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July 29, 2013 | Ed Paton Williams

Take action: Call out Cameron on online censorship

David Cameron is asking Britain to sleepwalk into censorship. Everyone agrees that we should try to protect children from harmful content. But unprecedented filtering of legal content for everyone is not the answer.

David Cameron wants your ISP to push you into switching on web filters. These proposals are incredibly dangerous. Cameron should drop them immediately.

David Cameron Stop Default Internet Filtering

ORG's been spending a lot of time speaking to the media to make sure Cameron and the pro-blocking lobby don't go unchallenged.

But we need another way of putting some pressure on and letting him know how many people think his plans are mistaken.

Tell David Cameron to drop his plans to turn on adult filters by default. Sign our petition to him now!

The Government should help people make informed choices about what sorts of websites their household can visit.

 

Introducing adult filters as default is not an effective way to help make children safe and will cause huge issues that Cameron can't just dismiss as teething problems.

"Set it and forget it" is the wrong message to send to parents. It risks giving people a false sense of security. Just because ISPs block adult content, children are not automatically safe. Content that you might want to block will still get through. And filters won't stop sexting, bullying or stalking on the Internet.

Instead of trying to make decisions for parents, the Government should give them better support. Help parents to actively decide which sites to make more difficult for their children to visit. Concentrate on encouraging them to talk to their children about their online and offline activity.

Let David Cameron know his plans aren't the answer to keeping children safe. Sign the petition now.

We've seen mobile operators apply parental controls with terrible results. When ISPs use adult filters, they block sites by mistake. Lots of people need to be able to access educational material on sexual health and sexuality. But adult filters can miscategorise this sort of advice as pornography and stop people of all ages finding crucial advice.

David Cameron's wrong to put people's access to crucial information at risk. Please sign the petition to tell him you're against his plans.

David Cameron mentions adult filtering and stopping child abuse in the same breath. But accessing adult content is legal. Accessing illegal content is clearly a crime and should be treated completely differently.

So creating a register of people who want to access adult content or just want unfiltered Internet access brings serious and unjustified privacy issues. How will people on this register be treated? Who will have access to these databases? Will it be secure? The Government needs to address these questions.

Adult filtering affects everyone, not just children or families. So after you've signed the petition, can you share the link with your friends, family and followers?


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July 29, 2013 | Jim Killock

Twitter abuse: let’s debate what the police are doing

Calls for abuse buttons on Twitter may help a bit, but we should look to the police for law enforcement.

Police, Brierley Hill, cc-by-sa West Midlands PoliceRape threats are vile. They are also illegal. Harassment is also an offence. The recent spate of such threats against Caroline Criado-Perez resulted in a change.org call for a Twitter 'abuse' button.

Now that somebody has been arrested for threatening Caroline Criado-Perez, the debate should shift to where it should have started. How should the police react to complaints of online harassment and threats of violence?

From a campaigning standpoint, focusing on Twitter seems to make sense. Twitter have a customer base and reputation they need to protect. Rape threats are unacceptable, and Twitter will be under immense pressure to take action. Inaction looks like protecting the bottom line. People will understand that campaigning can have an effect in raising the issue of online threats and abuse. Labour have joined in with Yvette Cooper accusing Twitter's response of being 'inadequate'.

Several campaigners speaking in favour of a new 'abuse button' said they had focused on Twitter because the police had failed them.

Kate Smurthwaite said that she had on some occasions approached the police, who advised her to ignore the behaviour, or come back if she had any information about who it was. Caroline Criado-Perez also reported that she had complained to the police, but did not think they would act. Hence the focus on Twitter.

It is a common complaint I have heard even from MPs who have suffered online abuse.

Their complaints to the police were about criminal acts, beyond the point where free speech is at issue. The actions that Twitter can take are limited, and truly, 'inadequate'. Twitter could at best delete an account of an abuser, leaving them unpunished and able to set up a new account and carry on abusing. They might pass information to the police: but this could easily lack context and would be prone to errors of judgement.

