Much of this is a reworking of an earlier blog post. I have rewritten it to address the proposed law change following the campaign I referred to earlier.

A parent will always be the best protection for a child on the Internet. Image CC:By-NC-SA OllieBray
The government is holding a consultation for a proposed new law which it says will protect children while using the internet. This proposal follows a campaign which I first came across in February 2012. It is called “SafetyNet” and is being run by Premier Christian Media and SaferMedia. The campaign and now the consultation is about requiring Internet Service Providers (ISPs) to “[block] pornography and other content at network level whilst giving adults a choice to ‘opt-in’ to this content”.
The campaign website and FAQ document are full of statistics which – as with any statistic – cannot really be argued with. These range from the percentage of UK households with internet access to how many children regularly access explicit images on their home computer. There are also a bunch of sound bite quotes to join the dots between these facts and the aims of the campaign.
The consultation is fairly loaded and appears based upon the “facts” purported by the campaign. As far as I am concerned facts are facts. If a USA survey i(take a single school by the way) says “1 in 3 10 year olds have accessed pornography online”, I’m not going to argue. I’m not altogether sure why 73% of UK households having internet access adds to the problem but I don’t doubt the figure is correct. What concerns me are the conclusions drawn and the way they are presented in the consultation document.
Perhaps I should introduce why I feel I can write about this. I am a UK Christian parent (so therefore fit neatly in the target demographic for the campaign), my children are between 5 and 9 years old and thus are well within the group the proposed law seeks to “protect”. I am also someone who works with and understands the “network level” Internet this consultation talks about. I have been building hosting webservers and websites since the mid 1990s and I still do. So I am fairly and squarley intarget demographic for the campaign, consultation and the proposed law. I would add I am also one of the people who understands the technology involved and by the sound of it I understand it better than those running the campaign or making the proposal.
Why this won’t work
The campaign calls for ISPs to “block pornography” at “network level”, the consultation expands this into two options. Firstly a universal switch which enables or disables blocking (or “filtering” if you prefer) for the internet connection and secondly an array of questions which apparently will allow the parent to decide which types of content are permitted or not permitted through the same connection. The wording is phrased as if this filtering can be decided on a per user basis rather than a per connection basis but the type of filtering they are describing cannot be managed in that way. In brief the type of filtering they are proposing (regardless of which option is used) is unworkable and dangerous. I’ll focus on pornography here because that is the main thrust of the campaign but the same points can be applied to other content types. Here is why…
How do you define “pornography”?
You can’t (as the campaign does) try to get away with a dictionary definition because we are dealing with parents here who may well have their own idea of what is appropriate for their child to view. Limiting it to just ‘the explicit representation of sexual activity’ may not be enough. As an example if that were all that was being blocked I still would need to check what my 8 year old was stumbling across on Google images at which point the “protection” is not coming from the blocking but from me (as it does now). Additionally who decides what content fits into what categiry and what level of “risk” there is? One parent may consider it perfectly aceptable for their child to see say a scantily clad woman in a provactive pose, another may not and yet both would expect such a filtering service to met their needs. It can’t. There is no part of the proposal which mentions fine tuning or configuration of the filters by the parent and to be honest if it did have such a feature I could not see many taking advatange of it because it would be what a friend of mine refers to a “too much of a faff”.
How do the ISPs determine what gets blocked?
Certain websites will be obvious by their name/domain but is the government really so naive as to expect the site owners to be scrupulous in what they call their websites? Also what of images and content provided through otherwise innocent websites? Google images for example has a safesearch option. Set that to “off” and your child will get a bit of surprise. But as the images are hosted and served by Google, the ISP cannot block them. So using the vaunted “network level” blocking, the explicit images can still be viewed. Other sites will be similar. In the end the only way for an ISP to properly block explicit content is to do it on an image-by-image, video-by-video basis. To do that they’d have to either rely of peer reviews which are inherently slow to react or they’d need to employ people to check and grade the content. Now I’m not an employement law expert but I’m pretty sure that an ISP employing somebody to view possibly illegal, often offensive and probably explicit material every day would be opening themselves up to legal consequences they could do without. Aside from that, given the constantly changing nature of world wide web content, this is something I cannot see any ISP being able to do properly. How long would it take before a parent brings an action against an ISP because their child was exposed to some piece of content which slipped through the filter?
Filtering does not work.
Anyone who uses filtering or blocking software will tell you that things slip through. Don’t believe me: how about your eMail spam filters? How about your anti-virus software? If they are so good why are you still suspicious of links in eMails you weren’t expecting? If you are not suspicious, you should be. Let’s look at Google images again. Google are huge, they dwarf any ISP by comparison and yet they still don’t guarantee that safesearch will hide all explicit or offensive images, they have a “report offensive images” link on their search results. If Google can’t make any guarantees how can I be sure an ISP would block everything?
