Policy document: the use of rating systems, website quality assurance schemes and options for domain names

Children are accessing large amounts of harmful material on the Internet, mainly by accident, and mainly when they are on their own. This is one of the key findings of Consumers for Internet Safety Awareness (CISA), a project under the EU Internet Action Plan, led by European Research into Consumer Affairs¹. There is therefore a clear need for action to protect children so that they can safely enjoy the benefits of the Internet. CISA is participating by running tests on filtering systems and websites, and training programmes for parents, teachers and children. However, the EU and governments need to back this up with a general duty on ISPs to protect children, which would provide the necessary legal background for them to apply the various array of codes and schemes that exist only on a voluntary basis.

Children use the Internet for a wide range of purposes. In November 2001, ERICA published the results of a survey of children into their use of the Internet, which was conducted in the UK, Austria and Greece². The survey found that almost 75% of children surveyed in the UK visit games site, 74% use the Internet for help with schoolwork, almost 64% to pursue hobbies or interests, 39% for chat rooms, 39% visit celebrity sites, almost 38% for sports sites and 22% visit shopping sites. Of the Austrian children surveyed 59% said they used the Internet to visit game sites, 73% to help with homework, 74% to pursue hobbies or interests and 68% to visit chatrooms. Amongst the Greek children surveyed 36% said they visited sports sites and 13% celebrity sites.

Almost 67% of children surveyed in the UK said they used the Internet at home, over 88% of them at school, 41% at a friend's house and 26% at a library. 55% of the children said that they were usually alone when they used the Internet. In Austria this figure was 36%. In Greece 45% of children over 13 said that they entered websites when their parents were not present. Of the Greek parents surveyed, over half said that they had no idea what their children were capable of on the Internet. Furthermore, 75% of children surveyed in the UK said they had found material which they described as rude, violent, nasty, upsetting and/or to do with gambling or betting on the Internet. Nearly a third of Austrian children surveyed said they had found violent sites and 46%, especially girls, said that they had received an invitation to meet someone over the Internet.

The best-known problems of concern to parents, teachers and children alike, are the vast amount of pornography on the net and use of the net by paedophile stalkers to gain access to youngsters. Less well appreciated is the problem that children can access violent games and videos without the usual age checks or benefit of the watershed (whereby television becomes more adult in content after a certain time in the evening).

Furthermore, children's lack of experience can result in them divulging private or sensitive information, such as their age, address, telephone number or their parents' credit cards number to unknown persons.

Parents bear the main responsibility for their children and, with teachers, have a crucial role to play in ensuring children's safety when they surf. They need to provide the guiding hand to children on how to use the Internet responsibly and safely. They need to be more aware of what their children can access on the Internet and to make sensible rules.

However, the Internet is unusual in that children often know so much more about it than their parents (and even their teachers) and the practical implications of that knowledge are so far-reaching. In particular, the older children get, the more difficult it is for parents to control their teenager's Internet access. In addition, the realities of modern life mean that it will not always be possible for parents to be around when their children want, or need, to use the Internet CISA's research showed that 55% of English and 36% of Austrian children were usually alone when using the net. For these reasons it is essential for protection systems to be built into the Internet, such as software-based solutions, quality assurance schemes and special areas created for children.

It is also important that principles and rules to protect children already established in other media should be transferred to the Internet. In particular the concept of public sector broadcasting should be applied on the Internet. Positive sites on the Internet that reflect the EU commitment to public service broadcasting should be encouraged. Content providers should also be aware that children are generally alone when they use the net and therefore show broadcaster responsibility.

There should be a general duty on ISPs to protect children on line that would force them to apply the excellent array of codes and schemes that exist only on a voluntary basis and that have failed without legislative back-up to attract a critical mass. To leave the matter of child protection on-line purely to self-regulation and voluntary codes would, we believe, fail to ensure that children are safe when they surf. As the report by the National Consumer Council on Models of Self Regulation found self-regulation by itself can seldom provide completely effective consumer protection³. Self-regulation and codes of conduct have an important role to play, but they must be backed up by legally enforceable rules to ensure their effective application. Such a general duty on ISPs, as described above, would contribute substantially to ensuring that children are protected on-line. This general duty would also put pressure on ISPs to encourage content providers to rate their material. Until and unless enough sites are rated (including harmless ones), it will be difficult for filtering systems both to protect children and to give them reasonable access.

