Culture, Media and Sport CommitteeWritten evidence submitted by EE
Introduction
1. EE welcomes the opportunity to provide comments to the Culture, Media and Sports Committee inquiry into Online Safety.
2. We treat this issue with the utmost seriousness and we recognise that, as the ways in which we all get connected to the internet develop, we have a responsibility to ensure a safe experience for our customers and for their children. This is a challenge which will continue indefinitely as online safety and the control of harmful content requires unremitting effort by individual companies, as well as collective endeavour.
3. EE is a British company which provides service to 27 million customers on EE, T-Mobile and Orange plans. In addition to voice and text, we host a variety of content services including music, games and video clips which are available within our mobile portals (Orange World, Web n’ Walk and T-Mobile) as well as providing general internet access. We also run a fixed ISP (EE Home) which currently has around 750,000 customers and a corporate WiFi service.
4. Turning to the particular issues raised by the Committee, this paper comments on the best approach to protecting children from accessing inappropriate content, recognises that technical solutions are only part of the solution and that education for children and parents is key and that both network and software filtering can meet the requirements of family friendly and effective filtering. It then details EE’s own policies on e-safety and addresses the issue of blocking other harmful content.
How Best to Protect Minors from Accessing Adult Content
5. EE strongly believes that the best way to protect children from accessing inappropriate content is by a combination of parental controls and education. Blocking websites maybe sufficient protection for a young child but will not deal with the needs of young teenagers who will use social media and other personal communications. Teenagers in particular will always try and find material that their parents or teachers would rather they did not see, and it’s the industry’s role to provide educational material, as well as the tools, to ensure children and parents are well equipped to make informed choices and do not inadvertently come across material that is not appropriate for them.
Parental Controls
6. EE supports the recommendation that came out of the Byron review of “active choice” or “unavoidable choice” where parents are forced to make a decision on whether they wish to apply a filter, as opposed to an across the board “default on”. The principles of “unavoidable choice” as set out in the Government’s white paper “Connectivity, Content and Consumers” include the availability of family friendly filters that block adult content for both new and existing customers, the need for customers to make a choice about whether they want filtering at first connection to the internet or at point of sale, age verification of the person setting up or removing the filter and communication of the benefits of filtering. These principles can all be met through either network based filtering or software based filtering on devices.
7. There is no “one” right answer for all customers, across all platforms or all devices. EE supports an approach that allows for a portfolio of network based and device based solutions to meet the needs of the tens of millions of people in the UK that access the Internet, through PCs, mobile devices, games consoles and, increasingly, TVs.
8. There are very good reasons why mobile and fixed operators have chosen to take different approaches to the delivery of parental controls for mobile and home internet. On mobile phones operators filter adult content on the network and it is on by default for all customers and can only be lifted on proof of age. On the fixed home internet many ISPs offer all customers free parental controls and provide unavoidable choice on set up. This difference of approach is because the way people purchase mobile and home internet differs:
all home internet customers sign a contract and are adults;
the home is likely to contain a number of PCs for each family member, each requiring different levels of filtering, and some no filtering at all; and
households attempting to accommodate this mix of PCs via a single network filtering profile are likely to experience dissatisfaction, and may well turn off filtering altogether. Allowing different PCs to be protected via their own filtering software provides the necessary degree of flexibility.
9. For mobile phones we filter content at a network level and it is set as on by default. This is because:
Mobile phones unlike home computers are personal devices and so a single filtering profile is effective.
Filtering software is not available for all mobile devices. Different operating systems (Android, Apple, RIM) each require a different solution which is why operators implemented a network based approach.
Mobiles are often bought by children who are unlikely to request at point of sale that parental controls software should be activated.
Many mobiles are sold through independent retailers where operators have little or no control over how the devices are sold or who they are sold to. The purchasing decision for mobile is very different for fixed with many indirect channels of distribution (such as supermarkets) who are not set up to discuss the benefits of parental controls.
