Culture, Media and Sport Committee Inquiry into harmful content on the internet and in video games
Memorandum submitted by the Internet Watch Foundation (IWF), July 2008
About the Internet Watch Foundation (IWF)
1. IWF was formed in 1996 and became a registered charity in 2005 with the following company objects:-
- The promotion of the care and protection of the health and welfare of the public, in particular children and young people, by working to minimise the availability of potentially illegal or otherwise harmful content on the Internet.
- The prevention of crimes relating to offences involving exposure to illegal content on the Internet in particular by:
- operating a hotline enabling the public to report such instances;
- operating a notice and takedown service to alert hosting service providers of such criminal content found on their servers; and
- alerting relevant law enforcement agencies to the content. - To further such purposes as are recognised as exclusively charitable under the law of England and Wales
2. We are a self-regulatory body, funded by the EU and the wider online industry. This includes internet service providers (ISPs), mobile operators and manufacturers, content service providers, telecommunications and filtering companies, search providers and the financial sector as well as blue-chip and other organisations who support us for corporate social responsibility reasons.
3. The IWF is the only recognised organisation in the UK operating
an internet ¡¥Hotline¡¦ for the public and IT professionals to report
their exposure to potentially illegal content online.
4. The Board of IWF has approved a remit which aims to minimise the
availability of potentially illegal internet content, specifically:
- child sexual abuse images hosted anywhere in the world;
- criminally obscene content hosted in the UK;
- incitement to racial hatred content hosted in the UK.
5. We work in partnership with UK Government departments including
the Home Office, the Ministry of Justice and the Department for
Business, Enterprise and Regulatory Reform to influence initiatives and
programmes developed to combat online abuse. This dialogue goes beyond
the UK and Europe to ensure greater awareness of global issues and
responsibilities.
6. Through the 'Hotline' reporting system, we help ISPs to combat abuse of their services through a ¡¥notice and take-down¡¦ service by alerting them to any potentially illegal content, within our remit, on their systems and inviting the police to investigate the publisher. As a result, less than 1% of potentially illegal content has apparently been hosted in the UK since 2003, down from 18% in 1997.
6. Through the 'Hotline' reporting system, we help ISPs to combat abuse of their services through a ¡¥notice and take-down¡¦ service by alerting them to any potentially illegal content, within our remit, on their systems and inviting the police to investigate the publisher. As a result, less than 1% of potentially illegal content has apparently been hosted in the UK since 2003, down from 18% in 1997.
7. In partnership with many organisations, we strive to create
continued awareness of the role and purpose of the IWF and aim to foster
trust and reassurance in the internet for current and future users.
Harmful content on the internet
8. IWF has responded only to internet issues associated with content hosted online.
9. We believe the issues that we raised in our response to the
Byron Review remain relevant to the Select Committee's terms of
reference and the IWF response to the Byron questions is included in
appendix 1 below.
10. In appendix 1 we refer specifically to:
-User-generated content in appendix 1, paragraphs 33 to 36;
-Personal data and social networking sites in appendix 1, paragraphs 33 to 36;
-Incitement to racial hatred in appendix 1, paragraph 15.
-User-generated content in appendix 1, paragraphs 33 to 36;
-Personal data and social networking sites in appendix 1, paragraphs 33 to 36;
-Incitement to racial hatred in appendix 1, paragraph 15.
11. We have achieved remarkable internationally recognised
success. Since 2003 less than 1% of reports of online child sexual
abuse content, which have been processed by the IWF, have been traced to
content hosted in the UK. This is down from 18% in 1997.
12. Working in partnership with the online industry, government,
police and the public, we are recognised as an exemplary and highly
effective model of self-regulation around the world. Our positive and
effective links with the wider online industry and the inclusive nature
of our work with diverse stakeholders and partners have all contributed
to this success. Our partnership model is explained more fully at
appendix 2.
