Culture, Media and Sport CommitteeWritten evidence submitted by The Authority for Television on Demand

Executive Summary

E.1 This submission is from The Authority for Television On Demand (“ATVOD”), the independent co-regulator for the editorial content of UK video on demand services. Of particular relevance to this inquiry is our experience of regulating UK based websites which offer pornographic video content on-demand. This submission therefore concentrates on how best to protect minors from accessing adult content.

E.2 ATVOD welcomes the inquiry. Although regulation can do much to protect minors from adult content, ATVOD considers that current regulatory rules and voluntary initiatives do not sufficiently address the challenges of protecting children in a converging media world, especially in relation to the widespread availability of free hardcore pornography which can be accessed by under 18s.

E.3 ATVOD supports recent initiatives to increase the uptake of parental control software, but considers that further action will also be required if children are to be adequately protected.

E.4 In the first part of this submission, ATVOD briefly sets out:

The action ATVOD takes to ensure that minors cannot access adult material when using UK based video on demand services (including pornographic services).

The extent to which the provision of pornography online is dominated by services being provided from outside the UK (but accessible from within the UK), such services being beyond ATVOD’s remit.

E.5 In the second part of this submission we invite the Committee to consider three main areas and pose questions in relation to each:

The legal framework for the regulation of UK video on demand services, including:

Should greater certainty be provided in relation to the statutory basis for requiring hardcore pornographic material on UK based video on demand services to be kept out of reach of children?

Is it appropriate that content which is prohibited for sale to adults on a DVD, even in a licensed sex shop, can be made available to adults on a UK video on demand service?

Is it too easy for those who operate pornographic websites to conceal their identity?

The existing criminal law:

Is the Obscene Publications Act being used to best effect?

Other public policy measures, especially in relation to non-UK services:

Can media education be the whole solution?

Can the uptake and efficacy of parental control software be improved?

Can a consensus for action be built among EU Member states?

Should non-EU VOD services which are targeted at the UK be brought within the scope of regulations designed to protect UK consumers and children?

Should UK financial institutions refrain from processing payments to non-EU services operating in breach of the Obscene Publications Act?

1. Introduction

1.1 The Authority for Television On Demand (“ATVOD”) was designated by Ofcom in March 2010 to regulate the editorial content of UK video on demand services. Its duties and powers derive from the EU Audiovisual Media Services Directive (“AVMSD”) which was implemented in the UK via amendments to section 368 of the Communications Act 2003 (“the Act”). Under the Act, UK services which meet the statutory definition of an on demand programme service (“ODPS”) must comply with a limited number of statutory requirements which have been incorporated by ATVOD in a set of Rules. To meet the definition of an ODPS a service must meet all five of the criteria set out in section 368A of the Act. Among these are the criteria that a service must have the principal purpose of providing “tv-like” programmes and that the provider of the service must be under UK jurisdiction.

1.2 ATVOD’s primary role in relation to protection of minors is founded in Article 12 of the AVMSD, which forms ATVOD’s Rule 11:

“Rule 11: Harmful Material: Protection of Under-18s

If an on-demand programme service contains material which might seriously impair the physical, mental or moral development of persons under the age of eighteen, the material must be made available in a manner which secures that such persons will not normally see or hear it.”

1.3 ATVOD’s interpretation of this Rule is that “material which might seriously impair the physical, mental or moral development of minors” when provided as part of an on-demand programme service may include content that has been classified “R18” by the BBFC, or material equivalent to content classified in that category. R18 is the UK film and DVD classification for audiovisual works which (a) have the primary purpose of sexual stimulation and (b) include explicit images of real sexual activity or strong fetish activity. Such material is referred to as “hardcore porn” in this submission. To comply with ATVOD Rule 11, an ODPS offering hardcore porn must ensure that such images are kept out of reach of children by having in place a robust age verification mechanism and a means of restricting access to hardcore porn material to those whose age is known to be at least 18. ATVOD’s considers that the following will normally be considered suitable mechanisms for verifying age:

Confirmation of credit card1 ownership or other form of payment where mandatory proof that the holder is 18 or over is required prior to issue.

A reputable personal digital identity management service which uses checks on an independent and reliable database, such as the electoral roll.

Other comparable proof of account ownership which effectively verifies age.