As regards harmful, but not illegal, content, we would like to see a 'notice and take-down' policy combined with more effective use of labelling and filtering schemes. A standards body would receive complaints about sites, and, if it ruled in their favour, would ask ISPs and search engines to remove access in the same way that complaints against offensive advertising are dealt with in some member states. ISPs should also themselves automatically operate a notice and take down policy based on a consumer complaint systems. Further recommendations are included at the end of this paper.

Finally, the Internet is a service and children are among its principal users. It is therefore an important issue for consumer protection which should be included in the Commission's current review of consumer protection legislation (see ERICA comments on the Green Paper on Consumer Protection ⁴.

Offensive sites are easy to find on the Internet and natural curiosity is likely to encourage youngsters to look for material which their parents would not normally allow them to see. Children can also stumble across offensive sites innocently whilst searching for something else. Some sites purposefully mimic the names of well-known companies and unscrupulous web sites also use meta-tags (words that summarise the site's content in order to help search engines) to lure in the unsuspecting. The CISA research shows that 40% of children found harmful sites by accident.

There is a range of software filtering packages and other programmes available. They can provide useful technical tools to protect children online, shielding them from unsuitable contacts or inappropriate material, and/or monitoring how the computers are being used.

Tests carried out towards the end of last year by CISA into filtering and rating systems show clearly that there are flaws in existing systems and substantial effort and investment needs to be made in developing and improving the software before it can be truly effective⁵. Of the 18 filtering systems tested, only 3 were judged to offer an effective filter. One of the main problems was the quality of the filtering. Whilst filtering of pornographic material was quite good overall, the software generally did not filter violent, racist and hate sites or material or sites about weapons, drugs or sects well. Another problem was that filters tested were in general not able to withstand attempts by cyber-savvy children to switch them off. Furthermore, many of the programmes were not very user-friendly.

However, despite obviously needing significant improvement, such software programmes can already contribute a great deal to protecting children on line. They can never substitute good parenting or good teaching practice, but they can act as an important aid to reinforcing and underpinning the good practice guidelines that parents and teachers want their children to learn and observe. Furthermore, CISA's filtering tests showed that they did not on the whole block inoffensive sites, which is a criticism often levelled at filtering systems.

It is important to bear in mind that no filtering or rating programmes actually stop anything from being published or placed on the Internet in the first place. All they do is empower the individual end user to make choices about what may or may not appear on their screens or their children's screens.

Filtering software products work in a number of ways, as set out below.

II.1. Filtering and rating systems

II.1.a. Negative list

The designer of the programme can draw up a 'negative' list that contains a series of site names that should be avoided. The sites present on the negative list can be put into categories (sex, drugs, violence, etc) so that the user can decide for himself (or for his/her children) what contents should be ruled out. Every time the user types in or clicks on a web address, the computer refers back to a database to see if the address is allowed. Some programmes also work on lists of banned words. Once these words have been detected in an address or in the site itself, access is refused. Negative lists need regular updating. They can be situated on the user's computer or they can be located on a remote server.

Drawbacks

• In view of the fast moving nature of the Internet these lists need constantly updating and it is difficult for the lists to keep up with the pace of change.
• Unsophisticated programmes based on lists of words often block inoffensive material, for example a filter may block material containing a banned word, although CISA's research indicates that this problem may be being overcome.

II.1.b. Real-time filtering

The filtering programme can carry out a real-time analysis of the textual contents of a certain Internet page. A similar process, but more complicated, involves a scanning of the picture contents of a page. Real-time analysis prevents a page containing any unwanted text or picture being (further) displayed. In some cases, the full site containing the 'offending' page is withheld from view.

Drawbacks

• The display of the harmless selected pages can be slowed down,
• An offending page can be partially displayed before the filter encounters the taboo word or picture.

II.1.c. Site labelling / Rating

In this procedure, the owner of a certain site voluntarily gives a label to his or her web pages using a technology called PICS Parental Internet Content Selection). Basically, a web manager rates the pages according to various categories (violence, nudity, gambling, sex, etc) and for varying degrees of severity within these categories. These categories and levels of severity have been established by an independent non-profit organisation ICRA (Internet Content Rating Association). Another market leader in rating is SafeSurf. The browser or other software will read these labels and determine whether or not they meet the acceptability criteria determined by the parent and therefore will decide whether to allow access or not. Thanks to the Internet Action Plan, the ICRA system is available free of charge to the consumer and is already installed in the main browsers.

The key point of this approach is that it is the publisher's judgement of their own material that determines the rating, not that of a third party.