Depending on the volume of complaints, abuse buttons would use automated sifting techniques. Thus they could be prone to abuse, or at the very least, mistakes. This may not mean that they are irrelevant, but they may not be as useful as is hoped.

We should worry if we make companies the main source of 'redress' for lawbreaking. From copyright through to libel, they are often badly placed to make fair judgements. Legal risk carries greatest weight rather than justice for someone complaining or complained about when a company takes an action. Companies making judgements can be a kind of privatisation of law enforcement that removes pressure on the police to deal with online offences.

After all, if a company deals with the problem statements, why shouldn't the police assume the problem has been solved and deal with something "more serious"?

There is a parallel between the proposals Cameron pushed last week, trying to blame search engines for inaction on paedophilia, and ISPs for failing parents. Even if companies can take some steps (and as difficult and complicated though that may be) the most important initiatives are in the hands of the state. For child abuse, policing is preferable to giving up and asking companies to take steps to obscure access to content, whether by search or 'web blocking'. In the case of children avoiding pornography, effective education and discussion are much more critical than whether ISPs sign up to "nudge censorship". 

In the case of victims of harassment, the police need to investigate, arrest and prosecute offenders. No doubt, after a few cases, people would start to avoid crossing a line. Just as importantly, it could create confidence among the victims that their complaint might be dealt with sympathetically by the police.

So far, incidents do seem to be resolved when the police have them drawn to their attention though mass media and online campaigning. This is not acceptable, however, if equally threatening situations are not taken seriously, purely because of a lack of public attention.

Once Twitter have provided better reporting tools, campaigners should focus back on the police, rather than starting from a point of view where they regard them as a lost cause.

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July 27, 2013 | Jim Killock

Who exactly is responsible for 'nudge censorship'?

We have no legislation, a contradictory official government policy, and ISPs promising that they will deliver a 'pre-selected' censorship approach.

claire-perry-cc-by-policyexchangeIn essence, DCMS's Maria Miller, Claire Perry and David Cameron's staff have hijacked agreed cabinet policy, pushed for something very different and persuaded ISPs that they should implement significantly worse policies than originally envisaged.

This is what was agreed in December 2012: some kind of compulsory prompt for parents to enable filters, that “does not impose a solution on adult users or non-parents”. Network filtering was never specified, although easy 'whole home' solutions were preferred. These could be in the hands of parents, at the router, rather than being placed in dangerously easily reconfigurable centralised ISP equipment.

For whatever reason, DCMS and Perry have been pushing both network filtering and 'nudge censorship' onto ISPs. ISPs have agreed; now those of us who think government has got it wrong have nobody clear to pressurise.

ISPs appear to have caved into the overwhelming PR issue that child protection can be, especially when conflated with the separate issue of child abuse images. But by refusing to insist that the government legislate, if it wants such specific provisions, they have opened themselves up to a number of problems:

  1. Are ISPs responsible for incorrect blocks?
  2. Are ISPs financially liable for incorrect blocks?
  3. What happens when government suggests that 'terrorist content' be blocked with not 'opt out'?
  4. Are ISPs responsible for adopting the nonsense 'preselected censorship' policy – as it is not official government policy, but apparently the personal position of Claire Perry and DCMS heads such as Maria Miller?
  5. Will Claire Perry continue to have a personal veto on the nature of broadband set up screens?

Finally, we would like to know if the Lib Dems are happy for Claire Perry and Cameron to go off piste in this way.

Here's the official government policy from December, so you can read what ISPs are actually meant to be doing, and how different that appears to be from what they have agreed to with Perry and Miller.

23. Although there was only minority support among parents for the three options consulted on, the Government does not believe parents are uninterested in their children's safety online: the very high percentages of parents who think they have the responsibility for their children's safety suggests otherwise. However, the offer to parents should be reformulated in a way that ensures that children can be given the levels of protection their parents think is appropriate for them, reduces the risk of uninterested parents avoiding online safety issues, and does not impose a solution on adult users or non-parents.

