Select Committee on European Union Written Evidence

Memorandum by the Internet Watch Foundation (IWF)

  The Internet Watch Foundation (IWF) is an independent organisation funded by the UK Internet Service Providers (ISPs), which works to an agenda agreed with the Department of Trade and Industry and the Home Office.

  IWF's primary roles since its launch in 1996 are:

    —  Operation of a public hotline to receive reports of illegal content, primarily child pornography, which are actioned by "notification and take down" procedures with ISPs and forwarding intelligence to the national Criminal Intelligence Service (NCIS) for police action.

    —  Encouraging the development of labelling and filtering techniques that allow responsible adults to restrict children's access to content, which might be harmful to them.

  Following a review of our performance by the relevant departments, we have added an education and awareness role which seeks to promote safe use of the Internet, especially by children.

  Details of IWF's operations, constitution and remit are available on its website at

  IWF does not address e-commerce directly, but its operations and experience are relevant to this inquiry in a number of ways. We offer the following written observations on the questions as listed, and would be happy to provide oral evidence to expand them.

  1.  Public trust in the medium is an important underpinning to the growth of connections and participation in the Internet, which in turn promotes continued growth in e-commerce. The ability to demonstrate that criminal activity on the Net can be traced and dealt with by industry and law enforcement working in co-operation, as illustrated by co-regulation activities of the IWF, helps to build confidence to enter the Internet environment. Similarly providing effective means for responsible adults to provide a safe environment for children to learn from and enjoy the Internet experience at home and at school is important to creating a competitive workforce for the information age.

  This aspect of trust was encapsulated in the comment of the E-Envoy, Alex Allan, on the recent re-launch of IWF: "I am delighted to support the re-launch of the Internet Watch Foundation. The work of the IWF is essential if we are to encourage people to trust the technology—and trust is an essential pillar of e-commerce. The IWF is also a shining example of co-regulation—which I see as a basic foundation for making the UK the best place in the world for e-commerce."

  We hope that the Committee will similarly endorse our role in this area.

  2.  We do not have direct experience of "e-Europe: An Information Society for All", but have closely participated in the earlier and parallel development of European Union policies on illegal and harmful content, now being implemented through the "Action Plan for Promoting Safer Use of the Internet."

  In terms of the confidence building referred to above, we believe that this action plan is well founded and offers a comprehensive and effective way forward in addressing content issues. IWF is a founding member, and first president, of the INHOPE association of European hotlines, which now includes Germany, France, Holland, Austria and Ireland with associates in the USA, Australia and Norway.

  IWF is about to publish its findings from the INCORE (Internet Content Rating for Europe) project, a preparatory activity to the Action Plan funded by the European Commission (EC), which examines the feasibility of an internationally acceptable self-labelling and filtering system ( We are also a partner in the Internet Content Rating Association (ICRA), an international consortium registered in the UK, which is contracting with the EC to deliver such a system within the next 18 months.

  3.  In our view codes of conduct and co-regulation provide the most effective means of protection. While they may not be ideal, we do not see a better alternative among the examples of more direct legislative and regulatory measures, either in Europe or other parts of the world (including USA, Singapore, Australia). Therefore in our view, there is not a case for more interventionist measures by national governments or the EU. In fact we believe that such measures, or the contemplation of such measures, would be counterproductive in that it would undermine trust in co-regulation by consumers, industry and free-speech lobbies.

  4.  We have found that the institutions of national governments and the EU framework has provided a surprising degree of flexibility and coherence in the production of policies and plans to address Internet content issues. The progress made in policy development in this field is a positive example of what can be achieved jointly. Indeed the nature of the medium means that international communication and co-operation is essential and the European Union framework is an asset in this regard.

  5.  However, as we move into an implementation phase, we are encountering increasing problems with the Commission's structures and procedures hindering practical progress.

  Bureaucratic procedures are particularly unsuitable to the effective management of research and development functions or pilot operations. Their reliance on pre-established procedures and conditions means that they restrict the development of new ideas and approaches to new situations—which are the essence of dealing with the unprecedented rates of growth and change being experienced in the Internet. They are risk-averse, in an environment where a degree of risk is inherent in testing new solutions to new problems. They are also inefficient in that far too much precious staff resources and expenditure are taken up on the administrative processes, rather than doing the job they are trained for.

  To an extent the letting of contracts to independent organisations or consortia, as practised by the EC, can reduce the bureaucratic inertia once a contract is let, but this reinforces the remaining difficulty with bureaucratic procedures, which is inflexibility on planning and decision making. Developmental activities require regular monitoring and evaluation of progress against intended results and rapid decisions and re-planning to adjust to emerging results and changes in the environment. The Commission's contract procedures on the other hand require planning of activities several years in advance and penalise variation from the plans recorded in the contract. This is a recipe for failure!

  6.  We are convinced that alternative structures and procedures are necessary at the cutting edge of research and design of new activities, particularly in the hothouse of the exploitation and regulation of Internet technologies. We therefore believe that a different management style is required for development projects. One that is more akin to how commercial businesses run R&D projects, or indeed the Commission's own open and flexible style in the policy formation stages. We appreciate that proper controls on public expenditure are essential, but these should concentrate on ensuring that expenditure has been incurred on relevant activities before it is re-imbursed. The protracted tasks of creating a planning and financial straitjacket in advance and then applying it come-what-may must be abandoned.

20 February 2000

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