Drawbacks

• In percentage terms very few sites are actually rated.
• As it is a voluntary system, those who are deliberately trying to reach certain users (eg children) with offensive material will not use it.
• To overcome this latter problem the user can set it to also block all pages that have not used the rating system, but because so few sites are rated at present this would effectively block most of the Internet.
• Rating does not deal with other issues which can cause problems for children (Newsgroups, etc).

However, as a component part of the overall plan to filter the Internet effectively, these rating systems do have a very important part to play. The objective therefore must be to increase the use of rating and the number of sites that self rate.

II.1.d. Walled-gardens

The system of "walled gardens" works on the basis of 'positive lists' of pre-selected websites that have been vetted and approved as being suitable for young children. Any access attempt to a site not being on this 'good list' is simply denied. This method is the safest for use with small children: only the scaled-down version of the Internet appears to them and in general they would not even suspect that the majority of it is kept well hidden. The positive list can be located on the user's computer or at a remote server, the latter system is sometimes operated by an ISP.

Drawback

• Walled-gardens are not suitable for older children who want to search the Internet for documentation and education purposes.

II.2. How the systems work

Using the above systems (not including "walled gardens"), if someone attempts to go to a particular site that is disallowed by the software, a blocking screen will appear. This screen can normally only be overridden by someone entering a predetermined password. The systems can limit or control the interactive elements of the Internet in any of a number of ways:

• They can block access to certain parts of the Internet altogether e.g. chat rooms or Newsgroups, or restrict access to a limited number of chat rooms or Newsgroups.
• They can control the amount of time the computer can be used, either at all or in relation to certain functions, or they can control at what times of the day or week it might be used.
• They can control both the sending and receiving of emails, i.e. a child might only be allowed to send emails to a restricted list of people and/ or receive emails from a restricted list of people.
• They can block certain types of information being sent or received e.g. credit card numbers, addresses, whether in emails, chat rooms or in other kinds of file transfers.
• They can record the addresses of all places visited on the Internet and give details of the activities engaged in.
• The systems can record or keep an audit trail of everything that happens on a particular computer or network.
• All conversations that take place in a chat room can be recorded.
• The addresses of all web pages visited can be recorded.
• The contents of all postings to Newsgroups or other parts of the Internet can be recorded.
• The contents of all emails sent and received can be recorded.
• If there is more than one user on a particular computer or network all of the above can be recorded against each individual.

In spite of the current flaws in the existing software, filtering and rating offers some protection for children on-line. It is especially appropriate for slightly older and teenage children for whom the concept of walled gardens is no longer appropriate and who wish to explore more widely for educational and other material.

In recent years there has been discussion about the potential use of new generic Top Level Domains as a tool to protect children on-line (for example, the creation of ".kids", similar to ".com", ".org", etc). More recently the discussion has moved to the potential of secondary level domains to create safe areas for children (eg ".kids.us"). This paper examines the pros and cons of using both gTLDs and secondary level domains, and how and whether these can be effective in practice.

There are essentially two main issues under discussion:

• The creation of a separate space for adult and non-child appropriate material
  (eg .xxx / .sex)
• The creation of a separate space for appropriate material for children (eg .kids)

III.1. Creation of a separate domain for adult material

One reason for creation of an adult domain is to allow parents to have easier control over their children's access to adult material: it would be very easy to use filtering software to block all URLs with a .xxx or .sex address. The main flaw in the proposal concerns the question how much adult material would actually migrate to the new domain and how much would remain outside. Would we ever reach a situation (especially if it remains a voluntary decision of the content providers) whereby most, or all, adult and harmful to children material was located in this domain? The more realistic situation is that the domain would only ever contain a certain amount of adult material and a great deal will remain outside, for a number of reasons:

• Existing sites would probably not want to give up their existing addresses because they are established and well known to their customers.
• There would be a certain stigma or 'marketing message' attached to being in the "adult only" domain which content providers might want to avoid. Also, providers of potentially harmful material who wished to reach children would inevitably remain outside.
• A lot of other potentially harmful material would not come under a .xxx or .sex category and would remain at large, e.g. violent material, intolerant, racist or otherwise objectionable material.

