Culture, Media and Sport CommitteeWritten evidence submitted by Intellect

Children and the InternetThe Context

Intellect welcomes the Committee’s inquiry into this important matter and the opportunity to provide written evidence. In the context of this inquiry, as the UK’s trade association for the technology industries, Intellect represents a major part of the industrial ecosystem enabling access to the internet: eg, telecommunications operators and Internet Service Providers (ISPs), device manufacturers (PCs, laptops, smart phones, tablets and TVs), operating system providers and security software providers. We also have very good working relationships with content aggregators and technology retailers. As such, we are well placed to provide expert and cross-industry perspectives on this important topic. Our response focuses on online safety for children and the role and contribution of the internet-access industry in enabling a safe internet environment.

Our starting point is that the internet is a good thing. Now entwined in the lives of young people, the internet represents a powerful tool for enhancing their learning, social interaction, and employment, as well as entertainment. The UK enjoys the largest and most vibrant per capita internet economy in the world and its rate of growth is outpacing those of USA and China. The internet enables a more enriched society and a productive economy. Creating an environment online where young people can safely reap these benefits is of paramount importance.

The online environment is an intrinsic part of everyday life. While it has some specific issues and challenges, such as the volume of “instantly” available content, it should not be seen as detached from the physical world and the issues young people face in growing up there. It is essential that online safety issues (eg, illegal content, inappropriate content and contact, bullying etc) faced by young people is seen as part of and in the context of society’s capacity to help them build the confidence, resilience and capabilities to live safe lives and have constructive relationships in the modern world. Technical tools such as parental controls and filters play a crucial role in supporting a safe internet environment and industry has an important role in delivering and ensuring awareness of these tools. However, building of the above resilience and capability in young people requires the constructive collaboration of a range of players from Government to industry, educators, child safety agencies, parents, guardians and children.

Role of Industry and Parental Control Tools

Consumers and children access the internet through a variety of devices and interconnecting routes. PCs, laptops, games consoles, set top boxes and Connected TVs now enable internet access via the networks provided by domestic (or business) internet service providers. Smart mobile devices (phones and tablets) enable access via mobile operators’ networks. Most mobile devices now also enable wifi access via the fixed domestic internet channels and the increasing number of public wifi hotspots. As technological innovation continues apace, the internet access landscape continues to evolve.

It is worth, at this point, to highlight the distinction between the handling of illegal content such as child abuse material and legal content such as adult material which are inappropriate for viewing by children. In the former case, telecommunications operators work with the industry-funded Internet Watch Foundation (IWF) and law enforcement agencies to identify and prevent access to websites with potentially illegal content. They also have procedures for customers to report such sites. In contrast, in the cases of legal but inappropriate content, the focus for industry is to enable parents and guardians to set the boundaries for their children’s access to the internet.

In this interconnected landscape, a range of parental control tools, not a single solution, are needed. The internet access industry is highly committed to playing its full part in creating a safe online environment. Apart from the desire to play a responsible role in society, it has a strong additional incentive because without such a safe environment its very market will be jeopardised.

In terms of network operators (fixed and mobile), as stated in the Mobile Broadband Group’s written evidence, mobile operators with their January 2004 “UK Code of practice for the self-regulation of new forms of content on mobile” took a proactive stance from the start on online child safety and the availability of content filters—considerably before online safety issues came to the serious attention of Government. Their policy is to apply network filters, for content determined by the British Board of Film Classification (BBFC) as being suitable for adults (18s and over) only. Similarly the main ISPs providing domestic internet access have rolled out parental controls presenting new and existing customers with an unavoidable choice of whether to apply filters or not. These filters cover the whole home, ie apply to all the devices used on a connection and allow parents to choose from a list of content that should be filtered including adult content, extremism and self-harm. Intellect is aware of a continual process to innovate and update these tools for example to enable differentiation between different devices in the home and set different controls depending on the user. Earlier this summer, the six main ISPs providing public wifi access (who are often also providers of domestic internet services) committed to implement filters to block pornography as a standard offering. The Internet Service Providers’ Association is now working with some smaller ISPs to understand the issues involved in offering a parental control solution and what alternative approaches could work for them.

Additionally, manufacturers of PCs, laptops, mobile devices and internet connected TVs have been increasingly implementing parental controls on their products. These are intended to complement and reinforce the tools made available by the network operators. One important factor for device manufacturers is that they are largely multinational companies addressing international markets. For them it is essential that parental control solutions implemented on the devices should address multiple markets and not be tailored country by country. The UK’s proactive role in promoting parental control tools has given it a lead in Europe and encouraged other countries to consider their approaches. The Government can however do more to encourage other countries to take a similarly proactive stance. Security software providers have also been quick to respond by providing parental controls software either via manufacturers and network operators or directly to consumers.

