- From: Joseph M. Reagle Jr. <reagle@w3.org>
- Date: Thu, 16 Jul 1998 14:12:15 -0400
- To: w3c-policy-ig@w3.org, <pics-interest@w3.org>
They unfortunately confuse (third party) rating and blocking. >http://europa.eu.int/eur-lex/en/dat/1998/c_214/c_21419980710en00290032.pdf > >------------------------------- CUT ------------------------------- > > > Official Journal > of the European Communities > ISSN 0378-6986 > > C 214 > Volume 41 > 10 July 1998 > > 98/C 214/08 > Opinion of the Economic and Social Committee on the > `Proposal for a Council Decision adopting a > Multiannual Community Action Plan on promoting safe > use of the Internet' > >------------------------------- CUT ------------------------------- 3. The Committee's comments 3.1. The Committee is, generally speaking, very favourably disposed towards the Commission's action plan. The Committee notes that the planned actions actually attempt to address the problem. Even more important than this is attempting to change mentalities, thus curbing excesses. The Committee realizes however than this is unrealistic. 3.1.1. The Committee is very glad that the Com- mission has drawn a distinction in its action plan between illegal and harmful content. 3.1.1.1. But the Committee notes that, in translating this into specific measures, very little attention has been paid to illegal content in relation to protection of intellectual property, human dignity and privacy or to offences relating to national and economic security. Although these issues are specifically listed in the action plan under the heading of illegal content, the bulk of the funding (ECU 20,1 million!) has been reserved for the action lines aimed at protection of minors (the awareness actions and the development of material for users). The Committee considers this a serious shortcoming and returns to this question in its con- clusions. 3.1.1.2. The Committee wholeheartedly endorses the Commission's conclusion that, in combating illegal content, the accent must be placed on self-regulation and application of the law. 3.2. The Committee wonders however whether, in dealing with harmful content, relying on public aware- ness of ways of preventing individuals from coming into contact with such content is not too limited an approach. The Committee is not convinced that the technological solution proposed by the Commission is the most effective way of tackling a social problem. 3.2.1. A danger of this technological approach is that, once a filter system has been installed, parents and teachers, believing that their children are now in a safe environment, will see no need for further supervision, not realizing that childrenwill quickly find any loopholes in the system. Experience has shown that children's computerknowledgeoften surpasses thatoftheir parents and teachers. The Committee also wonders whether the target group (parents and children) will be sufficiently involved in the development of the system. 3.3. Although rating offers great advantages in terms of the cataloguing and indexing of content, thus making the Internet more transparent and accessible, this applies both to desirable and undesirable information. The Committee would also point out in this connection that rating might in practice well be counter-productive. Ratings would be assigned not only to innocuous content, but also to potentially harmful content, such as pornography. This would greatly simplify the task of anyone searching for harmful content on the Internet. 3.3.1. TheCommitteenotesthat, contraryto previous assertions, only one major browser programme (Micro- soft Explorer) currently supports PICS (Platform for Internet Content Selection), on which rating and filtering are based. Other browsers, such as Netscape and (the European) Opera do not. Even if Netscape and Opera eventually become PICS-compliant, without legal com- pulsion there will always be programmes which do not support PICS, enabling a child to circumvent the restrictions relatively easily. Although the Committee is in general not unfavourably disposed to the development of PICS, it does question the claim that PICS will turn the Internet into an environment free of harmful content. 3.4. The Committee supports the Commission in its view that cultural and social diversity based on freedom of expression is a thing of great value which must not be compromised by efforts to achieve a safe Internet; also that, in deciding what is harmful and what is not, the onus must be on the individual, whether or not in his capacity as educator. In this connection, the Committee would point out to the Commission that, from a technological point of view, it is not only teachers who can use filter systems to protect children from harmful content, but also Internet access providers. This would mean a system which is presented as `user-empowering' becoming an instrument of control, actually taking choice out of citizens' hands. 3.5. The Committee would also point out that the Internet is more than just the World Wide Web. PICS offers no solution where chat groups, e-mail and news groups (discussion forums) are concerned. The Committee does not consider filter systems based on rating designed to achieve safe communication to be a realistic option. The proposed approach offers no solution for important Internet applications such as chat and e-mail, which are also used by children. 3.6. The Committee insistently draws the Com- mission's attention to blocking as an alternative to rating. Although perhaps a blunter instrument, it is for all that no less effective. Blocking programmes do not require rating by the owner or supplier of the content, but rely on third parties supplying target group-specific lists of proscribed expressions. In the USA there are already dozens of blocking programmes (such as Cyber- nanny, Surfpatrol etc) which, when installed on a PC, black out proscribed words and images on the basis of these lists. 3.6.1. The distinction between rating and blocking is an important one, as rating requires an industry-wide approach (all content suppliers have to participate), whilst all that is required for blocking programmes is targeted promotion of innovation. In the case of blocking programmes itisstimulationofthedemand side(parents, educators and teachers) which is important, whilst rating can only be successful if there is an industry-wide, supply-side approach. In view of the above (see points 3.3-3.5) the Committee pins its hopes on solutions aimed at developing the demand for useable blocking programmes. 3.6.2. The Committee does not consider realistic the argument of human rights organizations that blocking would restrict freedom of expression, as with pro- grammes of this kind it is not the disseminator of the information but the receiver of the message who is responsible for the correct use of the filter system. Experience (in the USA) shows that blocking pro- grammes are a useful tool in the hands of educators who need a safe environment for the children in their care. The Committee suspects that one major reason for the general lack of interest in blocking programmes of this kind in Europe so far is unfamiliarity with this approach to the problem, and with the medium. 3.7. The Committee finds no reference in the Com- mission's action plan to the distinction between open and closed networks. Citizens' need for high-quality and easily accessible information is creating a market for networks based on Internet technology which may be part of the Internet but which contain only a small proportion of the content available on the Internet. In terms of their diversity and quantity `mini-Internets' of this kind are thus not comparable with the worldwide Internet. 3.7.1. Providers of such large-scale mini-Internets or intranets have control and are thus in a position to offer their customers guaranteed quality of service, not only in terms of capacity and security but also as regards the transparency and reliability of the content. 3.7.2. In closed networks of this kind there is a clear distinction between information suppliers (firms) and information users (customers). Private users do not have home pages. It therefore goes without saying that intranets of this kind are easier to protect against illegal and harmful content than the open, worldwide Internet. The Committee foresees closed networks of this kind increasingly satisfying citizens' needs for a safe Internet. Partly in the light of the period for which the action plan is intended to run, the Committee wonders how far the proposed action lines take account of this development. ___________________________________________________________ Joseph Reagle Jr. W3C: http://www.w3.org/People/Reagle/ Policy Analyst Personal: http://web.mit.edu/reagle/www/ mailto:reagle@w3.org
Received on Thursday, 16 July 1998 14:11:51 UTC