Written evidence submitted by BT Group (OSB0163)




BT Group 



 Key Messages 




Online safety 



BT commissioned research on online harms 


Draw The Line and Hope United  



BT’s response to the Inquiry’s questions: 





Will the proposed legislation effectively deliver the policy aim of making the UK the safest place to be online?


BT welcomes the Bill and think the approach to new legislation is broadly the right direction of travel but now the government needs to press ahead with legislation.   



Will the proposed legislation help to deliver the policy aim of using digital technologies and services to support the UK’s economic growth? Will it support a more inclusive, competitive and innovative digital future?



Are children effectively protected from harmful activity and content under the measure proposed in the draft Bill?


BT is supportive of the Bill’s principles based and outcomes focused approach to illegal content, CSEA material. The Bill should ensure encrypted services including ancillary services such as VPNs - comply with the requirements of the Bill and not be used for circumvention purposes.


The approach to legal but harmful activity and content accessed by children depends on Ofcom requiring a child centred safety first approach in its codes of practice



Does the draft Bill make adequate provisions for people who are more likely to experience harm online or who may be more vulnerable to exploitation?


Does the Bill deliver the intention to focus on systems and processes rather than content, and is this an effective approach for moderating content? What role do you see for e.g. safety by design, algorithmic recommendations, minimum standards, default settings?


Requirements in the Bill on other types of harmful (racism, bullying, abuse, self harm) content should be strengthened


Safety by design: the Bill should have stronger requirements for algorithmic recommendations and default settings


Services should be required to know their users so that they can identify them and take action when necessary, but anonymity when posting should not be banned



Content in Scope


Earlier proposals included content such as misinformation / disinformation that could lead to societal harm in scope of the Bill. These types of content have since been removed. What do you think of this decision?


The Bill should require that in scope platforms consider the wider harm of misinformation on their platforms to not just an individual but to the UK economy and wider society



 Are there any types of content omitted from the scope of the Bill that you consider significant e.g. commercial pornography, or the promotion of financial scams? How should they be covered if so?


The Bill should address all the ways online consumer / economic harms, including fraud, IP rights and fake goods are marketed online, via advertising and user generated content. 

  1.                the infringement of intellectual property rights; 
  1.                the safety or quality of goods; and  
  1.                 the performance of a service by a person not qualified to perform it. 



The Bill needs strengthening to ensure that Ofcom develops clear codes of practice for commercial pornography services to both make clear the risks to adults and to take mitigating actions to minimise these risks




The role of Ofcom


Is Ofcom suitable for and capable of undertaking the role proposed for it in the draft Bill?



Are Ofcom’s powers under the Bill proportionate, whilst remaining sufficient to allow it to carry out its regulatory role? Does Ofcom have sufficient resources to support these powers?


Ofcom should have information gathering powers equivalent to those in telecoms and broadcast to enable it to best execute its regulatory role and responsibilities, and to be properly resourced



BT is supportive of the enforcement regime but believe it needs improvement to reduce the ease with which it can be circumvented by intermediate or ancillary services


The legal process should include a right of appeal  if the business disruption measure is technically unworkable. 




Are there systems in place to promote transparency, accountability, and independence of the independent regulator?


How much influence will a) Parliament and b) The Secretary of State have on Ofcom, and is this appropriate?


The principle of regulatory independence is important and enables good decision making



 Are the media literacy duties given to Ofcom in the draft Bill sufficient?


The Bill should include a framework for delivering a media literacy strategy, which also enables Ofcom to set ambitions and aims, and to scale and fund activity appropriately










How BT is working to make the internet a safer place


BT Group (BT, EE and Plusnet) offers fixed, mobile, and public wi-fi connectivity; mobile phones, tablets and mobile broadband devices; and online TV content via set top boxes.    We do not offer products and services directly to children, but children may access and use our products and services for example via his/her parent.


We are working to make the internet a safer place for children by offering free technology tools, supporting online safety education and awareness, and working in partnership with charities, government, and others.  Further information is provided below.   



Preventing access to inappropriate and illegal content


Parental Controls


Child sexual abuse (CSA) images



Supporting education and awareness


28 September 2021  




[1] Pg 19 Demos: Online harms, a snapshot of public opinion

[2] Pg 24 Broadband-Stakeholder-Group-Digital-Exclusion-2020-Final-report.pdf (broadbanduk.org)

[3] 2021 Ofcom data 6% of individuals do not have any internet access, including mobile while 14% of households do not have broadband Digital divide narrowed by pandemic, but around 1.5m homes remain offline - Ofcom

[4] https://www.nspcc.org.uk/globalassets/documents/online-safety/delivering-a-duty-of-care.pdf

[5] ‘Sex isn’t difficult any more’: the men who are quitting watching porn | Pornography | The Guardian