1.  INTRODUCTION

  1.1  The Internet is changing our lives. However, if we are to maximise the opportunities it offers we have to be confident that we can use it securely and as free from abuse as possible. To this extent Orange welcomes the House of Lords Science & Technology Committee inquiry into Personal Internet Security.

  1.2  This is a timely inquiry. Not only are more and more people using the Internet to go about their everyday lives but it is now mobile. Orange offers both fixed and mobile Internet services in the UK. We are no longer just a mobile communications business. In June 2006, we integrated with our sister company, Wanadoo, one of the largest Internet Service Providers (ISPs) in the UK, and under one brand—Orange—we are now able to offer consumers a "one stop shop" for all their communications needs: at work, in the home and whilst on the move. These include broadband, fixed telephony (including voice calls over the Internet), interactive "on demand" TV (coming soon) as well as the mobile communications we already provide to over 15 million people in the UK.

  1.3  Access to the Internet has become an invaluable communication tool for almost everyone, whether in business, at school or college, in the home or on the move. For work, learning or entertainment it is changing the way we do things—such as buying goods or services, banking, seeking information, listening to the radio, watching television or chatting and interacting with friends—and challenging our traditional cultures, such as enabling more flexible work patterns and transforming consumers into producers (via social-networking user-generated content sites such as Bebo, MySpace and YouTube). A world without the Internet is unthinkable, particularly for young people who have grown up with it. It is also transforming the lives of the older generation or those with disabilities by giving them access to online services (for example banking or shopping) when mobility may be restrictive.

  1.4  Demand for broadband connectivity continues to grow offering richer and higher-bandwidth services, such as interactive entertainment and communication. 72.6% of UK Internet connections are now broadband.[22] However, this figure does not include mobile Internet figures. Accessing the Internet whilst on the move is available via high-speed Third Generation (3G) mobile networks, allowing people to retrieve services when on the move rather than at a fixed place, such as a desk or in the home. The pace of change means higher speeds—both fixed and mobile—are ever increasing, making a greater range of services available.

2.  ENHANCING PERSONAL INTERNET SECURITY AT ORANGE

  2.1  Personal Internet security is a high priority at Orange. The challenge for a fixed and mobile Internet Service Provider is to put in place stringent security requirements without compromising the benefits of the Internet and the development of innovative services. We believe a self-regulatory approach will best achieve this.

  2.2  Our strategy is therefore designed to help cut-out illegal or unlawful activity (including spam, "phishing" activity and illegal content) and restrict inappropriate material (such as gambling sites and adult content) to those over the age of 18 years. We work very closely with the Home Office and the Child Exploitation and Online Protection Centre (CEOP). Orange is a member of the Home Office Taskforce on the Protection of Children on the Internet and the Internet Watch Foundation (IWF) and we work closely with children's charities and law enforcement agencies.

Fixed Internet

  2.3  Orange is at the forefront of the local loop unbundling revolution. All our current products (broadband and pay-as-you-go (dial-up) come with:

—  a free privacy service with parental controls to protect customers from offensive content and to keep personal information safe from hackers;

—  a 20% discount on an Internet security package;

—  a free 30 day trial of anti-virus software; and

—  anti-spam and anti-virus filters for webmail.

  2.4  We are working towards implementing a solution which will prevent inadvertent access to illegal child abuse images whether they originated in the UK or from abroad for all our customers before the end of 2007.

  2.5  Orange has a dedicated team who deal with all abuse reports (fixed and mobile) and who work to ensure that "spam" is managed effectively. We also work very closely with industry on reports of "phishing" that are prioritised and resolved as per agreed processes.

  2.6  Orange aims to make its chat rooms as safe as possible for users. The age for entry into our "teen" chat rooms is 16-19. We do not allow person to person (sometimes referred to as "p2p") chats in "teen" chat rooms and we have moderators on duty patrolling the service at all times. We employ professional moderators, who each undergo a Criminal Record Bureau (CRB) check, in order to protect our chat room users. Moderators are appointed to oversee our services in order to facilitate a cleaner and safer environment. Moderators can ban users or remove anyone from the service who doesn't adhere to our terms of use. Our chat service has compulsory registration with email verification and a clearly marked "report abuse" link.

  2.7  The page leading to our adult chat rooms contains an Internet Content Rating Association (ICRA) "tag" allowing parents or carers to use parental controls to prevent children from accessing the adult chat rooms.

  2.8  Orange is working closely with the Home Office to produce guidelines for the safe use of social networking sites.

Mobile Internet

  2.8  The Internet is now mobile and its availability over mobile networks, including high speed 3G networks, is growing. This can be done using a mobile handset or connecting a mobile "datacard" to a laptop. 12.3 million people accessed the Internet using a mobile network in the UK during June 2006.[23]

  2.9  Being able to access the Internet at a time and place convenient to the user opens up a whole new range of benefits, including location-specific information such as traffic news and information. However, the very nature of mobile communications means that services such as the Internet are no longer tied to a fixed place such as the living room. The monitoring of a child's use of the Internet is therefore not as easy.