III.2. Creation of a separate space for child appropriate material

In theory, the creation of a separate space for material appropriate for children could be a useful tool in child protection because children could be limited to such a zone. This would in principle be a more effective and comprehensive solution than the establishment of lists of child-appropriate sites or "greenspaces" for children. Any devices to increase child protection on-line are very welcome and should be given careful consideration. However, it is difficult to see how such a solution could work in practice and the risk of creating even more dangers for children, under the guise of protecting them, is very real. The main arguments against the creation of a separate domain for children are as follows:

• The concentration of children's activities in one area could attract paedophiles and set children up as an easy target for predators.
• The creation of a ".kids" domain would not be effective in addressing undesirable content in chat, newsgroups or instant messaging.
• Who sets the standards for content allowed in a child appropriate domain? There are very different views between cultures, religions, nationalities, even from one family to another, about what material is appropriate for children.The criteria for content to qualify for a ".kids" domain would need to be clearly defined by organisations dedicated to children's interests.
• There is a lot of commercial pressure behind the moves to create a separate space for children. Indeed, the four proposals to create a child-appropriate domain which ICANN (the Internet Corporation for Assigned Names and Numbers) received prior to its November 2000 decision on new generic top-level domains (see below) were all commercial in nature. The danger is that a ".kids" domain could become simply a means of marketing more effectively to children.

It is also true that consumer organisations in general view ICANN, which is responsible for allocating and operating generic TLDs, with a certain amount of suspicion. ICANN is heavily influenced by business interests and consumer organisations consider that its operations and work lack transparency. The changes which have been proposed to the ICANN structure, and which are currently under consideration, would make the organisation even less accountable. The Trans Atlantic Consumer Dialogue wrote to the ICANN Committee on evolution and reform on 29 April 2002 stating the following, "At present, ICANN is dominated by business interests, and the ICANN board has blocked the election of board members from the general public. The ICANN Domain Name Supporting Organization (DNSO) is greatly biased toward business interests. Individual or non-commercial domain holders have only three of 21 votes in the DNSO governing body, and may lose voting rights to even those three votes in disputes over DNSO fees."

We would therefore have little confidence in allowing ICANN to establish and manage a generic TLD for children. Furthermore, ICANN has in the past shown itself to be aware of the huge difficulties which would be presented by trying to administer a gTLD for children and ensuring that it remains a safe area. In November 2000 when it approved the creation of seven new generic top-level domains, ICANN considered, and then decided against, the creation of a ".kids" domain on the basis that this could not apply a reasonable standard of protection on a uniform international basis.

The US is currently considering creating a secondary domain under the United States' domain-name suffix (.us) which would be intended as a safe area for children. Congress is discussing a Bill which would create such a domain. The draft legislation includes provisions such as forbidding any website with a ".kids.us" address to contain hyperlinks to locations outside the ".kids.us" domain. The legislation would also prohibit chat and instant messaging features, except in cases where a site operator could guarantee that the features adhere to kid-friendly standards developed for the domain.

However, there has been opposition to such a move, notably by NeuStar, the company which is responsible for operating the ".us" domain and would therefore be responsible for ensuring that websites operating in the ".kids.us" space restricted their content to be suitable for children 12 and under. NeuStar does not believe it is equipped to judge what constitutes appropriate content for children and has called for the legislation to bring in children's advocacy groups to help operate the site. There is also disagreement about the legislative requirements driving the price of ".kids.us" addresses too high and thereby affecting the likely use of the domain. Other opponents of the secondary domain have also raised the question of who will define "appropriate content" and question whether agreement can ever be reached on this matter.  They feel that it should be left to parents to establish what their children can or cannot see.  Questions have also been raised about how to enforce whatever standards are set.

Conclusion

In view of the difficulties that would be presented in trying to establish, manage and police effectively a generic TLD for adult material or for child appropriate material, this, we believe, would not be a viable solution to the protection of children on-line. As regards the possibility of a secondary level domain designed to protect children, research could be conducted to examine whether such an initiative at EU level (creation of a ".kids.eu") could provide a useful tool for keeping children safe when they surf. Obviously lessons can be learnt from the experience gained in the US if a ".kids.us" domain is created. However, if such a secondary level domain should ever be considered at EU level, the following criteria should form part of any such decision. It should also not reduce the pressure for better child protection on the rest of the Internet.