10. Given that the majority of children are highly technically proficient and routinely share tips and information, it is considered that such controls would offer little or no practical protection. We continue to evaluate options for offering greater controls on mobile devices and will revisit this if viable solutions are identified.
11. As we have explained there are good reasons for taking different approaches for filtering mobile and fixed traffic. In addition, we believe mandating network filters for all fixed ISPs in order to have filters which are on by default, will be a huge expense and take considerable time to implement. The initial investment of providing network filters on the mobile network costs millions of pounds and there are also ongoing costs for maintenance and for the categorisation and filtering suppliers.
12. More information on the parental controls available across EE’s mobile brands, fixed business and Wifi network is set out in Appendix I.
Education and Advice
13. Parental education and engagement is vital. As Dr Tanya Byron set out in her review on child safety, parents have a responsibility to understand what their children are viewing and to educate themselves and their children on how to assess the appropriateness of content.
14. Education is so important particularly for teenagers and older children who want more choice in what they are able to access. Since access controls were put in place, content on the internet has continued to develop and more players are involved in its delivery. This means that even with the best filters available it is increasingly hard to block inappropriate content particularly on social networking, interactive sites and app stores. Raising awareness of e-safety through diverse channels therefore remains of paramount importance.
15. Our research shows that parents often feel overwhelmed and unable to keep up with the pace of change and consequently what their children are doing online.
16. Parents need to be made aware of the risks and given clear, simple signposting to sources of information and tools to help them manage their children’s online life. This would include clear messages about what the risks are and tools such as help with setting up parental controls.
17. We also advocate a “talk & trust” approach whereby parents are given guidance on how to open up dialogue and have conversations with their kids so that they understand the risks. We don’t believe that blocking and banning on every level is a sustainable solution as children will always rebel and find new ways to express themselves. It is far more important to arm them with confidence and trust and provide them with information to help them manage the risks as well as their parents.
18. As part of our rebranding, we recently updated our online safety information and launched EE’s Digital Living website with dedicated pages on keeping families safe online. http://explore.ee.co.uk/digital-living/keeping-children-safe
19. This includes a series of six short films together with activity guides, so parents can talk about e-safety issues with their children. The films cover a variety of issues including cyberbullying, digital footprint and posting information online and are EE branded versions of films provided in our previous award winning Orange education programme which had reached 67% secondary school penetration by the end of 2012.
20. Our network of employee volunteers (e-Safety Champions) reached over 10,000 young people directly with e-safety messages from 2009–12 as part of an employee engagement programme.
21. We continue to keep our material up to date and have recently updated our advice for parents leaflet which provides guidance on a range of issues including setting parental controls, cyberbullying, sexting, privacy settings, social networking, downloading illegal copyright, how to report abuse and controlling costs. The leaflet “Advice for parents” is now in all 600 plus EE stores nationwide and is also available from our Digital Living website.
22. By the end of the year all our frontline employees in retail and customer services will receive online training on E-Safety and Active Choice highlighting the tools and materials on offer across the brands. This module will also be included for new employees within their induction training.
Promoting Online Safety in Schools
23. In EE’s opinion more emphasis is needed in PSHE as part of the curriculum and specific attention given to e-safety issues. We feel that as a network operator we have a duty of care to provide information and guidance on how to use our technology in a safe and responsible way. We can share these messages with existing and new customers and our free education programme which is used in 67% of secondary schools shows that we go beyond this and out into the community. However the education system plays a vital role in equipping young people with life skills. With less emphasis on PSHE in recent years we feel the issues are not getting the traction they need. It should not be solely up to the network providers to fill this gap but rather for the education system to embrace the materials and resources that our organisations can offer and build them into daily school life. EE will continue to develop new materials on e-safety in the future for our website, but the real key to success is the way these, and other organisations’ resources can be slotted into a relevant and robust curriculum, so that teachers can take advantage of them.
