Culture, Media and Sport CommitteeWritten evidence submitted by Telefónica UK Ltd

1. O2 is the commercial brand of Telefónica UK Ltd, a leading digital communications company. O2 in the UK has over 23 million customers and runs 2G, 3G and 4G networks. The company also operates O2 Wifi, which provides over 9,000 free wifi hotspots and has over eight million customers across the UK. Telefónica UK Ltd owns half of Tesco Mobile and has over 450 retail stores. The company is part of Telefónica Europe plc (a business division of Telefónica SA), which uses O2 as its commercial brand in the UK, Slovakia, Germany and the Czech Republic.

2. Telefónica UK Ltd (Telefónica) is a member of the UK Mobile Broadband Group (MBG), which has separately submitted evidence to the Select Committee on behalf of our industry. This paper is an additional submission on behalf of Telefónica. Although the inquiry will consider a range of issues relating to online safety, this paper is primarily concerned with that part of its terms of reference that is focused on “how best to protect minors from accessing adult content”.

3. Telefónica does not believe there is a “silver bullet” solution that will address every issue and challenge relating to online safety, many of which will evolve rapidly over time through advances in understanding and technology, as well as changes in online behaviour. No technology can be a full substitute for parental responsibility, which is vital to the overall task of ensuring online safety. In addition, while there is widespread agreement on the need to protect children from inappropriate online content, there is no such consensus on how this can be achieved and what the exact roles should be of, for example, parents, schools, IT companies, statutory regulation etc.

4. The “internet industry” is at times referred to as having a collective responsibility for online safety. Telefónica does not shirk its own responsibility and believes that collaboration on this issue across the industry is vital. However, Telefónica believes also that it is important to understand the distinctive role and actions of mobile network operators within the broader industry.

5. Illegal Content. Telefónica is a longstanding member of the Internet Watch Foundation (IWF) and sits on its board. We have, therefore, a long track record of involvement in its work. We support its new focus on proactively hunting out and removing illegal images from the internet and have committed additional funding to the organisation to help it fulfill this revised and expanded brief. We block internet access to the IWF master-list of illegal websites not just from O2 mobile phones but also from O2 Wifi (see below). For a number of years we have deployed “splash” pages to explicitly warn customers if they seek to access an IWF blacklisted site. In addition, this summer O2 promptly implemented the new IWF splash-page co-authored by the Lucy Faithfull foundation in support of the Stop it Now! campaign. This splash-page may be accessed at

6. 18+ Content. All 18+ content is placed behind an Age Verification (AV) “shield”. A customer cannot get access to 18+ content on an O2 mobile phone unless he/she successfully completes this AV process to prove they are aged 18 or over. The AV process is based on the MBG-led British Board of Film Classification (BBFC) Framework.

7. Parental Controls. Our free Parental Control service limits the websites that children can access on their mobiles. It only lets them access sites that have been classified as suitable for children under 12 years old. Parental Controls are easily applied, with guidance and instruction available online, in-store and by telephone from our customer service team. When customers purchase a phone, they are asked if the phone is for a child and if they would like the Parental Controls switched on at the point of sale.

8. Education & Information. We are committed to establishing and maintaining a dialogue with parents and young people to increase their awareness and knowledge of the safety tools available and the behaviours they need to adopt to maximise online safety. For example, in August O2 sent SMS messages to all of its consumer customers, inviting them to Staying Safe—an online portal where they can learn of online and mobile safety issues and be provided with some practical help and advice. This campaign has been O2’s biggest SMS campaign to date. Staying Safe highlights topics requested by our customers, such as what content we block, think before you post, online bullying, phishing or scam emails, how to spot a scam email, keep your money safe; in-app purchases and protect your phone. O2 also has a dedicated website for parents (; and we have published and distributed the book “Who WNTs 2 No” to schools and libraries. This book aims to teach children not to share their personal information online using funny characters and children’s language. It has also been released as an application available free on Apple devices from iTunes. We are also long term supporters of Safer Internet Day and participate in its activities; we produce an “Advice to Parents” booklet that is available in-store; we have made use of child safety pledge cards in the past; we have trained people in our business as “digital ambassadors” who have then visited schools to run online safety sessions; we undertake child safety research among our customers; and do focus group research work with partners such as Mumsnet. We also have a link from our website to ParentPort.

