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Culture, Media and Sport Committee

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.

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.

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 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.

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.

(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.

(5) See IWF's faciliation of the blocking initiative.

(6) See List of recipients of the IWF URL List.

Report here