|
UNCORRECTED TRANSCRIPT OF ORAL EVIDENCE To be published as HC 353-iii House of COMMONS MINUTES OF EVIDENCE TAKEN BEFORE CULTURE, MEDIA AND SPORT COMMITTEE
HARMFUL CONTENT ON THE INTERNET AND IN VIDEO GAMES
tuesday 18 March 2008 MR JIM GAMBLE QPM and MR ALEX NAGLE MR NICHOLAS LANSMAN, MS CAMILLE DE STEMPEL Evidence heard in Public Questions 164 - 257
USE OF THE TRANSCRIPT
Oral Evidence Taken before the Culture, Media and Sport Committee on Tuesday 18 March 2008 Members present Mr John Whittingdale, in the Chair Janet Anderson Philip Davies Mr Nigel Evans Alan Keen Mr Adrian Sanders Helen Southworth ________________
Memorandum submitted by Child Exploitation and Online Protection Centre
Examination of Witnesses
Witnesses: Mr Jim Gamble QPM, Chief Executive Officer, and Mr Alex Nagle, Head of Harm Reduction, Child Exploitation and Online Protection Centre, gave evidence. Chairman: This is the third session of the Committee's inquiry into harmful content on the Internet and in video games. I would like to welcome Jim Gamble, chief executive officer of the Child Exploitation and Online Protection Centre and also the ACPO lead on extreme pornography on the Internet, and Alex Nagle, head of harm reduction at CEOP. I invite Adrian Sanders to begin. Q164 Mr Sanders: Our focus today is on the risks of harmful content on the Internet rather than risks of harmful contact. Are the risks of contact such as grooming greater than the risks of exposure to harmful content? Mr Gamble: You come immediately to the nub of the problem. In essence the issue for us is that content is generated by people. We have become seduced by technology and very often by technologists themselves who paint the picture that it is too difficult and vast and is a technical labyrinth that is hard to understand. This is about people who create content and through that behaviour place it on the Internet. I think some of the confusion arises on dividing the two. The content is often a symptom of behaviour. An individual who says on Hyde Park Corner something that is in essence a breach of the law and someone who goes onto the Internet to generate content to reflect that are no different. We should not be forced into a position where we are made to believe that it is different. Yesterday I listened to Sir Tim Berners-Lee who was asked whether we should regulate the Internet like the rest of society. When he answered that the Internet is part of society I breathed a sigh of relief because nothing is truer. If we try to isolate different types of behaviour committed in different public environments - because the Internet is a public environment - we make our job much more difficult. Q165 Mr Sanders: Do you agree? Mr Nagle: I agree. Q166 Mr Sanders: I do not think anybody round this table would disagree. Are you saying therefore that whatever happens within the environment of the Internet should be treated absolutely no differently from what happens outside? But are there examples where that is not so? Mr Gamble: First, if we are looking at either harmful content or conduct it can be mitigated in several ways, for example by the criminal law. That which is a crime in the real world is still a crime in the virtual world. It can be mitigated by a framework that looks at access, so if it is harmful content and you say that it is perhaps not harmful to an adult but to a child the question is how you limit access to it. Some people will say that that is not possible on the Internet. Try to buy itunes from the American site and you will be diverted to the UK site. Therefore, where there is a commercial imperative it can be done. You can mitigate first with the criminal law and, second, with access controls. As to the third issue, we have to regard the Internet as a public place and mitigate it by virtue of bringing that place together in a way whereby those who operate to commercial imperatives are duty bound to ensure it is safe for their young customers because they use those customers to attract advertisers to the environment and thereby make profit which is wholly legitimate. As a counterbalance people will say that they want to encourage e.commerce; it must thrive. I wholeheartedly agree that we want to encourage e.commerce so it thrives and this country must lead the way. However, coming from Northern Ireland as I do and worked there previously as a police officer for many years I am aware of the enterprise zone scheme whereby we recognise the need to encourage a particular industry in some areas where it is not imbedded. For many reasons, not least social and economic, we create enterprise zones where tax benefits are applied in the first few years. But even in the zones where we try to encourage new industry to grow we do not say that it can make up the rules in that environment or that it does not have to comply with the rules that apply elsewhere because we are so desperate for that industry to thrive. Health and safety, building regulations and the way we protect one another in society, in particular the vulnerable, come first. I see no difference. Therefore, one mitigates with the criminal law and the framework that protects those individuals who should not have access; one mitigates with those regulations that encompass any environment that is a public place where members of the public are encouraged to go and underpin it with an absolute commitment to free speech and the Human Rights Act so that people can explore the limits of behaviour both online and offline. I would love someone to give me an example of some harmful behaviour online that is not of itself harmful offline. Q167 Mr Sanders: We know that blocking tools are available to parents, but you are saying there are blocking tools available to somebody else who would intervene and prevent access. Who should be controlling that blocking tool? Is that a role for government or a regulatory body? Mr Gamble: If as a parent you
allow your child to go into a shopping mall you will warn and educate that
child about the dangers. You have a responsibility with regard to how you
empower young people with information that makes them safe so they can go out
and enjoy the opportunities in the offline environment in a way that enhances
their lives. Equally, as a parent you have a responsibility to engage and
educate yourself about the opportunities in the online environment so you
manage the risk and children can capitalise on the fantastic opportunities.
Therefore, the parent has a responsibility. If we go back to the shopping mall,
those people who operate it with a commercial imperative will have a
responsibility. If children are encouraged to go to a young person's
environment, be it about go-karting or amusements for young people that are
specific to and bespoke for them, that will require a level of moderation.
Every parent will want to understand what moderation is present and how the
young person is protected. When a young person is placed in harm's way each of
those environments will be expected to give that individual immediate and
direct access to law enforcement. That is how we protect, not nanny, and create
an environment in which people are able to operate to the full extent of their potential.
Many of my online industry partners do exactly that. They work with best
intent; they are good people within good organisations who work hard with us, but
is it fair that only the ones that are big enough to invest in that do so? Is
it right that some do not do it, and how do you create a level playing field? I
have been involved in this work since 2002. I learned lessons through the
application of Operation Ore, the creation of the National High Tech Crime Unit
and paedophile online investigation team and the building of the Child
Exploitation Online Protection Centre. There are many excellent examples of
industry working with the police service, government and the third sector which
has a big role here, but I have not seen clarity of purpose and thought in a
uniform way that makes a real difference. Regulation has become a difficult
word because some people do not like it. Let us move away from the word
"regulation". There must be some kind of framework that allows us to work
better together but recognises that each of us has a different role. It is not
about a group of individuals telling industry what to do. Government tells me
what the speed limit is when driving along the road. That is about ensuring
that I use that infrastructure, comparing it with the information superhighway,
in a safe and sensible way. The picture of a speed camera lets me know that
perhaps there will be a consequence if I break that law and represent a danger
to someone else. What is different about the online environment? We need to
occupy it in a way that is sensible and sensitive to the needs of industry but
says to predators or persons who want to post harmful content that if they do
that we are policing the environment. It is a forensic and digital environment
by its very nature and we will find them. In 1998 many thousands of people in
the UK went online and accessed the Landslide website in the United States.
They handed over their credit card details, personal passwords, billing
addresses and dates of birth. They did that because they believed there would
never be a consequence. The 2,500 who have now been held to account many years
later now know there is. Let us not lose the impetus that that has delivered
but continue to drive forward and recognise that it is a great environment and
we will ensure that every one of our citizens can capitalise on the
opportunity. To give an example of how to make that work, I have brought with
me a very small graphic illustration which perhaps can be passed round. This is
a representation of a particular vehicle online. One of the benefits of
operating solely in this area is that we collect and collate all of the
intelligence and information that comes into the UK from foreign law
enforcement agencies, industry, NGOs and members of the public here and abroad
and all of our own domestic services. This is Microsoft Instant Messenger. It
is a vehicle with which every child in this country will be familiar because
children spend significant amounts of their time day and night talking to one
another. I hope that those Members who have Instant Messenger or another
vehicle - AOL has a similar product - will instantly recognise the front page.
You will see that this is an environment within which the child spends a
significant portion of time. We know from our statistics and the work we do
that 60% of grooming cases that arise will at some point leave the chat room,
social networking or other environment where people have met up and go to
another vehicle, primarily an Instant Messenger-type environment. This is one example.
