Memorandum by the Internet Watch Foundation
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
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
Details of IWF's operations, constitution and
remit are available on its website at http://www.iwf.org.uk/
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 technologyand trust is an
essential pillar of e-commerce. The IWF is also a shining example
of co-regulationwhich 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 (www.incore.org). 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
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 situationswhich 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