24. Our approach to child internet safety should therefore evolve in ways so that it: 

  • actively helps parents to make sure they have appropriate safety features in place when their children access the internet and also encourages them to think about issues such as grooming, bullying and sexting as well as potentially harmful or inappropriate content
  • covers existing ISP customers as well as new ones prompts or steers parents towards those safety features
  • makes it easier for parents to take charge of setting up the internet access their children will have, and less likely that they will abdicate this responsibility to their children

25. The Government is now asking all internet service providers to actively encourage people to switch on parental controls if children are in the household and will be using the internet. This approach should help parents make use of the available safety features without affecting internet users aged 18 and over who can choose not to set up controls.

26. Internet service providers have made great progress to date in implementing "active choice" controls where all new customers are asked if they want to switch on parental controls. The Government is urging providers to go one step further and configure their systems to actively encourage parents, whether they are new or existing customers, to switch on parental controls. The Government believes providers should automatically prompt parents to tailor filters to suit their child's needs e.g. by preventing access to harmful and inappropriate content. We also expect ISPs to put in place appropriate measures to check that the person setting up the parental controls is over the age of 18. This builds on the child internet safety approach already established by the four main ISPs by steering parents towards the safety features and taking responsibility for setting up those that are most appropriate for their own children. It will also help parents think about the knowledge and skills children need to prevent harm from the behaviour of other people on the internet: we are clear from the consultation that parents are conscious of these risks as well as those posed by age-inappropriate content.

27. This is only one part of the approach which the Government is pressing for. All of the information and communication industries, including retailers and device manufacturers, should work to develop universally-available family-friendly internet access which is easy to use. The Government wants to see all internet- enabled devices supplied with the tools to keep children safe as a standard feature.

Update


We've launched a petition calling for David Cameron to drop his plans for default Internet filtering. Sign the petition here: https://www.openrightsgroup.org/campaigns/cameron-stop-sleepwalking

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July 25, 2013 | Jim Killock

Sleepwalking into censorship

After brief conversations with some of the Internet Service Providers that will be implementing the UK's "pornwall" we've established a little bit about what it will be doing. To be fair, the BBC were pretty close.

The essential detail is that they will assume you want filters enabled across a wide range of content, and unless you un-tick the option, network filters will be enabled. As we’ve said repeatedly, it’s not just about hardcore pornography.

You'll encounter something like this:

EDIT NOTE: the category examples are based on current mobile configurations and broad indications from ISPs

(1) Screen one

"Parental controls"
Do you want to install / enable parental controls
☑ yes
☐ no

[next]

(2) Screen two [if you have left the box ticked]

“Parental controls”

Do you want to block

☑ pornography
☑ violent material
☑ extremist and terrorist related content
☑ anorexia and eating disorder websites
☑ suicide related websites
☑ alcohol
☑ smoking
☑ web forums
☑ esoteric material
☑ web blocking circumvention tools

You can opt back in at any time

[continue]

The precise pre-ticked options may vary from service to service.

What's clear here is that David Cameron wants people to sleepwalk into censorship. We know that people stick with defaults: this is part of the idea behind 'nudge theory' and 'choice architecture' that is popular with Cameron.

The implication is that filtering is good, or at least harmless, for anyone, whether adult or child. Of course, this is not true; there's not just the question of false positives for web users, but the affect on a network economy of excluding a proportion of a legitimate website's audience.

There comes a point that it is simply better to place your sales through Amazon and ebay, and circulate your news and promotions exclusively through Facebook and Twitter, as you know none of these will ever be filtered.

Meanwhile ISPs face the unenviable customer relations threat of increased complaints as customers who hadn't paid much attention find websites unexpectedly blocked.

Just as bad, filters installed with no thought cannot be expected to set appropriately for children of different ages.

Of course, all of this could be easily avoided by simply having an 'active choice' as the ISPs originally suggested: with no preset defaults, forcing customers to specify whether they wanted filters, or not.

It's really very surprising that Cameron's campaign has spent six months insisting on a system designed to fail consumers, threatening ISPs with legislation if they didn't use the inaccurate, error prone method that Number 10 seem to believe in.

