Culture, Media and Sport CommitteeWritten evidence submitted by BT

BT welcomes the opportunity to provide written evidence to the inquiry.

Key Points

BT takes the issue of online child protection very seriously. We have long played an active role in trying to ensure that children and young adults can safely experience the many benefits of the internet. BT has invested over £5 million in tools and education since 2010 alone to ensure the UK is the safest online environment in the world for young people.

BT has made substantive progress in supporting the Government’s objective of providing family friendly internet services and continues to invest in our network and software whether in the home or public wi-fi networks. Active/unavoidable choice to install parental controls and not “default on” (where parental-control blocking is already applied and a user has to switch it off if it is not required) is better suited to engaging parents and driving awareness of the need to protect children online.

It is not just about providing tools and gadgets—raising awareness of the need to protect children online and providing education on how to do so is crucial.

Industry and Government have shown the potential of collaborating effectively on online child protection. A voluntary approach should be left to develop before considering any formal regulation or legislation.

In the absence of clear primary legislation from Parliament, or an EU-wide legislative instrument, internet service providers (ISPs) should not be asked to police the internet beyond preventing access to illegal material such as child-abuse images.

It is vital that ISPs receive clarity and comfort under the Regulation of Investigatory Powers Act (RIPA 2000) that their employees and/or those of their wi-fi site partners would not be at risk of a criminal prosecution related to the provision of network level content filtering services for blocking unsuitable content from reaching vulnerable individuals.

Further information will be found in our submission below.

Blocking Access to Inappropriate Material

1. BT blocks access for the following reasons, to:

prevent access to illegal online child-abuse material, according to the Internet Watch Foundation (IWF) list. BT will automatically block any website that is on the IWF’s list. This will be blocked for all BT customers, regardless of their connection. If a customer tries to access a web site that is blocked because it is in the IWF list, they will be redirected to a splash page.

fulfil a customer request to block inappropriate online content, eg, if a BT broadband customer has opted into parental controls or a wi-fi site partner has decided that it wants wi-fi filters in its place of business.

protect children in public places: providing BT Wi-fi’s site customers with the ability to block pornographic material being viewed over the free wi-fi access provided in cafés, restaurants, shopping centres, etc.

BT Takes Online Child Protection Very Seriously and has Long Played an Active Role

2. In 1996, BT and other internet industry members came together to found the Internet Watch Foundation (IWF) of which we are a board member. BT then worked with the IWF to develop “Cleanfeed”, the world’s first system for blocking online child-abuse images. We have recently committed to increase our financial support of the IWF to enable it to proactively identify and remove illegal content from the internet.

3. BT has served as an active member of the Government’s UK Council for Child Internet Safety (UKCCIS) since its inception in 2008. We are currently a board member and play a central role in developing the policies for online child safety for fixed and public wi-fi access. BT was also instrumental in developing the UK Government backed ISP Code of Practice, published in October 2011. This code outlined a set of core commitments for each of the UK’s top four ISPs to inform and educate parents on content filtering tools available to them to enable a safer internet for their children and families.

4. BT has also played a key active role in the work initiated by Commissioner Kroes on the CEO Coalition initiative: “To make a better internet for kids,” which has again shown the potential for industry and government to come together and collaborate effectively on child protection.

5. We have also been an active member of the Family Online Safety Institute (FOSI) since 2007. BT was instrumental in the launch of Childline 26 years ago and continues to be a strategic partner. We also work with partners such as The Parent Zone and the Child Exploitation & Operations Protection centre (CEOP) for reporting of online content. These arrangements work well and we continue to work with these partners, improving online safety for users and non-users.

6. Our customers have been offered free parental control software for years. Parents can block up to 35 categories of online content, everything from pornography through to suicide-promotion sites. Parents can also limit the time spent online by children every day; receive email and text alerts if children try to visit blocked sites or chat-rooms; control their use of social media and get reports on children’s online activity. Different settings can be chosen for children of different ages, and the settings can be easily adjusted by parents.