13. With regard to Extreme Pornography, in December 2005 IWF made
the following points as part of its response to the government's
proposals to criminalise the possession of extreme pornographic images:
- The IWF has not identified any criminally obscene content that might fail the obscene Publications Act threshold hosted on UK servers in the last two years. Our current remit with regard to obscenity is restricted to UK hosted content only.
- It is almost impossible to estimate how this statistic might change with the introduction of a possession offence because it seems that little attention has hitherto been given to content published in the UK that appears to have no underlying commercial motive.
- Most criminally obscene reports (not child abuse content) that we process relate to content hosted abroad but 12% of all those content allegations would fail the current UK test of criminally obscene if hosted in the UK and would fail the simple 'possession' offence proposed.
- There are no reciprocal arrangements with any other country to exchange information on criminally obscene content.
- There is no UK national police unit currently dealing with obscenity issues.
- A search on the internet using the word 'bestiality' and with filters turned off returns thousands of hits; the top one is a website of humans engaged in sex acts with animals which is hosted in Denmark. A similar search for images with filters turned off returns hundreds of pictures depicting bestiality.
14. In 2007, IWF received around 36,000 reports of online content
which reporters judged to be within our remit. There were 75,000
visitors to the IWF online reporting page and a further 30,000 visits to
our FAQs. On a daily basis we receive telephone calls from the public
about content which has caused concern. These figures indicate that
there is public concern about content outside IWF¡¦s remit.
Appendix 1
IWF responses to the Byron Review
Understanding the potential risks
What are the potential and actual risks to children and
young people who use the internet and how should the Review approach
defining and measuring those risks?
15. It is evident from our work that there is a huge number of web site 'landing pages' (1)
and web pages from around the world which are accessible to the UK
consumer and host content which may be considered potentially illegal,
harmful or inappropriate for children. Within our remit, such content
may include:
- Potentially illegal child sexual abuse content - In 2007, IWF processed 35,656 reports of which 9,053 URLs were confirmed to contain child sexual abuse content and would have failed the UK legal definition had the content been found on a defendant's electronic device (2) .
- UK hosted R18 adult pornographic content, accessible to all users (including children) and on landing pages without access controls such as age verification systems or credit card requirements, which could be interpreted as potentially illegal under the Obscene Publications Act (as likely to deprave a child seeing the content).
- Potentially illegal content likely to incite racial hatred - In 2007, IWF processed 847 such reports and assessed 203 of these to be content likely to incite racial hatred. However, only one report identified content which could be traced to a UK host and could therefore be forwarded to the appropriate UK authorities (3).
16. A web search using unambiguous and explicitly adult terms and with search filters switched off (4) ,
returned 10,100,000 web pages. In this particular test, all of the
links on the first three pages of the search linked directly to content
which might be considered as potentially illegal under UK law if hosted
in the UK and almost certainly could be construed as inappropriate for
children to view. If the links are accessed without a 'pop up blocker'
on the web browser, then a number of sexually explicit images also
appear as 'pop ups'. The same search query with filters on returned
1,660,000 web pages; mostly online discussions or news items and no
direct links to sexually explicit content were found. Searching for
images without filters applied and using a common term such as 'teen',
returns a number of sexually explicit images which are not potentially
illegal child sexual abuse images but are likely to be considered
inappropriate content for children. The images are hosted on web pages
which are accessible to anyone without any search filters or access
controls. Repeating the search with filters on returned no sexually
explicit images or inappropriate content for children within the sample
viewed.
17. In November 2005, the Home Office Task Force on Child Protection on the Internet published the 'Good Practice guide for search providers and advice to the public on how to search safely'. The guidance and advice contained in the publication can help protect young people.
18. In June 2007, IWF responded to a government consultation on criminalising possession of non-photographic visual depictions of child sexual abuse. In order to estimate the volume of such content, a search of the web on various 'cartoon fantasy'¦ terms known to refer to pre-pubescent children was carried out. The search returned a total 68,600 web pages and a sample indicated that the percentage of the search results, which contained child sexual abuse depictions assessed to be at level 3 or above, was 7.5%. Such content is likely to be considered potentially harmful or inappropriate for children. None of the content appeared to be hosted in the UK but would be available to UK consumers.
