Culture, Media and Sport CommitteeWritten evidence submitted by Virgin Media

DIGITAL MAKES GOOD THINGS HAPPEN

Introduction

Virgin Media welcomes the continuing parliamentary interest and opportunity to respond to the Committee’s inquiry into the issue of online safety. As a responsible ISP, providing broadband services to more than four million homes and families, Virgin Media puts the issue of internet safety above all others in terms of importance. Debates about these complex issues can often be dominated—on both sides—by a small group of stakeholders with strongly held views. Often the voice of the ordinary consumer has been lost. In this consultation, Virgin Media aims to set online safety in the context of the views of the average UK internet user.

Virgin Media’s customers, and the UK public, believe in the internet as a force for economic, societal, educational and personal progress. Overwhelmingly, they believe that digital makes good things happen.1

67% agree digital benefits families and enriches life.

Naturally, as consumers they think first about how the internet has empowered them with more product information, comparison and lower prices. But beyond their pockets, our customers tell us they believe in the wider good of digital to strengthen family bonds, contribute to business growth, and enrich their child’s education.

They come to that view despite the vast majority of public debate about the impact of the internet on their daily lives focusing on the dangers not the benefits of being online.

76% of media sentiment about the internet is negative.

Of course, those dangers are often very real, serious and demand vigilance from all users if the benefits of the internet are to be enjoyed free from harm.

Our role as a responsible ISP is first and foremost, to encourage that vigilance by educating our customers about where risks do lie, and providing them with the tools to combat those risks how they see fit.

Positively, through education we are seeing that our customers’ awareness and vigilance against online risks is becoming increasingly sophisticated. There are understandably knowledge gaps given the subject matter is fast evolving technology, but parents identify a broad range of risks, beyond just the content available online, to include the people their children meet and the personal information that they and their children share.

7% of parents with children under 18 say they wouldn’t know how to protect their child online.

As a result, our customers adopt approaches to online safety that best suit the needs and maturity of their families—and they see it as fundamentally their choice as to how they go about that. That often includes applying parental controls, but also involves proactive digital parenting such as putting in place rules around where in the home the internet is used, monitoring usage, and, crucially, having conversations with their children about online safety.

The recent tenor of debate about the online world has failed to reflect the generally positive view that the UK public have about digital and their pro-activity in managing online risks they might encounter. Inevitably, this has led to largely reactive, sometimes knee-jerk policy making in recent months.

Virgin Media is hopeful that moving forward, the parameters and expectations that Government have already set industry in relation to online safety will remain firm and clear, and that future policy is developed in a sober, evidence-based way, taking account of the overwhelming view of the UK public that digital is a force for good.

With that in mind, Virgin Media sees three key challenges for Government:

First to provide certainty to ISPs that an “active choice” approach to parental controls remains the most proportionate, effective way of engaging parents with online safety, and continue to give ISP technical flexibility over the solutions they implement.

Second to focus its efforts on driving engagement amongst parents in these issues through clear advice and education, delivered through evidence-based means that demonstrate behavioural impact.

Third focus Government’s resources on tackling child abuse at source through 1. considerably increasing CEOP’s resources beyond the 0.08% of Home Office budget it currently has available as it moves into the National Crime Agency; 2. conducting an inquiry into, and developing a strategy to tackle, the wider societal causes of child abuse.

The remainder of this response is divided into three sections:

Our Customers Views about Online Safety

Throughout 2012 Virgin Media engaged in a national listening exercise—Our Digital Future www.ourdigitalfuture.co.uk—to understand how our customers and British consumers felt about their lives online. Over 3,000 people2 were asked about the practicalities of their digital habits—hours spent online, their preferences for content and access—but more deeply, what their reactions were to the growing debate about the balance of risks and responsibilities on the internet.

They were asked about their views on a broad range of online behaviours and risks—access to adult content; sharing of personal data; exposure to malware; piracy—and where they see the balance of responsibilities in protecting children from those risks between themselves, their ISP, and the state.

In summary, we found a UK public that is engaged with the issue of online safety, aware of a range of risks, and confident in taking the actions appropriate for their families to manage those risks in order to make the most of the internet.

Behaviours and Risks

Reflecting the predominant view of the internet’s impact on society as overwhelmingly positive, UK parents are generally very comfortable with their children’s online behaviour.

17% of parents are concerned about child internet us.

Source: OFCOM Media Literacy Report3

Policy makers might conclude that this reflects ignorance or naivety to the realities of online risk amongst parents. However, evidence points to high levels of activism amongst parents, suggesting that their confidence is borne out of a firm view that they have created the right environment for their children to get the most out of the internet.

