Culture, Media and Sport CommitteeWritten evidence submitted by the Internet Watch Foundation
“Online Safety” is a very broad concept that covers a wide and diverse range of issues. When addressing this topic, it is important to clearly identify the issue at stake as different problems will require different solutions, from a technical as well as a procedural perspective.
The Internet Watch Foundation is concerned that the issues relating to legal adult content filtering and the fight against criminal child sexual abuse images become conflated.
The Internet Watch Foundation has been very successful in fighting child sexual abuse images and videos on the internet and has become one of the most successful hotlines in the world.
The success of the Internet Watch Foundation is mainly due to its specific focus on child sexual abuse content and the continuing support from the online industry.
The Importance of Clearly Defining the Problem
1. Different problems require different solutions and it is therefore important to clearly distinguish between the different issues under consideration. Combatting illegal online content (which is content that by definition should not be uploaded or viewed by anybody) is different from protecting minors from accessing harmful content (for instance adult content), which is content that in itself is not necessarily illegal. Preventing abusive or threatening comments on social media might be considered a problem related more to conduct rather than content, notwithstanding that the result of this conduct leads to abusive or threatening online content (ie the actual comments).
2. The merit of taking into account the various aspects of online safety lies in the fact that each of these specific issues opens up a different range of possible solutions, both on a technical as well as a procedural level. Other actors can be involved, other safeguards and processes developed. The most effective solution in one area of online safety could therefore be very different from the preferred solution in another. Equally, an effective solution in one area might have negative implications for the effectiveness in another area. Considering the various different challenges individually will protect against developing general, however well-intentioned, solutions that might have an unforeseen negative impact in particular areas of online safety.
Combating Illegal Content on the Internet
3. Even in the area of combating illegal online content, it is important to keep in mind the differences between various types of illegal content, for instance the difference between child sexual abuse content and material intended to promote terrorism or violence.
4. For different types of illegal content different questions have to be considered and depending on the answers different solutions can be formulated. Issues to consider include:
(i)
(ii)
(iii)
5. The answers to these questions will be different when considering material intended to promote terrorism, material constituting a copyright infringement or child sexual abuse material. Depending on the answers, different solutions will be available to effectively deal with the issue and different procedures, actors and safeguards might have to be considered.
Fighting Online Child Sexual Abuse Content—The Internet Watch Foundation
6. The UK has currently one of the most effective systems in the world for dealing with child sexual abuse content on the Internet. This success is based on the efficiency and experience of the Internet Watch Foundation (IWF), the support it receives from the online industry and its close cooperation with law enforcement, in particular with CEOP, the UK’s Child Exploitation and Online Protection Centre.
7. IWF Background: The IWF is the UK hotline where the public can report child sexual abuse content, criminally obscene adult content and non-photographic images of child sexual abuse. The IWF is a charity founded in 1996 by the UK Internet industry and it is therefore independent from Government and Law Enforcement. However, the IWF has very close working relationships with law enforcement and its operations are covered by a Memorandum of Understanding with the Crown Prosecution Service and the Association of Chief Police Officers and a Service Level Agreement with the Association of Chief Police Officers.
8. The IWF is a membership organisation and is funded by over 100 global members, including internet service providers (ISPs), mobile operators, content providers, hosting providers, filtering companies, search providers, trade associations and the financial sector, as well as by the EU as part of the UK Safer Internet Centre together with Childnet International and South West Grid for Learning. As an independent body, transparency and accountability is of the utmost importance and the IWF is governed by an independent Board and the Hotline is independently audited by a highly qualified team every two years. The IWF also operates a thorough complaints procedure and has commissioned an independent Human Rights Review.
9. IWF processes: When the IWF receives a report from the public, its analysts assess the content to confirm whether it is within its remit and potentially in breach of UK legislation. If the content is considered to be potentially criminal, the IWF can take action against the child sexual abuse images and videos hosted anywhere in the world. It can also act against criminally obscene adult content and non-photographic child sexual abuse content hosted in the UK.
10. Depending on where the content is hosted, the process for dealing with potentially criminal images and videos differs. When child sexual abuse content is found to be hosted in the UK, the IWF will inform CEOP. After confirmation from CEOP that action can be taken, the IWF will notify the hosting provider who will remove the content from its servers, typically within 60 minutes after receiving the notification from the IWF. This process is commonly referred to as “Notice and Takedown”.
11. When child sexual abuse content is found to be hosted outside the UK, the IWF will inform its counterpart hotline in the hosting country through INHOPE, the international association of hotlines or link in directly with local law enforcement. As other countries take significantly longer to remove child sexual abuse content—50% of the content the IWF passes on internationally is still available after 10 days—the IWF adds the links (URLs) to the content to its URL list (or “blocking list”). IWF members can use this list to voluntarily block access to these URLs to protect their customers from stumbling upon the images and videos. The URLs on the list are as targeted as possible, often comprising a single image or video. This is done in order to prevent the blocking of anything outside the criminal images or videos.