19. IWF also receives reports about 'mutilation' sites which depict extreme violence or bodily mutilation of people or animals and are particularly graphic. The web sites are rarely, if ever, hosted in the UK, but are available to UK consumers and may be considered inappropriate content for children to view.
20. IWF research suggests that as many as one in twenty UK adult internet users (or 1.5 million people) stumble across child sexual abuse content on the internet. Furthermore, our research would suggest that those seeking legal online adult pornography are almost twice as likely to stumble across indecent images of children. Whilst this cannot add specifically to an understanding of young people's online behaviour, it can inform understanding of how illegal online content may be inadvertently accessed. The UK industry has agreed to reduce instances of "stumbling across" child sexual abuse content by blocking third party websites which have been reviewed by the IWF and found to be containing child sexual abuse images (5). The IWF and the UK have been seen as a great success in promoting self-regulation around child sexual abuse images.
What do a) children and young people and b) parents already know about the potential and actual risks of using the internet?
21. IWF industry members, many of the UK's major online brands, joined forces in their efforts to raise awareness of our organisation and the first IWF Awareness Day, held in October 2007, was a culmination of such efforts.
22. Our industry members and stakeholders provided fantastic
support of the Awareness Day by running adverts on their websites and
intranets and other communications channels, and by emailing their
customers and staff with information about our work. The aim of the day
was to reach out to the UK's vast online population to raise awareness
of our 'Hotline' and let them know that the IWF is dedicated to getting
potentially illegal online content removed.
The media coverage we received for the day was very impressive with
almost 300 articles, including 70 radio and TV broadcast features -
regional, national and international. We were particularly pleased with
the positive messaging around the industry's responsible approach and
IWF support and the UK success. Our website statistics show we had a
320% increase in visitors on Awareness Day and the day after and a
comparison of the same 2 day period with the previous month shows a 67%
increase in reports to the Hotline about child sexual abuse content
online.
Helping children, young people and parents manage risks
What are the range of mechanisms that exist to help
children, young people and parents manage the potential or actual risks
of engaging with the internet?
23. IWF operates a self-regulatory partnership with the UK online
industry, government departments, law enforcement agencies and the
public, whilst ensuring effective consultation and coordination with
wider stakeholders. The success of this approach is clear, particularly
that of ensuring UK networks are some of the most hostile spaces in the
world to the hosting of potentially illegal online content within our
remit. Confirmed reports of child sexual abuse content apparently
hosted in the UK has reduced from 18% in 1997 to less than 1% since
2003. On the rare occasion it is hosted in the UK, the quick and
effective partnership with the online industry means it is removed
within hours. A more detailed description of the IWF model is shown at
appendix 2.
24. In addition, many UK internet access providers, and all major
search engines, licence the IWF's list of child sexual abuse URLs hosted
outside the UK and block users' access to this content (6). This helps prevent users of all ages inadvertently stumbling upon such criminal content online.
Are children, young people and parents aware of the tools available and to what extent do they use them?
25. IWF has found that there is a low level of consumer awareness
about potentially illegal online content issues within our remit and the
processes and mechanisms for dealing with or reporting such content.
Although IWF was formed in 1996, consumer awareness of us and our role
remained low for many years - 1 % awareness in 2005 - and only recently,
following investment in awareness raising campaigns, do we believe
public awareness of IWF has increased to around 19%.
26. IWF awareness work to increase the visibility of the IWF
'Hotline' around the UK as well as raise the profile of our successful
model around the world is ongoing. We consistently target law
enforcement agencies, IT professionals, parliamentarians and
policymakers as well as child protection workers, teachers and other
relevant professionals. This year we completed a campaign aimed at men,
particularly young men, following research into their online habits.