If it all seems to work badly, at what point is it ok for ISPs to start running their own businesses, and change the setup screens?

Update


We've launched a petition calling for David Cameron to drop his plans for default Internet filtering. Sign the petition here: https://www.openrightsgroup.org/campaigns/cameron-stop-sleepwalking

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July 23, 2013 | Jim Killock

ISPs need to explain their filtering systems

ISPs have a lot of questions to answer. While they may feel that no legislation is better than letting parliament loose on the issue of content restriction, the turf on which they have been fighting with government is extremely narrow, but important.

Claire Perry cc-by Policy ExchangeWe are asking ISPs to explain how their systems will work, and to what extent David Cameron has represented or misrepresented their intentions. Do ISPs support or oppose active choice?

It’s worth explaining how the government got into this argument, and what precisely they are arguing about. It seems to us they are arguing over the precise ways in which “splash screens” are likely to operate, and whether or not they can be claimed as offering a “default” or a “active choice” to enable blocking.

The campaign for blocking began with Mary Whitehouses former group Media Watch and her erstwhile allies the christian Safer Media campaign calling for ‘default blocking’ of pornography, picked up by the Daily Mail, and then being backed by Claire Perry MP and a group of MPs who recommended this in a report sponsored by Safer Media and Premier Christian Radio. (Incidentally, the Perry report was not a 'parliamentary' report – it has no formal standing, unlike the last government's Byron Review, for instance, which opposed default filters.)

Claire Perry later became central to the government’s child safety work.

The government – or Claire Perry - argued for default network blocking, on the grounds that some parents would be too lazy to set filters up.

However, ISPs countered with the idea of 'active choice' - a question that must be answered asking if you want parental filtering enabled. The idea was that people would unavoidably make a choice, eliminating any need for defaults.

The government ran a public consultation, and decided that 'active choice' was best, but that filters, if being set up, could include preticked options.

The main reasons for this were that the Department for Education accepted that 'defaults' could mean children receiving less protection than appropriate, and creating more collateral blocking damage than necessary.

ISPs The major ISPs conceded that they would provide network level filtering. Despite advice that device filtering may well be more effective at blocking content (you can control it more closely) ISPs accepted that network filters may be 'easier' - easier for the government to know everyone has taken a choice over them.

The Daily Mail cried foul. People making a choice wasn't good enough: filters must be enabled by default, despite the evidence that this could harm children. Cameron responded, saying defaults would be there.

This is the ground on which this policy has been debated. ISPs have repeatedly ask that customers make an 'active choice' while the Prime Minister and Claire Perry insist that they be able to claim victory to the Daily Mail, by making the system in some way default to filtering.

All the harms come with defaults. If people understand what filtering is, then only those who want it will enable it. Those who enable it, will understand what they are or are not preventing, so can tailor it to their child's needs.

Let's hope David Cameron has been, shall we say, overstating things: the ISPs TalkTalk, BT, Sky and Virgin need to state clearly what is happening.

Edit note: this article refers to the major ISPs, TalkTalk, BT, Sky and Virgin, rather than ISPs in general and has been edited to reflect that

Update


We've launched a petition calling for David Cameron to drop his plans for default Internet filtering. Sign the petition here: https://www.openrightsgroup.org/campaigns/cameron-stop-sleepwalking

 

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July 22, 2013 | Jim Killock

David Cameron is issuing bad advice to parents

Moving onto filtering today, David Cameron has created a very unfortunate debate about what he expects from Internet Service Providers.

David Cameron cc-by-nc-sa WorldEconomicForumLast week, we published a list of questions about the impacts of filtering technologies, on privacy, Internet applications and user awareness of the technology. These are a baseline of the concerns. We do not expect filters to be 'default on' but rather 'active choice': we expect adults to make a choice about what they install, as the government promised following their DfE consultation last year.Cameron states that:

"By the end of this year, when someone sets up a new broadband account the settings to install family-friendly filters will be automatically selected. If you just click 'next' or 'enter', then the filters are automatically on.