What you see on the front page is a small logo of a stick man. That is our
report abuse logo. It means that if you are a child in this room you can at any
time with one click go to the second page which gives you top tips and advice
about what you should and should not do. In that vehicle the safety belt is on the
child. That is about industry doing the right thing for the right reason in the
right place, not running away from responsibility and making a potentially
dangerous environment safer for the educated and informed child. We have been
engaging industry across the board in respect of this since we began. This is a
good example of one huge industry partner that is often ridiculed. I do not
know whether that is right or wrong in other areas, but I know that in this they
have put their money where their mouth is because that tab in the online
environment is revenue potential. We do not pay for that. That means every
child in that vehicle with one click gets advice and the second click reports
directly to us. There are people in prison today because teenagers have used
that vehicle at the time they are being seduced or engaged or have seen
something online that they do not think they should see. That is critically
important. On 26 August 2006 that went live. In the week that followed our
reports went up 113%. In the month that followed instead of 22% of our reports
coming from the under-18, 54% of such reports came from that source. This is
about partnering with industry that puts up a sign. We have gone into schools
with our education programme because none of us will be able to police the
Internet by ourselves. To date we have engaged with 1.5 million children
primarily between the ages of 11 and 16. Q168 Chairman: How many reports do you receive a week? Mr Gamble: In a month we would average anywhere between 450 and 550 reports. We do not take anonymous reports. If you phone me up and say that someone is breaking into your house and I ask where you live and you say you will not tell me we will not send out every police car into the city to look for you. We are devoting specialist resources to this. To put the 500 reports a month into context, one report can be one offender, 26 offenders or, in the case of the Son of God investigation last year, 700 paedophiles across two paedophile rings. The amount of investigation that goes into each of those reports is huge. We triage them and look at children at risk now, persons who are potentially grooming and all of the rest. We turn round a child at risk report within a day or overnight. We also get reports from our good partners in the NSPCC. We now work with other agencies that perhaps fear children are suicidal to identify, locate and safeguard those children. Lots of good work is going on. The BT Clean Feed system is an outstanding, world-leading initiative which we applaud. It is a good crime prevention tactic. We applaud the work done by the IWF. That is also a good crime prevention tactic. Ultimately, they are crime prevention tactics and it is putting a burglar alarm on one house and diverting people to another. You have to address the principal issue which is not technology but people's behaviour. Q169 Chairman: You will have seen the Panorama programme a few weeks ago in which a fictitious 14 year-old girl, I think, was put up on Facebook to see what would happen. The impression given by the media is that the Internet is basically a playground for paedophiles and any child will almost immediately be approached. Is there hysteria growing up about this? How big a problem is it? Mr Gamble: It is a big problem but we should not treat it in a disproportionate way. The benefits of the online environment - unless you are the parent of the individual child who is being abused - far outweigh the risks. I do not think the media exaggerate. There is hysteria; you cannot have a sensible debate about the subject of child sex abuse and the Internet without emotion coming into play which can sometimes be very negative. I believe that the emphasis is sometimes wrongly placed. We are about to publish our annual review. Without giving away the headline figures - we can supply a copy before you finish taking evidence - we have more than tripled the arrests we made in the first year. We have increased the number of children rescued and the number of children educated. The emphasis should be on that and how the environment is becoming safer. I have not seen a headline in any paper which says that Microsoft Instant Messenger is now one of the safest environments in the UK because you can report directly. Therefore, the good news is not reflected. Without reflecting the good news about the initiatives we take with constructive partners we do not balance the bad news. I believe that the emphasis is wrong. Any environment in which our children participate must be one that we are prepared to protect with a framework. I have a 15 year-old daughter. If when she was 13 - or even now - she went to the cinema and tried to access a film for 18 year-olds and above she would have been stopped because the broadcasting certificate saying that the film was suitable only for 18 year-olds would be policed, not by law enforcement but those who operate that cinema to a commercial imperative. There is a sanction against them if they allow in that individual. If she leaves it and goes to an off-licence and, because she appears more like a 19 or 20 year-old than a girl of 15, and is sold a bottle of vodka and leaves the off-licence the child will be held to account in that regard. It is about making sure that responsibilities are properly balanced and we do not fall into the trap of creating an impression that it is all far too ambiguous and difficult and really we just have to agree to get along until it sorts itself out. That is not my view of it. Q170 Chairman: You have praised MSN. Yahoo is the other major IM service. Do they have a system similar to MSN? Mr Gamble: They do not have the system we have. To be fair, each of our industry partners will run a system whereby when reports come to them they transfer them to us. I believe that each and every one of them is committed. You will hear from AOL later. We have been talking to and working with AOL very closely in the UK for a period of time and engaging them in the US. The online industry shifts and changes so much that sometimes in this market environment you will be talking to one group one day that will be owned by another group the next. That creates some difficulty for them, not us. That is why you need a framework. People need to understand that it is not down to personality. Some of the people at AOL are in my view absolutely committed to child protection, but how that manifests itself as an institution or organisation - AOL has great child protection credentials, so I do not talk about them in particular - is different. We can say that we should bring together industry and reach a consensus and deliver guidelines, but do we do that in enterprise zones? Do we bring together different industries and agree how to do this and the limits to which they can go? We do not. We create a level playing field where it is the same for everyone. In essence we have worked very closely with industry. I appreciate some of the difficulties they have which should not be minimised. They balance a number of imperatives, the principal one being the commercial one which is wholly legitimate. Our principal imperative is to protect children. Q171 Alan Keen: You have a very impressive career in tackling the more unsavoury aspects of life. Maybe lots of your colleagues enjoy chasing robbers about the place, but you must be a real expert on this matter. What should we be doing as politicians? What contact do you have with people who make the decisions? Presumably, you have contact with the Home Office, but what do you believe politicians should be doing to assist in your work? Mr Gamble: I am not party-political in any sense, but the support we have had from our two Home Office ministers, previously Paul Goggins and presents Vernon Coaker, has been second to none. They understand the issue and have engaged with us and taken time out to understand it, and I applaud both of them for that. In a broader sense in government we need to be more closely engaged and have a good level of resilience around the funding support we are given. We need to be able to engage much more constructively through government with industry and make sure we are not always going to industry with cap in hand. Constructive partnership is hugely beneficial, but if we are continually asking industry to help us when we should be helping them on some occasions it is not a constructive way to form relationships. I think that on occasion we all suffer because of that. I know that the Chairman and a number of Members will be coming to visit the centre to see how and what we do. It is important that more people who have a critical influence in government take time out to visit and understand and use that influence. We are a cross-sectoral multi-agency but law enforcement-led as you will understand that when you see the centre. Camille de Stempel who will give evidence to you later invested in the centre one of the people from AOL when it began. That person was a director of research for AOL but at their expense worked with us as we built an idea around Safer by Design and decided how it would move forward. We have representatives from other industries. We have very worked closely with Vodafone. Government needs to recognise and capitalise upon the cross-sector environment. DCSF has imbedded with us a person from the department so we can eradicate duplication of effort and ensure a single vehicle that delivers programmes to schools. Sometimes there is unseemly competition; a number of people will produce an education package and schools are left wondering which one to take. You have only 45 minutes in the classroom and you want to do it right, so it needs a whole school approach. We need to demonstrate that understanding and government needs to educate us to that effect. The Department of Health also has someone imbedded in the centre. We are cross-sectoral and I believe our governance should represent that personality in government. Q172 Alan Keen: You mentioned the IWF to whom we have spoken. Is there anything more they could do to help? Presumably, you are in continuous liaison with them. Mr Gamble: We have a great relationship with the IWF. What they do with regard to maintaining and administering the list provides a vehicle to refresh the blocking mechanisms that each and every ISP can use. We are engaged in a programme of work to move much more closely to them so we can look at who is behind these postings and who uploads them. Is there also an issue about looking? If a site is blocked who is attempting to visit it? How often have they attempted to visit it, and is it a real person or simply a web spider that is going out remotely? That is about resources and engaging in this environment in the same way as anywhere else; it is not about it being a labyrinth. Today we do not have a police officer on every street in London, let alone every street in the UK. We prioritise where we go and what we do and we do it on the back of a framework. We need much more clarity with regard to the framework we impose in the UK. Q173 Alan Keen: You deal with extreme pornography. Is it possible to draw a line as to what perhaps would be illegal and what is acceptable to some people and society as a whole however much we might dislike it? How do we draw up those sorts of guidelines? Mr Gamble: We make what we call the "reasonable person" judgment, do we not? When we introduce that to the Internet sometimes it becomes wholly unreasonable, but the Obscene Publications Act 1959 which has been about for a long time, or even the Video Recording Act 1984, is based on reasonable people making an assumption. I accept that an assumption can be high risk. Who said that we need a watershed at the time? As reasonable people we make an assumption at a particular time as to whether access by young people who are monitored and governed by parents is reasonable or unreasonable with regard to the Obscene Publications Act and the fresh approach to take account of the nuances of the Internet in the new legislation now going through Parliament in the form of the Criminal Justice and Immigration Bill. It does that as well. It is about the test of reasonableness. We already apply these tests in the real world. I do not know why we lose confidence in our ability to apply the same test of reasonableness in the online environment. Two weeks ago as a guest of Sky Television I was in a room not dissimilar from this in Second Life. My avatar was much slimmer, had a full head of hair and no double chin and so it was a very pleasant period for me, even if it lasted for only about 20 minutes. It taught me a lot and reflects what Sir Tim, the creator of the Internet, said yesterday about being part of society. When I was questioned by the avatars in the room on the panel set up by Sky 341 avatars were queuing outside who could not get in, so there was significant interest. It was all about: what difference does it make if I create a child-like avatar and have sex with it because it is not real? The conversation went down all sorts of roads about the extremities of behaviour. Two things emerged. First, when I suggested that the world we are in represents people from the real world and that perhaps there could be an undercover police officer in the room sitting beside one of the people expressing these views the conversation moderated immediately. Is that a good or bad thing? What does it say about human behaviour and psychology? It says that if people are told they can do what they want they will go to extremes. Where do we let anyone go to those extremes? Do we let them do it outside the house? I do not think we would. Second, someone