Appendix C - Current Examples of
Approaches to Best Practices

Even acknowledging the many challenges of implementing best practices aimed at keeping children safe online, as noted previously, most if not all companies in the “Internet industry” already have substantive practices in place including providing parents with technology-based tools, resources and information.  As examples, several companies represented on or consulted by the task force provided comments on their products, policies, and recommendations for best practices.  The following are their contributions:

AOL

Corporate Focus

  • A global Web services company that operates some of the most popular Web destinations;
  • Offers a comprehensive suite of free software and services;
  • Runs one of the largest Internet access businesses in the U.S.;
  • Provides a full set of advertising solutions.

Policies and Procedures

AOL has been a leader in helping keep kids safer online by offering:

  • Appropriate, evolving policies
    • Terms of Service & Privacy Policy
    • Community Guidelines (Based on Context & Intended Audience)
    • Product Guidelines  (Based on Product Features and Functionality)
  • Age-appropriate programming
    • Specific content areas for Kids (KOL) and Teens (beRED)
    • Content based on industry ratings (e.g., ESRB, MPAA)
    • Walled garden option for kids and teens
  • User empowerment tools
    • Parental Controls – More than a decade ago, we introduced parental controls to help prevent children from accessing undesirable or inappropriate content.  We continue to update and enhance our parental control software to stay current with changes in technology and online features.  Parental controls are available free on the Web at .   Key features include:
    • Pre-set age controls for web browsing:  make the set up process easy by offering pre-set age ranges such as Kids (12 and under), Young Teen (13-15) Mature Teen (16-17) to automatically align Web filtering and monitoring settings to provide an age-appropriate online experience.
    • Parental flexibility:  when a child tries to access a Web site that is blocked by Web browsing, Parental Controls offers a "Get Permission Now" button which lets the parent approve immediately. If the parent is not close by, the child can send an email to his or her parent for approval. The email Web request shows the name of the Web site and provides the ability to immediately approve or deny access directly from the email.
    • IM and Email controls: parents can know a child's online friends by setting approved IM and email contacts.
    • Time limits:  parents can manage a child's Internet time allowing access to the Internet during specified times.
    • Activity Reports: parents can choose to view a child's Internet activity online or have a daily or weekly activity reports sent automatically to their email.
  • Privacy preferences – AOL offers privacy settings within products such as email and IM enabling consumers to control their own online experience by determining who can interact with them:
  • Safety messaging and education – AOL recognizes that education is one of the most effective ways to help protect kids online.  In our continuing effort to teach online safety we: 
    • Offer SafetyClicks.com, a safety blog that features articles, videos, and topical blog posts designed to support and inform parents as they teach their kids to navigate in the Internet.
    • Offer safety tips to kids and parents at the product level such as Kids Message Boards.
    • Provide child online safety education in the form of formal presentations or hands on demonstrations at schools, PTA or other organized meetings.
    • Work with myriad child advocacy organizations to help educate kids, parents and caregivers about safe Internet use.

Current Response to Problems

  • Enforcement and moderation
    • AOL branded services offer a “Report Abuse” button for consumers to report unacceptable behavior.  It automatically captures text of IM and chat conversations so that they are authenticated and cannot be manipulated prior to sending the report.
    • Abuses are referred to teams of trained professionals who process consumer complaints on a 24 hours a day, seven days a week basis. 
  • Law enforcement support
    • We provide free training to Federal, State and local law enforcement at a host of venues every year.
    • We assist law enforcement via our 24-hour dedicated law enforcement hotline.

Recommendation for Developing Best Practices

  • A multi-pronged approach to best practices that includes setting consumer expectations through a terms of use and privacy policy;
  • Supporting users with empowerment tools and education;
  • Implementing proactive and reactive violation prevention strategies including working with law enforcement as required;
  • Collaboration with industry, NGO’s and others who play a role in online child safety.
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Comcast

Corporate Focus

  • Create a safe and secure environment for kids and families;
  • Raise consumer awareness about online safety; and
  • Concentrate on family and parental controls, privacy protection and identity theft and safeguards for digital assets.