Crucially, our industry members, many of the UK's major online brands,
joined forces in their efforts to raise awareness of our organisation
and the first IWF Awareness Day, held in October 2007, was a culmination
of such efforts.
27. Our industry members and stakeholders provided fantastic support of the Awareness Day by running adverts on their websites and intranets and other communications channels, and by emailing their customers and staff with information about our work. The aim of the day was to reach out to the UK's vast online population to raise awareness of our 'Hotline' and let them know that the IWF is dedicated to getting potentially illegal online content removed.
28. The media coverage we received for the day was very impressive
with almost 300 articles, including 70 radio and TV broadcast features
- regional, national and international. We were particularly pleased
with the positive messaging around the industry's responsible approach
and IWF support and the UK success. Our website statistics show we had a
320% increase in visitors on Awareness Day and the day after and a
comparison of the same 2 day period with the previous month shows a 67%
increase in reports to the Hotline about child sexual abuse content
online.
29. It is important that all adult internet users are aware of our
'Hotline' reporting mechanism and know what to do if they stumble across
online illegal content so that we can continue our work getting this
content removed. It is also necessary in order to foster trust and
reassurance in the internet, that UK consumers are aware of the actions,
support and funding from a mature and responsible UK online industry.
30. The IWF has also published a list of providers who have committed to using the IWF's URL list to block users' access to known child sexual abuse images hosted outside the UK. This can help concerned consumers make an informed choice.
What opportunities exist for children, young people and
parents to learn about safe, responsible and fulfilling internet use ¡V
and do they help?
31. IWF has invited child protection professionals, police,
teachers, policy makers and other interested professionals to various
awareness raising events and sign-posts interested parties to similar
events and sources of important information, such as CEOP.
GENERAL
What impact will new ways of accessing media have on the questions being considered in this review?
Mobile:
32. In Japan there is more access to the internet via mobile
technologies than from fixed access points. There is every reason to
think that this trend will apply to the UK as more and more portable
electronic devices come on stream. Therefore the old adage that a single
family computer should be placed in a family room for parents and
carers to supervise their children's use of the internet is being
overtaken by smaller and portable devices being used by many young
people.
Social networking services:
33. IWF are aware of concerns about user-generated content of
under-18s posting provocative and indecent images of themselves, which
may constitute child sexual abuse content, and place them at risk of
inappropriate contact from adults (through their online profile and
image which becomes widely available to the internet community).
Currently the IWF has received few reports about user-generated content
of this type but there is concern that this may change if young users
take risks with the types of images they post.
34. At this stage we are unable to quantify the extent of the issue
or the risk to children and young people. We have received just over
150 reports since social networking sites started to become popular in
2005. No potentially illegal content has been found although we have
passed on 6 Police Intelligence reports (usually where profiles were
requesting meetings with children or looking to exchange potentially
illegal images).
Photo sharing services:
35. Around 18 months ago, we noted a growth in the number of
reports about potentially illegal child sexual abuse content being
hosted in photo-sharing sites including some which support social
networking services. Recently, in the larger companies, abuse of these
sites has reduced significantly, probably due to improvements in
security and abuse management. However new photo-sharing sites are
constantly appearing and newer companies, unaware of the risks, have
their services abused by the posting of potentially illegal content.
When the content is reported to the IWF and assessed to be potentially
illegal child sexual abuse which is hosted outside the UK, it will be
added the URL list and blocked to UK consumers.
Personal data:
36. It is important for parents and carers to understand that the
presence of online personal information about children and their
pictures can result in unrestricted availability and place them at
risk. Images can be used and altered to produce potentially offensive,
inappropriate, abusive or illegal pseudo-images.
The popularity of social networking sites amongst young people, and Web 2.0 developments and virtual world websites, present new challenges for parents and carers to keep up with the pace of technological change. The developments present new challenges with regard to potentially illegal and inappropriate online content which may put children at risk.