1. The domain should be operated and controlled exclusively by children's groups, educators, those experienced in on-line child safety, and those operating purely in children's interests, with no profit involved.
2. There should be a clear definition of what constitutes "appropriate content", with the focus laid heavily on quality, educational content and material that promotes positive experiences. There should also be specific rules regarding the kind of content which is not allowed (for example that there must be no material that causes moral, mental or physical harm, etc). Responsibility for establishing these definitions should lie with those responsible for operating the domain.
3. There should be a ban on chat and instant messaging in the domain, except where a site operator can guarantee that the standards established for the domain are respected.
4. Websites in the domain must not contain hyperlinks to locations outside the domain.
5. The domain should be very tightly controlled and policed, including real time monitoring and making use of the best filtering and rating systems available. Any websites which infringe the rules should be removed from the domain immediately and severe penalties imposed on the offending party. For serious infringements there should be appropriate law enforcement back-up to clamp down immediately on any activities potentially harmful to children. There should also be an easily accessible procedure for parents and children to make complaints.
6. There should be strict privacy provisions for websites operating in the domain. There should be a ban on the collection of personal data from young children unless prior parental consent has been obtained.
7. Any advertising in the domain should be clearly identifiable as such and separated from content.
8. Website operators in the domain should not encourage, nor indeed permit, young children to contract for the sale or rental of goods and services or for credit without explicit, verifiable parental consent, and should confirm all orders at least by e-mail.
9. Safety guidelines should be displayed prominently. Websites in the domain should be required to provide links to appropriate safety information for children.

Over the last few years, there has been a proliferation of website quality assurance schemes. These schemes can play an important role in protecting consumers, if they are properly run and subject to common criteria to avoid confusing consumers. Consumer organisations across Europe have called for the introduction of a common agreed standard and common criteria for the quality of these schemes. All schemes should have specific criteria to protect children, based on the understanding that they are more vulnerable than adult consumers and need special protection. BEUC and UNICE last year agreed a European framework for such schemes, which is a big step in the right direction. ERICA inputted into the framework during its drafting to improve the requirements in relation to children. However, we would still like to see requirements regarding children go further and would invite the Commission to take the following recommendations into account when deciding how to take the BEUC/UNICE agreement forward.

Furthermore, we would like to see the introduction of a webtrader tag recognisable to filtering schemes. In this way, filtering schemes could allow children (and adults) access to sites which conform to the criteria of the website quality assurance schemes and block their access to sites which do not.

Below we have set out the minimum criteria, designed to protect children, which should be included in all website quality assurance schemes.

IV.1. Protection of children on-line

• Participants must be required to rate and label their sites (eg with the ICRA ratings).
• There should be a general requirement on WQAS participants that they must not cause moral, mental or physical harm to minors, nor encourage children to behave in a way which could jeopardise their health, safety or general welfare, taking into account the age, knowledge and level of maturity of the intended audience.
• They should not encourage minors to enter inappropriate websites or communicate with strangers.
• WQAS should not approve any sites that contain material which incites to hatred on grounds of race, sex, religion or nationality.
• WQAS should provide information about child safety on the Internet, for example by linking to guidelines such as the multi-lingual ERICA guidelines on keeping you child safe on-line guide.htm.
• Producers of violent or other adult material should make it very difficult for minors to access that material, for example, by use of payment systems such as credit cards which require an adult holder. Furthermore, there should be no free down loads of such material.
• If participants breach any of the criteria relating to children, the WQAS approval should be withdrawn and they should be placed on a negative list under the WQAS, together with reasons why until they have resolved the situation.

IV.2. Protection of children in electronic commerce

• Code subscribers should not permit young children to contract for the sale or rental of goods and services or for credit.
• Advertising or other forms of marketing directed at children must be clearly marked as such.
• Code subscribers should not encourage minors to persuade their parents or others to purchase the goods or services being advertised.
• They should not encourage minors to buy a product or service by exploiting their inexperience, sense of loyalty, credulity or the special trust that minors place in parents, teacher or other persons.
• They should not charge minors through premium phone lines.
• Code subscribers must ensure that they provide the same level of consumer protection for children in on-line marketing as they do in traditional marketing.
• Traders must not encourage children to give out personal information, nor should they collect personal information from children. Any order which requires any personal information should be referred to their parents.
• Because of the impulsive nature of children and of Internet buying, and for consumer protection generally, traders should confirm an order at least by e-mail. There should also be a requirement for explicit and verifiable parental confirmation for children under a certain age (electronic signatures will help).
• No cigarette or tobacco advertising should be permitted (there may be a company in the scheme which also sells tobacco). There must be rating of alcohol advertising to exclude under 16s and such advertising must comply with national codes and legislation.

Last year the European Commission launched its Green Paper on Consumer Protection, which includes the area of electronic commerce. More recently, it has published a follow-up to the Green Paper. The Commission recognises that children are a particularly vulnerable group that needs separate consideration. Any further policy or rules that arise from this process should take account of the requirements set out above. See ERICA's paper for further comments on the Green Paper⁴.