If age verification does not take place each time the user returns to the service, the service provider must control further access to hardcore porn material by the use of mandatory security controls such as passwords or PIN numbers. ATVOD’s full guidance on Rule 11 (and on the other 12 rules it enforces) is published in its Rules and Guidance.2

1.4 In addition to investigating complaints, in 2012–13 ATVOD carried out a number of targeted investigations and such investigations resulted in 18 cases3 across 26 websites in which breaches of Rule 11 were determined because the services were making available “hardcore” pornographic material without having adequate safeguards in place to ensure that such material could not normally be seen by under 18s.4

1.5 In 15 cases the breaches were brought to an end shortly after the Determination that a breach had occurred, though in two of these cases ATVOD had to use its power to issue an Enforcement Notification in order to secure compliance. In the other three cases, the matter was referred to Ofcom for consideration of a sanction. Ofcom imposed the following financial penalties in relation to those cases:

Playboy TV (provided by Playboy TV UK/Benelux Ltd): £35,000.

Demand Adult (provided by Playboy TV UK/Benelux Ltd): £65,000.

Strictly Broadband (provided by Strictly Broadband Ltd): £60,000.

1.6 The Demand Adult and Playboy TV services are no longer being provided by Playboy TV UK/Benelux Ltd (a company registered in the UK, and subject to ATVOD regulation) after a group re-organisation by a parent company which operates across multiple jurisdictions. The Strictly Broadband service was sold to a provider outside the UK following the ATVOD Determination. ATVOD has no evidence that such changes were made in order to place the services outside UK jurisdiction in order to avoid the need to put in place age verification and access control mechanisms which would ensure that explicit content is kept out of reach of under 18s, but that is the effect. ATVOD has also seen a number of examples in which it is claimed that editorial responsibility for a service has been transferred from a UK provider to an entity outside the UK, for example through the sale of the website, while the UK entity continues to supply content to the service. Although ATVOD requires evidence that any such transfer of editorial responsibility is genuine, it is clear that moving is an option for a service which seeks to avoid the obligations placed on UK providers.

1.7 Given the response of a minority of providers of adult services to enforcement of Rule 11, ATVOD has considered how children might better be protected from hardcore pornography online, and especially from such material on websites operated from outside UK jurisdiction, whether from other EU Member States or from outside the EU altogether.

1.8 ATVOD is acutely aware that the hardcore porn services most commonly accessed from within the UK are operated from outside the UK. The most frequently accessed services5 use a variation on the You Tube business model (and are consequently commonly referred to as “tube sites”). Such tube sites offer significant quantities of unrestricted free hardcore porn videos as a shop window in order to attract large number of viewers whose visits are monetised in a number of ways: by up-selling to a premium version of the free service (offering a wider choice, longer videos, better picture quality, etc); by driving traffic to other paid (pornographic) services operated by the provider of the tube site; by charging on a “click through” basis to affiliates whose content is featured on a “try before you buy” basis on the tube site; and by selling advertising space (eg for “contact” services or penis enlargement treatments).

1.9 Even those non-UK hardcore porn services which operate a more traditional business model, requiring payment before the user can access significant quantities of video material, typically offer free access to hardcore still images and “preview” videos on an unrestricted basis.

1.10 As noted above, provided the services are operated by entities outside UK jurisdiction they are not subject to regulation in the UK, even if the service appears to be specifically targeting UK users or otherwise has a strong association with the UK. Options for addressing this issue—such as blocking payments to services which allow minors to access hardcore porn—are discussed in section two.

1.11 A significant minority of such services operate from other EU Member States. Such services are subject to the same AVMS Directive requirements as UK based services, however not all EU Member States share ATVOD’s view that hardcore porn might seriously impair the development of under 18s. For example, in the Netherlands, the regulator takes the view that hardcore porn does not seriously impair the development of under 18s and so hardcore porn services operating from the Netherlands are not required to ensure that under 18s cannot normally see or hear the hardcore porn material. The AVMS Directive includes derogation procedures6 which might allow the UK to restrict services operating from another Member State on the grounds that such restriction was necessary to protect minors, however such measures would be subject to the examination of the Commission who would ask the UK to refrain if the measures were considered incompatible with European Union law. ATVOD notes that to date UK Govt has not used the derogation procedures in relation to on-demand media services regulated in other Member States.