  2.10  Along with the other mobile network operators, Orange recognised the potential dangers of making the Internet mobile. In 2004 operators published a Code of Practice for the self-regulation of new forms of content on mobiles[24] including the use of Internet services. The Code included a commitment to classify and restrict adult content to those over the age of 18 years. This means that Orange has placed all adult content (whether on our mobile Internet portal or the wider mobile Internet) behind access controls. The service prevents anyone under the age of 18 years from accessing adult content, whatever its source, while enabling them to surf the rest of the mobile Internet. An additional benefit is that all customers are prevented from accessing sites with illegal content as defined by the IWF.

  2.11  In addition to this, Orange—again along with the other mobile operators—has also produced a separate Code of Practice to govern the use of passive location-specific services (ie using the mobile network to track or trace another person or asset). These services are strictly consent-based and comply with existing data protection legislation. The Code of Practice[25] supplements the legislation.

  2.12  The growth and prevalence of the mobile Internet has also prompted Orange to develop and launch an anti-virus solution for handsets. To date we have launched an easy to install system, F-Secure, for all our Internet-enabled smartphones. The system is available as a download from Orange's mobile Internet portal and customers are protected from over 2000 viruses, worms and trojans. Future handsets will be sold with the latest software pre-installed and will be continually updated so that the customers remains protected.

  2.13  The increase in mobile handset ownership in the UK and the ability to access the Internet from most handsets available today means that procedures must be in place in the event of the handset being lost and stolen. Orange's approach is therefore to make the SIM card and handset redundant when reported lost and stolen. This reduces the criminal's incentive to steal the handset in the first place and ensures that the customer's credit and personal information is protected in the event of theft. In 2002, Orange and the rest of the mobile phone industry implemented a system whereby a handset blocked on the Orange network will also be barred across all UK networks in the UK. Whilst a criminal will always target portable devices, such as mp3 players and mobile handsets, we believe this approach is helping to reduce street crime and personal robbery in the UK.

3.  CONSUMER INFORMATION

  3.1  Consumer advice is the heart of our strategy—both fixed and mobile—to help keep our customers secure online as well as keeping consumers aware of the potential dangers of the Internet, whether fixed or mobile. Our website includes a safety advice area offering advice to parents, carers and children. It includes the NetSmart guidelines written by the children's charity NCH and links to this area have been introduced across the communicate area of our website.[26] Orange promotes the Parent's Guide to the Internet, produced by the NCH, which seeks to educate parents about the Internet and how to help their children enjoy a safe and productive environment.

  3.2  In the mobile space, Orange offers specific consumer information to assist parents or carers better understand the technology and what they can do to prevent children accessing inappropriate material using a mobile handset. This formed part of our commitment under the Code of Practice. As a result, Orange has produced a guide—available in retail outlets or online[27]—offering parents specific advice on a wide range of issues, including adult content, handset theft, passive location-specific services and bullying.

4.  IS THE REGULATORY FRAMEWORK FOR INTERNET SERVICES ADEQUATE?

  4.1  Orange has implemented personal security features into its Internet services in conjunction with government, law enforcement agencies and children's charities. This self-regulatory and partnership approach has been welcomed by the Government and we believe it is the most effective way in ensuring regulation maintains pace with the technology and remains up-to-date. For example, UK mobile operators put in place the Code of Practice on new content prior to the mass take-up of Internet enabled mobile handsets.

  4.2  We believe a more formal regulatory approach (ie via statutory legislation) would not necessarily achieve this and may not reach the right balance between the need for regulation, the freedom to enjoy the Internet and the development of innovative services.

  4.3  However, this is a partnership approach and to this extent we do believe there is work the Government and Law Enforcement Agencies can do to help us ensure that our procedures are effective. Below we set out several ways that this can be achieved.

5.  RECOMMENDATIONS

  5.1  Orange believes the self-regulation of both fixed and mobile Internet services, in partnership with other key stakeholders, is the most appropriate method of protecting consumers from potential Internet dangers, whether personal or financial. We believe working closely with stakeholders—law enforcement, industry, government and consumer groups—is the best way of meeting the balance of achieving consumer protection whilst providing the flexibility to innovate and invest. Formal regulation would deny us this flexibility and would place at risk the benefits of many Internet services.

  5.2  However, Orange believes there are areas where government and law enforcement can assist us in this approach, particularly in relation to consumer protection. In particular:

—  We would like to see the Government bring forward legislation to make anonymous proxy servers illegal. In doing so, the Government would be greatly enhancing our investigative procedures in tackling consumer abuse on the Internet.

—  We believe there should be greater clarity for the procedures in reporting suspicious Internet behaviour to law enforcement agencies and providing supporting information to assist cases. In doing so, this would ensure that, as an industry, we comply with the required legislation and support law enforcement effectively in their investigations, so assisting the partnership approach in tackling potential problems.

23   Mobile Data Association: June 2006. Back

24   www.orange.co.uk/about/regulatory_affairs.html Back

25   www.orange.co.uk/about/regulatory_affairs.html Back

26   See www.orange.co.uk/communicate/safety/ . Back

27   www.orange.co.uk/about/regulatory_affairs.html Back