We hope he is inaccurate. Why wouldn't the set up require you make make an 'active' decision, yes or no, as previously agreed? Anything less would mean parents not engaging with the technology. It would mean accepting  that the collatoral damage from filtering would apply to many people entirely pointlessly. This won't just be pornography: it will be likely to include alcohol, gambling, web forums, and supposedly extreme political views.

However, today's comments from Cameron also constitute misleading and dangerous advice to parents. He said:

"in a really big step forward, all the ISPs have rewired their technology so that once your filters are installed, they will cover any device connected to your home internet account. No more hassle of downloading filters for every device, just one-click protection. One click to protect your whole home and keep your children safe.

"Once those filters are installed, it should not be the case that technically literate children can just flick the filters off at the click of a mouse without anyone knowing. So we have agreed with industry that those filters can only be changed by the account holder, who has to be an adult. So an adult has to be engaged in the decisions."

This places too much faith in technical tools that have historically proved flawed in achieving their goals.

Teenagers are usually sexually curious, and the forbidden has its own cachet. This may motivate them to try to bypass filters. It is poor advice to suggest that they will not succeed.

The filtering being suggested is only likely to work for those not actively looking for adult content, and even then no filter is perfect.

For instance devices, left unchecked, could be used to bypass filtering with extreme ease. Filtering can often be bypassed by anyone with an admin password, by using a VPN or proxy. This may sound technical, but is trivial. Many children learn how to do this to access Facebook at school.

Additionally, many network filters will only be applied to content sent "in the clear" and not encrypted content. In this circumstance, if available, SSL can be used to trivially bypass filtering - anyone capable of adding an "s" into a URL can do this. (As a consequence, pornographers may move to SSL if a large part of their adult market is enduced into a filtered Internet.) 

Thus Cameron's advice is just plain bad and misleading. Children will not necessarily be any less likely to be able to access whatever they like as the result of network filters, even if they are deterred. That may be a reasonable objective – but it is wrong to suggest that a magic bullet has solved the problem he talks about.

But that is symptomatic of the policy conundrum he has placed himself into, by pandering to a demand from the Daily Mail that 'porn must be blocked' and only accessible through an 'opt in'.

Education and parents talking to their children remain the only way for children to be helped. Cameron today should have been heavily caveating his claims, and by failing to do so, many parents will think the technologies ISPs are about to provide do a much better job than they will.

Update


We've launched a petition calling for David Cameron to drop his plans for default Internet filtering. Sign the petition here: https://www.openrightsgroup.org/campaigns/cameron-stop-sleepwalking

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July 21, 2013 | Jim Killock

Cameron demands action on child abuse images

Today we were expecting an announcement from David Cameron on the Andrew Marr Show previewing a speech on Monday about filters to stop children accessing adult pornography. Instead we have an announcement about paedophiles on the Internet. These are very different issues, needing different policy responses.

David Cameron cc-by GPaumierEvery right minded person wants to get rid of child abuse images, and stop people from accessing them. But Cameron's targeting of search engines seems wrong headed and rather 1995.

Firstly, most child abuse images are circulated in private networks, or are sold by criminal gangs. Banning search terms seems unlikely to combat the serious activity, which is independent of search engines. It may help for casual searches, but this seems at best a marginal help, and certainly not worth a Prime Ministerial announcement, nor threats of legislation implying that this action is critical for child safety.

Let us accept that some identifiable search terms will bring up illegal images. If a list of blacklisted terms exists, then new terms will be invented so that people can find what they want. Thus Cameron invites a game of cat and mouse which is likely to have very limited impact. The terms used may hide themselves into search terms that cannot be banned because they are innocuous. This, for instance, is the kind of reason why the term 'Lolita' was adopted to signal such material.

The first thing that should be done is for Cameron to ask for statistics about the searches he wants to ban. It would be interesting to know if this has been requested but no figures have been quoted so far.

In any case, search engines have moved well beyond being dependent on identifying content through a small set of accurately reproduced keywords. Banning a few terms seems unlikely to prevent any kind of material from being available through search.