1.12 Even if the problem was solved at a European level, the majority of online hardcore porn services which allow UK children to see hardcore porn material, and which are most commonly accessed from the UK, operate from outside the EU (most commonly from the USA). As well as the standard website version of the service, the content is commonly provided in a parallel web-version formatted specifically for access via a smartphone.

1.13 An indication of the scale of the problem can be gained from web analytic data which suggests that five of the top 50 websites most commonly accessed from the UK are tube sites offering unrestricted access to hardcore porn videos.7 ATVOD has seen figures which suggest that those five hardcore porn tube sites were (collectively) visited over 214 million times by UK internet users during January 2013.

1.14 Although accurate figures for children accessing hardcore porn online are difficult to find, it is worth noting that, according to Ofcom research:8

62% of 12–15 years old have a smartphone.

12–15 year old on average spend 17.1 hours a week online.

43% of 12–15 year olds mostly use the internet in their bedroom.

55% of 12–15 years mostly use the internet while alone.

1.15 Although the problem has existed for some years it has recently become much more visible and has acquired much greater potency over the past year. This is evident in the results of research9 conducted by ICM Research on behalf of ATVOD which found that:

77% of British adults think hardcore porn videos are easy for children to see online.

88% of British adults think it is important that UK websites offering porn-on-demand are required to take the steps set out in the ATVOD Rules and Guidance—such as restricting access, to credit card holders or by checking information against a reliable database, eg the electoral roll—to ensure that under 18s do not normally see hardcore porn material.

Women are particularly concerned, with 94% saying the measures required by ATVOD are very or quite important (with 82% specifically saying they are very important).

Overall, 69% of British adults say the measures required by ATVOD are “very important”.

Views are broadly the same for adults with or without children.

1.16 The transformation of the business of monetizing hardcore porn material online over the past 10 years, and the technological changes that enable minors to have unsupervised access to the internet can only have increased the likelihood of minors accessing explicit adult material online, despite the effective interventions undertaken by ATVOD in relation to UK based porn on-demand websites.

2. Improving Online Safety

2.1 This section sets out questions that the Committee may care to take into account when considering how best to protect children from the hardcore pornographic material which is available online.

The legal framework for the regulation of UK video on demand services

Should greater certainty be provided in relation to the statutory basis for requiring hardcore pornographic material on UK based video on demand services to be kept out of reach of children?

2.2 Under Part 4A of the Communications Act 2003 (“the Act”), ATVOD requires UK providers of pornographic on-demand services which meet the statutory definition of an on-demand programme service (“ODPS”)10 to ensure that any hardcore pornographic material on their service is normally kept out of reach of children. ATVOD’s policy derives from its view that hardcore porn, equivalent to that passed R18 by the BBFC, might seriously impair the moral development of minors and a precautionary approach is therefore appropriate.

2.3 At the request of DCMS, in 2010 Ofcom produced a report11 which indicated that there was uncertainty as to whether R18-equivalent material “might seriously impair” under 18’s. In its 2011 response,12 Government stated that it intended to address this issue comprehensively in the ongoing Communications Review of the current regulatory framework. Government also supported the ATVOD position in stating that there was a good case that the existing Regulations require a precautionary approach. Ofcom and ATVOD were asked to take any steps necessary in the interim period to ensure that children remain adequately protected under the ATVOD Rules, in the knowledge that Government could bring forward further Regulations in the short term if it proved necessary to support this position. Adopting the precautionary principle, ATVOD had already concluded that R18 equivalent material might seriously impair the development of under 18s, and ATVOD continues to interpret the legislation in that way (see paras 1.2 to 1.5 above).

2.4 The DCMS strategy paper (“Connectivity, Content and Consumers”) published in July 2013 sets out Government’s intention to legislate to make clear that R18-equivalent material on ODPS must be provided only in a manner which ensures that under 18s do not normally see or hear it. ATVOD considers that such legislation would provide clarity for consumers and industry and better ensure deployment of effective safeguards. Such legislation would also remove the possibility of ATVOD’s consumer protection measures being undermined by a legal challenge. The Committee may therefore care to consider whether to support the proposed legislation, and what form it might take.

