They want filtering to be offered even by small ISPs, so some thoughts, off the top of my head - just some ideas...
1. If they don't make legislation?
No problem - stay as we are - easy.
2. They legislate that we have to offer a choice of filtering, even default on?
So fine, we offer filtering on the order form, but at present, like almost any other business, we do not have to actually accept an order from a new customer. We can choose our customers, so we simply choose not to accept any orders where filtering is requested. As long as our choice is not discrimination on race or sex (neither of which we know or ask) then that should be fine.
Forcing someone to take all customers would be a huge step in any legislation. At present there are very few cases that force that on anyone (BT universal service obligation, for example).
3. They legislate that existing customers have to have the option?
Again, at present, we have the choice to stop providing services to anyone. So simple - ask for filtering and we stop supply. May be a slight issue with min term services.
4. They don't say the filtering is free?
Fine, filtering available at £1,000,000 a month - please do choose it.
5. They somehow legislate that we cannot discriminate based on filtering choice and have to take the order and not cancel it for this reason?
OK, so the filtering is "no packets pass", after all it is the only way to be sure. We have that system in place now (for credit control). Pick the option if you like.
6. Somehow they define that we have to access some of the Internet in the filtered service?
That would be harder - but we'd be able to block the Daily Mail, right? Could the service only be to Clare Perry's web site (yes, I know that has a risk of seeing porn, but probably OK now). It would not be hard to comply with a very slim set of IP addresses to whitelisted endpoints, and be useless so nobody picks the option.
7. Somehow they insist that the filtered service accesses all legal content not on the filtering list?
That would be interesting, as lots of ISPs do not allow access to www.loopsofzen.co.uk at present as it is IPv6 only - that would be a fun law to force all ISPs to provide access.
But suppose we had to filter - does the law apply to us?
8. Really somehow forced to do a filtered service
One really simple answer is we sign up as a BT Retail or TT Retail reseller. Anyone asking us for filtered broadband gets put on one of their retail services with the filtering with us as the reseller. This keeping A&A service unfiltered. This is the same as the choice people have now - picking a filtering service from one ISP or picking an ISP with no filtering. Forcing us to filter does not really mean we have to, just means we get to make a mark-up on someone else's service. Totally daft and pointless.
9. Not apply to business lines?
I think that is the case, so we could be "business only" ISP, or maybe we include the creation of a Ltd Company in the price for non business customers. After all a Limited Company can be created on-line and have annual return and simple accounts all filed by a script. Could be a new business opportunity for us, and is only a few pounds more a year in cost.
10. Not apply to staff lines?
So what if it is not applicable to a business providing Internet for employees. Oddly enough the changes recently for HMRC and RTI and BACS mean we could automate having lots of employees. We could make every customer an employee - only working for us for a few minutes a month on so on a salary of a few pence. It would not actually cost us anything to do this as we would automate it all.
Legislating that companies have to filter for employees would have a huge impact.
11. What about a private club?
We have considered this before, and even asked OFCOM (who were very non committal). We could create a friendly society, non profit, members owned, and provide Internet only to members. Obviously get the existing customers to join.
With suitable membership rules (perhaps simply a membership veto on new members) it would be the case that a member of the public cannot automatically get service just because they order. In practice, almost all people would, I am sure, but there would be no guarantee.
That takes us out of most of the rules and legislation as we would not be a public communications provider. Covering every private club would be hard.
12. Other ideas
What if we only provide L2TP handover (like BT wholesale) and the ISP is off shore?
What if transit providers forced to filter (really?) and we have to run transit via a tunnel to off shore?
What if BTW start filtering in the L2TP (really?) and we have to start running encrypted PPP links?
What if we just start selling off shore tunnel endpoint services direct to end use routers. Some small broadband routers can do IPsec these days. That would be an interesting business model.
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