Policies and Procedures

  • Use a comprehensive, multi-layered approach that includes tools, education and resources;
  • Developed a dedicated Security Web site (www.security.comcast.net) to provide tools, tips, best practices, security alerts, FAQs on online safety;
  • Provide the highly acclaimed McAfee Security Suite to Comcast High-Speed Internet customers at no charge, giving parents controls to block selected web sites, filter inappropriate content, monitor chat sessions and manage children's Internet activity; and
  • Partner with leading organizations (e.g. iKeepSafe, FOSI, McGruff, NetSmartz) to give parents and kids content-rich tips and guidelines on online safety, cyber-bullying, networking and keeping personal information private.

Current Response to Problems

  • Provide multiple, easily accessible tools and resources to report safety issues (e.g. child pornography, child endangerment, cyber-bullying, Phishing) to Comcast, the National Center for Missing and Exploited Children, and law enforcement agencies; and
  • Work with law enforcement.

Recommendation for Developing Best Practices

  • Increase education and awareness among consumers about online safety issues and tools available;
  • Promotion and adoption of media/digital literacy among youth; and
  • “Best practices” seal that gives parents and families confidence that their Internet provider has made available appropriate tools to make their online experience safe and secure.
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Google, Inc

Corporate Focus

Google is committed to providing all of our users with a safe experience through three primary elements:

  • Powerful tools to empower families to control their activity online;
  • Cooperation with law enforcement and industry partners to stop illegal content and activity online;
  • Educational efforts to increase awareness about online safety. Visit our for more information.

Policies and Procedures

  • Google has developed its own filter, which uses advanced technology to block pornographic and explicit content from search results. Users can customize their SafeSearch settings.
  • Clear policies
    • Each of our services has clear policies such as terms of use or community guidelines, as in the case of .  Our guidelines are purposefully written in easy-to-understood language and designed to provide users with clear advice on what content is acceptable and what is not (e.g., hate speech, pornography, images of drug abuse, and graphic violence).
    • Zero tolerance for predatory behavior, harassment, revealing other users’ personal information, or any activity that endangers the safety or privacy of a child.
  • Community policing
    • Many of our products, including YouTube, employ an innovative and reliable community policing system that involves our users in helping us enforce our Terms of Service and Community Guidelines.
  • Innovative safety features
    • We are continually developing innovative tools to keep our community safe. For example, we use digital hashing technologies to prevent the re-upload of files that have been removed on YouTube. We also offer our users tools to protect their privacy on the site, such as the ability to hide personal information, make videos private, filter comments, or share videos selectively with family and friends.

Current Response to Problems

  • Empowering users
  • Information – Through our product , we provide our users with tips and articles for staying safe and protecting their privacy.
  • Reporting mechanisms – We also invite our users to tell us about illegal content or abuse they encounter on the web or in our products through our Help Centers.  lets users report concerns to the YouTube team, block comments from specific other users and disable the video comments feature on videos. Users who repeatedly violate our policies will have their accounts terminated.
  • Robust enforcement
    • When we discover child pornography or are made aware of it, we respond quickly to remove and report it to the National Center for Missing and Exploited Children (NCMEC) in the U.S. or the appropriate law enforcement authorities. We also use databases from designated organizations listing websites suspected of containing child sexual abuse images in order to remove any illegal URLs from our search results
  • Cooperation with law enforcement to combat child exploitation
    • Google cooperates with local and federal child safety investigations, and has a legal team devoted to this effort 24 hours a day, 7 days a week. We also provide training and technical assistance to law enforcement officials investigating online crimes against children through forums such as the Internet Crimes Against Children (ICAC) National Conference and the Virtual Global Taskforce (VGT).

Recommendation for Developing Best Practices

  • Companies should invest in innovative technologies and solutions to keep families safe.
  • Awareness through education is the key to empowering parents, teachers and families about the dangers and solutions online.
  • Companies can't do this work alone. Partnering with leading child safety organizations to empower parents, lawmakers and teachers with information and resources is a cornerstone.
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Microsoft

Corporate Focus

  • Provide a suite of products and online services (i.e., X-Box 360, X-Box Live, Windows Vista).
  • Empower parents to make their own decisions about what is appropriate for their children.