1. Regarding harmful, but not illegal, content, there should be a 'notice and take-down' policy combined with more effective use of labelling and filtering schemes. A standards body would receive complaints about sites, and, if it ruled in their favour, would ask ISPs and search engines to remove access in the same way that complaints against offensive advertising are dealt with in some member states. ISPs should themselves automatically operate a notice and take down policy based on a consumer complaint systems.
2. There should be a general duty on ISPs to protect children, which would provide the necessary legal background for them to apply the various array of codes and schemes that exist only on a voluntary basis and have failed therefore to attract a critical mass.
3. Internet content providers should rate and label their material and those that do not should be penalised. In particular, ISPs should insist that content providers rate their sites. The EU should make a sustained and public effort to have all content providers label their material, as a minimum to the ICRA standard. Those who do not rate their material should be frozen out of the market because they will not be picked up by filtering systems. Consumer organisations can help by rating their own sites and encouraging all Internet using businesses to do the same. In particular the consumer organisation's webtrader schemes should require all participants to rate their sites. This should also be a requirement of all website quality assurance schemes. Furthermore, WQAS should introduce a "webtrader tag" recognisable to filtering schemes.
4. The EU and member states should place greater emphasis on encouraging the development of filtering and rating systems and the improvement of existing systems, especially to block violence. The consumer tests show that there are still substantial flaws in many of the systems currently available to protect children on-line.
5. All Internet ready computers going into homes, schools or public libraries or anywhere that children regularly gather to use computers, should be sold with child-safety software pre-installed and set by default to a high level of security which the consumer can reduce or uninstall. Internet ready computers should be sold with easy-to-understand point of sale material explaining the basics of on-line safety and of filtering and rating. A cheap and easy opportunity to adopt such systems needs to be offered to owners of older computers.
6. ISPs should provide safety guidelines to parents and children on their home pages, similar to the ERICA guidelines on keeping your child safe on-line guide.htm.
7. Whilst recognizing the nature of the modern family, parents need to supervise their children's surfing when they can. In particular, they need to be helped to understand the technical options available to protect children from both harmful material and stalking.
8. There is an overwhelming case for broadcaster/ISP responsibility to support parents and protect those children whose parents are unable to do so. Except for those few ISPs specialising in an adult membership, ISPs should advertise child-friendly search engines and signpost areas especially for children. Positive sites on the Internet that reflect the EU commitment to public service broadcasting should be actively encouraged. Content providers should also be aware that children are generally alone when they use the net and to show broadcaster responsibility.
9. There needs to be greater priority on creating protected quality areas for younger children (walled gardens), where they can surf safely and confidently. ISPs that allow children onto their networks and give access to Internet chat rooms should also provide, and promote the availability of, moderated chat aimed specifically at children. Chat safety messages should be prominently displayed close to, or in, chat areas, and mechanisms should exist which would allow suspicious behaviour towards children to be noted, reported and dealt with very rapidly.
10. Current ISP procedures should be reviewed to include wherever possible the recording and storing of chat-room conversations, as is already the practice with premium-rate telephone services, linked to the given identities of the participants. Costs can be kept low by using compression software to increase capacity/ storage space.
11. An extension of the EU definition of illegal content should be considered to cover material which incites to hatred on grounds of race, sex, religion or nationality
12. Producers of violent and other adult material should make it very difficult for minors to access that material, for example, by use of payment systems such as credit cards which require an adult holder.
13. We do not support the creation of a gTLD for adult material, nor for child appropriate material, as this could create more dangers for children on-line. However, the creation of a secondary domain as a safe haven for children under the ".eu" top level domain (eg".kids.eu") could be researched as a possible useful tool for protecting children on the Internet.

Acknowledgements

The CISA partners would like to thank the Consumers in Europe Group and the National Consumer Council for giving financial support for this policy paper, as well as the European Commission for co-financing the project under the Internet Action Plan.

¹ The other partners in the project are Test Achats (Belgium), EAC (Italy), EDOCUSA (Spain), EDIDECO (Portugal), EKATO (Greece), INC (France) and AFMK/Landesakademie (Austria).

² Survey on Children's use of the Internet, November 2001, http://net-consumers.org/erica/pr.htm

³ NCC report Models of self-regulation: An overview of models in business and the professions October 1999

⁴ policy/consumers.htm

⁵ See Test-Achats magazine, no. 452, March 2002