said it was not understood that this was a three-dimensional world where we generated our own lives. I understand that and obviously so does Sir Tim because we live in a multi-dimensional real world where we generate real lives. The online and offline distinction with children does not exist; that is their real world. The statistics are two or three years old and are hugely out of date. Anyone who thinks that kids spend only a couple of hours online has not paid his child's mobile phone bill for a while. When you look at the mobile industry you ask: why do we license them in the way we do? Why do we create a framework for them but not in this other environment that is about how we communicate, gather, post information and lead our lives? We can make the decision either to wait and follow others or lead. We have a clear understanding because of the steps that have been taken to put in place cross-sectoral, multi-agency, law enforcement-led initiatives like CEOP. I am not an expert in this field. Many people who follow me may want to argue that point. I was head of counterterrorism in Belfast and, after that, deputy director of the national crime squad, so I have dealt with many and varied types of crime. In my experience the best recipe for reducing harm is sensible, consequent deterrent for those individuals who do not respect. What is the difference between grooming and radicalisation? I do not think there is one. What is the difference between the posting of an obscene photograph outside this building and posting it online? Very often we will try to hold to account a person who puts it outside this building but abdicate responsibility for it when it happens online. Why would we do that? Q174 Chairman: You say there is no difference between offline and online, but in one respect there is. When most of the laws governing this area were passed these kinds of activities were not even contemplated. I took part in a report on Channel 5 about two weeks ago on Second Life about paedophiles having sex with what appeared to be avatars of 14 year-old girls. I understand the chances are that they were not 14 year-old girls but probably 50 year-old men, but at the moment there is nothing in law which says that is illegal. Mr Gamble: You will know that at the minute the Government is involved in consultation on computer-generated images. If that conduct took place in Canada, for example, Canadian citizens might take the view - they have laws about it - that it was illegal. I was asked the same question in the Second Life debate. Should that be a criminal offence? The answer was that we were not sure yet because consultation was under way. Should it be investigated? Absolutely. Do you know why? If you want to have sex with a child and are fantasising about it either in this world or the real one we need to establish whether you represent a risk to real children. If you demonstrate that behaviour - classically in old police terms it would be called circumstantial evidence - you have shown a propensity for a particular thing. Why should we become seduced because it is committed in another environment? Q175 Chairman: Your bottom line is that you suspect there will be a need to legislate and update the law to take account of what is now happening online? Mr Gamble: I think some laws need to be refreshed. What is being done around extreme pornography is absolutely sensible and is an opportunity to refresh and reflect the new environment. If the police are trying to discover whether an offence has been committed there are certain principles. A public place was defined by common law many years ago as any place to which the public have access whether free of charge or otherwise,. Ultimately, we need to police those public places and ensure they are safe. This room is exactly like the Internet; it is defined in character by the people who sit in it. This room will be as good or as bad as those of us who sit in chairs around this table. There will be some who represent themselves, not just on my side of the table, and not tell the truth; there will be a given number in any room who will have criminal instincts, demonstrate previous criminal behaviour and represent a risk. That is a fact of life online and offline. I believe we need to grasp the opportunity to do something significant on the basis of our considerable collective experience over the past few years, and certainly from 1998 onwards. Q176 Mr Evans: I know that we are to visit the centre but, to give me a better idea about how you are able to cope with what you are doing already, you mentioned funding and working with industry. How many people work at the centre and how are you funded? Mr Gamble: As of today there are 115 people working full-time in the centre. We are affiliated to the Serious Organised Crime Agency for the purpose of the delivery of corporate services, so the people working there are dedicated to child protection activity. We are supported by that agency with mechanisms that allow us to maintain the building and do the things we do, for example to pay salaries and provide the infrastructure. Last year we were core funded to the tune of £4.5 million. That was red-circled and delivered to us by the Home Office via SOCA. That funding was supplemented by support benefit in kind from partnership with industry to the tune of £3.5 million. In any affiliated relationship there will be hidden costs, so the current estimates are that we would benefit to the tune of about £2 million in hidden costs because we are supported by a much bigger organisation. Last year we identified a huge increase in engagement with the public in the first few months of operation compared with what we anticipated. Reports increased by one thousand per cent. We engaged with the Home Office and additional funding of £400,000 was made available to us. We continue to grow and engage significant support from industry, but we need to invest to save. Our work is principally about protecting children online from sexual exploitation. In doing that we recognise that we have to deal with people. We have two teams, formerly the serious sex offenders unit subsumed within our organisation and its UK and overseas tracker. They work with multi-agency public protection panels and foreign law enforcement to track sex offenders who represent a threat both online and offline. We also have education teams. We learned very early on the importance of educating and empowering young people. They are tomorrow's parents. The gap that exists in what parents know and what their children know today will be much less with the next generation. Q177 Mr Evans: Do you have sufficient funding to be able to do what you need to do? It sounds as if it is growing exponentially. The number of emails has grown every year; it is nothing like what it was 10 years ago. Do you say that youngsters are being put at risk or paedophiles are allowed to operate simply because you do not have the manpower to be able to track them down as a result of funding problems? Mr Gamble: Do we have sufficient funding? No. Are children being put at risk? That is a very difficult question for me to answer. I have said we do not have sufficient funding. We have to recognise the reality of the world in which we operate. The reality is that there is no new money. This is a new phenomenon. Whilst people say that social networking has existed for years, it took off about a year and a half ago in a way that no one anticipated. The benefits are huge. I agree with Sir Tim that the very young and very old are the people who will capitalise on the huge opportunities to improve their quality of life. There must be a balance between how we engage through the Police Service, government and industry to identify critical resources that are not always about money. But do we need greater investment now? The answer to that is yes. Q178 Mr Evans: What is the backlog of cases where people have emailed you to say they believe individuals are either stalking them or are not who they say they are? Mr Gamble: We do have a backlog of cases. Q179 Mr Evans: Can you give a rough idea of its size? Mr Gamble: I need to clarify the position on the cases. First, we deal with cases at three levels. The first level is the child at immediate risk. Those cases are dealt with immediately, so none of those forms part of the backlog. The second level is those cases where we have a suspect who may be grooming. Those are dealt with in the short term. The third are all of the rest. Thirteen per cent of the reports we received from the public last year were about bullying. We are changing our website so we can divert those reports to a site that gives parental advice and child advice about bullying because in the playground bullying is a terrible thing. Once you put it onto an internet site it is even worse. I do not have an updated figure on the backlog, but I believe we have about 700 cases at level three. It may be slightly more or less. Q180 Mr Evans: But none at level two? Mr Gamble: Not that I am aware of. To clarify, you can never say until you have been through a case and examined every aspect that it has been reported properly. There is huge pressure on our referral staff who take on this work. You cannot switch off the tap. It is about how you identify it. We have reconfigured our website and the reporting mechanism; we are reconfiguring it again to make it simpler and to take away those reports which whilst not immediately relevant to us are relevant to the person reporting. That is about creating a conduit. That is why we would resist anything that duplicated effort because it would simply waste money. Much of the activity in which we are involved is about trying to work with others to deliver something collaboratively and in a collegiate sense, as opposed to all of us spending the same amount of money but doing slightly different things. Q181 Helen Southworth: Referring to your triage system and the clear and obvious focus on giving priority to serious threats of harm, what is the relationship between the centre and the different police forces round the country, and how are you managing that? I am asking about that on a theoretical basis. A few weeks ago I was in one of my local police stations when a number of young people were brought in because of content they had posted on the Internet. There had been an assault on another young person which had been filmed and posted. That was dealt with in the local police station with the young people and their parents. What is the relationship? Mr Gamble: That is quite appropriate. Our relationship with the Police Service is such that we are not direct service delivery vehicles; they are. I am a chief police officer and I hold the title chief executive officer but the policing element and authority derive from the position I currently hold. I hold ACPO portfolios on child abuse investigation, countering child abuse on the Internet and extreme pornography and also the data communications group and how one accesses subscriber data under part 1, chapter II of RIPA. Our relationship with forces is constructive, but we create pressures for them because the throughput of information we get goes out to them. There is work at hand at the minute among myself, the president of ACPO, the HMI and others to look at how we can streamline it and better support that mechanism. But when CEOP identifies a child at risk it does not turn up at the house and rescue that child; it provides the information to the local force. Collaboratively we want you to be reassured by your local police force about rescuing your local children and that is about people feeling safe. It is about dealing with criminality but delivering reassurance is something we need to do in a more sophisticated way. Therefore, we are engaged with the Police Service and every police force and with ACPO. Q182 Helen Southworth: How good is the information that comes back the other way? You have a group of people collected together who are international specialists and can identify threats, problems and dangers. How are the police on the ground developing the skills to identify that intelligence and pass it through to you? Mr Gamble: In the past 12-month period of the reports we have generated - it may be 3,888 or something like that but do not hold me to the exact number - 88% went out to the Police Service. We have begun counting reports that come back in. We see a very positive increase in feedback from the Police Service. Since August of last year we have had 800 intelligence reports come back to us from the Police Service. Therefore, 88% of the work we do is going out to UK policing - that is positive - and a significant number of reports come back in if you measure simply from August last year. I think the situation is improving. We need to tailor the service we deliver to the broader child protection teams in the community as opposed to just the police. Within the centre - the reason I do not speak with authority but the centre does - we have a number of child protection advisers who are accredited social workers bought and paid for and imbedded by the NSPCC in the work we do. They have a right of veto over any of the investigations or operations we undertake if they think that child welfare is not being put first. They have a direct line with us into social services. Police forces, be it Devon and Cornwall, Surrey, Greater Manchester and West Midlands, have seconded and imbedded police officers in the centre. Multi-agency working is not something you do once a month or once every fortnight; it is every day round the same table. That brings together collective experience that I believe is hard to undermine. For example, we have an individual from the National Centre for Missing and Exploited Children in America. He has worked there for 10 years and now leads our work on partnership. Natalie Mead who led much of the child protection work and CSR for a large UK-based IT company