Network level blocking means blocking sites and images before they get to your house. Such things already exist. I use a free (and very good) service called OpenDNS which – among others things – allows me to have it block websites that either declare themselves as “adult” or have been reported as such by other users of the service. Such sites are blocked before they even get down my phoneline. So this is pretty much what is being proposed here. It doesn’t work. Well that’s not true, it does work just not 100%. Google images is not blocked and other sites which have mixed content are not always blocked. If my daughter searches for “girls bedroom posters” on Google images with safesearch on “moderate” (the default setting by the way) she gets images which are possibly not what she was after. Filters can of course be too aggressive such as the one I heard of recently which blocked access to the Essex Radio website (and presumably Sussex and Middlesex too). Lord knows what it makes of Scunthorpe.
The point again is that even with Google images safesearch on strict and OpenDNS I still have to monitor what my children surf. The main “protection” for my children comes from me not any blocking software or service.
It’s all or nothing
The consultation allows for the fact that adults can request the ISP blocking is switched off either entirely or by specifying types of content. This sounds fine as long as all the adults use one connection and all the children use another. But that’s not how the world is. Those 73% of UK households with Internet access probably have a single main connection for each household. Many of them almost defnitely have a mixed range of ages using the Internet. So if a parent wants the blocking switched off, the child gets it switched off too. ISP blocking at “network level” is by defnition all-or-nothing. Now you may argue that parents should not be watching such content if they have kids. But I’ll wager they do and if they have the blocking turned off, the children the proposed law seeks to protect are no longer protected.
I’m not here to tell other adults what to do and by the sound of it the proposal doesn’t want to either but if an adult wants it turned off (and I doubt this would be something the ISP would want to keep switching on and off on an hourly basis) then it’s off for the kids and again the “protection” that should be provided by the blocking will have to be provided by the parent (as it should be now).
The consultation makes reference to filtering services supplied by mobile operators. The problem with this is that mobile internet connections are supplied to a single device, home internet connections are supplied to a single point (a hub or router) and this distributes it to a range of devices within the home. If you turn off filtering on a mobile device you disable it for that single device. If you disable it (or part of it) for a home Internet connection you do so for all devices and all users. So while it is entirely practical for a child’s phone to have fiiltering but the parent’s one to not have it, this is not practical or possible on an average home Internet connection as proposed here.
It gives a false sense of security to parents
You’ll have gathered by now that this is my main point. The campaign raises concerns which all parents whose children have Internet access should consider. But the solution offered by the proposed law and consultation is poorly thought through. As you have seen above, ISP blocking will still require a parent to monitor what their kids are surfing. This is good and I wholeheartedly agree that a parent/guardian is the best protection for children online. As parents we should be interested in what they are doing whether online or not. But what worries me is that this ISP blocking idea would cause a lot of parents to stop paying attention (or pay less of it) to what their children are doing online. It would give a false sense of security. Lets revisit the anti-virus analogy. Anyone running a Microsoft Windows PC should run anti-virus software, that is a given. But just having it there does not mean you will be “safe” from malware, phishing or other nasties. Ask anyone who supports Windows PCs and they will tell you that you are only as good as your last update and also just because you have software which the manufacturer promises will protect you (no matter how much you pay for it) you still have to be vigilant. It’s the same with blocking or filtering. The model is flawed. It does the best it can under the circumstances but it’s flawed.
It’s been suggested to me that I am not actually the type of parent this is aimed at. It’s a complement to be considered so and I know there are parents out there who do not pay attention to what their children are doing online. The problem is that if that is the target market aren’t they exactly the ones who will presume this filtering alleviates them of any further concern to their child’s online activity? Doesn’t that – in the terms set out by the campaign and consultation – put their children at greater risk? I’m not convinced that inadequate, unpractical and unworkable filtering is a solution. I’m not convinced that filtering is anything other than an assistance and even then if it is not voluntary introduced by the parent it is less likely they will fully understand it or implement it properly.
Oppose it
In the end, as shown above, ISP blocking would still require a parent to monitor/participate/be involved in their child’s online activity. That means the blocking is next to useless. Even if you presume it will help or do some of the job for you, you still run the significant risk that your child will find an image, video or site that you’d rather they didn’t. Sadly pornography is part of our culture and so is the Internet. But the Internet does not work like a TV, radio of a shelf of magazines in the newsagents. It’s different and it needs to be handled differently. As a Christian parent you might expect me to support this campaign but I just can’t. I do believe that my children should not be exposed to certain types of material until such a time as they are ready to understand it but I do not believe this is the way to achieve that.
The SafetyNet campaign might have the safety and protection of children at its heart but its using the wrong tactics. We do not need scaremongering, knee-jerk reactions based on shaky “evidence” and headline-grabbing phrasing. The government may use rhetoric which says it is trying to protect our children but the consultation is loaded and ill-thought out. Such a law, if passed, would not protect children any more than an 18 certificate on a DVD does. Educate parents, get them to speak to their kids, help them. Don’t make laws which would have a worse effect if passed.
Filtering, blocking and other such technologies can help a parent, but in the end, technology cannot protect our children, only we can. Such laws do not prevent children getting access to the filtered content (whether deliberately or by stumbling across it).
What can we do
The Open Rights Group has provided ways to write to your MP on this matter. In addition if you are a parent or business involved in Internet Services you can take part in the government consultation. The closing date for the consultation is 6 September 2012.