79% of parents have rules in place on internet usage.4

84% of parents trust their child to use the internet safely.5

7% of parents with children under 18 say they wouldn’t know how to protect their child online.

In reality, parents have a relatively granular understanding of online risk and can identify a wide range of potentially dangerous channels. As might be expected given the direction of recent public debate, pornography ranks highest as the content that parents are most concerned about their child having access to.

However, access to adult content is only one of a number of concerns for parents. Clearly, there is considerable concern amongst parents about the risks presented to their children through exposure to people they don’t know online (so-called stranger danger). In fact, when asked to directly compare risk associated with different types of online activity—as opposed to ranking different types of content—parents registered more concern in relation to stranger danger than exposure to content.

Whilst generally parents have a reasonably sophisticated understanding of online risk, there are gaps in their awareness and understanding.

In part these gaps relate to technological developments that many parents do not fully understand. For instance, whilst in general, parents are well aware of the threats posed by malware and viruses to online safety—70% of customers understand the risks associated with malware—there is limited understanding of how that risk extends to mobile, where only 32% are concerned about the impact of malware.

Other knowledge gaps relate to a lack of exposure to certain types of behaviour. Whilst there is research pointing to high levels of concern about cyber-bullying amongst parents, there was a significant disjunction between levels of exposure to cyber-bullying amongst the parents and children that we surveyed. 47% of children have had some direct experience of cyber-bullying versus 18% of adults with children under 18.

Parents not only identify a variety of risks but in turn adopt a variety of different approaches to digital parenting, reflecting the fact that content filtering—for instance—addresses only one of a range of online risks. A recent comparison of parental mediation strategies across the EU found that the UK has the second highest proportion of parents adopting “All Rounder”6 approaches to their child’s internet safety ie, a heterogeneous mix of active monitoring and restrictive technical measures.

Responsibilities

In light of the many approaches and activism of UK digital parents, it comes as no surprise that they see themselves as having greatest responsibility for protecting their children online, and are not comfortable with one-size-fits-all approaches imposed by their ISP or the state.

13% of parents comfortable with ISPs setting filtering levels on their behalf

That is not to suggest that ISPs, or indeed the state, have no role to play in supporting parents to create a safe environment for their children online. Indeed when asked a slightly different question—who has some (rather than greatest) responsibility for online safety—parents clearly identify ISPs, schools, central Government and other internet companies as all having a role to play. First and foremost, that role begins with establishing processes in partnership with law enforcement that allow for the removal of illegal content at source. Beyond illegal content, ISPs have the responsibility to use all of their technical expertise to advise parents of the risks and realities of online life, and make available easy to use tools that can support their digital parenting.

Our Role in Delivering a Safer Internet

Virgin Media, as an ISP governed by the EU Telecommunications Framework and E-Commerce Directive, has no regulated responsibility to block consumer access to any content. However we exercise three core responsibilities to help create a safe environment for internet users:

There is an important and clear distinction between the voluntarily, proactive approach that Virgin Media adopts in collaboration with law enforcement to remove content that they judge to be illegal versus our view on where responsibility lies for accessing legal content. Virgin Media believes that it is for adult internet users to decide whether they or their family can access legal content. Virgin Media is therefore strongly of the view that the industry-led and Government-supported approach to parental controls for legal content, which places the decision in parents hands, reflects the right balance of responsibilities.

Child Abuse, Terrorist and Virus-containing Material

Virgin Media has a zero tolerance policy on the availability of child abuse material (CAM) online, so we take the following steps to help remove it from the internet:

Co-founder and top tier funder of the Internet Watch Foundation (IWF). Virgin Media has supported the organisation’s outstanding success in reducing the proportion of CAM hosted in the UK to less than 1% and blocks access to child abuse images hosted abroad.

Established a dedicated Online Security Team at Virgin Media to work with the IWF to process requests, block and remove thousands of pages of CAM from the internet every month.7

Work with CEOP and other law enforcement agencies to support investigation into the production and distribution of CAM. We support the training of CEOP and other law enforcement professionals through programmes to ensure that they remain up to date with technological developments. We provide in kind support to CEOP by waiving the data costs associated with their work, amounting to approximately £100,000.

Implemented splash pages on every blocked url advising users that the content they are attempting to access is CAM, the legal and personal implications of accessing that content, and signposting perpetrators to the Stop It Now support site.

Continued commitment of funding for efforts to prevent child abuse online. Virgin Media has committed £250,000 over the next four years in addition to our existing funding for child abuse prevention. Part of that commitment will be spent on increased membership fees for the IWF to support expansion of its existing, proactive work. We are in discussions with the IWF and other organisations about how additional funds beyond membership fees might best be used to expand the reach of child protection efforts.