Of course, Google and other search engines, once they are aware of such material, will always remove it from their databases. Organisations like IWF who look for it may well, of course, be using search engine terms to find it as well, probably in more sophisticated ways than the casual searchers Cameron believes he is trying to target: he should be careful that his policy does not make the lives of the IWF more difficult.

It is also being reported that Cameron is going to say tomorrow to Google, Microsoft and Yahoo! that:

You're the people who take pride in doing what they say can't be done.
You hold hackathons for people to solve impossible internet conundrums.
Well – hold a hackathon for child safety.
Set your greatest brains to work on this.

On the face of it, this would be an open invitation to the public — in that any member of the public can create a search engine, or any other kind of network software  — to engage in an activity that would almost certainly result in a violation of the Sexual Offences Act 2003*. One may well expect someone to use this in a future defence: "I only downloaded those images to help train an algorithm to block them".

The real ways this offensive and rightly illegal material is combated is through takedown and targeting criminals. Takedowns of child abuse image websites still take days, rather than hours in the case of bank phishing attempts. More could be done to make sure international co-operation improves the speed that images are taken down, therefore.

CEOP have done work to restrict the use of payment mechanisms, with some success, but more could be done to stop the money laundering that is necessary for images to be traded.

Search engines are an easy target. They cannot be seen to aid criminality as serious as paedophilia. They will therefore be under immense pressure to do what Cameron asks, no matter if it is counter productive or simply irrelevant to his aims. Cameron will be able to chalk up a victory and move onto the next Daily Mail headline generating press stunt.

Should we, therefore, care? We should: it is embarrassing for our Prime Minister to stand up and demand a policy that is likely to be of highly marginal impact, and discuss it as if it was of vital national interest, while failing to concentrate on the real answers. 

Cameron's announcement is symptomatic of the way the Internet is viewed and treated by policy makers. The technical challenges and consequences of policies are viewed as less important than the moral purpose justifying calls for action. Policies are announced before they have been properly considered. And worse, these announcements risk being another case of blaming the commercial intermediaries – in this case search engines – because that is easier and cheaper than doing what is really necessary.

 

* Actually, Section 1 of the Protection of Children Act 1978 and section 160 of the Criminal Justice Act 1988.

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July 19, 2013 | Peter Bradwell

Questions ISPs must answer about Internet filtering

Internet Service Providers have agreed to roll out network level filtering to protect children online, following significant political pressure. We have sent them 20 questions on how their Internet filtering systems will work - questions policy makers have failed to ask.

Over the past few weeks the Government has held meetings with Internet companies about child protection online. These are designed to prompt more more action to protect children, on the assumption that these companies could and should be doing more.

Sadly the Government has seemed keen to appear as if they are taking tough action, and not so keen on thinking carefully about what their action should be.

Nowhere is this problem clearer than in an extraordinary letter written by the Department for Education to internet companies, which was leaked to Rory Cellan-Jones at the BBC. The letter sets out a fairly direct interventionist industrial policy - these businesses are asked to make various commitments in service of a speech that the Prime Minister would like to make. The ISPs are asked to implement 'pre-ticked' boxes, a 'browser intercept' to prompt users to turn on filtering, and to refer to the system as 'default on'.

Policy makers who are pushing for more Internet filtering for child protection do not take the related practical and technical questions seriously. They tend to throw about ideas for technical interventions such as internet filtering without considering how these would work, or what unintended consequences they might have.

They simply want 'more' done. What that 'more' is, or what it will achieve, seems to be an irrelevant detail. This is despite the Government having run a consultation last year, after which they settled on a fairly reasonable policy of helping parents make the right choices about filtering. They seem determined to edge towards a stricter 'default on' regime.

We have seen no evidence that during the meetings with internet companies the Government has taken account of any of the broader public policy questions related to the implementation of Internet filtering systems. Along with Index on Censorship, English PEN and Big Brother Watch, we wrote to the Culture Secretary Maria Miller asking her to invite us to the discussions so these issues could be raised. The Department has subsequently set up a meeting between us and the Minister Ed Vaizey MP.

