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I write the consultants....
Dave Bird, xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
West Midlands group of the National Council for Civil Liberties(Liberty)
to: Dr Adrian Colbrook,
Smith System Engineering,
Surrey Research Park,
Guildford,
Surrey. GU2 5YP 06/march/1997
re: W.MNCCL'S RESPONSE TO THE E.U.GREEN PAPER ON INTERNET CENSORSHIP
(AKA "THE PROTECTION OF MINORS IN AUDIOVISUAL SERVICES"), kept at
http://www.xemu.demon.co.uk/censor/eu_green.html; I will send a
paper copy of this letter enclosing a paper copy of the response.
===============================================================
1. RATING FACTUAL MATERIAL
2. COMPLEXITY OF RATINGS
3. NEED ALL PAGES CARRY THEM?
4. MARK TEXT, OR ASSURANCES?
5. CHECK AT PAGE, OR AT RATINGS SITE?
===============================================================
Dear Dr Colbrook,
I was interested to read in Computer Weekly that your company is
investigating censorship mechanisms for the European Parliament.
I enclose our submission to DG-X on the issue, and would be
grateful if you would tell us your response to some of the
points in it. I suppose the obvious question would be what
expertise Smith Systems is bringing to bear on questions of
law and sociology, which affect not just whether but also _how_
some of these mechanisms should be implemented. The sections on
accountability for unlawful material are self explanatory, so I
will concetntrate here on restriction or obstructiveness against
lawful content by ratings systems. The PICs system itself is
fairly suitable to carry both useful indexing material and
censorship by ratings; the debate is largely about whether,
and what sort of, ratings there should be carried on it.
1. RATING FACTUAL MATERIAL
(1) The relationship between author and _carrier_ on the Internet
most resembles that between speaker and phone company i.e.
monitoring of every individual call is impracticable. The
relationship between author and reader is more like a system
of numerous small factual or hobby newsletters. There is
therefore a poor fit between this and a ratings system
devised for entertainment such as films or computer games,
where the premis is that the authors add sex or violence
as an arbitrary choice to "spice it up". This is clearly
not true where there is a report of a murder or rape which
took place, e.g. in the context that the wrong person has
been jailed for it. Are you aware that the Australian Council
for Civil Liberties has lodged a complaint over a false RSACi
rating by MSNBC news? The rating is minimum, but the page
carries reports of violence, including the effects of violence
e.g. spilt blood visible, which clearly violate its RSACi rating.
Have you considered whether there should be an exemption for
factual reports of real events [for everyone -- not just news
magazines]. For example, V-Chip systems usually exempt
news and sport, although both can be quite violent. But if
you do this, then you must realise that V Chip ratings are
mostly for dramatised fictional entertainment, and WWW pages
mostly aren't such so VChip type ratings are mostly inappropriate
for them. This was why I wondered what expertise you have to
deal with social/legal points like this. If you are simply
investigating how, technically, to carry out what is a wrong and
foolish action, then this will prove rather a waste of money.
2. COMPLEXITY OF RATINGS
(2) Again, a key question is what type and complexity of ratings
to use. I believe in Canada a complex system of 1,2,3,4 scores
in each of sex, violence and swearwords has been found to be
far too complex and largely ignored by viewers. Webpage content
[as opposed to means of transmission] is not so much akin to
films and computer games, as to newspapers and magazines.
The sole categorisation of such paper media is that some are
marked "not suitable for under-18s", and this seems sufficient
for parents to stop under-18s seeing material of which the
parents disapprove; which is presumably the aim of the exercise.
Requiring authors at each update to answer complex
questionaires and perhaps wait for the result to be returned
has a chilling effect on free speech, and is surely DISPRORTIONATE
if applied only to electronic media and not to the exact
same text and images in print media. Alternatively, if it is to
be introduced, would it not be reasonable and ptoportionate
to demand the same 1/2/3/4 sex/violence/swearwords ratings
on the covers of all newspapers and magazines. If not, why not?
3. NEED ALL PAGES CARRY THEM?
(3) Is it necessary and to force people to wear
a mark of somebody else's disapproval on their webpages
like a yellow star, if the exact same effect of under-18s being
stopped form seeing what their parents disapprove of can be obtained
by having an "approved for minors" mark which is witheld from
those pages which don't want or deserve it. Surely a
compulsory mark would be DISPRORTIONATE in these circumstances.
The following questions relate to this:
[a] What would be the extent of resistance, opposition,
disruption, protest, people moving pages abroad etcetera
if subjected to that sort of imposition?
[b] What would be the effect of bottlenecks produced by
demanding all pages register by a given date, and is
it necessary that this mess and disruption be caused?
[c] Is it lawful to compel speech e.g. demand that people
write childrens books for you, and would would be more sensible
alternatives of *encouragin* child-safe pages in a voluntary system?
4. MARK TEXT, OR ASSURANCES?
(4) Does the mark relate to, and checksum, the literal text,
or an undertaking about the general nature of the text?
For example, I often update my page every 2 or 3 days. Do you
suggest I re-apply, and wait a day or two, at each update;
and re-apply the same day when I spot a syntax or spelling error
on the server to re-upload? What about pages constructed
on the fly? Or which are the front ends of databases?
Do you think that if it only, perhaps automatically,
collects a piece of text that says "RSACi are silly buggers",
then it has blown its "swearwords" rating?? Or is it perhaps
impracticable to checksum the literal text in this way.
5. CHECK AT PAGE, OR AT RATINGS SITE?
(5) What is checked when a page is accessed. Does every single
followed hyperlink access a ratings server, and would this
perhaps cause bottlenecks? Or is it perhaps only a checksum
on a text which says "We recived ratings assurances about {URL}
on {DATE}." If so, how are false tags withdrawn?
Who has the contractual arrangement to see that tags
are correct, the page author or the server owner? Part of
the problem with RSACi is the messy contractual arrangements
with the individual user.
These are the main questions, and they seem to be driven
mainly by points of contitutional law [what is PROPORTIONATE
under the E.C.H.R] and sociological/political, which is why
I'm a bit puzzled they seem to fall under high speed
computing. A report which simply said how, technically,
to implement the wrong solution would not be much use
to anyone. And if it was presented by politicals as
"this report says it can be done technically" == "therefore
it is the right thing to do", this would be somewhat
dishonest of them though not of your choosing.
I look forward to your considered reply on these points, and
to seeing how you have dealt with them when the report
emerges in May, assuming my local MEP can get me a copy.
Yours Sincerely,
DAVE BIRD.
DAVE BIRD, Secretary of W.M.NCCL__________________________________________
Dave@XEMU.demon.co.uk -/censor,Censorship -/Clam,$cientology|
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