RESPONSE TO THE CONSULTATION ON SAFER INTERNET AND ON-LINE TECHNOLOGIES FOR CHILDREN
BT’s Response

 June 2007

This briefing can be downloaded in PDF format [46KB]

1. Summary

BT is a leading provider of communications solutions serving customers throughout the world. We take the issue of Child Protection and Internet Security very seriously and have been involved in several initiatives to protect children, customers and our employees. BT was the first company in Europe to have a dedicated e-Crime and Internet Abuse team and we have spearheaded numerous initiatives to provide a safe and secure internet environment.

The Commission distinguishes between a) Illegal Content, b) Harmful Content and c) User Generated Content and BT firmly supports this approach. Certainly, looking at the discrepancies between EU Member States it is essential to keep this distinction in the debate as is the only way to work together while also maintaining respect for some fundamental differences in approach between Member States.

BT strongly endorses the Safer Internet Programme that the Commission has successfully run and wishes to see the initiative continue. We also believe that INHOPE and its hotlines have, and will continue to have, an important role to play in tackling illicit material on the internet. The international network of awareness nodes that have been created through this initiative is an appropriate way of dealing with all three themes explored in the questionnaire.

The internet remains a new and developing medium and there must always be a firm evidence base prior to a potential initiation of new legislation in this field.

Empowerment of parents is key in aiding the protection of children in the on-line world. In recognition of this, as a part of all of BT’s consumer broadband products, we offer free parental controls and parental guardian tools along with free identity and security products throughout our product range. Examples of some of these tools which serve to minimise risks are given below.

Some issues touched upon in the questionnaire remain issues for law enforcement authorities alone. BT has not commented on these as they should be addressed by the relevant and responsible authorities.

2. Fighting Illegal Content

BT believes that the issue of fighting illegal content is an on-going issue and we support a continued pro-active approach by the Commission. In the UK and abroad we work closely with authorities to tackle illegal content on-line.

There are a number of measures required to tackle and contain problems of illegal content on the internet and there is no one easy solution. BT believes an exchange of best practice coupled with self-regulation can assist in creating a dialogue, a climate for understanding what action is required to tackle illegal content as well as providing appropriate action in some cases.

The work of hotlines and INHOPE

BT strongly commends INHOPE and its hotlines in their coordinating work. We believe that the body has been a major factor in the successful fight against child abuse images being hosted in the EU and third countries. Therefore, BT calls on the Commission to BT’s response to the consultation on Safer Internet and On-line Technologies for Children 2 continue its support for the coordination node and to invest greater effort in global cooperation.

Law Enforcement

Constructive engagement between industry and law enforcement agencies (“publicprivate partnership approach”) is essential to provide good opportunities for law enforcement agencies to understand the business and technologies. BT supports this in a variety of ways and has a specialist team which works closely with the authorities to tackle illegal material on the internet.

Third Country Relations

In relation to problems with third countries, we see a need for increased and effective global cooperation. Even though the EU is making progress in tackling issues, this is not the case in some other third country jurisdictions. In order to tackle child abuse images on the internet, more efforts need to be made. BT endorses the approach of the UK’s Internet Watch Foundation (IWF) as being highly effective, including through providing a good forum for discussion for a range of stakeholders. We also welcome the calls for greater international cooperation between law enforcement bodies made in the Commission’s Communication on Cybercrime of May 2007.

Below, as a part of the exchange of best practice, we highlight some of our solutions and initiatives to fight illegal content on-line:

BT Yahoo Personal Guardian

We believe parents need to be equipped with tools to monitor their children’s internet usage. BT provides parental security tools and enhanced monitoring services to customers, allowing parents to have regular reports on their children’s on-line activity. The system provides parents with detailed information about chat rooms, the sites the child has tried to access and who they have emailed and received emails from.

Child Abuse Initiative (“Cleanfeed”)

BT’s subscribers are protected from inadvertently accessing images of child sexual abuse which have been identified by the IWF. Those who attempt to access a web page which contain illegal sites automatically receive an error message which indicates that the page is unavailable. This initiative, which contributes to cracking down on abuse online, relies on a list compiled by the IWF.