In relation to terrorism content Virgin Media has worked with law enforcement on a voluntary basis to:

Establish a process with the Counter Terrorism Internet Referral Unit (CTIRU) for terrorism/extremist content where we host on a Virgin Media homepage. Under that process, Virgin Media refers suspect content to CTIRU for further investigation. CTIRU review the material and, if judged to be terrorism content, can ask Virgin Media to remove that content, or take no immediate action if that supports their ongoing investigation. That process was established as a trial in 2012 and is now enveloped into the work of Virgin Media’s Online Security Team.

In relation to content that impacts on the security of our network or our customers’ personal data, such as malware, Virgin Media has worked with law enforcement on a voluntary basis to:

Establish processes with other relevant law enforcement bodies, such as SOCA, to identify and take action against malware hosted on Virgin Media’s network. Virgin Media also has processes in place to inform customers of malware that may have infected their home device when notified by the relevant law enforcement body. In addition, Virgin Media provides all broadband subscribers with free anti-virus software to help protect their home devices and personal data from malware.

Whether dealing with child abuse, terrorism and virus-containing material, Virgin Media is highly reliant on the expertise and legal footing of law enforcement bodies to make judgements on what action should be taken in response to a particular type of illegal content. Whilst Virgin Media takes proactive steps to minimise the harm of these forms of content, we do not do so unilaterally or without the oversight of law enforcement. In Virgin Media’s opinion, efforts to limit exposure to these extreme forms of content are best targeted at removal of the content at source, by the host.

Parental Controls

Virgin Media believes that parental controls can provide one set of tools for parents to help limit harms associated with children accessing adult content online. However, no technological solution is ever infallible, and so it is important that parents see parental controls as just one of a range of things that they must do to create a safe environment for their children online. Virgin Media:

Are committed to providing an “active, unavoidable choice” to all new and existing customers to ensure that each customer decides whether or not they wish to install parental controls. That reflects Virgin Media’s view that a “default on” approach to filtering software is not in line with parents expectations that they should make the decision on what content is accessible in their homes.

Are introducing a new, free of charge “whole home” parental controls product to replace our existing device-based client and making that available to our four million broadband subscriber base throughout 2014. Our new DNS based solution is applied at a household router level. It uses the IP address assigned to the subscribers’ router to deliver a consistent level of filtering to any and all devices connecting to that home broadband connection. Where a subscriber has opted in to apply the filters, DNS lookups (the URL inputted into the search bar) associated with that subscriber’s IP address will be analysed against our block list to determine whether access is permitted.

Are making those filters as intuitive and easy to activate as possible, through a simple, “one click” Websafe button which is pre-selected with the presumption that new customers will want to install filters. We have worked with a range of child safety NGOs and experts to define a list of content categories that will be included in the one click Websafe mode.8

Are putting in a place a robust, two-stage age verification process to ensure that the person making the decision on whether to install filters is the adult account holder. Our closed-loop system will require the account holder to log in using their email address and password before making their “active choice”. Following that decision—and any future changes to the level of filtering applied—the account holder will be sent an email with notification of the filtering decision.

Are adding layers of sophistication to our parental controls to give parents the flexibility to meet the needs of their households. Parents have told us that they are not comfortable with one size fits all approaches to filtering that are not adaptable to the digital maturity of their child. So whilst the early version of the product will only offer customers a simple, one-click Websafe mode, as we roll out the product we will also allow parents to select specific categories of content they wish to filter and tailor their filters more uniquely.

Are committed to ensuring that child can benefit from a safe internet experience however they access it. Virgin Media is signatory to the 2003 IMCB Code of Conduct governing mobile internet access, which requires that all mobile operators put in place default filters on adult content across mobile devices. Adult users must request to have the filters removed before being able to access adult content. Additionally, in 2013, Virgin Media worked with UKCCIS to develop a statement on filtering across public WiFi, which commits all providers to apply default filtering of pornography and illegal child abuse material on public WiFi connections, unless the client specifically requests otherwise.

Education and Awareness

Our responsibility does not stop with providing the tools to block access to content. Nor would that be sufficient to meeting the range of challenges that children face online—covering not just what they see, but who they meet and what they share. To adequately meet a challenge of this scale, parents first and foremost must be aware of all of the potential risks that their child encounters and need to be engaged in continuing, active, digital parenting. Virgin Media therefore believes that the absolute priority of all online safety stakeholders should be to provide clear advice to parents on the risks their children face online and the steps they can take to ensure their children stay safe. In meeting that priority, Virgin Media:

Is a core sponsor of Safer Internet Day and a member of the UKCCIS working group on Education and Awareness. Working in those partnerships, Virgin Media contributes to efforts to disseminate online safety advice to millions of UK parents. In 2012, over 150,000 people directly participated in Safer Internet Day worldwide and more than 20 million parents were reached with information on child internet safety.

