The ISP filtering Pilot provides the opportunity to test a range of content filtering solutions in a real world environment, with the cooperation of ISPs and their customers.

This Pilot is adding to the information obtained via the laboratory-based tests of filters published by the Australian Communications and Media Authority (ACMA).

The outcomes of the Pilot will inform the Government's decision making on the ISP filtering framework.

2. Who is eligible to participate in the Pilot?

Participation in the Pilot is open to all ISPs that provide an internet service to persons residing in Australia (including relevant mobile telephone operators).

The Department of Broadband, Communications and the Digital Economy (the Department), will consult on the details of participation with all ISPs who lodge an Expression of Interest.

Ideally, in order to obtain a comprehensive set of results, the Pilot will involve a representative cross section of industry; including small, medium and large ISPs; and metropolitan, regional, rural and mobile providers.

The Pilot aims to test filtering across a broad range of delivery systems, including wireless, satellite and mobile internet providers, and broadband and dial up customers.

Participation in the Pilot is at the sole discretion of the Department.

3. Why should ISPs participate in the Pilot?

Participation in the Pilot provides ISPs with an invaluable opportunity to inform the Government's approach to ISP filtering.

ISPs will be recognised for their participation in the Pilot. This recognition will strengthen their brand image within the community.

The Pilot provides the opportunity for ISPs to test new filtering business models with the assistance of the Government and the Department's technical advisor.

4. Is it compulsory for ISPs to participate?

No.

Involvement of ISPs that have applied to participate in the live Pilot is being negotiated on a case by case basis.

5. What are the time frames for the Pilot?

The Pilot 'Request for Expression of Interest', 'Technical Testing Framework', 'Application Form' and 'Draft Deed of Agreement' were released on 10 November 2008.

Applications to participate in the Pilot on a funded basis closed on Monday 8 December 2008.

ISPs will participate in the Pilot for a minimum of six weeks.

The pilot has now commenced and a report of findings is scheduled to be available mid-2009.

6. What funding is available for ISPs participating in the Pilot?

Some limited funding has been provided to ISPs who applied to participate by the 8 December 2008 deadline, to help defray the costs directly attributable to participation in the Pilot, such as:

procurement of a filtering solution
installation and configuration of the filtering solution, and
costs associated with any required modifications to network infrastructure.

While it remains open for other ISPs to apply to join the Pilot, any applications accepted will be on an unfunded basis (see also Question 7 below).

7. Is it too late for other ISPs to participate in the Pilot

The Department will endeavor to accept late applications that are seeking participation in the Pilot on an unfunded basis, but cannot guarantee that such applications will be accepted.

8. Where can I get information about the Pilot?

Go to the ISP Content Filtering Live Pilot page and download the following documents:

Request for Expression of Interest
Technical Testing Framework
Draft Deed of Agreement, and
Application Form.

9. What consultations with industry has the Government undertaken?

In the preparations for the Pilot, consultations have been undertaken with the Internet Industry Association (IIA), the Australian Mobile Telecommunications Association (AMTA) and a number of individual ISPs and mobile operators.

A draft of the Technical Testing Framework was used as the basis of subseqent consultations leading up to release of the EOI.

Consultations will be on-going throughout the Pilot with both industry and the Government's Consultative Working Group on Cyber-safety.

10. Will a report of the Pilot be made publicly available?

Yes, taking into account undertakings made to ISPs and their customers in relation to privacy and confidentiality of information.

Data will be generated from the Pilot which will provide information on ISP level filtering in a live, real world environment.

The data will be compiled into a final report that will be provided to the Government to assist its consideration of policy in regard to ISP filtering.

Testing

11. What is the Pilot testing?

The Pilot is testing a range of filtering solutions and is deliberately flexible.

The specific filtering solutions used, and the size of the customer base filtered, are being or have been negotiated with individual ISPs. However, all participants in the Pilot must, at a minimum, filter the Australian Communications and Media Authority's (ACMA) blacklist.

12. How is the testing being conducted?

The Department's independent technical advisor is working with the Department to conduct the Pilot, and is tasked with undertaking the technical assessments, including drafting reports on the results of these assessments.

The Pilot has been designed to minimise imposts on ISPs. Wherever possible equipment will be configured to enable the Department's technical advisor to access the test information it needs remotely.

The live Pilot is expected to provide information on:

the impact on network speed from the perspective of both the user and the ISP
accuracy of filters in terms of over and under blocking of internet content
relative ease of circumvention of different filtering solutions
ease of use and privacy/security from a user perspective
costs associated with introducing ISP filtering
scalability (i.e. can the service be used for a much higher volume of internet traffic without a significant impact on performance)
effectiveness of any additional functionalities of the filter products, and
snapshots of filtered and unfiltered performance covering representative samples of each participating service.

