1. Industry Perspective on Combatting Child Sexual Abuse Content
Child Online Protection in Kenya Proposals for industry response on COP
NOTICE & TAKEDOWN:
Industry Perspective on Combatting Child Sexual Abuse Content
Shola Sanni, Policy Manager – Africa, GSMA

2. Outline About the GSMA GSMA Commitment to Internet Safety
GSMA Mobile Alliance
What is Notice & Takedown?
Establishing NTD Capabilities
Policy & Procedures
Sample NTD Process
Relationships & Collaboration
Practical Guides for Liaising to Address CSAC
Complimentary Tools & Capabilities for NTD
Conclusion

3. About the GSMA

4. Provide strategic direction and thought leadership to our members
GSMA: What We Do
The GSMA has four main activities:
INDUSTRY FORUM
Drive collaborative industry programmes aimed at maintaining operator relevance in the digital world
POLICY ADVOCACY
Advocate for the industry to regulators, policy makers and society as a whole
THOUGHT LEADERSHIP
Provide strategic direction and thought leadership to our members
CONVENING
Convene the broad mobile communications ecosystem at our industry leading events such as Mobile World Congress

5. GSMA: Snapshot of Our Programmes

6. GSMA Commitment to Internet Safety
Promoting mobile/internet as enabler of children’s rights and platform for socio economic development
Program in Africa aimed at helping to develop national COP strategies & contributing to global collaborative effort
mYouth Programme
Coalition of operators across the world against child sexual abuse content (CSAC)
Convened by GSMA to apply technical measures, co-operation and information sharing to combat CSAC
Mobile Alliance
Broad principles to guide different stakeholder groups to take action in contributing to COP effort
Capacity building & toolkits interpreting COP principles for implementation
ITU/UNICEF COP Guidelines for Industry

7. Mobile Alliance: Combatting Child Sexual Abuse Content
GSMA Mobile Alliance Against Child Sexual Abuse Content
Mission: To obstruct the use of the mobile environment by individuals or organisations wishing to consume or profit from child sexual abuse content
Minimum commitments: Hotlines, Notice and Take Down processes, blocking CSAC websites
The second GSMA programme of relevance to today’s discussions is the GSMA Mobile Alliance Against Child Sexual Abuse Content.
The Mobile Alliance was formed by an international group of mobile operators to work collectively on obstructing the use of the mobile environment by individuals or organisations wishing to consume or profit from child sexual abuse content. The Mobile Alliance uses a combination of technical measures, co-operation and information sharing, to create significant barriers to the misuse of mobile networks and services for these purposes. The Mobile Alliance works with external stakeholders to stay abreast of trends and developments in this area, and generate best practice and show leadership for the wider mobile industry.
When we created the Mobile Alliance, back in 2008, we were keen to avoid the proverbial ‘paper tiger’. So, with our founding operator members, we agreed that all Mobile Alliance members would undertake three key commitments:
To support and promote ‘Hotlines’ mechanisms for customers to report child sexual abuse content discovered on the internet or on mobile services
To implement ‘Notice and Take Down’ processes to enable the removal of any child sexual abuse content posted on their own services
To implement technical mechanisms to prevent access to websites identified by an appropriate agency – for example, INTERPOL or a hotline - as hosting child sexual abuse content.
All of these commitments are readily achievable if your operations are based in countries where legislation is robust and child sexual abuse content defined; where hotlines and dedicated law enforcement are largely in place and active; where there is a culture of acknowledging and addressing the issue of child sexual abuse, both online and offline. Equally, the commitments are incredibly challenging in countries where this is not the case.
That is why, although industry has a role to play in this area, it is critical that all stakeholders work together and this is understood to be a multi-stakeholder issue…. [see next slide]

