Open letter to Baroness Howe

Dear Baroness Howe,

I see that you mentioned Andrews & Arnold in your recent speech in The House of Lords in relation to child protection and Internet censorship.

I would be delighted to have the opportunity to discuss such issues with you if possible, both on a technical basis, and a practical basis, but also as a father having raised five children in the Internet age.

Whilst I am pleased that our marketing efforts have brought us to your attention, I am slightly puzzled that you seem to have mentioned Andrews & Arnold in a context of being something of a problem ISP, and a reason for your amendments. Therefore, I would like to take this opportunity to clear up any misunderstanding you have about our service.

For a start, we appear to be a company that already complies with the requirements of your proposals:
  1. We do not sell to individuals under 18. We already ask anyone ordering to confirm that they are not under 18. Obviously if OFCOM were to come up with some practical means to verify age on an on-line order we'd be more than happy to consider integrating such a system, but at present we feel it very unlikely that an under 18 could order. For our type of services it means having access to a phone line (without Internet already) in order to install equipment, or access to allow a phone line to be installed - both of which seem unlikely to go unnoticed by parents in a household. Our services are also unlikely to be cost effective for a minor to purchase.
  2. We already confirm that our customers want fully unfiltered Internet access, and this is made very clear when ordering. Indeed, it is one of the main reasons people come to us in the first place to obtain Internet access.
So it seems to me that we are already exactly the sort of ISP you want - one that does not sell to minors and only provides unfiltered Internet access to those that specifically request it.

I am quite sure that most other small ISPs would be happy to work in a similar way, and I would be happy to engage with ISPA, LONAP, LINX, and UKNOF to try and build an informal arrangement regarding such clear information at the point of sale.

Indeed, specifically for parents, we even go as far as providing means to set alternative DNS servers which are a way of helping block accidental access to unsavoury content on a customers Internet access with us.

In light of this, I am somewhat surprised that you appear to use us an example of why legislation would be needed. It seems to me that we are exactly the opposite, an example of why legislation is not needed.

However, as I said earlier, I would be delighted if there was an opportunity to discuss such matters more directly. I am sure, if you would like, that we could arrange a dinner/meeting with a number of similar small ISPs if that would be helpful. Alternatively, I would be delighted if you would like to visit our offices in Bracknell and discuss matters and see what we do.

I also have a suggestion for age verification which could be achieved by a change in BACS, using a variation of normal Direct Debit set up as a means to verify that an account holder is 18 or over. After all, the banks already do significant checks on account holders, and it would be ideal to make use of their information for such a purpose.

Adrian Kennard

[Being posted as well, I'll update any reply]

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