Child Exploitation and Online Protection (CEOP) and Virtual Global Taskforce (VGT)

BT works closely with Child Exploitation and Online Protection (CEOP) Centre. This unit works across the UK’s territory and seeks to maximise international links to tackle child abuse wherever and whenever it happens and comprises experts in child welfare and children’s charities as well as law enforcement experts.

BT also maintains a good working relationship with the Virtual Global Taskforce. This organisation creates a global police presence on the internet. Users who are concerned about the activities of a user towards a child can click on the VGT logo on the BT Yahoo homepage, thus reporting the incident directly to the child protection agencies.

The VGT covers the UK, USA, Canada and via Interpol in other jurisdictions.

Get Safe Online

BT is a major sponsor of this initiative along with the UK’s SOCA (Serious and Organised Crime Squad), UK Government and industry partners. This designated website gives BT’s response to the consultation on Safer Internet and On-line Technologies for Children 3 advice on protecting your personal computer, your family and your business. It covers many aspects, such as viruses, hacking and e-privacy.

Internet Green Cross Code

BT created the first Government, Police and NGO endorsed internet safety message that simply and technically neutral explains how to stay safe on- line using the message “Stop, Think and Stay Safe”.

The leaflet is freely available and has been widely adopted in the UK and other parts of the world. Its message is also accompanied by simple advice for teachers and carers.

3. Fighting Harmful Content

BT wishes to emphasise that what constitutes harmful content is subjective in nature, given different cultural variations between the Member States. Hence, there are limitations on the extent to which it is possible and appropriate to reach a common EUwide definition of what is harmful. This is why we advocate an evidence- based approach and one which also takes into consideration cultural sensitivities.

In relation to whether there is a need for a continued pro-active fight against harmful content, BT believes that there is still a need for further effort in this area. The type of material considered harmful should be for the Member States legal and cultural systems to establish.

BT participates in a series of initiatives in the UK and beyond to tackle harmful content and we fully endorse a multi-stakeholder approach. This approach provides for debate about products, potential measures and potential tools, and also serves to educate users. On the questions of the role of the media and educational establishment, BT firmly believes in joint efforts. Schools have a particular role to play. They can help raise awareness about threats for children in an on-line environment and at the same time can inform parents of the need to be involved in what their children do on the internet. Effective awareness-raising may perhaps be best achieved in the context of a holistic approach which deals with a range of inter-related matters covering risks affecting children, growing-up, literacy and citizenship, i.e. so that “real life” and on-line issues are treated together rather than through dealing with online issues in isolation or as a matter to be addressed primarily through ICT education.

We wish to draw the Commission’s attention to CEOP’s “Thinkuknow” campaign, which serves as a good example for trying to inform children about their vulnerability to grooming online.

On tackling harmful content online internationally, BT is of the view that international networks and nodes in each Member State can be beneficial. This, combined with technological measures, can improve internet safety of users but we also believe that parents have to be enabled to monitor what their children do on-line. BT has special parental tools available, described above, to its subscribers, which go some way to addressing and managing risks. However, continued education for adults and children alike on how to use the internet and what the risks are would further minimise those risks to children and improve the situation.

4. User-generated Content and On-line Communication

BT acknowledges that there are risks associated with user-generated content. However, we wish to highlight the positive evolution for consumers and ISPs alike. This mode of communication is in its infancy and it provides excellent platforms for creativity, interaction and communication for all users.

Again, BT’s Yahoo Personal Guardian and “Cleanfeed”, described above, help to reduce risks to children in the on-line environment. BT’s response to the consultation on Safer Internet and On-line Technologies for Children 4 Bullying and grooming are distressing societal problems Since they arise irrespective of developments in communications technologies, tackling the problem behaviours at their root should be the primary focus of efforts. In terms of efforts that can be made by industry, BT advocates the continuation of multi-stakeholder efforts seeking to tackle these problems. Any efforts to get children more accustomed to on-line environments, whilst also highlighting the risks associated with their actions on-line, will facilitate safer use of this medium.

5. Conclusion

BT thanks the Commission for its consultation.

We acknowledge the work of the Safer Internet Programme and see good reasons for its continuation. BT hopes that its input can contribute to the Safer Internet Plan.

Further discussions about best practice between different operators, Member States and the Commission would be welcome.