is now head of Safer by Design. People we pick come in with specialist skills because they add an ingredient that allows us to attack the problem from a 360-degree standpoint. Q183 Helen Southworth: You have given us some really good information around how professional bodies are upping their skills levels to be able to identify these issues and work together to deal with them and also how you work with parents to enable them to take control of their own children's safety. What about those children who are most vulnerable because they do not necessarily have families who can or wish to support them some of whom are made even more vulnerable because they no longer have a sense of personal safety because they do not have a sense of personal value? They find it very hard to report things that are happening to them because they do not believe they deserve better. Mr Nagle: That is one of the main reasons why we are working very closely with local children's safeguarding boards and engaging them in our education programme, so hard-to-reach children get the same benefit that other children have. We want to make sure that our education programme goes to every single child in the country, not just the ones in mainstream schooling but those who are vulnerable and harder to reach. The value of what we do is that we can create products that are nationally consistent and allow local people to deliver that to their kids locally. They know the ones who are vulnerable and know how to reach them in a way we cannot. We can give them the method and means to do it but allow them to deliver that message for us. Q184 Helen Southworth: Are you working with children who are disengaged? It is an incredibly difficult question to ask because by virtue of the fact they are disengaged they usually do not have contact with statutory bodies or parental support, but those are the children who can be specifically targeted by exploiters? Mr Gamble: We have worked with SENCO and many other groups. We are consulted on the Care Matters report. The issue is: how do you stretch out to those difficult places to reach to make sure you educate, empower and engage those children? Our educational products are free to every credible entity that has legitimate access to children. We recognise the need emotionally to engage them. The ThinkuKnow range of films we have produced has won numerous awards. If you include the website and programme itself, it has won nine awards ranging from the IBC awards here to the British Film Institute awards and two gold awards at the New York Film Festival. They are deliberately short and have emotional content supported by modern music so they stick with young people and the intellectual message is delivered. For us reaching children in care is important and we support those who deliver that direct service. Reaching children with special needs is also critically important and we support those who do that. We configure the service we deliver to the needs of those particular organisations that are already required by statute to do those tasks; otherwise, we would simply create confusion in the marketplace by trying to deliver directly ourselves. The last thing we need in the market is more confusion. Q185 Helen Southworth: You are focusing very clearly on sexual abuse. You have given us some information about directing other reporting activities. Do you think that the future of CEOP is to deal with some of those issues as well or is it about supporting perhaps other more appropriate bodies to deal with it? Mr Gamble: That is an interesting question and is one to which certainly my mind is not closed. Do I believe that we probably have the best contemporary understanding from a statutory organisation's point of view? The answer to that is yes. Whilst I am from CEOP and am concerned with images and we are talking about child abuse, I think that the principles established apply across the board. You could reinvent something if others felt more comfortable for that to be dealt with by something that perhaps did not have the element of law enforcement attached to it. Law enforcement is what makes us different. We have teeth. Ultimately, when those people create a threat we will find them and hold them to account and our statistics stand testimony to that. It depends on what that other thing would be. If it is an environment where people come together as a collective and agree mutual interest, achieve consensus and then do things I am not sure. There needs to be a framework that lays down the minimum standard. The minimum standard cannot be agreed by those people who occupy the enterprise park because I believe that ultimately public will be put in jeopardy. It will gravitate to the lowest common denominator and no one will be thanked for that. We have built something that is credible. On your visit I would welcome any of you robustly to test anything we have said here to lift the stone and apply the principles you see there to other areas. If it is an abusive image and it passes the "reasonableness" test and you can be prosecuted for it under the Obscene Publications Act then you will be prosecuted for it if it is online; if it incites an act of terrorism or another criminal act then you will be prosecuted for it. If it is something that a reasonable person of 18 would see in a cinema then it needs to be treated in that way wherever that manifests itself online. If those people want to behave reasonably and ethically as an over-18 access area they must make provision to ensure that happens. Simply to abdicate responsibility and say there are other small parts of the Internet that will not comply is like saying that we will not civilise any town in the wild west because there are certain elements that will not comply and we will try to get round it. Fix the biggest part and then concentrate on the smallest. Mr Nagle: They key point is not to confuse parents of children any further. In the same way that we do not have a different number for different types of crime, why do something different online? There should be one reporting mechanism so people and children understand they can go to that. We must make sure there is not duplication. We want to avoid confusion among the general public which can easily happen. Mr Gamble: If you contact our report page today we will divert you automatically to the IWF; if you come to us on bullying we will send you to There4me with the NSPCC. If you need to you will be able to talk to someone. It is about creating a sensible portal where people can go. What can government do? It is about awareness raising which is critical. We go into schools and do cascade training. If you want to raise awareness in one place quickly to make a difference the answer is television but that costs money. Q186 Chairman: You praised both Microsoft with MSN and AOL for the work they are doing. What about sounding out other companies like those that provide social networking sites such as Facebook and Bibo? Do you think they are doing enough to protect young people? Mr Gamble: Very few people are doing enough. Those people who have in place a mechanism for reporting abuse where danger manifests itself are doing a good job and the right thing. I am absolutely positive having talked to Haymoo and MySpace that they are working towards the creation of a safer environment. I believe that we should be able to come to some form of accommodation with them. I hope it is much sooner rather than later because at the end of the day we have the frustrating position where people say they need to talk and engage and we do that, but talk is cheap and money buys whisky. Ultimately, we can talk only for so long and then we need to see action and not words. We are coming to the point where we expect to see action very soon; if not, then the answer to your question concerning a broad range of groups would be significantly different. Q187 Chairman: Are there any who prove unwilling to co‑operate with you? Mr Gamble: Yes. Q188 Chairman: Would you like to tell us who they are? Mr Gamble: I would not. Are people unwilling to work with us? In my experience and judgment some people who say they are willing are not but they are the minority although a difficult one. It would be unfair and unhelpful for me to put a corporate label on that. Q189 Chairman: Are we talking about specific ISPs? Mr Gamble: We are talking about specific members of the online industry as groups. I will not sit in front of you and say that everyone engages with us 100% because you know that is not true. Are some people difficult and do they avoid engagement? Yes, they do. Is that down to individuals within the organisation or to a greater organisational imperative? I am not sure of the answer to that question and that is why I am not prepared to malign any organisation on the basis of my view having engaged one or two individuals within it. That would be unhelpful and extremely destructive. Sometimes we talk about industry as if it is a huge single entity, but it is not. As with every area of life, be it Parliament or elsewhere, one has the good, mediocre and bad. Many industry partners are very good; some are mediocre and some are just not good. Q190 Chairman: But if you are to obtain a level of protection it requires presumably that all the various players in the industry co-operate. If there is one who does not that will immediately act as a magnet for all the people who wish to take advantage. Mr Gamble: Let us ask ourselves: why would there be one, two or three who do not? If you have a veto you can exercise it. If in an enterprise park one business says it will not comply with health and safety or moderate its amusement arcade they will all play to the same rules. That is why it is unfair to some industry partners who do the very best for the very best of reasons that others do not. Unless there is a framework within which they work you disadvantage those who do the right thing. Q191 Chairman: But if there are one or two who refuse to co‑operate what can you do about it? Mr Gamble: We can further engage and lobby individuals in government and industry. There are individuals in industry who believe that there should be a better framework in which to deal with this. I am the father of three and I head up the Child Exploitation Online Protection Centre. I will not let anyone who represents a risk for children to hide behind me. There come a time when you say that enough is enough and you believe that this or that individual or company is not constructively engaging, but we have not yet reached that time. Q192 Chairman: Perhaps I may suggest to you that naming and shaming will possibly have the greatest influence on a company to come into line. Mr Gamble: That is something I have resisted. My level of resistance to that idea is being reduced as time goes on, but I do not think we are there yet. We have an opportunity in what you are doing and in the Barron review. Tanya Barron understands children and this environment. No matter what, we all come to this table with our own baggage, so I come from a particular point of view. That does not mean - I accept this - I am right. I give you my experience and understanding; others will come with their own. Tanya has engaged each and every one of the individuals operating in the field and has come to it with fresh eyes that perhaps are not tainted by negative or positive past experience. I look forward with interest to seeing what comes out of that and to reflect on how we can play a part if we believe it is constructive. Q193 Helen Southworth: You talked about the environment being the same and said that it was all society. You also referred to a young person going into an off-licence and purchasing alcohol which would be dealt with under the law. One of the matters that has quite impressed me in terms of management of the night economy has been the policing concept of the 10 best and 10 worst; that is, you identify best practice which is supported and encouraged and identify those people who do not choose to participate in best practice and have what you suspect is poor practice and so there is police focus on those premises. Have you thought about that sort of thing in terms of internet providers and the industry, that is, to choose whether they want to be among the best or to have a lot of police focus? Mr Gamble: We have not thought about it in those terms, but because of limited resources across the Police Service we are intelligence-led. We will manifest our interest where we know there is a threat or we believe the environment is such that it creates a threat. I spoke at a school just on the outskirts of London yesterday and a 17 year-old who had done some research for the presentation - she did it, not me - said she had gone to a site designed for people below the age of 10. She joined up and gave a false age. She asked 20 whether they would be her friend and 15 accepted. These are very young kids. Externally, we have to know about that before we can deal with it. Is that a one-off? When you advise that site of the issue do they listen to that advice and work with you to construct a Safer by Design environment? If so, that is good. Do we go to a position where in our annual report we show the top 10 and the 10 areas where there is the greatest danger? First, we have to remember that we are dealing with a range of commercial entities, some of whom are outstanding and some of whom will immediately resort to litigation. If you undermine their market value be prepared for a battle in court. We debate whether or not the law applies in the virtual world all the time but I do not see that taking place when it has to do with the commercial viability of a particular entity, or one commercial harm compared with another in that area. There is no problem about one suing another over virtual or real space. We need to be conscious of the environment in which we live. If government recognises that it would be valuable to