The popularity of social networking sites amongst young people, and Web 2.0 developments and virtual world websites, present new challenges for parents and carers to keep up with the pace of technological change. The developments present new challenges with regard to potentially illegal and inappropriate online content which may put children at risk.
Appendix 2
The IWF model
37. The Internet Watch Foundation (IWF) was established in 1996
following agreement between Government, police and the internet industry
that a self-regulatory approach was necessary to combat the growing
problem of child sexual abuse content on the internet. The IWF is
funded by the UK online industry and receives a grant from the EU Safer
Internet Plan. The IWF now operates the only recognised non statutory
UK internet 'Hotline' for the public to report their exposure to online
child sexual abuse content hosted anywhere in the world and criminally
obscene and incitement to racial hatred content hosted in the UK.
Working in partnership with the online industry, Government, police and
the public, we are recognised as an exemplary and highly effective model
of self-regulation around the world. As a result of our positive and
effective links with the wider online industry and the inclusive nature
of our work with diverse stakeholders with different philosophies, we
have achieved remarkable, internationally recognised success, not least,
that less than 1% of online child sexual abuse content reports
processed has resulted in traces to content hosted in the UK since 2003,
down from 18% in 1997.
38. In order to fulfil our role and remit we deploy a range of approaches and offer various services to our members, these include: the Hotline reporting service, notice and takedown, a code of practice for members, Usenet newsgroup policies, the provision of keywords, a child abuse spam alert service and blocking. To facilitate blocking the IWF produces a list of URLs containing potentially illegal child sexual abuse content hosted overseas and this unique list is made available to IWF members under licence so that they can develop technical solutions to prevent their users from being inadvertently exposed to this type of content.
39. Our industry members have grown from 9 in 1999 to nearly 80 in
2007. We were a founding member of INHOPE, the association of Hotlines
around the world, and we make a significant contribution to the Home
Secretary's Task Force on the Protection of Children on the Internet.
Importantly, we are consistently referenced as a national and
international model of effective self- and co-regulation and are
commited to sharing our best practice around the world.
40. The IWF is recognised as an influential and relevent authority
by many sectors, from commercial and media to charities and
policymakers. We maintain the high standard we have set in this country
as we raise awareness of our work and focus global attention on those
challenges still to be addressed; particularly those issues requiring an
international approach which transcend country borders, to which we can
add expertise.
41. Our governance structures are based on consultation; with the
online industry and with key stakeholders, ensuring our response to new
challenges in the constantly evolving field of online criminal content
within our remit is responsible, informed, effective and widely
supported. Our industry members have put aside market-place rivalry in
their united support of our important work and aims.
42. We work to foster trust and confidence in the internet for
current and future users, working to ensure they are aware of our
'Hotline' reporting mechanism and that there is a body combating
potentially illegal online content. The online industry is acting
responsibly by funding our work, supporting our aims and volunteering to
block their customers access to child sexual abuse content hosted
outside the UK.
The full report of the Culture, Media and Sport Committee Inquiry into Harmful Content on the Internet and in Video Games can be found here 
.
Notes
(1) A landing page is the web page on which a visitor arrives after clicking on a link or advertisement.
(1) A landing page is the web page on which a visitor arrives after clicking on a link or advertisement.
(2) The figures have been updated since the submision to the Byron Review to include the latest 2007 information.
(3) The figures have been updated since the submission to the Byron Review to include the latest 2007 information.
(4) Some search services will have filtering
defaults set to 'moderate' which filters out explicitly adult results.
Users may choose to switch off the filter altogether or choose a higher
setting. With some search companies parents can also opt to lock safe
search to 'on' for a particular computer so that no-one in the household
using that computer can change the settings.
Please note: The IWF uses the term child sexual abuse content to accurately reflect the gravity of the images we deal with. Please note that child pornography, child porn and kiddie porn are not acceptable terms. The use of such language acts to legitimise images which are not pornography, rather, they are permanent records of children being sexually exploited and as such should be referred to as child sexual abuse images. If you see such content online please report it to the IWF.