13. How will the Pilot deal with over-blocking and under-blocking?

An aim of the Pilot is to assess the impact of filters in terms of over-blocking (i.e. blocking content that should be passed) and under-blocking (i.e. content that should be blocked), and to identify filtering solutions that limit the level of over and under-blocking.

The level of over-blocking and under-blocking is known to vary significantly with the technology being used, how an ISP's hardware is set up and with the kind of filtering solution proposed.

The Department acknowledges that the possibility of restriction of legitimate sites through over-blocking is a concern in the community and industry. The Department will reserve the right not to include in the Pilot any proposed filtering solution which is likely to involve a high level of over-blocking or under-blocking. Any filtering solution proposed by an ISP that reveals a high level of over-blocking or under-blocking during the Pilot may be aborted early, or may be tested without involvement of actual customers.

The Department's technical advisor will perform accuracy and effectiveness testing early in the Pilot for each solution. If over-blocking is detected the Department's technical advisor will notify the ISP and re-test until the matter is satisfactorily resolved before proceeding.

For participating ISPs that do not have an over-blocking reporting mechanism, the Department's technical advisor will engage with each respondent organisation in planning and preparation sessions to discuss and address such issues.

14. Why is the Pilot testing a blacklist of up to 10 000 URLs when the current ACMA blacklist is around 1100 URLs?

Filtering of the ACMA blacklist will be a requirement of all participants in the live pilot. However, in consultations with ISPs, concerns have been raised that filtering a blacklist beyond 10 000 unique addresses may result in network performance issues, depending on the configuration of the filter.

The pilot will therefore seek to also test network performance against a test list of approximately 10 000 sites. While details of this testing will be negotiated with the ISPs participating in the Pilot, the intention would be to test the impact of the size of such a list on filtering when installed on the participating ISP's network.

This element of the Pilot will be a closed network test and will not involve actual customers. A list of 10 000 sites will be developed by the Department's technical advisor who has access to URL lists of this size. Because this test is being performed to test the impact on network performance against a list of this size, and actual customers are not involved, the make-up of the list is not significant.

The use of approximately 10 000 sites in this test should not be seen as reflecting an expectation on the part of Government that the ACMA blacklist will increase to 10 000. The number has no significance beyond the fact that it has been raised in consultations as a possible tipping-point in terms of network performance for some types of filtering, and therefore needs to be looked at in the Pilot.

15. Why does the Pilot involve two levels of filtering?

The aim of the Pilot is to test both simple black list filtering of illegal and prohibited sites on the ACMA black list as well as more extensive filtering products where an ISP's customers, particularly parents, have greater choice in what is filtered.

ISPs have the choice of which stream they wish to participate in. They may choose to participate under both streams if they wish.

This approach will ensure that the Pilot tests a broad range of filtering solutions in a broad range of networks.

It will enable comprehensive information to be provided to the Government to assist development of policy in this area.

Customer participation

16. How will an ISP's customers be consulted on the conduct of the Pilot?

The ISP filtering Pilot will ideally involve surveying a sample of an ISP's participating customer base to seek information on the customer's filtering experience.

The Department is conscious of the need to minimise any impact on both customers and the ISP. Therefore, the survey will be undertaken electronically where possible.

The Department and the Department's technical advisor will discuss the survey process and associated correspondence with participating ISPs, prior to issuing the survey. Any surveys will only be undertaken with the agreement of the relevant ISPs.

17. How will a participating ISP's customer's privacy be protected?

The purpose of the Pilot is not to track or monitor an individual customer's internet usage.

Rather, the purpose of the Pilot is to gather information on the impacts of various ISP filtering solutions in a live real world environment, by comparing filtered and unfiltered customer connections.

No personal information on customers will be sought as part of the Pilot. Survey results will be provided in an anonymous form.

In administering the Pilot, the Department is bound by the provisions of the Privacy Act 1988. Section 14 of the Privacy Act contains the Information Privacy Principles which prescribe the rules for handling personal information.

ISP Filtering

18. Is it true that filtering can be easily circumvented?

Online content filtering solutions, including the ones that have been introduced by ISPs in other developed countries, may be circumvented by motivated people with sufficient knowledge.

While ISP filtering is not a 'silver bullet' that will forever fix the problem of illegal content on the internet, it can help to disrupt online distribution of such material, and prevent accidental exposure to it.