highlight poor practice, in the same way that Her Majesty's Inspectorate of Constabulary will inspect police services and they will be scored as being satisfactory or not meeting the standard, then perhaps that is an excellent idea and we will certainly take it on board. Helen Southworth: Perhaps this is something for industry to look at. Q194 Mr Evans: How dangerous is the Internet for children? Mr Gamble: The Internet represents huge opportunity and risk. The issue for us is managing the risks so they can capitalise on the opportunity which outweighs the risk. Q195 Mr Evans: Are there any sites out there that come to your attention time and time again as being the most dangerous ones for children? Mr Gamble: The most dangerous sites are the ones we occupy and close down. For a variety of operational reasons I would not highlight where we operate under cover because that is how we do it. It is more to do with trends and themes. Many of the social networking sites, for example, will be about venture capital and investing in something to see if it works. They can be undermined by young people moving from one area to another. My saying an area is bad may increase the throughput of traffic and thereby it will be able to attract more advertisers because young people being young people will want to go somewhere else. Q196 Mr Evans: Without naming it, is there a site that takes more of your time than others? The paedophiles seem to know what the sites are and tend to congregate on specific sites. Mr Gamble: I think that would be unfair. The paedophiles in the real world will go wherever children loiter, whether it is outside school or a youth club or swimming pool; they will do exactly the same thing online. Wherever young people go they will follow. The Internet did not invent this. My office is in Pimlico. There used to be a photographer's studio half a mile away run by a Henry Hiller. His premises were raided by the Metropolitan Police and 132,000 images - many of his own young sons - printed on glass were recovered. He was raided in 1874. The Internet did not invent this and is not responsible for it. People will break the law online or offline; people will post things that are inappropriate online or offline. What we have to do is adopt a sensible position where we all accept our responsibilities: government, industry, law enforcement agencies and parents. We need to collaborate sensibly and make it as easily accessible as possible. Q197 Mr Evans: Facebook is probably now too old for youngsters because a lot of politicians have gone onto it and probably frighten them off, but Bibo and maybe one or two other sites - I do not have the faintest idea what they are - are the place where youngsters will go. There is also a social responsibility, is there not, for the owners of those sites to give advice to youngsters who go on to them? Mr Gamble: Absolutely. To be fair, we do see some very constructive behaviour on those sites and we have engaged with them. As to those sites, why is our report of abuse mechanism not in there? Why is it not alongside the traffic, in other words when the children go in? Why is it not where the predator can see it so they are aware this is a policed environment? Q198 Mr Evans: I know you do not want to name these sites, but the fact is that if there are any sites where we know youngsters go onto and they refuse to put up your reporting links to them those are the ones that are dragging their feet; they are not playing ball? Mr Gamble: Before we jump to conclusions, in some cases those sites are engaging with us at the minute about how best to do it, so we are reconfiguring what we do and they are helping us with that. We need to be clear about this. Do we want it on all sites? Yes. Do we need to listen to industry's concerns so we deal with more than simply the issue of sexual abuse? Yes, we do. Q199 Mr Evans: I am with the Chairman on this. I think that you should consider long and hard that if there are sites out there that youngsters use and the owners of the sites are not prepared to play ball and take social responsibility you have a responsibility to name them. Mr Gamble: I agree with you, but that is not the issue here. I am not going to give the name of one social networking site or another on the back of this. I am frustrated by the length of time it takes when we engage with some companies as opposed to others to make progress around child protection. We need to recognise that this is a shifting marketplace where personalities and ownership move. There needs to be a consistent framework; otherwise, we sometimes jeopardise legitimate business that is working with us by saying the wrong thing at the wrong time. Should we create a list? I would welcome government inviting me to create a list of those cases where we have engaged positively and received positive support and those cases where we have not. That is an issue for my government sponsoring department to consider. Ultimately, we are genuinely moving forward. The social networking sites are a new phenomenon. I do not believe we understood them properly. The advent of WebPoint 20 self-generated material changed the dynamic. For goodness sake, we should not be further seduced by technology or technologists. Governance is not about nannying but creating safe environments where young and not so young people can capitalise on the opportunities. We need a better framework because the present one is not as good as it should be. Q200 Mr Evans: You talked earlier about publicity and sometimes the lack of it because a lot of people who want to prey on children do it because they think they have anonymity. Now and again there are high profile cases like Peter Townshend or Chris Langham where, all of a sudden, you realise what they have been doing. They are not anonymous and can be tracked down. Do you think that the media have a responsibility to give greater publicity to the fact that these people who prey on children or try to groom them do not have anonymity and in a number of cases these people end up with custodial sentences? Mr Gamble: Absolutely. Those who saw Crimewatch last night would have seen the Son of God operation which involved a site called Kids the Light of our Lives. That investigation was co‑ordinated and delivered through the Child Exploitation Online Protection Centre and the Virtual Global Task Force which is a law enforcement alliance across Canada, America, Australia and Interpol. Seven hundred paedophiles were identified around the world and already in the UK 120 have been prosecuted through the work we are doing. The issue of anonymity has gone. We may not find you tomorrow but we will knock on your door one day in future because the one thing for sure about this environment is that you leave a forensic fingerprint. When I joined the police nearly 30 years ago the first thing I was taught in the training school in relation to forensics was that every contact left a trace. That is never truer than in this environment. Take child abuse as an example here. Child abuse images are a symptom of crime; they are a symptom of the fact that if someone has hurt a child, photographed it and used the image, sometimes as a commodity and sometimes as a means to engage and influence others, it does not matter what it is. You can take any real world scenario and police or govern it in the virtual world. We in the UK can choose to wait and follow or to lead. I believe that because of our collective experience across industry, government and policing we have an opportunity to lead it. Chairman: Those are all the questions we have. Thank you very much. Memoranda submitted by the Internet Service Providers' Association and BT Examination of Witnesses Witnesses: Mr Nicholas Lansman, Secretary-General, Internet Service Providers' Association, Ms Camille de Stempel, Council Member of ISPA and Director of Policy, AOL, and Mr Mike Galvin, Managing Director, Global Customer Experience Programme, BT, gave evidence.
Chairman: I welcome to the second part of this morning's session Nicholas Lansman, Secretary-General of the Internet Service Providers' Association, Camille de Stempel, a council member of ISPA and also Director of Policy at AOL, and Mike Galvin, Managing Director of Customer Experience at BT. Alan Keen will begin. Q201 Alan Keen: I presume that you favour quite a lot of self-regulation on the issue about which we are speaking today. Where should the dividing line be in relation to self-regulation? Mr Lansman: Perhaps I may start by giving a little bit of backdrop to self-regulation. ISPA has always been very supportive of self-regulation in certain circumstances. In the very fast-moving world of the Internet and all the changes mentioned this morning in terms of social networking sites - just changes generally in the Internet and how it has been used - self‑regulation has proven to be an effective way to regulate in certain circumstances. A good example of that is that 11 years ago ISPA was a pioneer in the UK's internet industry in creating a code of practice that I am proud to say has been adopted in other countries in the world. Those codes of practice have been useful to an extent. One part of the code was for the industry to set up the Internet Watch Foundation in the first place. I think everyone will agree today that that has been a tremendous success. However, self-regulation can go only so far. We have seen examples today where regulation is needed sometimes. It is needed, for example, with computer-generated images to give clarity in that field. We have talked about extreme pornography. It is possibly needed there as well. However, care must be taken that this regulation offers what is required to the police to give clarity and the regulation must be implementable; in other words, it must do the job and be enforceable and useful. Care must be taken that when new laws are needed they come about in the appropriate way. I know that ISPA and my colleagues here have been very much involved with various government departments when new legislation has been put forward to make sure it can be put into practice properly. Mr Galvin: I do not think you would have seen the pace of our co‑operation with legislation because inevitably it goes more slowly. Self-regulation has accelerated to the point where you get a much better view of what is possible in the industry; in particular, you develop a set of best practice. You heard Jim Gamble talk about best practice earlier. I think that self-regulation can take you to that point. The important issue for legislation is clarity of what is right and what is wrong because ultimately all self-regulation looks back over its shoulder to the law to say what is right and what is wrong. That is where there is a role for legislation. Q202 Alan Keen: You mentioned the Internet Watch Foundation which provides a list of banned websites. It led us to believe that 100 ISPs do not take any notice of that. Why? Does that not damage self-regulation? Mr Lansman: You are talking about the blocking of certain URLs by the Internet Watch Foundation. Of the large consumer-facing ISPs in the UK I am not aware of any that do not take the list provided by the Internet Watch Foundation. The source of that list is trusted and the ISPs receive it twice a day. Mr Galvin can probably go into this in a bit more detail in a moment. There are ISPs that provide purely business services and would argue that their audience is so different that they provide their own mechanisms to protect their staff. These are early days in terms of the concept of blocking. It seems to be working very effectively. There is encouragement on the part of ISPA to make sure that as many ISPs as possible take the list. I believe that work is taking place with ISPA and the Home Office to encourage ISPs to develop mechanisms to do so. Q203 Alan Keen: Everything moves so fast in modern technology and the habits of individuals who use it. I well understand that self-regulation can move quicker than anything else, but where do we need more regulation? In this fast-moving world what do you understand to be the areas where regulation needs to be imposed from above? Mr Galvin: Let us take the example of the IWF list that we have just talked about. That list is founded on the Protection of Children Act which has, unusually for UK law, an exceptionally clear definition of what is and what is not legal in terms of child abuse images and makes actual possession of such images illegal. There are very few other such things in our law that are treated so severely as possession. In those circumstances it is possible for the Internet Watch Foundation to develop a list of what in their opinion - after all, they are only an industry body - would constitute illegal images and it is possible for them to distribute that list and for ISPs to blacklist those sites on the basis of the IWF list. If you then step back from child abuse images it is very difficult to find other parallels where there is so much clarity about what is and what is not legal. I cannot think of any now. It would be so much easier to produce a list if the law was clear in different areas. There is a role for the law to make much clearer what is and what is not acceptable. If you turn to almost any other area and look at other laws there is always an element of doubt. Setting up a site with these images and downloading them may be legal but what you do with them after they are downloaded may be illegal. Therefore, the law lacks clarity. There is a role for law and regulation to provide a much greater degree of clarity in the online world to enable people to act on what is right and what is wrong. Mr Lansman: Possibly a picture has been painted that somehow the internet industry does not want regulation, but in certain circumstances the opposite is true. The need for clarity is quite important for the internet service provider industry. One example is the ability to push back on "judge and jury", that is, the concept that the ISP has to interpret the law where it is not clear or there could be grey area. That has been a frustration for the internet industry for quite some time. Sometimes regulation can clarify the position and make the job of ISPs much easier to enforce their own terms, conditions and rules. Q204 Alan Keen: Is there a role for Ofcom? Should Ofcom be involved or should a new body be set up to help to co‑ordinate it? What do you see as the next steps to be taken? Mr Lansman: Ofcom is the body that looks right across communications broadcasting and indeed is the regulator. It depends on the aspects of the area in which you want Ofcom to become involved. Obviously, they would be in a better position to offer that advice. I think the issue is that if you are talking of defining content, whether extreme pornography or other areas - computer-generated images - should come within the law, it is really for Parliament to give a steer on that. There are quite a few bodies and groupings where the industry takes part with government, law enforcement, charities and Ofcom to discuss these issues on a regular basis, but ultimately Parliament should make the judgment call on whether or not new legislations is required, and opportunities like this to give our views are very helpful and will it is hoped provide information to parliamentarians to make those decisions in future. Mr Galvin: Currently, Ofcom does not believe that it regulates the Internet. If Ofcom or any other body were to be established to regulate the Internet you would have to give them terms of reference; you would have to say what their powers were and clearly indicate what was expected of them and what level of performance would be required from such a function. Talking for our customer base - the internet industry and UK general public at large - I do not believe there is yet a consensus on what that level of regulation or intervention would be. That is something which Parliament would have to decide and agree upon. Q205 Alan Keen: You heard Mr Gamble hesitate to name names when Nigel Evans asked him about this a few minutes ago. If you were forced this morning to give us an opinion - we want your views before we put our report together, which we hope will influence them - what would you like us to put in the report about the extent of self-regulation as against maybe even a new body to enforce it upon those with whom he is beginning to lose patience? Mr Galvin: This is a fast-moving technological area. For example, Facebook was mentioned today. Even one year ago no one had even heard of Facebook. BT has been operating an internet service since 1996, that is, only for 12 years. It is a relatively recent innovation. I believe that self-regulation has a very important role to play to ensure we can keep pace with technological changes and keep on changing best practice as new services and new threats in terms of child protection, general crime and best practice threats on the Internet come along. Legislation has a role in defining what the minimum standard is, if you like, and enshrining best practice when there is sufficient consensus around what is technically possible and what is acceptable to the UK public at large and Parliament, and legislation then has an important role in setting the gold standard. If you look at self-regulation in any aspect of industry worldwide you will always find people at the front pushing for it and saying more can be done and there will be laggards at the back who have not yet caught up. Therefore, the minimum standard will be set by legislation. Mr Lansman: In terms of what should be in your report, Mr Galvin has espoused the balance between self-regulation and perhaps the need for new regulation. What Jim Gamble was calling for, quite rightly, was more resource and structure so that he and colleagues in law enforcement could do the job of policing, which is entirely correct. I think the internet industry has always been reluctant to take on the role of policing. ISPs. Companies that offer services such as websites and social networking are not the police but commercial bodies which are there to provide a service and do their best to co‑operate with law enforcement, government, Parliament and so forth, but ISPA would certainly echo the need for more resources to be able to police properly and accept that some of the crimes in the offline world apply in the online world, and vice versa. That is entirely right. I believe that the co‑operation the industry has offered law enforcement and government has been positive. Maybe there are one or two companies that have been less than helpful. ISPA's membership comprises just over 200 members who represent about 95% of the whole industry. If between .5% and 1% are not playing ball but the others are doing between a mediocre and very good job that is not such a bad position in which to be. Ms de Stempel: I would like to highlight some of the work that has been done. For example, through the Home Office task force we have developed some guidelines around social networking. The conversation was the most interesting bit of this debate because we could get practice out of all our competitors and then integrate them into our products and make sure they delivered what we were aiming to do. Some part of the approach we have taken allows flexibility to suit different ISPs, content providers and social networking. The aim is to protect a child but then we might have different ways to go about it. Q206 Mr Evans: I am Chairman of the All-Party Identity Fraud Group. Somebody from KPMG came to see me last year and told me about the deep web that operates at a different level. Those who need to know where it is can get access to it and they trade credit card details, dates of birth and passwords on it. How it operates is quite amazing. Are you aware of this? Can anything be done to block people getting onto the deep web to do this? Mr Galvin: There is no specific network such as deep web. One has an informal group that uses a variety of tools including open access to the Internet but backed up by sites - things like cryptography using proxies to try to disguise identities, et cetera - to swap information illegally. You see this in a number of crime areas. Financial fraud is the main one, but you also find the paedophile community taking extreme counter-surveillance activities to avoid the detection when they do this. They use facilities in different countries, hidden identities and so on. There is widespread use of cryptography. These are not networks in the sense of connected wires but people who have common applications and processes to share this data illegally. Q207 Mr Evans: Are you able to do anything to block them? I guess you have to find them first. Mr Galvin: The industry can and does co‑operate very closely with law enforcement authorities to provide technical information for the detection of this activity. As an industry we are not part of the police; we do not go out and look for illegal activity and check what our customers are doing. We act as a support for the police force in that role and provide them with technical facilities for the detection of that activity. Quite often the types of activities you describe might also cross several international borders. You find that you are co‑operating with your own local law enforcement authorities which are also co‑operating with counterparts abroad which in turn are co-operating with industry partners in those countries. Q208 Mr Evans: Would it be unfair of me to summate what we heard earlier today and in the past in our inquiry that in some cases ISPs will not take action to block access to sites because basically they say they do not adjudicate on the law? If it is illegal they will take action; if not they will do so and pass the buck to Parliament. But if they were to take action on their own they would be afraid of the commercial advantages that would be won by other ISPs who did not take any action? Mr Galvin: I have heard of instances of ISPs outside the UK refusing to take down sites because they are not illegal. There are many examples of that. For example, you might go to a site that is freely trading MP3 material and the ISP refuses to take it down because it says that what is being done is not illegal. Within the UK that is much more unusual. I cannot think of a single example where an ISP has refused to take down a site once it has been requested to do so. Quite often these requests come via the IWF or the local police force. In some cases we have taken down sites when individuals have requested us to do so because it contains what they regard as personal information. I cannot think of a recent example over the past few years where that has happened in the UK. Mr Lansman: Obviously, there is a regulatory backdrop to notice and take down which is the European e.commerce directive which is transposed into UK law. For many years that process has not been clearly defined in UK law; it does not say who can give notice. Having said that, over the past 10 years almost it has proved to be quite a robust system in the UK in the sense that ISPs that host material do take down contents or other sites. The difficulty is that a lot of the sites about which you are probably most concerned are not hosted in the UK, so one problem is the difference in concept in terms of going through the law enforcement of other countries and getting to the ISPs in those countries. The issue is also about making decisions on what is harmful. We have talked about images of child abuse where the position is clear in law. There are other areas where the position is less clear; and there are areas of harm at which I believe the whole of this evidence session is looking. Obviously, the difficulty is deciding whether it is harmful and to whom. Is it harmful to a six year-old child, a 16 year-old child or an adult? In addition, quite importantly you have extended the scope of this evidence session beyond content itself to things like fishing, spam and other areas of abuse. I think that is an area in which ISPs have been very robust over the past several years. They have been looking at new issues such as fishing and tackling those issues. An earlier example was financial fraud. That is dealt with in co‑operation with law enforcement, government, ISPs and the banking sector and it will be an ongoing battle. We have to accept that many of the issues we raise today are not ones that can be quickly solved. It will be a permanent battle based on co-operation by the internet industry itself but lots of other sectors of society including consumers themselves to address these issues as these and new problems emerge that we cannot even think of today. Q209 Mr Evans: Do you believe that things like Net Nanny and other security software are effective? One hears of examples where sometimes simply because normal sites contain certain wording - perhaps it is to do with breast cancer - they are blocked because of one word. How effective is security software in protecting people? Ms de Stempel: They are very effective but they are built around artificial intelligence and so, like anything, they need to learn that "Père Noël" in French is "Father Christmas" in English. It might be blocked because the software does not know about it. That is why all the powerful controls that we offer to ISPA members have a mechanism whereby people can feedback on under-blocking and over-blocking. Something is changing; an address has been sold to some other site which was good before and now is not good. All that requires participation by users. But one of the things we have found with parental controls is that they are very robust but are under-utilised. Some of it we offer for free; some are offered for a very small charge. We advertise it; we make it a unique selling point. Although we market it there is still under-utilisation. We work very closely with Tanya Barron but also with many of the industry initiatives to see how better to educate parents as to the usefulness of parental controls, making sure it is about tailoring an online experience rather than prohibiting things. How can you get to good sites in a timely manner? If you search for "bomb" you get things about history rather than information about how to make a bomb. Q210 Helen Southworth: Perhaps I may ask BT how much of its annual budget is spent on online child protection. Mr Galvin: I do not have the answer to that off the top of my head. There is a considerable investment in online child protection with the facilities we provide within the browser. Q211 Helen Southworth: If it is considerable what is the approximate figure? Mr Galvin: You are asking me to make a quick mental calculation. One would be talking of something in the region of six figures. It would include systems like Clean Feed. Q212 Helen Southworth: What would be the six-figure amount? Mr Galvin: It is about £1 million, possibly more. You would have to take into account the fact that where we have logos on the home pages, for example, it displaces advertising revenue. It depends on whether or not you take into account that type of cost. Q213 Helen Southworth: I am focusing on your research and the people who are working directly on the issue of child online protection? Mr Galvin: We have an abuse desk which deals with issues that come from our customers. Q214 Helen Southworth: How is that staffed? Mr Galvin: It has permanent BT staff and is based in the UK. The staff vary but typically it would be in the range of 12 to 15 people. Q215 Helen Southworth: Is that seven days a week 24 hours a day? Mr Galvin: It is online and on mail and it is an office hours service. We also have frontline staff providing a service 24 hours a day seven days a week who are trained help desk people, if they are not trained abuse desk people. They would deal with issues that came to them and would take that to the abuse desk. Q216 Helen