Is committed to providing online safety advice directly to our four million customer base through our own channels and materials.

Virgin Media has developed a Protecting Children Matters portal which contains information on all of the child safety tools we make available to customers and practical information on How To Protect Your Family.

Virgin Media is currently designing a Child Protection Guide—following on from the Our Digital Future big conversation—and app, which will contain new forms of advice and act as a forum for debate and support amongst our parents.

Virgin Media has developed a range of video resources on child protection including Having the Talk, which introduced viewers to the big issues acting as barriers to greater digital engagement and invited their views.

Is committed to using the power of our brand and reach of our marketing efforts to further engage UK broadband users with issues of online safety. Virgin Media is participating in a cross-industry working group to consider how best to reach customers with these messages and will come forward with detailed plans later in 2013.

A Role for Government

Virgin Media welcomes the current focus and scrutiny of efforts to deliver a safe internet for children. However, the overwhelmingly negative tenor of recent debate on the subject has not reflected the views of the average UK parent on the digital world, nor the steps that parents, ISPs, Government and other stakeholders are already taking to ensure that children are able to reap all of the benefits that the internet offers in safety. As a result, the direction of policy in this important area has been largely reactive, sometimes knee-jerk, in recent months.

Virgin Media is hopeful that moving forward, the parameters and expectations that Government have already set industry in relation to online safety will remain firm and clear, and that future policy is developed in a sober, evidence-based way, taking account of the overwhelming view of the UK public that digital is a force for good.

With that in mind, Virgin Media sees three key challenges for Government.

First the message from parents is clear—they expect to be in control of setting the rules for their child’s life online. “Active choice” is a better vehicle for delivering that than default filtering. Government should provide certainty to ISPs that an “active choice” approach to parental controls remains the most proportionate, effective way of engaging parents with online safety, and continue to give ISP technical flexibility over the solutions they implement.

Second filtering is part of the solution to delivering a safe online environment for children but not the whole solution. A robust response to this wide ranging challenge requires vigilant, well informed, and active digital parents. Government should focus its efforts on driving engagement amongst parents in these issues through clear advice and education, delivered through evidence-based means that demonstrate behavioural impact.

Third child abuse is a deep routed societal problem, of which distribution of, and access to, that material online is arguably both a symptom and a driver. The ISP community is therefore committed to ridding the internet of that content—an ongoing, considerable challenge. Virgin Media believes Government should target its resources on tackling child abuse at source through 1. considerably increasing CEOP’s resources beyond the 0.08% of Home Office budget it currently has available as it moves into the National Crime Agency; 2. conducting an inquiry into, and developing a strategy to tackle, the wider societal causes of child abuse.

September 2013

1 Where a specific citation is not referenced, the data is taken from Virgin Media’s own consumer research

2 The research element of Our Digital Future consisted of a quantitative and qualitative survey of 2,000 people conducted by Ipsos Mori; outreach to 1,000 other members of the public through a national listening tour of UK high streets and the Our Digital Future website, and in-depth interviews with 15 sectoral experts, MPs and academics.

3 OFCOM Media Literacy Tracker 2013, http://stakeholders.ofcom.org.uk/binaries/research/media-literacy/2012-Metrics-Bulletin/2012-Metrics-Bulletin.pdf page 12

4 OFCOM Media Literacy Tracker 2013, http://stakeholders.ofcom.org.uk/binaries/research/media-literacy/2012-Metrics-Bulletin/2012-Metrics-Bulletin.pdf page 12

5 OFCOM Media Literacy Tracker 2013, http://stakeholders.ofcom.org.uk/binaries/research/media-literacy/2012-Metrics-Bulletin/2012-Metrics-Bulletin.pdf page 12

6 http://eprints.lse.ac.uk/52023/1/Helsper_Country_classification_opportunities_2013.pdf Table 3 page 28

7 The most recent available statistics from the IWF on number of blocked pages is from May 2013 when an average of 189 urls were sent to Virgin Media daily and a total of 3,960 throughout the month.

8 There are nine categories in our Websafe mode: Child abuse material; pornography; hate; crime; drugs; violence; fraud; hacking; sites that circumvent the filters.

Prepared 18th March 2014