Is it appropriate that content which is prohibited for sale to adults on a DVD, even in a licensed sex shop, can be made available to adults on a UK video on demand service?13

2.5 Some video on demand services contain hardcore pornographic material which goes beyond the limits of R18. This means that on a DVD it would not be classified by the BBFC for supply to adults in a licensed sex shop. Currently, the Act does not prohibit such content on an ODPS provided it is restricted to adults. Consequently, material which is considered to carry such a risk of harm that it cannot lawfully be supplied on a DVD to adults who visit a licensed shop is freely available to adults on video on demand services which operate and are regulated in the UK. Although ATVOD’s interpretation of the statutory requirements mean that UK video on demand services must prevent minors accessing such content, its availability to adults nevertheless poses a potential risk to children. This is because material which goes beyond the limits of R18 may include pornography which simulates non-consensual sex, under-age sex, incest or other material likely to encourage an interest in abusive sexual activity which, through its impact on adult viewers, may ultimately have a detrimental effect on minors.

2.6 The Communications Act 2003 only prohibits on ODPS material which is likely to incite hatred. Pornographic content would not ordinarily fall into this prohibition.

2.7 The DCMS strategy paper (“Connectivity, Content and Consumers”) published in July 2013 sets out Government’s intention to legislate to prohibit on an ODPS material which is “beyond R18”. The Committee may therefore care to consider whether to support the proposed legislation, and what form it might take.

Is it too easy for those who operate pornographic websites to conceal their identity?

2.8 Determining whether a service is an ODPS and who is the provider is central to ATVOD’s regulatory remit. ATVOD proactively investigates whether pornographic services which appear to be provided from the UK meet the relevant statutory criteria and therefore fall within the scope of the regulations it enforces. Often the decision turns on whether the provider of the service (ie the person who exercises general control over the selection and organisation of the programmes) is within UK jurisdiction. Providers of pornographic services frequently neglect to publish contact details or even the name of the provider. Without this information it is impossible for ATVOD to determine that the service is an ODPS.

2.9 To enable such investigations, the Act confers upon the regulator a power to demand information from “a person who appears to them to be or to have been a provider of an on-demand programme service”.14 While this power is useful where a service can be linked to a person15 who appears to be the provider (eg because the website is registered in their name, or because they are listed on the service as holding proof of age records for the performers), in many cases the only identifiable person is the third party payment processor. Current legislation does not appear to give the regulator power to demand information (such as the identity and contact details of the recipient of the payments) from an entity such as a payment processor which is clearly not itself the service provider.

2.10 The Committee may therefore care to consider whether it is currently too easy for UK providers of porn on demand to hide behind third party payment processors, proxy registration services16 and other third parties which provide support services or content to the service. One way in which the current UK regulatory arrangements might be made more effective without extending the scope of content regulation would therefore be to include provisions relating to those who provide financial, hosting or proxy registration services which facilitate the provision of an ODPS in a manner which obscures the identity of the service provider. Such ancillary services could then be required to provide to the appropriate regulatory authority information necessary to identify the provider of an ODPS.

The existing criminal law

Is the present law—notably the Obscene Publications Act 1959 &1964 being used to best effect?

2.11 In carrying out its statutory regulatory duties, ATVOD has drawn attention to the current Crown Prosecution Service (“CPS”) guidance for prosecutors on the interpretation of the Obscene Publications Act (“OPA”), which states that:

“where children are likely to access material of a degree of sexual explicitness equivalent to what is available to those aged 18 and above in a licensed sex shop, that material may be considered to be obscene and subject to prosecution. This applies to material which is not behind a suitable payment barrier or other accepted means of age verification, for example, material on the front page of pornography websites and non-commercial, user-generated material which is likely to be accessed by children and meets the threshold. see R v Perrin, [2002] EWCA Crim 747.”

Yet ATVOD can find no recent example of a prosecution being launched under that guidance. This seems all the more remarkable in the light of research findings showing the extent of consumer/parental concerns.17

2.12 The Committee might therefore question why prosecutions under the OPA in relation to online content in recent years appear to have been limited to websites offering material which is more extreme than would be available in a licensed sex shop. Furthermore, such OPA convictions have declined dramatically in recent years, from 81 in 2000 to just seven in 2010.

2.13 Given the disparity between the CPS guidance and actual enforcement activity under the OPA, might this be an area to explore in order to strengthen the protections for children online? Significant enhancement of consumer protection could be achieved through operational change by the police, without the need for further legislation or public policy revision.