Southworth: It would be very helpful if you could let us have the annual budget for specific work on online child protection. What is the position with AOL? Ms de Stempel: We do not have a figure because it is integrated in any of our products. When we develop a product we look at lots of different functionalities including child protection. For example, we have a reporting mechanism for all our products. Q217 Helen Southworth: But you do not allocate anything specifically for child online protection; you do not have anything ring-fenced for that specific purpose? Ms de Stempel: For example, the equivalent to BT's Clean Feed would be part of the cost. We have law enforcement support which would be another part of the cost, but they do other things as well. If we apportion a particular cost to AOL staff, some of their work would concentrate on child protection and some on consumer protection. Q218 Helen Southworth: I am thinking in terms of what gets measured gets done. Ms de Stempel: It gets done because it is in the DNA of what we do. Q219 Helen Southworth: But you cannot quantify it at all? Ms de Stempel: No. I can ask but we look at this issue globally. For example, like other ISPs we contribute to the IWF and that would be one of the costs. Q220 Helen Southworth: Does ISPA have a specific budget for child online protection? Mr Lansman: We do. It is perhaps unfair to judge big corporate companies for failing to split up budget lines into the minutiae of detail. However, I do take your point which is very important. Q221 Helen Southworth: I do not think child protection online is "minutiae of detail". Mr Lansman: The big corporates will have multi-billion pound budgets. I think that splitting up-------- Q222 Helen Southworth: I do not know whether their customers would think the same. Mr Lansman: I volunteer to go back to the membership and suggest that we try to provide the Committee with some information on that. I can see where you are coming from. As to ISPA itself, it is a not for profit trade association and every year it allocates £20,000 out of a sum of between £200,000 and £300,000 which is the turnover from membership fees in the main, so somewhere between 10% of the revenue of ISPA goes to the Internet Watch Foundation as a fee. In addition, a great deal of the time of ISPA staff and members is spent on secondment to various charities, CEOP and work with the Home Office. The problem is one of trying to allocate an enormous amount of time and resource from people whose jobs are to deal with lots of things where child abuse images and child protection are just one of the issues. It is more a problem of unpicking the financials than a lack of willingness to do it. Q223 Helen Southworth: I want to ask about notice and take down policies for potentially illegal content. Once something has been reported as potentially illegal how long does it take before it is removed? Ms de Stempel: It is a matter of 24 hours. We have a system similar to that of CEOP and an escalation process, for example, for child abuse images if it is flagged as such. Unless people flag us as to exactly what it is, all abuse might end up in the same box, but that would be removed from our service, so it will no longer be available to anyone else who has not opened an email where it is attached and law enforcement then picks it up for us. Mr Galvin: It is done in 24 hours. Often to speed up the process when something is reported to us rather than have a debate about whether or not it is illegal it is a lot quicker to say that under our taste and decency policy we have the power to remove it immediately and not get into a debate about the legalities of it. Quite a lot of the notice and take down occurs under our taste and decency policy rather than a debate about whether or not it is illegal. Q224 Helen Southworth: Is 24 hours an industry standard? Mr Lansman: The law defines the notice and take down procedure as "it should be removed expeditiously", so there is no clarity on what the time should be. But on issues such as child abuse images for the industry the answer is "as quickly as possible". We have referred to 24 hours. I think there are other types of content where there must be a greater reflection, but I think that for child abuse images it is done as quickly as possible and 24 hours is an industry standard. Q225 Helen Southworth: Are you confident that it is met? Mr Lansman: It is best practice. Q226 Helen Southworth: You just added "best practice" as I asked whether you were confident it was met. There are issues as to whether something is best practice or it is the standard. Mr Lansman: I am confident that the Internet Watch Foundation which obviously will deliver the notices has never reported anything other than speedy co‑operation with industry. Q227 Helen Southworth: What about users reporting content that they find distasteful but is not necessarily illegal? Ms de Stempel: We have very stringent conditions of service attached. Each member of ISPA has its own standards of service, so if it breaches any of our terms of service it will be taken down expeditiously as well. Q228 Helen Southworth: For example, bullying or pro-suicide sites? Ms de Stempel: Absolutely. If it is hosted on our service and is against our policy it will be taken down. Mr Galvin: Absolutely. I think the importance of a taste and decency clause in the terms and conditions is that it gives you much more freedom of choice about what sites you host. We and all the reputable ISPs have a very low bar for what we consider to cross the taste and decency line. A pro-suicide site would make it over the bar by miles. We are now taking down things that would cause offence, for example the publication of people's personal details. Basically, the taste and decency policy is defined as anything that causes distress to our customers. Mr Lansman: ISPA's position has been to help quite a lot of the smaller ISPs which have acceptable use policies (AUPs). This has developed a best practice template for an AUP. Obviously, the issue about "harmful" is one that is open to interpretation. To whom is it harmful? I think it is right that different ISPs through their exceptional use policies can take slightly different views on what is acceptable or not to their service. There are ISPs that provide access to the Internet and take a much stricter family view where their communities are more geared to families and there are other ISPs which will take a slightly more open‑minded adult view, accepting that customers might be in a different community. I think that is right because it is difficult to get the balance right between what is someone's harm and another's freedom to look at. Ms de Stempel: Within those constraints we might have even greater granularity as to some of the things that are allowed in kids' chat rooms or in a football chat room after 11.30 when pubs are closed. The language we would allow in football chat rooms after pub closing is very much more permissive than in a child's chat room. For example, if you say a bad word beginning with "f" in a kid's chat room you will get a warning about that language. If you use the same word after 11.30 at night in a football chat room it may be seen as banter rather than a bad word. Q229 Helen Southworth: How would you handle the fact that irrespective of what time it is put on it can be accessed at any point at a later date? Ms de Stempel: Because we have reporting mechanisms. If somebody reports me for saying a bad word it will have a stamp as to where I was exactly on AOL's or any other service and at what time. Q230 Helen Southworth: But the fact is that you have a football chat room which you say takes place after the pub is closed and is put on a site at a specific time. Ms de Stempel: Yes. Q231 Helen Southworth: You do not have a watershed like television. If television puts out something after nine o'clock there is a watershed but if it wants to repeats it next morning at nine or 10 o'clock it cannot put it out again, whereas yours will remain on the site; you cannot hold the watershed. Ms de Stempel: No. A chat room has gone as soon as the page has gone, so it will not remain on the site. Q232 Helen Southworth: You work on the assumption that by the time other people add to it the site will have disappeared? Mr Galvin: Yes; it lasts for only a few minutes and has temporary content. Mr Lansman: You are alluding to the difficulty that the Internet is a global environment and someone's watershed in the UK is not someone's watershed in America. That is an issue because of global time differences and the fact that the Internet is available everywhere at all times. Mr Galvin: What is regarded in this country as bad language may not be so regarded elsewhere. Q233 Chairman: Are your chat rooms moderated? Ms de Stempel: For children, absolutely. Q234 Chairman: Not the football chat room? Ms de Stempel: You can call in someone to help you if something is happening in the football chat room. Q235 Chairman: I can set up a chat room now. There are lots of sites that allow individuals to set up chat rooms that cannot possibly be moderated? Ms de Stempel: No. Q236 Chairman: You are operating a walled garden but outside of that it is a free for all? Ms de Stempel: It is not a free for all; it is about the people who are in the chat room. That is why we build those reporting mechanisms. We have different approaches to the reporting mechanisms to which Mr Galvin referred. Different ISPs or content providers have different approaches to the concept of exactly where it leads but everyone has a reporting mechanism. The important thing is to be able to report an activity on one's service so the service provider can take appropriate action. Q237 Chairman: But if I go onto one of the websites which allows the creation of chat rooms - one is called Chatsy - it has no system whereby I can report abuse. Mr Lansman: You are right in pointing out the difference between an internet service provider and a chat room which may be a website set up by anyone, including yourself. Where an ISP such as AOL provides a chat room service for children and so forth it can monitor and moderate it and make sure it is safe for its community. If it is set up by anyone or another organisation it has to be treated as a website and if necessary end users can filter so as not to go into that website. Q238 Chairman: If you were moderating a children's chat room and you became suspicious that somebody who came into it was pretending to be a child would you report it to the police? Ms de Stempel: Absolutely. Q239 Chairman: Therefore, you are proactive in seeking out abuse? Ms de Stempel: We are not seeking it out, but if someone is seen to be behaving inappropriately we will report it. Not long ago we reported a message on the message board which was not illegal or against our terms of service; it just smelt inappropriate. We reported for advice as to what we should do. We take it down just in case but then we report it for advice. We have to build on our experience as commercial people. Q240 Chairman: But would you report to the police the identity of the person who posted it? Ms de Stempel: We report all the information they would need to serve us with a RIPA notice. Q241 Chairman: Every PC has an identification number which will allow it to be identified. Would you supply that? Ms de Stempel: Any connection has an IP address which can come back to a subscriber. Q242 Chairman: You would supply the information that would allow the police to identify that subscriber? Ms de Stempel: Yes. Mr Lansman: On service of the appropriate legal notice. Mr Galvin: You will get back to the internet connection, so it does not tell you who the person on the PC is; it will just give the location of the particular connection. Q243 Chairman: It would be the account holder? Mr Galvin: It depends on the individual ISP but in most cases, yes. Q244 Chairman: But it is your policy which is industry-wide to reveal the identities or account holders of the IP addresses only when served with a legal order? Ms de Stempel: Yes. We have a very good, robust and swift process. We have single points of contact in all the forces. They have a system of priorities as to whether something is a risk and we give the information straight away, or it can wait. The police then decide where they need their investigation to go. Mr Galvin: It protects the individual and is also a system that works very well. We have an agreement about how long we keep the information post any particular session. You need to know the date and time as well as the IP address to be able to identify the individual. IP addresses change as people connect and disconnect from the network. We have a very robust agreement with law enforcement authorities. When they want information quickly we have a process for that and also a process for pulling out archival information. It is now quite a well run process. Q245 Chairman: Short of a legal order from the police, if you saw somebody behaving inappropriately against such terms and conditions would you terminate that account? Ms de Stempel: If it is against our terms of service, yes. Q246 Chairman: The making of inappropriate suggestions in a chat room would be against the terms of service? Ms de Stempel: Absolutely. Q247 Mr Evans: How many accounts did you terminate last year? Ms de Stempel: Offhand, I do not know. Mr Lansman: The punishment must fit the crime. I think it is appropriate that ISPs have a variety of policies to deal with their own users and customers. I know that some of them and AOL will give warnings and wait for behaviour to be modified before taking the ultimate sanction. Q248 Chairman: The approach would be two or three strikes and you are out? Mr Galvin: It depends on what they have done. For example, if you are hosting a suicide website that is not two or three strikes and out; that is just out. If someone was using bad language or perhaps sending difficult