IWF response to the EC consultation on Safer Internet and online technologies for children
1 Introduction
On 13 April 2007, the European Commission launched a public
consultation to identify the most effective ways of making the online
environment and communication technologies safe for users, in particular
children.
The current Safer Internet plus programme will end in 2008 and the
Commission is conducting this consultation in order to create a basis
for deciding whether to propose a follow-up programme from 2009 to 2013
and how best to address issues relating to online technologies in the
future.
2 About the Internet Watch Foundation (IWF)
The IWF is the only authorised non statutory organisation in the UK
operating an internet ‘Hotline’ for the public and IT professionals to
report their exposure to potentially illegal content online.
Our aim is to minimise the availability of potentially illegal internet content, specifically:
- child abuse images hosted anywhere in the world
- criminally obscene content hosted in the UK
- incitement to racial hatred content hosted in the UK
We work in partnership with police and UK Government departments
such as the Home Office and the Department of Trade and Industry 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.
We are funded by the EU and the online industry including internet
service providers, mobile operators and manufacturers, content service
providers and telecommunications and software companies, as well
blue-chip and other organisations who support the IWF for CSR reasons.
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 on their systems and
simultaneously alerting the police to investigate the publisher.
We also provide a comprehensive list of websites containing child
abuse content for organisations such as ISPs, mobile network operators,
software companies and search engines to block access to potentially
illegal child abuse images and a list of newsgroups which we regularly
contain or advertise child abuse content.
3 IWF response to the European Commission’s consultation on Safer Internet and online technologies for children
- IWF has responded to the questions in questionnaire 1 only – fighting illegal content - see appendix 1 below.
4 Contact information
For further information please contact:
Internet Watch Foundation
5 Coles Lane
Oakington
Cambridge CB24 3BA
Tel: 01223 237700
Appendix 1
Questionnaire 1 – Fighting illegal content
The IWF response to questionnaire 1 - Fighting illegal content
1.1 In your opinion, is there a need beyond the year 2008 to pro-actively fight against illegal content?
Yes, there is a need to continue to pro-actively fight against illegal content.
1.2 If so, please give indications on what kinds of illegal content/material should be dealt with.
The IWF’s remit includes the following content:
- child abuse images hosted anywhere in the world
- criminally obscene content hosted in the UK
- incitement to racial hatred content hosted in the UK
It is critical that there is a continued worldwide effort to
pro-actively combat potentially illegal content, especially child abuse
content.
The key to success must be a collaborative international effort.
The issues transcend national boundaries and the EU is clearly best
placed to drive the European response forward.
1.3 Which should be the means of fighting
the production and distribution of illegal content, in particular child
sexual abuse material, and what stakeholders should take initiatives
(industry, governments, NGOs, financial institutions etc.)? Please
suggest ways in which the different stakeholders can contribute in
fighting against production and online distribution of illegal content.
The UK has an effective multi-agency partnership with the UK-based
internet industry, government departments and law enforcement agencies.
In that partnership, clear roles and responsibilities are defined
resulting in an effective self-regulatory model based on a voluntary
notice and takedown code of practice and mutual trust.
The key to success must be a collaborative international effort.
The issues transcend national boundaries and the EU is clearly best
placed to drive the European response forward.
The concept of an EU child abuse URL database project needs to be
realised to facilitate more effective targeting of EU resources. It
would also enable the EU to develop an improved understanding of the
extent, spread and trends in potentially illegal content. It is vital
that the EU is aware of the scale of potentially illegal content in
order to target resources and respond to trends. As a by-product, the
database could also be used to supply data to European service providers
who voluntarily wished to filter child abuse material to protect
consumers
Consideration should be given to removing domain names that are
clearly linked to child abuse material. Nominet, the .uk domain name
registry, works in partnership with IWF to minimise the risk of any
domain name implying that child abuse images may be available. Nominet
has also been active in trying to ensure that registration details are
accurate. However, internationally, evidence appears to suggest that
some of these types of domain names are registered with false
information. Where possible domain name registries should adopt the
good practice and partnership working that Nominet provides in the UK.
1.4 A central element of the fight against
illegal content for the Safer Internet plus Programme has been to
support an international network of civilian hotlines where the public
can report illegal content, should they chance upon it online. In your
opinion, is this the most appropriate way of dealing with illegal
content beyond 2008? How could their cooperation with law enforcement
agencies be strengthened?
To be effective across the EU, the network of hotlines and other initiatives need high level political support and resourcing.
The UK government chairs a multi-agency Internet Task Force which
brings together a whole range of stakeholders who have a collective
ambition to make the internet a safer place for children to use. This
model is seen as good practice and might be considered as a worthwhile
model to replicate in an intense effort to tackle the wider problems of
potentially illegal online content.
The loss or reduction of EU funding for hotlines could cause
financial difficulties for a significant proportion of the European
network. The potential disappearance of hotlines due to lack of funding
could result in parts of the EU being vulnerable to criminal
exploitation and the hosting of potentially illegal content
At a time when the number of internet users is growing
exponentially in Europe and beyond, there can be no better reason to
support the network of hotlines.
The network of hotlines provides important local knowledge and
contacts to assist in an international response to the tracing and more
efficient removal of potentially illegal content. As a consequence of
their special knowledge and relationships, within their nation states,
the network of hotlines is a reliable, trusted and credible source of
information.
Hotlines provide a reporting point for the public which can allow
closure following their exposure to potentially illegal content.
Civilian hotlines allow a degree of anonymity with their distance from
law enforcement – there may be some public reticence about reporting to
police hotlines.
The network of international civilian hotlines can reduce the
demands on national police agencies and prevent them from being
inundated with reports of content which is hosted outside their
jurisdiction.
1.5 How can other organisations support
national/local and international law enforcement agencies in dealing
with the production and online distribution of illegal content?
The UK has an effective multi-agency partnership with the UK-based
internet industry, government departments and law enforcement agencies.
In that partnership, clear roles and responsibilities are defined.
1.6 The internet has a global dimension:
illegal content can be produced in one country, distributed from a
second, and accessed/downloaded in many countries across the world.
Please specify which actions should be taken internationally. Are there
specific countries which should be focussed on?
IWF refers the EU to the statistics in our Annual Report 2006,
which gives a breakdown of where potentially illegal child abuse content
in processed reports appears to be hosted. The figures for 2006
indicate that 54.3% appears to be hosted in the US and 28.2% in Russia.
1.7 Research and development of efficient
technological tools (filtering systems, image recognition etc) can
contribute to reducing online distribution and indirectly the production
of illegal content. Which are the subjects which should be addressed
when supporting the development of technologies?
The concept of an EU child abuse URL database project needs to be
realised to facilitate more effective targeting of EU resources. It
would also enable the EU to develop an improved understanding of the
extent, spread and trends in potentially illegal content. It is vital
that the EU is aware of the scale of potentially illegal content in
order to target resources and respond to trends. As a by-product, the
database could also be used to supply data to European service providers
who voluntarily wished to filter child abuse material to protect
consumers
1.8 Analysis of psychological effects of victims and studies
of how offenders use the Internet to distribute the evidence of the
sexual abuse of children can also contribute to the fight against
illegal online content. Which are the subjects which should be addressed
in these areas when conducting research?
1.9 The legal situation concerning online distribution of
illegal content and indeed the definitions of what is illegal differ
across the EU Member States. Which are the issues which should be
addressed when harmonising legal provisions across Member States?
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.