8. Mobile Alliance: Combatting Child Sexual Abuse Content
Mobile Alliance Against Child Sexual Abuse Content

9. What is “Notice and Takedown” (NTD)?
A company’s procedures for handling reports that may come from customers, employees, law enforcement or hotlines that child sexual abuse material has been discovered on the company’s networks or services.
Elements
Notice: Report or “notice” of child sexual abuse content (CSAC) present on recipient’s networks - received from law enforcement, internet hotline or other source
Takedown: Acting promptly to confirm reported material is illegal, and to remove and isolate such content from being viewed or circulated by the public – to be contrasted with deletion of CSAC
Deleting CSAM may compromise an ongoing criminal investigation that is unknown to the company, and also prevent the identification of children who are being abused.
If CSAM is confirmed, it should be securely isolated within the company’s networks and services and accessible only to those employees authorized to investigate and take action on CSAM reports. Companies should check the law applicable in their jurisdictions on handling child sexual abuse material.
ADVANTAGES OF NTD: vital tool in removing CSAM at its source, keeping the Internet free of this content, and disrupting the cycle of sexual exploitation and abuse of children and their re-victimization.
Receiving reports of, and preventing further access to CSAC

10. Establishing NTD Capabilities
Fundamental steps companies can take
Board-level commitment, support & sign-off
Develop clear policy on commitment & position on CSAC
Assign responsibility for policy implementation & develop documented procedures
Establish dedicated function of trained employees
Establish MOU between company, LEAs or Hotline
• First, seek board-level commitment, support and sign off to outlaw and combat CSAM. This will send a
clear message to employees and any person using the company’s networks and services that child sexual
abuse material will not be tolerated and that the company will cooperate fully with law enforcement and other stakeholders to combat CSAM.8
• Second, develop a clear policy that sets out the company’s commitment and position on CSAM. This is
important for setting a company’s internal direction.
• Third, assign responsibility for putting that policy into practice, and develop clear documented procedures
and capabilities for removing CSAM from public access and further circulation. Ensure these procedures are accessible within the company and also apply to third parties used by the company and who have a role in notice and takedown.
• Fourth, establish a dedicated function staffed by trained employees. This minimizes the impact on other
employees from exposure to CSAM and helps avoid a company’s liability from possible prosecution where possessing or viewing CSAM is illegal even for employees (see Section 4.2).
• Fifth, seek to establish a memorandum of understanding between the company, national law enforcement
and your national hotline that gives protection to employees acting in a professional capacity to investigate,
report and remove CSAM. This will help address employees’ concerns and anxieties over possible
prosecution for simply doing their jobs.

11. Policy & Procedures Policy Development Implementing NTD Processes
Should reflect national law
Clear & understandable; set out Dos & Don’ts of processing CSAC reports
Policy Development
To cater for indemnification of employees, preserve evidential integrity of process & data for prosecution
Swift removal of CSAC to facilitate recovery/safekeeping of children
Implementing NTD Processes
Easy to use reporting mechanisms
Develop consistent approach to support investigation & prosecution
Standardized Function for Reporting CSAC
Secure environment for taken down data & proper custody/access
Preservation of CSAC & Associated Data
Employee Considerations
Terms and conditions offer a crucial way for a company to make clear what content and behaviour is acceptable and
to prohibit illegal activities such as the circulation of CSAM. Clearly state details on the following items in terms and conditions:
• Note that offering or distributing illegal materials such as CSAM or other actions to sexually exploit children are
not allowed.
• Specific actions that will be taken by the company, such as reporting CSAM to law enforcement or hotlines, and
cooperation with any investigation and prosecution, including the preservation and disclosure of associated data.
• Whether you will suspend or close accounts and services if the terms and conditions are violated.
• The redress process that is available if customers wish to challenge a decision to remove or otherwise act on
reports of CSAM.
It may also be useful to provide hyperlinks to information about the company’s position on CSAM and an acceptable use guide, and/or links to guidance or resources provided by law enforcement or a national or international hotline organization.
The intent is to leave customers in no doubt about their responsibilities and the rights and powers of a business to deal with reports of potential CSAM.
Legal framework for indemnification/exemption from prosecution
Training & support to adequately equip staff to process CSAC
Clarify Customer Terms & Conditions
Designed to keep customers fully informed of their responsibilities in relation to CSAC
Define acceptable use, prohibit illegal activity, set out company CSAC position & right to deal with reports

