Select Committee on Culture, Media and Sport Minutes of Evidence

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 important inquiry.

  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" of peers).

  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 by:

    (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 2008.

    (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 it.

  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 category—Conduct.

  21.  There are two sub-categories of potentially harmful conduct:  

    (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 of pornography.

  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 updated—see Bebo's aim is to have programmes of education designed for parents, teachers and young people easily accessible on the site—see 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 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 lesson plans.

    (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 (, 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 online.

  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 prevention strategies

  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 meets Bebo's content standards policy, as described to users in Bebo's Terms of Service.[1]

  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 public.

    (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 team.

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

  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 boundaries—the 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 and Schuster.

 (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).

January 2008

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