Thus it is clear that an irreversible momentum has developed across the industrial ecosystem providing internet access to continually develop technology tools in response to the fast evolving internet environment. It is this application of technology innovation which will ensure the diverse set of tools needed to support a safe online environment—not regulation which in contrast could freeze innovation.

Thus we feel that the industrial players have worked exceedingly well in making available the set of technology tools needed and continue to innovate solutions that are of benefit to their customers. Given the availability of a diverse range of tools provided by the industrial players (operators, manufacturers and software providers), a potential area for future focus is to ensure that these tools “dovetail” with each other to maximise complementarity and mutual reinforcement.

Education and Awareness

As stated earlier, important as they are, parental control tools and filters are only part of the solution in delivering a safe internet environment for children. Ultimately, in a fast changing environment, more effective education and awareness for parents, guardians, educators and children are the only sure ways of providing a holistic and pro-active approach to creating a safe online environment for children and young people.

The 24 June Intellect round table discussion conducted at the House of Lords involving industry, Government, teachers and children’s and parent’s agencies helped to demonstrate that while there are some excellent initiatives undertaken by companies, agencies and schools, the impact and reach of these education and awareness activities is considerably constrained by a lack of leadership and co-ordination.

Given the interrelatedness of a safe online environment for children with the wider priorities for helping them build the resilience and capability to thrive in modern society, the education and awareness activities (for parents and children) must be tackled holistically—and the leadership and co-ordination for this must come from Government and its agencies.

While the exhortations by Government, for industry to “do more” on parental controls, has at times been helpful in stimulating industry momentum, there is a lack of active leadership on a holistic approach discussed earlier. Furthermore, there has been some confusion as to the role of the Department for Education (now DCMS) and “No. 10” which has not been helpful in terms of providing a clear steer from Government about its policy aspirations in this area.


Industry has expended considerable resources into the development of parental control tools (including filters) and a variety of tools now exist.

According to Ofcom’s 2013 Report, “Children and Parents: Media Use and Attitudes”, 83% of parents say they trust their child to use the internet safely and 85% of parents use a combination of interventions ranging from parent-child discussions to the application of parental control tools. While this is a healthy sign, the focus now should be about driving these numbers up even further through education and awareness.

While the Government’s recent focus on online child safety has been helpful in driving up public debate on the issues as well stimulating further industry momentum on technology solutions, we feel that the climate of public discussion and Government stance should change from one of “industry should do more” to facilitating a constructive dialogue which recognises and supports the good work undertaken voluntarily often in best practice partnerships with trusted bodies such as the BBFC and IWF.

Government has an important leadership role in creating the partnerships for a holistic approach to enabling a safe online environment for children and providing clear consistent guidance to industry on its expectations. There needs to be clear and adequately resourced lines of policy responsibility with consistency of Government approaches to avoid the at times fragmented Government approach. Industry will be more than a willing partner.

The climate of public discussion needs to change from admonishing industry for not doing enough to one of positive collaboration.

About Intellect

Intellect is the trade association for the UK technology industry. In 2007, the industries Intellect represents accounted for 8% of UK GDP, £92bn of Gross Added Value and employed 1.2 million people.

Intellect provides a collective voice for its members and drives connections with government and business to create a commercial environment in which they can thrive. Intellect represents over 750 companies ranging from SMEs to multinationals. As the hub for this community, Intellect is able to draw upon a wealth of experience and expertise to ensure that its members are best placed to tackle challenges now and in the future.

Our members’ products and services enable hundreds of millions of phone calls and emails every day, allow the 60 million people in the UK to watch television and listen to the radio, power London’s world leading financial services industry, save thousands of lives through accurate blood matching and screening technology, have made possible the Oyster system, which Londoners use to make 28 million journeys every week, and are pushing Formula One drivers closer to their World Championship goal.

In response to a request by Government Ministers in late 2011, Intellect established industry working groups covering the fixed, mobile and (most recently) the connected TV environments with a view to developing cross-industry approaches on parental controls. Through these activities we have played an industry leadership role in promoting better understanding within industry and between industry and Government on parental controls and online child safety activities. In recognition of this role, Intellect’s Director General, Mr. Julian David has been recently invited to join CEOPs Strategy Group, as its industry representative.

October 2013

Prepared 18th March 2014