Policies and Procedures

  • Family settings (i.e., parental controls) are built into each product including:
    • Content controls with filtering,
    • People controls (i.e., parents create white list of persons their children can interact with online), and
    • Timer controls (i.e., amount of time allowed for product use).
  • Provide powerful but easy to use controls and resources to educate parents:
    • Default settings based on a profile that can be changed,
    • Online games that are actively monitored by site and gaming personnel,
    • A “Report Card” feature that shows parents what Web sites their children are accessing,
    • “The Pact” whereby parents create a paper agreement with their children that states terms of product use (e.g., the kind of game and amount of time) and post in the home.

Current Response to Problems

  • Mechanisms to report abuse are in place.

Recommendations to All Stakeholders for Developing Best Practices

  • Tools are important, but not enough - education is always needed,
  • Work with law enforcement,
  • Work collaboratively with industry, and
  • Initiatives must be ongoing for children's online safety.
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News Corp/My Space

Corporate Focus

  • Offer educational outreach.
  • Empower users to be safe online.
  • Provide a welcoming environment for customers that accommodates the News Corp. advertising business model.

Policies and Procedures

  • Tools are structured for the problems they need to solve.
  • Eye review of every picture and video uploaded (10 million videos/photos per week).
    • Terms of use define what is allowed on the site (i.e., none of the following: nudity, drugs or drug paraphernalia, hate speech, violence, pornography).
  • Databases based on key words are built in to block users from going to pornographic sites and redirect them to the homepage.
  • Maintains a database of 600,000 registered sex offenders.
  • Content Assurance Team (CAT) in place to attempt or look for bad things.

Current Response to Problems

  • If users post content that is not allowed, they receive a warning or the content is deleted.
  • When discovered, convicted sex offenders are removed from MySpace.
  • Report abuse button on the bottom of every profile that provides seven options, and teams for complaints to be handled within 72 hours:
    • Customer support - technical help;
    • Customer care - problem with another user;
    • Criminal act - reported to police 24/7 - hotline for them to contact MySpace immediately;
    • Amber Alert posted on MySpace in the same region of the country where issued.

Recommendations to All Stakeholders for Developing Best Practices

  • The biggest challenge for all is to find the at-risk children and help them.
  • Respond to what research indicates are real problems rather than issues that may be exaggerated or timely due to media or government focus.
  • Industry should not try to control the environment but give tools to parents so parents can choose what to control.
  • Venture capital dollars should be sought and utilized to address safety and security issues.
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Verizon Communications, Inc.

Corporate Focus

  • A global leader delivering innovation in communications, information, entertainment and technology
  • The architects and innovators behind the world's most advanced broadband networks
  • Our customers' trusted guide in the new world of communications and information technology

Policies and Procedures

  • Verizon provides a robust set of parental controls on all of our platforms:
  • We cooperate with law enforcement efforts in several ways:
    • Deleting child pornography images from our servers
    • Forwarding reports to and receiving reports from law enforcement and NCMEC
    • Retaining data for law enforcement purposes for 18 months across all platforms
  • Verizon reaches out to parents, teachers, and kids through our Partnership for a Child Safe Internet initiative:
    • Events in seven states to date with more to come in 2009
    • Provide actionable information about staying safe online
    • Curriculum materials available through our Thinkfinity site at www.thinkfinity.org

Current Response to Problems

  • If a customer has a complaint about child pornography, or other illegal activity involving children on any of our systems, they can report it to us by sending an email to .
  • Alternatively, they can also make a report directly to the National Center for Missing and Exploited Children through its CyberTipline located at www.cybertipline.org.

Recommendation for Developing Best Practices

  • A three prong approach to family online safety is necessary - education, tools, and law enforcement
  • The threats are ever-changing, so policies and procedures must be flexible enough to adapt, i.e., legislated mandates cannot keep pace with new, emerging threats
  • Industry groups such as the Family Online Safety Institute and the new NTIA Online Safety and Technology Working Group are an excellent way for companies to stay up-to-date on trends and threats
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The Walt Disney Company

Corporate Focus

To create:

  • A robust online environment for children;
  • A site where children and parents are comfortable; and
  • A large quantity and variety of content to engage families.

Policies and Procedures

  • All chat is moderated;
  • There are different layers of chat (e.g., drop down/white board/black list);
  • Children design and create Web pages based on content Disney provides; no outside content; and
  • Parents are engaged.