7. BT also provides customers with information on safety, privacy and reporting on our website (see Annex 1), which also contains links to the IWF and CEOP. BT has developed a number of Acceptable Usage Policies (see Annex 1) that help customers benefit from safer surfing and minimise the risk of suffering online abuse.

BT Continues to Invest in Network and Software Solutions and has made Substantive Progress in Ensuring a Family Friendly Internet

8. The Bailey Review of the commercialisation and sexualisation of childhood in 2011 and the 2012 Government response to the DfE consultation both concluded that “default on” was not the right approach but rather active/unavoidable choice was better suited to engaging parents and driving awareness of the need to protect children online.

9. With this in mind, we have:

launched active choice parental controls for devices in the home this year. This is free downloadable software which provides full protection and parental controls for a particular computer. These parental controls work for any internet connection and allow blocking of particular pages/content on a website, eg, certain YouTube clips can be blocked without restricting access to the whole website;

pledged to provide all new and existing customers with an unavoidable choice to install network-based parental controls. By installing additional functionality within our network we are able to provide protection for all devices either at home or in UK BT Wi-fi hotspots;

launched a pornography filtering solution, BT Wi-fi Protect, for our wi-fi site partners, eg, Starbucks in 2013 and writing to all customers to encourage them use it while applying by default blocking to all site partners where unsupervised children are reasonably expected to be present. To protect BT’s consumer broadband customers who have access to BT Wi-fi’s estate of c4.5 million public wireless hotspots, BT will extend the same filtering protection that BT customers receive from their home BT broadband following the role out of our new network based home-filtering solution this year. Where a non-BT customer is accessing our hotspots, the vast majority purchase access via credit cards which effectively validates they are adults;

launched the use of a “splash page” (the first ISP to do so) in place of an “error 404” message when users intentionally or accidently access child abuse material that has been flagged by the IWF; and

supported the development of industry-wide marketing campaign to drive awareness and education around online safety for children for launch in 2014.

Raising Awareness and Education is Crucial

10. BT believes that there is no substitute for parental engagement and diligence in monitoring children’s use of the internet. To raise parental awareness of safety concerns and to provide education for protection against these, BT provides a range of helpful articles, videos and tools (see Annex 2). BT is also piloting our Living with Technology project where trained BT staff volunteers visit schools to help parents understand some of the key risks that children are exposed to on the internet and what tools and techniques are available to keep their children safe online.

11. Feedback from parents to date has been very positive as follows:

96% said they felt more confident about keeping themselves and their families safer online after the school workshop.

91% learnt something about keeping children safer online that they hadn’t previously considered.

88% said they would discuss e-safety issues with their children.

ISPs should not become Arbiter of Taste and Decency for Online Content

12. In the absence of clear primary legislation from Parliament, or an EU-wide legislative instrument, BT does not wish to police the internet beyond preventing access to illegal material. To do so would set an unfortunate precedent in which an ISP would become the arbiter of taste and decency in relation to online content. It is not for an ISP to be placed in such a position.

RIPA 2000 Concerns

13. Legal opinion informs us that filtering any internet material on home broadband or public wi-fi may be illegal under RIPA 2000 and that this is so even if the purpose for filtering is child protection, and even if the internet user has chosen to set up filters. BT has raised with government the potential conflict between network-level content filtering and the Regulation of Investigatory Powers Act (RIPA 2000). We would expect to receive clarity that our employees and or those of our wi-fi site partners would not face a criminal prosecution under RIPA 2000 by offering filtering activities to our wi-fi site partners for blocking unsuitable content from reaching vulnerable individuals.

Industry Voluntary Approach

14. Industry and government (UK and EU) have shown the potential of collaborating effectively on online child protection. This voluntary approach should be left to develop before considering any formal regulation or legislation in this area.

