the online world and Bebo is in a continual cycle to respond
to these challenges. We have therefore welcomed the opportunity
to share our experiences with the Culture, Media and Sport Select
Committee, as part of the vital dialogue that needs to take place.
49. In the course of its inquiry, we urge
the Committee to approach the issue from a similar base that we
have adopted at Bebo: attempting to understand the very particular
forms of harm that can exist in web 2.0 contexts and by recognizing
the responses that are likely to most effective in dealing with
those forms of harm: company safety policies + multi-stakeholder
dialogue and self-regulation + digital literacy.
(i) Web 2.0 or social media can refer
to a perceived second generation of web-based communities and
hosted services which aim to facilitate creativity, collaboration,
and sharing between users. This group of services can include
social networking services, which enable the creation of online
social networks for communities of people who are friends or colleagues
or who share interests and activities. Social networks enable
interactivity through functions such as chat, messaging, email,
video, voice chat, file sharing, blogging, discussion groups.
The addition of access to professionally generated content such
as video, TV, film and music allows a social network to also become
a social media network.
(ii) Source: comScore, Bebo.
(iii) Putnam, R D (2000) Bowling Alone.
The collapse and revival of American community, New York: Simon
(iv) Researchiv conducted in 2002 found
that nearly one fifth of American adolescents had used the internet
in the previous year as a means to seek help when they felt "very
upset, sad, stressed or angry. These findings suggest that the
rate of adolescents seeking help on the internet was comparable
with the percentage of adolescents who saw a mental health professional
or a school counselor in the previous year. Olweus, 1990.
(v) O'Connell and Bryce (in preparation).
1 http://www.bebo.com/TermsOfUSe.jsp Back