The details are very important. Internet filtering can easily block more content than it is designed to – for example, if people do not understand what is being blocked and why, or if sites are incorrectly categorised. People may also easily get around blocking. It can give people a false sense of security. Making Internet filtering fit multiple devices, ages or beliefs within a household or other setting is almost impossible. And there are other consequences, such as the speed of access or an impact on privacy where traffic or blocking events are logged.

That's why we are putting these questions to ISPs. We will be sending the questions and replies to the relevant policy makers, and will hope to explain to them why we think these are important questions.

You can read our questions below, and the letter we have sent to ISPs on the correspondence page.

Twenty questions for ISPs on Internet filtering systems

A. On how the technology works

Under the Internet filtering system set up following discussions with the Government about online safety and child protection:

1. Is any traffic of users who are not opted in to filtering inspected and / or logged? If so, is it logged in a way that links the traffic to a subscriber? What logging will there be of blocking events? How does this work?

2. Is filtering applied to all forms of connection offered by the ISP (dialup, ADSL, cable, fast fibre connections etc)?

3. Have you estimated the impact of the through-put of filtering technology on the speed of users' internet access (both for those who are opted in and opted out)?

4. We are concerned about the impact on Internet applications in general as well as web traffic. Does filtering take place only of HTTP traffic on port 80, or will other traffic be affected? What steps will be taken to avoid interfering with non-HTTP traffic on port 80, for example non-HTTP applications that use this port in order to bypass firewall restrictions?

5. What impact does the filtering have on end-to-end security measures such as SSL or DNSSEC?

6. Can you guarantee that your networks will not be susceptible to mistaken blocking as a result of using specific IP addresses for forwarding filtered traffic, for example as seemed to happen in a case involving Wikipedia?

7. Have you made any estimates on the impact of filtering systems on infrastructure upgrades?

B. On setting up the filtering

8. Are users faced with pre-ticked boxes when choosing to activate filtering? What is the impact on customers who do not have access to or who do not use a web browsers on a network such as a home broadband connection that is only used for Smart TV video on demand applications? (ie who will not be presented with a web-based set up screen?)

9. How granular are the available choices? Will a household be able to cater for:

a. Multiple ages or a variety of beliefs?
b. Can specific sites be unblocked by a user?

10. Have you done user-testing for your opt-in systems?

11. What information about the filtering is available at the point of sign up? Does it include:

a. Detailed information about what types of content are blocked, with examples?
b. The providers of their filtering tools, if a third party is involved?
c. Information about the possible problems with and limitations of blocking, with information about how to report problems?

12. What age-verification processes will be in place? How will this work?

13. Is a customer's decision not to activate filtering a one-off decision, or will it have to be periodically repeated?

C. On managing problems and mistakes

14. When a site is blocked, what information is supplied to the end-user about why and how it has been blocked?

15. Are there easy ways to report mistaken blocks, either over-blocking or under-blocking? Are these clear when users encounter a block?

16. Are there easy ways for people to check if URLs are blocked, and will this include a reporting tool for requesting corrections and reclassifications?

17. How will complaints, from both your subscribers and from owners of sites that are blocked, be dealt with?

a. Are there plans in place to train customer service staff for dealing with these reports?
b. Are there targets for dealing with mistakes in a timely manner, or estimates of how long responding to and correcting mistakes will take?
c. Will you share error reports and corrections with other ISPs?

18. Have you specified acceptable error rates to suppliers of filtering services? If so, what are they?

19. Have you sought legal opinions relating to liability for incorrect blocks, including both false positives and false negatives? Do you have plans to offer compensation for businesses harmed by blocking errors, for example when potential customers are unable to access the site?

20. Are there or will there be systematic reviews of the effectiveness and quality of filtering, including reporting on problems and complaints? Is there a process for review and improvement? Is there or will there be an ombudsman or other oversight body to handle disputes and review performance?

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