emails, which would be a type of abuse query we would receive, we might warn them and if they did not stop they might be out. Q249 Chairman: Both of your two companies were commended by Mr Gamble as examples of very good practice, but we are concerned with the ones who are not very good examples. Therefore, your approach of monitoring and giving notice of inappropriate behaviour or co‑operating with the police does not appear to be a universal practice. Do you believe that you are being let down by some of your competitors? Ms de Stempel: I do not have the feeling that other people are not co‑operating. In the UK there is a real willingness on the part of the industry to become involved in all the different initiatives of the Home Office and cyber bullying task forces and the Internet Crime Forum. I do not think we see colleagues from other companies not participating in that and contributing very much to the debate. Q250 Chairman: Were you surprised by Mr Gamble's remarks? Ms de Stempel: Some of the reporting mechanisms that Mr Gamble advocate are perhaps not the way other people decide to proceed. However, they have reporting mechanisms and I know they have been engaged with CEOP and their colleagues to try to develop a solution that suits both parties. Mr Lansman: Unless I misheard Mr Gamble, he was heaping praise on the industry but referred to one or two organisations with which he was having words. I trust Mr Gamble to be able himself to have those robust conversations with the companies to which he refers. He mentioned only one or two and heaped praise on a large part of the industry which is not only generous of him but also entirely correct. Q251 Chairman: I accept that, but the problem is that it takes only one or two. If people wish to abuse this industry all they need to do is find the one ISP that will not insist on appropriate content or go out of its way to co-operate with the regulatory authorities and then they have the access they need. Mr Lansman: Like any other sector, the Internet can have one or two apples possibly spoiling in the barrel, but I do not think we should ignore all the good work by the rest of the industry. It is a long list. For many years ISPA and its individual members have been involved not just with the IWF but other organisations and task forces; they have co-operated with government departments, law enforcement and Parliament on a long-term basis, and long may it continue. Q252 Chairman: Is it your general attitude that whilst there are various activities which rightly give rise to public concern the industry is on top of it, the self-regulatory structure is working, protections are in place and not a lot more needs to be done? Mr Lansman: I think the industry in the UK is leading the way. It would be complacent to think that the job is done; it is not. This type of thing will be an ongoing battle. As new services that we cannot even imagine today come onto the Internet the industry will be required to co-operate again with law enforcement, government, children's charities and other organisations to make sure it stays on top of things. There are some very good examples of what the industry is doing, but it is a question of continuing engagement with all parts of society, realising that the good parts of the Internet are there and are wonderful in terms of education and entertainment but also recognising that there are some bad parts. It is incumbent on industry as a whole and individual members to make sure we address the bad parts whilst we keep pushing the wonderful rewards offered by the Internet. Mr Galvin: Even the best managed ISPs - AOL and BT are good examples - have not eliminated all the risks; indeed, by technical means we probably never will be able to do that. One requires more arrows in one's quiver than technical means to do this. There remain significantly higher levels of risk with activity outside the UK. That is a problem of reach not only for ISPs but also UK law. If you look at the statistics from the Internet Watch Foundation about child abuse material hosted in the UK it is almost but not quite down to zero compared with very significant levels of such content hosted abroad. Self-regulation has given you a shining example of best practice in the best ISPs. The challenge for the rest of the industry is to get everyone up to that level. Industry as well as government and people like Mr Gamble and CEOP have a role in advocating that. It must be a concerted effort. The Home Office task force has proved to be a vital piece of glue to bring together the industry here as well. We all have a duty to bring the industry up to best practice. I do not think we would be where we are today without a few ISPs leading the way and developing best practice techniques and what we have in the UK. I echo what Mr Lansman said. We cannot be complacent; the threat is constantly changing and we are getting new people on the Internet now at a rate of knots. The customer base continues to grow. As a generalisation, new customers who arrive are probably less computer and threat-aware of what is on the Internet than customers who have already accessed it. The nature of the environment, customers and technical threats changes constantly. Q253 Chairman: But you see no need for statutory regulation? Mr Galvin: I would not say that. I go back to my earlier comments. Statutory regulation provides the minimum standard and it is the role of Parliament and government to define what is right and the height of the bar. It is difficult. Imagine a slope at the very top of which is the almost universal consensus that child abuse material is wrong; the public absolutely buy into that. Think about the position of BT in 2004 when it introduced the Clean Feed system. We are a commercial company with shareholders. We took the decision to censor this material on the Internet. That is not a role that one normally associates with a commercial company. It was only because it was universally abhorrent to our customers who went along with it, with superb support from Paul Goggins and the Government, that it was successful. Part of it was the position of child abuse material under the Protection of Children Act. You then have to decide where government and Parliament want to draw the line. There is a descending curve at the top of which is child abuse material and perhaps ordinary pornography at the bottom. The suicide websites would be in there as well. Where do we draw the line between harmful, unpleasant and illegal content? When do we say that there cannot be access because it is illegal, that there can be access to the material but with certain protection or that there can be free access to the material? Who draws that line? I believe that is a role for Parliament and government. Q254 Janet Anderson: This issue spreads across a number of government departments: the Home Office and the Departments for Children, Schools and Families, Health and Culture, Media and Sport. Do you think it would help to get a clearer message from government if we had a minister with specific responsibility for child protection? Mr Galvin: I think it would help to get a much clearer position on child protection, but potentially there is more harmful content on the Internet than child abuse. I am not demoting child protection, but if you look at other content, for example some of the material that comes out of Iraq, you also have to decide how you treat that. It would be a useful unifying link for child protection but perhaps we would miss some of the other key areas on the Internet. Q255 Helen Southworth: I want to ask about two aspects of education. One is the work that you do in terms of educating people who are your direct customers - we saw an interesting example earlier of that direct connection with customers - but also the work that you do on a wider basis in view of the earlier comments about some children who do not have anybody there to fight their corner. You have taken considerable steps in the education of your customers but how will you drive it forward? Mr Galvin: This is a never-ending task with many facets where you can never do enough. It is a matter of educating customers about how to get the most out of the Internet which is a tremendously powerful tool, how to find their way about and find the material they want, where they can participate in things and how to give them basic control of the navigation of it. We have in our minds the model that most parents do not know how to use the Internet and their children have to set it up for them. As a generalisation that is not particularly true of the customers with whom I deal. You cannot predict who in a household will run the computer system, the level of computer education in that household and what access to training facilities a person will have in any particular household. You have to cater for all possibilities. It is about providing basic information about navigation and threats. At one end of the scale it may be child protection and at the other end it may be dealing with spam mail and fraud, and fishing would be somewhere in the middle. It is also a matter of providing online information which is proactive and regularly updated which customers can use as a reference tool, and also at the point where you set up the service you provide information which introduces customers to the facility so they can use it themselves. You then have to back it up with a comprehensive help arrangement. We provide telephone and online help and both are extensively used. If you look at our help desk operation much of it deals with faults but it also helps customers to configure their own systems and deal with queries. For more serious cases we back it up with an abuse desk which deals with customers who are concerned about their experience of the Internet. We provide buttons that allow customers to report to CEOP, for example, but remember that child protection is only one aspect that might worry a customer online. In some cases a customer might have a significant problem for which he cannot use the child protection reporting mechanism. Let us say the customer is receiving anonymous emails or something like that. We provide an abuse desk to deal with cases like that. Ms de Stempel: I believe that all ISPs regularly promote those education initiatives, but also help to promote some of the government initiatives on which we have worked. For example, a lot of ISPs have supported the anti-bullying guidance that emerged from the DCSF campaign. It was instructive and very well done. Therefore, we can give that information which also comes from a source that is not commercially involved. Sometimes we believe that if we say it it may not have the same weight as the DCSF talking about certain behaviour. It is also about catching some of the behaviour of kids in a chat room. They may send their mobile number. We immediately send them a mail about security. The moderator will send an email saying it is inappropriate or dangerous to do this. It is not a warning; it is about safety. For example, Bibo has a fantastic thing about putting on a profile the IP address. It says, "This is your IP address. Learn more." It says that you are not anonymous on the Internet, so it gives information and education about safety and behaviour. Mr Lansman: You asked about existing customers. I believe my colleagues have given information about how all of them, from Tiscali to Sky to Oceano, give information to customers online and it is updated. You have to have in mind two things. First, access to the Internet is now not just traditionally through a PC; it is also through mobiles. I know you have heard from colleagues in the mobile industry. Many of those members are also members of ISPA because they realise that access to the Internet is through mobile devices; indeed, many children get their Internet connection only through mobile devices. Second, you mentioned existing and new customers. It is important for the Internet industry to realise that in some contexts information must be in hard copy that parents can read because they do not get onto the Internet to get the downloaded information. Many ISPs send information in booklets and hard copy that can be read by parents and children. Equally, ISPs go into schools and provide presentations to children, many of whom are not yet online. They are probably online in school but not necessarily at home. All of these are extremely important issues and I am confident that the industry is looking at them. The end point for the ISP industry as a commercial imperative is to have more and more people on the Internet, so it is in its interest to make sure that the Internet is understandable, safe and provides a rewarding experience for new customers as well. Q256 Helen Southworth: Has the industry looked at making a specific budget allocation for educational initiatives to roll out some of those things? Mr Lansman: My colleagues can give more information on this, but I suspect that in general terms it is just part of the good practice of marketing. You could argue that information and education are part of quite a large marketing budget to get people onto the Internet in the first place. Q257 Helen Southworth: I was looking at it specifically in terms of protection from harm. Ms de Stempel: It depends. For example, if there was a lot of concern about bullying on mobile phones, which was something we did not expect, we would find some budget to support that campaign by advertising on our service which is costly. We would allocate part of the budget to promote that campaign, or if our safety and security area needed to be redesigned we would allocate a new line of budget to redo some pages including safety and security. It is a rolling exercise and part of what the ISP industry is trying to do especially in the UK to be seen as the best in helping to protect children online. Chairman: I think that is all we have for you. Thank you very much. |