Consistent Application of Active Choice
24. ISPs no longer control all aspects in the value chain. We firmly believe that content providers and increasingly device manufacturers have a significant part to play in child safety if controls are to remain effective. Government should also be ensuring that the responsibility for child protection applies across the wider value chain with manufacturers, software providers, WiFi providers, search providers and social networks, as well as ISPs. Not only will this provide more channels to market for child safety messages and products but it will also ensure there is a level playing field in terms of implementation costs and responsibility.
25. Furthermore WiFi providers and manufacturers of consumer electronics products such as games consoles, smart TVs and set top boxes, which are offering an ever richer and open online experience, should also be required to offer active choice.
Filtering Out Extremist Material
Tackling Child Abuse Images and the IWF
26. EE has been an active member of the IWF for nine years and is one of the companies that contributes the maximum amount to the IWF. We fully support the recent extension to the IWF’s remit to allow proactive reporting by the IWF (rather than only investigating reports made through the hotline). This will lead to a more effective use of the IWF’s resources. Any subsequent proposals put forward by the IWF should always be supported by detailed plans and agreed through the normal budgeting process.
27. EE has never received a notice to take down content for any of our hosted services. We have strict guidelines on the type of content hosted on our mobile portals and our interactive services such as chatrooms, message boards and commenting facilities are all moderated.
28. We implement the IWF’s child abuse blocking list across all our platforms each day and return a splash page to those customers looking for or stumbling upon illegal images. We also participate in the quarterly testing programme to confirm that the block is operational.
Blocking other Forms of Content
29. There have been increasing calls by Parliament and lobbying groups for other types of illegal or inappropriate content such as extreme pornography, racist or anorexia sites to be subject to the same treatment as child abuse images with ISPs blocking offending websites for all its customers. For EE there are practical and policy concerns with extending full blocking into other areas. The challenge comes in areas where there is no consensus on the appropriate role of providers. Asking ISPs to block content that is offensive to some people but is clearly legal, places ISPs as arbiters in deciding what customers can access.
30. We believe it is ultimately for Parliament, not ISPs, to take a view on unpalatable content and to determine what is illegal or whether the legislative framework requires revision. The current process with online copyright is that the courts through a court order decides whether a website is facilitating access to illegal material and which IP addresses should be blocked and on what terms.
Radicalisation/Terrorism
31. EE believes that sites that promote radicalisation and terror sites (as defined in the Terrorism Act 2006) are already filtered by our mobile parental controls under the “criminal skills” or “hate” or “violence categories”. However to be certain we require the Home Office to send across a list of the websites so we can check how they are categorised by our filtering supplier.
Preventing Abusive or Threatening Comments on Social Media
Social Media
32. Social media and interactive services have revolutionised the way people connect with each other and offers tremendous benefits. However EE recognises there are concerns over potential access to inappropriate content, bullying and grooming. Due to the sheer volume of postings moderation of all content is impossible. However providers could publicly commit to respond to all reports of potential child abuse, grooming and bullying with an agreed time (such as 48 hours). Furthermore greater transparency of the safeguards available on sites should be available as these vary greatly between services. We also believe that some moderation of content that has potentially the most harm could be implemented.
33. All user generated content that EE hosts on our portals (T-Zones, Web n’ Walk and Orange World) including chatrooms, video sharing, picture galleries, message boards and commenting services are moderated by trained staff working to a documented and defined set of standards that define who is able to use the service and what constitutes acceptable behaviour. There are slightly different policies in place for different services and between the brands however all images are pre vetted against agreed guidelines before they are posted online. In addition we have clear policies on dealing with complaints and on notice and take down.
34. Our message boards are moderated by EE Digital Staff and we also have a Site Feedback form where people can contact the editorial staff to flag any issues. This is monitored between 9am -5pm every day of the week. If there is an instance where we need to take down content that is already live we aim to do it in less than 30 minutes. However the frequency of complaints is very low.
35. For article commenting we enable customers (or anyone who is viewing the website) to report abuse. This is sent to a live dashboard which our moderation company monitor.