2.14 ATVOD also notes that the provisions of the OPA allow a conspiracy charge to be brought against a person responsible for distributing, retailing or producing the obscene material. Might this enable action to be taken against UK entities or persons who are involved in the provision of hardcore porn without suitable controls, but who do not meet the narrow definition of an “ODPS service provider”?

Other public policy measures, especially in relation to non-UK services

Can media education be the whole solution?

2.15 There is widespread support for initiatives designed to inform and empower parents about the risks children face on line and the steps they can take to protect them. ATVOD also actively supports such initiatives, not least through its work with UKCCIS on age verification tools and “active choice” initiatives for internet connected TVs, and through its support for Safer Internet Day. However, given its limitations, not least with regard to the most vulnerable children, can media education alone ever be sufficient if children are to enjoy appropriate protection from exposure to hardcore pornography online?

Can the uptake and efficacy of parental control software be improved?

2.16 ATVOD supports initiatives to improve the take up of parental controls, not least because it is aware that the use of filtering software by parents is significantly lower than might be desired, and has not been rising. It is not clear why more than six out of 10 households with child internet users do not use parental control software, but as such software is often pre-installed or available free as part of a contract with an ISP, it is unlikely that cost is a significant factor. Research18 has indicated that parents who are regular and confident internet users, who say they worry lot about their children seeing inappropriate material online, and who have younger children, are more likely to use parental control software. Yet there remains a lack of clarity about the reasons why so many parents do not. The impact of recently announced policy changes designed to build upon the active choice initiative will need to be carefully monitored.

2.17 The usefulness of parental control software depends not only on its uptake but also on its effectiveness. This is especially important lest parents who use parental control software are lulled into a false sense of security about the extent to which their children have been protected when using the internet. Should the public debate around parental controls therefore also concentrate on improving understanding of the limitations of parental controls software, especially in terms of efficacy in blocking inappropriate content on protected devices or networks?

2.18 ATVOD notes that five years after the Byron Report recommended a BSI Kitemark for such software only one product19 carries the relevant Kitemark. ATVOD further notes that EU Commission research20 suggests that the filters themselves when set to block “adult” content suffer from relatively high rates of over-blocking (accidentally blocking non-adult sites) and under-blocking (failure to block adult sites). The under-blocking rate varies greatly, from 9% to 54% and those with lower under-blocking rates tend to have higher over-blocking rates. Some of the best known filtering options had significant failure rates. For example:

MacAfee Internet Security was found to under-block 50% of the time, and over-block 27% of the time;

Net Nanny was found to under-block 41% of the time, and over-block 1% of the time;

Windows Live Family Security was found to under-block 9% of the time, and over-block 54% of the time

Overall, the study concluded that “In general, [PC parental control] tools have a low effectiveness.”21

2.19 Although the efficacy of parental controls may have improved since that research was conducted in 2011, it is clear that both “over-blocking” and “under-blocking” still occur. Both must be of concern. Under-blocking because it allows children to access material which is supposed to be blocked, and over-blocking because by restricting access to legitimate content it undermines confidence in the software. ATVOD also notes that parents are much more likely to have anti-virus software enabled than to have parental controls enabled (67% compared with 39% according to Ofcom research22). Some of this differential may result from parents disabling a parental control system when it is found to over-block.

2.20 The Committee may therefore care to consider whether public policy initiatives to improve take up of parental controls in households with children should be balanced by efforts to improve the efficacy of the systems available to parents. If so, it may be sensible to keep in mind the fact that if all responsibility is placed on parents, many children will remain unprotected.

Can a consensus be built among EU Member states?

2.21 The UK is joined by at least five other EU states23 in requiring services that provide access to hardcore pornographic material to ensure that such material is kept out of reach of children. However, many other EU states impose no such restrictions, and service providers operating from within The Netherlands, for example, do target the UK consumers with hardcore pornographic video on demand websites which offer inadequate (or non-existent) protections against access by children. ATVOD has no power to insist on such protections being offered by these services.

2.22 Providers established in Member States which do not require such restrictions on VOD pornography services would argue against any attempt at extra-territorial criminal arrest and prosecution by the UK (eg under the OPA by means of a European Arrest Warrant.) They would say such action would infringe their right to freely provide services in the EU under the country of origin principle enshrined in the AVMS Directive (Article 3). To take action, the UK would therefore have to derogate on the grounds that the measures are necessary for reasons of public policy (eg the protection of minors) or for the protection of public health, and would be required to notify the Commission. Any such action would be likely to be challenged robustly.