Clear Set of Policies for Conduct Standards across BT’s Social Media Presences

15. BT’s social media team has a very clear set of policies on conduct standards across our social media presences. On Facebook we have house-rules and we deploy a “swear filter” to hide the most offensive comments. On our BTCare1 forums we publish Terms of Use & Guidance and we have an abuse report feature on the forums to allow members to alert us to violations. We also train all our social media advisors, forum moderators and managers on what they should do if they see behaviours which need moderation action. These include, but are not limited to, trolling, bullying, & spamming.

September 2013

Annex 1


For the Internet to operate in a manner that satisfies the majority of its users, all users need to observe some rules and behaviours governing their use of it. These requirements are usually contained or referred to in the relevant terms and conditions governing the particular Internet service as well as the law.

To enable its customers to have a better understanding of what is and is not acceptable when using the Internet, and to help you get the best out of the Internet, BT has developed a number of Acceptable Usage Policies. These policies should help you benefit from safer surfing and minimise the risk of suffering “online abuse”.

We have also included some general advice on how to protect you and your computer to each of these policies which we encourage you to follow.

Illegal and Inappropriate Activities

As an Internet user, whilst connected to the Internet via BT you must comply with the relevant laws that apply in the UK. You should also be mindful of the fact that the Internet is a global medium and is regulated by the laws of many different countries. Material which is legal in this country may be illegal in another and vice versa.

These are some of the things that you must not do whilst connected to the Internet:

You must not, by using the service, download, possess or transmit in any way, illegal material (for example indecent images of children).

You must not send, publish, distribute, circulate or otherwise propagate any material that may be deemed to be grossly offensive or of an indecent, obscene nature or menacing in character.

You must not send, with the intention of causing annoyance, inconvenience or needless anxiety a message that you know to be false, or to cause such a message to be sent or to persistently make use of our service for that purpose.

You must not gain or attempt to gain unauthorised access to any computer systems for any purpose, including accessing the Internet.

You must not, without authorisation intentionally impair or attempt to impair the operation of any computer, prevent or hinder access to any program or data held in any computer or to impair the operation of any such program or the reliability of any such data (this could include deleting files, changing the desktop settings introducing viruses etc).

You must not infringe the rights of others, including the right of privacy and copyright (an example would be sharing without permission of the copyright owner protected material such as a music or video file).

Many of these activities could result in legal action, a fine or a term of imprisonment or both.

If you are in any doubt as to the legality of anything, take independent legal advice before proceeding.

BT’s Obligations

BT is obliged under the Regulation of Investigatory Powers Act to disclose information to Law Enforcement Agencies and Public Authorities that are legally entitled to obtain such information. Similarly BT must comply with court orders to disclose information. In serious instances of abuse we may also notify the police or relevant law enforcement agency. BT cannot and does not monitor content of its’ customers webspace or content of chat rooms, instant messaging, email, newsgroup or indeed of any communications and therefore BT cannot and does not guarantee that all of these are free of illegal material or other content considered unacceptable by others including the Internet community.

Changes to the Acceptable Use Policies

We may change the Acceptable Usage Policies’ from time to time and will inform you on this website when we do so. To make the most of the guidance contained in the AUPs, please keep up to date with changes and look at them on a regular basis. We hope you will find them useful and informative.

Breaches of Acceptable Use Policies

Reports of breaches of these acceptable use policies by BT customers can be sent to

BT may operate systems to ensure compliance with these acceptable use policies, including without limitation network scanning and testing of open servers and mail relays.

Annex 2


Teens and social media

Safe surfing for kids


An article on online grooming is currently being created and will be live by the end of September 2013.

BT Family Protection parental controls

A video to help customers set up Family Protection parental controls,2771,2774/session/L3RpbWUvMTM4MDExMjA3MC9zaWQvcE9ET25jQmw%3D

1 BTCare is a service brand in the social space which aims to drive customer loyalty by making it easy to get help they need.

Prepared 18th March 2014