12. Sample NTD Process

13. Relationships & Collaboration
Liaison with industry, government, LEAs & Hotlines required to develop robust processes for addressing CSAC
Connected society requires cross-border cooperation & enforcement to address joint responsibilities –
Swift removal of CSAC from circulation
Supporting flow & collation of intelligence to help identify & rescue children who appear in CSAC
Global collaborative effort to ensure ‘no space’ online for CSAC

14. Practical Guides for Liaising to Address CSAC
Consider establishing relationship with industry peers and jointly develop standardized industry-level code of practice on NTD
Encourage & participate in best practice sharing on NTD
Identify national hotline where available and engage to establish good practice with dedicated line of communication
Where no hotline, consult GSMA & INHOPE on setting up one
Engage local law enforcement to collaborate on effective NTD procedures
Access international law enforcement resources –
INTERPOL training on combating CSAC
Virtual Global Task Force on regional law enforcement & CSAC reporting hotlines
Council of Europe’s Guidelines for Cooperation between Law enforcement and Internet Service Providers Against Cybercrime
Consider establishing relationships with industry peers and developing an industry-level code of practice that sets
out policy and standardized practices on notice and takedown of CSAM. This encourages the sharing of best practice and strengthens actions against CSAM at the national and international levels. An example of this is the global Mobile Alliance Against Child Sexual Abuse Content, which has produced a range of guidance and advice and created a network of invaluable relationships to help keep mobile services free from CSAM.23
In the United Kingdom, a broad coalition of industry engaged with the national hotline, the Internet Watch Foundation, and agreed on a code of practice that defines the notice and takedown procedure by which service providers remove or disable access to potentially illegal content hosted on their networks after receiving a notice from the IWF.24

15. Complementary Tools & Capabilities for NTD
List of URLs containing CSAC maintained by hotlines, such as IWF and NCMEC; made available to member organizations for blocking
INTERPOL ‘Worst of’ list of URLs that can be used to limit the distribution and availability of CSAC on access networks
BASELINE, which is being deployed by INTERPOL, is a scheme that will allow industry to scan its systems for CSAC by sending hash signatures to a server for a ‘hit/no hit’ response to help identify and remove CSAC from networks.
PhotoDNA, developed by Microsoft, is a technology that automatically helps detect and report the distribution of child exploitation to expedite removal of such content
Industry initiative ‘Hash Value Sharing’, wherein hotlines such as the IWF, NCMEC and INHOPE are creating unique digital fingerprints, to aid blocking of CSAC
Notice and takedown is but one crucial tool to combat child sexual abuse material. When you develop products and services, it is good practice to identify in what ways they could be exploited and misused to sexually exploit children and create or distribute CSAM. Asking such questions helps identify solutions and has led to the development of a number of other tools, resources and practices to help prevent and disrupt the availability of CSAM online. Some of these tools and resources include:

16. Conclusion
Effective NTD requires national, regional and international cooperation and & information sharing Overarching role of collaboration should inform the revision and development of legal frameworks towards a stronger global effort. Interoperability between legal frameworks across borders is necessary to ensure there is no space online for child sexual abuse material. Combating child sexual abuse material and keeping children safe from sexual exploitation is everyone’s responsibility, and needs us all to play our part.
Notice and takedown is but one crucial tool to combat child sexual abuse material. When you develop products and services, it is good practice to identify in what ways they could be exploited and misused to sexually exploit children and create or distribute CSAM. Asking such questions helps identify solutions and has led to the development of a number of other tools, resources and practices to help prevent and disrupt the availability of CSAM online. Some of these tools and resources include:

17. Thank you! Shola Sanni Policy Manager – Africa, GSMA
GSMA Mobile Alliance Against Child Sexual Abuse Content:
Help your organization join the battle against CSAC by accessing the GSMA-UNICEF Notice & Takedown guide available at
Shola Sanni
Policy Manager – Africa, GSMA
Mobile: ;
Web:
Thank you and we look forward to working with you
….. ETC