2.23 Given the common stance of a significant number of EU Member States, including the UK, the Committee may care to consider what options there are to build a consensus behind a proposal for an EU wide requirement for access controls to prevent under-18’s being exposed to hardcore pornography. ATVOD has already made such a proposal in its response to the European Commission Green Paper—“Preparing for a Fully Converged Audiovisual World: Growth, Creation and Values”. Rather than setting a test such as “might seriously impair”, which is open to widely differing interpretations, such a measure might simply define hardcore pornography and require each Member State to ensure that media services within their jurisdiction secure that under 18s cannot normally access such material.

Should non-EU VOD services which are targeted at the UK be brought within the scope of regulations designed to protect UK consumers and children?

2.24 As noted in paras 1.8–1.9, a majority of on demand services/websites offering hardcore pornography without effective access restriction operate from outside the EU, notably from the USA and Canada. They are therefore beyond the reach of any European regulator. The exclusion applies even if the service is specifically targeted and marketed at UK consumers.

2.25 Given the large number of such services, and the wide scale of their consumption in the UK, the Committee may care to consider whether consideration should be given to broadening the scope of the relevant UK legislation to enable determinations to be made in relation to VOD services from outside the EU which:

2.26 Although such a move would raise substantial enforcement issues, it would allow determinations to be made that such services were acting in breach of UK law when hardcore pornographic material is provided without effective barriers to prevent child access. Such a move would send a strong message. It might also encourage UK entities who do business with such services, or who facilitate their provision, to reconsider their relationship with the service provider.

Should UK financial institutions refrain from processing payments to non-EU services operating in breach of the Obscene Publications Act

2.27 As noted in para 2.11, Crown Prosecution Service (“CPS”) guidance for prosecutors on the interpretation of the Obscene Publications Act (“OPA”), states that:

“where children are likely to access material of a degree of sexual explicitness equivalent to what is available to those aged 18 and above in a licensed sex shop, that material may be considered to be obscene and subject to prosecution. This applies to material which is not behind a suitable payment barrier or other accepted means of age verification, for example, material on the front page of pornography websites and non-commercial, user-generated material which is likely to be accessed by children and meets the threshold. see R v Perrin, [2002] EWCA Crim 747.”

2.28 The same guidance also advises that:

“There are very difficult jurisdictional issues about whether material hosted overseas is within reach of the English criminal law. It will depend on a range of factors including who posted the material on the site, where it is hosted and what the person intends the material to do. If a web site is hosted abroad and is downloaded in the UK, the case of R v Perrin [2002] 4 Archbold News 2 will apply.

R v Perrin is specifically concerned with ‘publishing’ electronic data under the Obscene Publications Act 1959 and states that the mere transmission of data constitutes publication. It is clear from the decision in R v Perrin and in the earlier case of R v Waddon (6 April 2000 unreported), that there is publication both when images are uploaded and when they are downloaded. In the case of R v Waddon the Court of Appeal held that the content of American websites could come under British jurisdiction when downloaded in the United Kingdom.”

2.29 CPS advice therefore suggests that a US website which offers sexually explicit material which is not behind a suitable payment barrier or other accepted means of age verification is likely to be operating in breach of the OPA if the material is accessed in the UK.

2.30 The Committee might therefore consider whether action might be taken by UK entities which facilitate the provision of such services to UK consumers, for example by processing payments. In this regard, ATVOD notes that while the pornographic services most frequently accessed from within the UK are so-called “tube-sites”, which offer content free of charge, those tube-sites depend for income primarily on driving online traffic to their own or affiliated pay sites. The free content is merely a shop window for services which involve a financial transaction with the user.

2.31 ATVOD has therefore posed to the UK financial industry the question: is it appropriate to process payments to services which, according to CPS guidance, appear to be operating in breach of the OPA? This has been followed by a series of constructive bilateral meetings with key players in the UK financial industry which have in turn led to a summit being held on 10 October 2013, chaired by ATVOD and including senior representatives from The UK Cards Association, the British Bankers’ Association, the Payments Council and a number of leading payment scheme operators.

2.32 ATVOD would be happy to provide the Committee with an update on the summit once it has taken place and to discuss further any of the policy options set out in this submission.

October 2013