It is one of a number of possible tools that can be used as part of a more comprehensive approach to cyber-safety.

The live Pilot is testing the ease with which different filtering solutions can be circumvented and the capacity of filters to detect and provide warnings on circumvention attempts.

The live Pilot will help inform policy on ISP filtering.

19. Is it true that ISP filtering is unable to filter non-web based traffic such as peer-to-peer and chat?

ISPs in other developed nations that have introduced filtering have done so mainly to help address the proliferation of child sexual abuse material on the web using a blacklist of mainly child sexual abuse sites. These blacklist filtering services do not deal with non-web traffic such as peer-to-peer and chat.

The Department understands that a number of ISP filtering products allow blocking of non-web based applications, and that vendors are undertaking development in this area. A small number of ISPs in Australia and overseas provide ISP level filtering services that seek to help parents manage non-web based applications such as peer-to-peer and chat.

To the extent possible, the Pilot will test the effectiveness of more sophisticated ISP level filtering services and products to help parents manage use of non-web applications.

It is understood that technology exists to filter peer-to-peer networks. If such technology is proposed as part of the Pilot by an ISP it will be considered.

20. Will the introduction of ISP level filtering slow the performance of the internet?

ISP level filtering using a blacklist of mainly child sexual abuse sites has been introduced in a number of comparable western countries with little perceived impact on network performance.

However, the Government acknowledges the community concerns that the introduction of ISP level filtering can impact on network performance and it is important that decisions on the implementation of ISP filtering are grounded in sound evidence.

Therefore the Pilot is seeking to as certain the performance impact of the introduction of the range of ISP filtering approaches on the internet end-user experience, and the impact on the service providers' overall network.

The data collected as a result of the Pilot will inform the Government's thinking on the final shape of its policy framework.

21. Shouldn't parents take responsibility for their children's internet use?

ISP filtering potentially provides parents with an important tool to assist them in managing their children's online use.

The Government's approach does not remove the responsibility of parents and guardians to manage their children's use of the internet.

Educating and empowering the public about the means to manage their and their children's use of the internet, is an important component of the Government's cyber-safety policy.

22. Have ISPs in comparable western democracies moved to implement similar ISP filtering systems?

ISPs in a number of comparable western democracies have co-operated with Governments and law enforcement agencies to filter predominantly child sexual abuse material through the introduction of ISP level filtering.

The list of countries where some or most ISPs have to date implemented blacklist filtering focused mainly on child sexual abuse includes: Canada, Denmark, Finland, Norway, Sweden, and the United Kingdom.

Australian Communications and Media Authority (ACMA) blacklist

23. Why is the ACMA blacklist confidential?

The blacklist is comprised predominantly of URLs relating to child sexual abuse images. Many countries including Australia have laws against online distribution of child sexual abuse images. The list also includes URLs relating to other categories of material which would be refused classification under Australian law. Such material may not be legally imported, distributed or exhibited.

ACMA is exempted from the Freedom of Information Act 1982 in relation to internet content documents related to its internet content regulatory functions under the Broadcasting Services Act 1992, This exemption is on the basis that disclosure of the information would likely jeopardise the regulatory objective of preventing access to harmful and offensive online material, and would also likely compromise ACMA's ability to efficiently refer online child sexual abuse material to overseas law enforcement agencies.

24. What are the requirements around security and confidentiality of the ACMA blacklist?

ISPs participating in the Pilot must enter into a non-disclosure undertaking with ACMA to obtain the blacklist.

The undertaking acknowledges that the URLs contained on the blacklist relate to prohibited content under the Broadcasting Services Act 1992 and that the blacklist is provided in confidence, for the sole purpose of allowing the participating ISP to prevent access to the material contained in the blacklist for users of the ISP's service.

Participating ISPs must not disclose the blacklist to anyone, or for any purpose, not directly related to the ISP taking the necessary steps to prevent the users of its services from accessing such material by way of its participation in the Pilot.

25. Does the Government intend to increase the scope of the blacklist?

The Government is committed to strengthening the blacklist in relation to child sexual abuse material.

The Government is doing so through arrangements for ACMA to share child sexual abuse blacklists maintained by the National Centre for Missing and Exploited Children in the United States, the Internet Watch Foundation in the United Kingdom, and other overseas bodies involved in the investigation of such material.

Any decision to expand the types of content to be added the blacklist would require an Act of Parliament.

The Government has no plans to expand the parameters of the ACMA blacklist.

Document ID: 90871 |
Last modified: 13 May 2009, 4:37pm