12. In addition to “Notice and Takedown” and the URL list, the IWF also compiles a keyword list of terms that specifically refer to child sexual abuse content. This list is used, for instance, by search engines to prevent people from finding images and videos of child sexual abuse content. The keywords are very specific—or very specific combinations of words—that carry no meaning besides the specific reference to child sexual abuse content. This means the keywords will not prevent access to legitimate websites such as, academic research papers into the area of child sexual abuse or websites aimed to help or inform people in relation to child sexual abuse.
13. Finally, the IWF also monitors newsgroups and can issue notices for removal of individual postings where child sexual abuse content is identified or entire newsgroups if these are being used to specifically distribute child sexual abuse content.
14. IWF achievements: In 2012, the IWF processed 39,211 reports and assisted with the removal of 9,696 URLs containing potentially criminal child sexual abuse content. A URL can be as specific as a single image or could refer to an entire website containing potentially thousands of child sexual abuse images or videos. The majority of victims (81%) appeared to be 10 years old or younger (with 4% 2 years old or under) and 53% of the images and videos depicted sexual activity between adults and children, including rape and sexual torture. Over the past 17 years, the IWF has assessed over 400,000 webpages and assisted with the removal of 100,000 URLs containing potential child sexual abuse content. By sharing intelligence with the police, the IWF aided with the identification and rescue of 12 children in the past three years.
15. IWF success: In the past decade, the UK has become the world leader for dealing with child sexual abuse content and the IWF is considered as one of the most successful hotlines in the world. Both the amount of reports received/processed by the IWF and the speed with which action is taken is amongst the best within Europe and beyond. As a result, the share of child sexual abuse content that is hosted in the UK is less than 1% of the total amount of known content, down from 18% in 1996 when the IWF first started. This means that—because of the efficiency of the current system—the UK has become an extremely hostile territory to host child sexual abuse content.
16. The success of the IWF is foremost due to its very clear and specific remit. Because of the strong focus on child sexual abuse content, the IWF has accumulated a very thorough and extensive knowledge on how to deal with this content effectively. On the one hand, this means the IWF’s analysts have become experts in this area, often recognising images and even victims/perpetrators within the images. They can pass on this information to law enforcement to aid the investigation into the sexual abuse. On the other hand, the IWF has been able to develop a strong network to fight the availability of child sexual abuse content. This multi-stakeholder approach is crucial for successfully dealing with child sexual abuse content and the IWF has built a very strong network, both with law enforcement, the online industry and international partners, for specifically dealing with child sexual abuse images. In addition, the success of the IWF is also a result of its self-regulatory model which allows the IWF to adapt quickly to new developments and of the strong support it has received from the online industry over the past 17 years.
17. IWF future: The online environment is ever changing and the IWF is committed to continue developing in order to fight child sexual abuse content effectively in the future. Following a donation from Google and additional funding from other Members, the IWF will increase its number of analysts from 4.5 (full-time equivalents) to 11.5 (full-time equivalents). In addition, the IWF was asked by Government to start proactively searching for child sexual abuse content rather than working only from public leads. The IWF will continue its role as the UK hotline but will be able to add-on the proactive work in order to increase the amount of child sexual abuse images it can take action on. An ongoing membership review is addressing the need to improve IWF’s resources in order to ensure a sustainable future for the IWF and its increased activities.
18. A final aspect of IWF’s future development concerns its international activities. As 99% of the known child sexual abuse content is hosted abroad, it is of the utmost importance that international cooperation is further developed to remove the child sexual abuse images and videos at source. The IWF is actively engaging with international partners to share its expertise. It has developed “OCSARP”, its “Online Child Sexual Abuse Reporting Portal”, which countries without child sexual abuse content reporting facilities can implement, while the IWF provides assistance with the assessments of the reports.
Conclusion
19. The area of “Online Safety” is very broad and very volatile, with risks as well as possible solutions developing constantly. It would be worthwhile to clearly frame the debate and break up the overall topic in clearly defined aspects of online safety. Online conduct is different from online content. Criminal or illegal content is different from legal but potentially harmful content and an image of a child being sexually abused is different from the promotion of terrorism. This is not to say there is necessarily a hierarchy between the “severeness” of different types of illegal content, but different types of content will require different procedures, different checks and balances and the involvement of different actors.
20. The IWF—and the online industry—has been very effective in fighting child sexual abuse content over the past 17 years. The IWF’s very specific self-regulatory and multi-stakeholder model is extremely effective for dealing with child sexual abuse content and the IWF remains committed as ever to continue developing and improving the fight against child sexual abuse content in the years to come.
September 2013