Current Response to Problems

  • A warning email is sent to parents when a problem is first noted by the moderator;
  • When the parent replies to the email, it is used as a “teaching moment” regarding the issue;
  • A second infraction results in a three-day hold on the account;
  • Stronger action is taken upon a third infraction;
  • Users can “Report a Player” - instantly, confidentially, and anonymously; and
  • An “Alert System” codes to pull logs or contact law enforcement.

Recommendation for Developing Best Practices

  • Moderated chat is a continuing challenge but is a positive action companies can take for their users.

 

With this input the task force recognizes the vital work of industry to manage risk in the ever-changing online environment where gaps and limits will always exist. The child's life has had a paradigm shift and stakeholders must likewise shift their philosophical and practical approach to children's well being. The task force collectively agrees that a new framework of best practices is needed.
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Yahoo!

Corporate Focus

  • As a leading global Internet brand and one of the most trafficked Internet destinations worldwide, Yahoo! is focused on powering its communities of users, advertisers, publishers and developers by creating indispensable experiences built on trust.
  • Provides comprehensive educational outreach to children, parents and communities about how to stay safer online and has created tools for users to safeguard themselves
  • In 1996, was the first Internet company to launch a child and teacher-friendly Web resource -
  • Promotes online safety experts in local and national events and through the website .

Policies and Procedures

  • User Empowerment Tools
    • A dedicated educational site, , provides resources and safety tips for children, parents and educators including comprehensive guides to using Yahoo! products safely, blogs by national safety experts, and teen focused safety videos.
    • Provides parents (or legal guardians) the option of opening a Yahoo! family account for children under the age of 13 by charging a one-time, 50-cent fee to their credit card to help ensure parental consent for account creation. Yahoo! donates a portion of the fee to help NCMEC’s efforts to protect children.
    • Offers users the ability to set Yahoo! search preferences. Users can turn Yahoo!’s “SafeSearch” ON to avoid the display of adult content, and parents can lock SafeSearch ON for under-18 year old users in their households. features search results that have been human-reviewed for appropriateness and safety for children.
    • Offers robust tools to assist users in reporting inappropriate or harmful behavior.
    • Has a comprehensive that provides tools that enable users to customize their experiences on Yahoo! and those of their children.
  • Partnerships with Law Enforcement
    • Partners with local and national law enforcement to provide online safety training to middle school and high schools students. Efforts include support of a nationally distributed curriculum from i-safe.org, ikeepsafe.org and the DARE program.
    • Maintains a 24 x 7 compliance team whose members immediately respond to law enforcement if contacted about a situation that indicates that child may be in danger.
    • Created a Law Enforcement Compliance Manual to ensure that law enforcement personnel are familiar with Yahoo!’s policies, procedures, and systems, and understand how to obtain the appropriate investigatory information in child exploitation cases.
    • Yahoo! provides law enforcement training for members of the Internet Crimes Against Children task force, state Attorneys General, the National Association of Attorneys General, and others.
  • Education and Awareness
    • Hosts an annual summit for K-12 education leaders and leading Internet safety experts to facilitate dialogue, collaboration and best practices around emerging online safety issues, with a focus on digital citizenship and cyber-bullying prevention.
    • Participates in several industry groups such as the Financial Coalition Against Child Pornography, the industry Coalition for Child Protection Technology, as well as industry working groups organized by our non-profit partners ikeepsafe.org, FOSI.org, and the Ad Council. Yahoo! is participating in NTIA Online Safety and Technology Group.
    • Donates millions of dollars worth of public service announcements on child safety issues through banner ads and sponsored links.

Current Response to Problems

  • Empowering users through implementation of clear and accessible safety and privacy policies and innovative safety features and tools
  • Implementation of technology and policies to help detect inappropriate and illegal material.
  • Regular monitoring and enforcement of Yahoo!’s own safety policies,
  • Partnering with NCMEC and the UK-based Internet Watch Foundation in an effort to reduce the proliferation of child pornography by removing known apparent child pornography URLs from Yahoo! search index results.

Recommendation for Developing Best Practices

  • Industry must work collaboratively with peers, child safety experts and law enforcement to address safety concerns; particularly emerging trends.
  • Safety education needs to be integrated within product offerings and focus on allowing parents to make the “safety” decisions most appropriate for their family.
  • Tools should be readily available for users to report abuse when it occurs.