9. O2 Wifi. O2 Wifi was launched in 2011 and provides free public wifi to our own customers and those of other networks on the London Underground, Canary Wharf and many restaurant and store chains, including McDonalds, Costa Coffee, All Bar One, Subway, Toni & Guy, Debenhams and Café Rouge. All 18+ content is blocked on O2 Wifi, including the IWF list, on O2 Wifi, which also has a default safe search engine setting. These features are standard and free.

10. Public Policy. In addition to our involvement with the IWF and Mumsnet (see above), we have regular dialogue with organisations such as the Child Exploitation & Online Protection Centre (CEOP), Childnet, the Children’s Charities Coalition on Internet Safety etc and are founder members of the CEO Coalition (to make the internet a better place for kids), established by the European Commission in 2011. We have also been founding participants of UKCCIS with representation on the UKCCIS Board. We have regular contact with Ofcom, PhonepayPlus, the Office of Fair Trading, the Information Commissioner’s Office, the DCMS, Home Office and Department for Education on child safety issues. Our commitment to policy engagement, therefore, has been and remains very strong, but there are many issues and bodies to deal with.

11. Telefónica also offers the following observations on the key issues and challenges in the field of online safety:

International. Sexual child abuse images on UK based URLs are typically removed from the internet within 60 minutes of the IWF learning of their existence. However, about 99% of such images are hosted in other countries, so a huge amount of work is required by foreign and international agencies to make a strong impact on the problem. This is an international issue, not one specific to the UK. In our view, therefore, the government needs to show strong leadership in working effectively with international regulators and other governments to ensure there is cross-border coordination and action. This requires policies in favour of internet standards and enforcement.

Enforcement. It seems that the flow of work from identifying illegal content to prosecution needs to work smoother. The proactive approach now being taken by the IWF will deliver more intelligence to CEOP on victims and criminals. The investigative and prosecution authorities will require a level of resource to manage this increased workload. We need a higher number and rate of prosecutions to increase the efficiency, actual impact and value that is being delivered to act as a further and stronger deterrent. On both enforcement and prosecution a greater level of international cooperation and action is required. Inter-governmental summits need to put this on their agenda for pragmatic action.

Online/Offline harmonization. While Telefónica and other operators operate a robust system of age verification to ensure the safeguarding of under-18s from adult internet content, many offline vendors are not as effective and vigilant in this regard. Perhaps it is time to insist that all publishers in the UK—online or offline—should have the same UK legal obligations to protect children from being exposed to inappropriate images and content.

Education and skills. We are committed to supporting and encouraging digital skills and entrepreneurship in young people through such initiatives as Campus Party and the Think Big School (which will work with over 3,000 14–18 year olds this year). We are looking at how we can incorporate online safety messages into the Think Big School schedule, but the government’s new computing and D&T curricula offer a good opportunity for online safety messages and content to reach many more young people.

Devices. Telefónica cannot fully control the human factors (HMI) or ease of use on devices. Many devices and Apps are purchased through independent channels or Apps stores. It is important that devices approved for connection to the internet meet essential requirements and that Apps are deemed legal. One avenue that could be considered is whether we have the right Type Approval procedures to assure internet safety, pragmatic HMI controls and trusted Apps.

12. In conclusion, there is a lot of goodwill and effort already being exercised in support of online safety. Telefónica and other mobile operators have a strong track record of commitment and achievement in this area. New challenges and players are bound to emerge, of course, and to help ensure online safety is effectively addressed, a partnership approach is required between industry, government, charities and parents. In the UK Council for Child Internet Safety (UKCCIS) a body already exists that can bring together the range of stakeholders needed to make a coordinated and sustained contribution to delivering online safety.

September 2013

Prepared 18th March 2014