Cyberbullying
36. EE’s Customer Services provide advice to customers who are concerned about bullying by text or on calls. If the problem persists customer services can offer to change the customer’s phone number and the most serious incidents are referred to the Nuisance Call Bureaus where dedicated staff help customers who wish to report cases of harassment or malicious calls to the police. The Nuisance call bureaus receive around 300 enquiries per month and of these around 50 will be referred onto the police and the remaining 250 will be provided with appropriate advice and guidance.
APPENDIX I
EE’S PARENTAL CONTROLS
Parental Controls—Mobile
All three mobile brands (EE, Orange and T-Mobile) offer the highest level of protection:
All prepay and contract customers are offered parental controls free of charge and this is applied by default for new customers across all mobile devices (handsets, dongles and tablets). Age verification (via credit card, name and address check or instore) is required to lift the controls.
All networks now offer three parental control settings: Strict, Moderate and Off. We are the only mobile networks to offer a Strict setting as we recognise that parents of younger children may want to filter some content which is not classified as “18” but that they don’t wish their children to view.
The three settings manage visual content (both commercial content and websites) as follows:
Moderate—this is the default setting which will be on for all customers. It allows customers to view user generated content but blocks “18” content as defined by the BBFC (British Board of Film Classification) based on the BBFC’s Classification Guidelines which are the result of public consultations held every four to five years. This is wider than pornography and also includes criminal skills, drugs, gore, hacking, hate, self harm, suicide and violence. For more information see http://www.bbfc.co.uk/what-classification/mobile-content
Strict—on request customers can select this setting which blocks all “18” content as above plus content that is deemed unacceptable for younger children including dating, cyberbullying, unmoderated user generated content, chat, glamour, occult, weapons and cults.
Off—on proof of age (such as credit card or name and address check) customers can switch off filtering which gives access to the open internet. The Internet Watch Foundation list is still filtered for all customers.
EE has invested, and will continue to spend, millions of pounds in setting up and operating our parental control systems offering the best solutions that are available to the industry. The current filtering arrangements have been in place for nine years and work well with very few complaints about children viewing 18 classified content on their mobile devices. Customers who believe content or websites have been misclassified can email safeguard@ee.co.uk. This email box is forwarded to the Safeguard Product Manager and issues are dealt with within 48 hours.
Our Digital Living website provides detailed information on our parental controls, the full list of the categories blocked for each setting and how to report abuse or misclassified content http://explore.ee.co.uk/digital-living/keeping-children-safe
Parental Controls—Fixed
EE Home (our fixed business) now offers all new and existing broadband customers McAfee Family Protection software which is free of charge for 12 months. Customers can install the software on up to five devices are protected even when they’re outside the home as the software sits on the computer.
It offers five predefined age settings (under 5, 6–8, 9–12, 13–15 and 16–18) and parents can also customise the settings, add or delete websites and set time restrictions. It also provides activity reports detailing web activity and it will send email or text alerts if access to inappropriate websites is attempted. It will also report on what information is being shared on social media sites and by instant messaging and blocks the downloading of music with explicit lyrics. The software is easy to install and we have developed a help video with McAfee which is available on our safety website.
We actively promote parental controls at point of sale and at all points in the customer’s journey including in the Welcome Pack, in the router guide, in the customer’s first email after activation, in the Home Mover Pack and Online on our Digital Living Website. Twice a year, as part of the EE Broadband Newsletter, we include information on the Family Protection Software to existing customers. We will also send a dedicated email to all customers every six months highlighting the benefits of online security and parental controls.
By the end of the year all new broadband customers will be presented with a “splash page” when they open their browser for the first time which will force them to make a choice on whether to download the parental controls software. If they choose to opt for parental controls they just click on the link provided which will take them straight to the McAfee download page.
Parental Controls—Wifi
EE offers both branded and white labelled Wi-Fi services to a range of corporate customers. We are engaged in the UKCCIS (UK Child Safety Council) working group and we are committed to offering a Family Friendly Wi-Fi service. All our hotspots currently block illegal child abuse images on the IWF list. By the end of the year we plan to set Adult Content filtering as “on” by default. It is then up to the venue owners to actively choose to disapply the filter if they want to.
September 2013