The Hotline: Introduction
In 1997, the Department of Justice, Equality and Law Reform established the Working Group on the Illegal and Harmful Use of the Internet and it presented its report in July 1998. The Working Group recommended a self-regulatory regime. The Internet Service Providers' Association of Ireland established a Code of Practice and Ethics on which the self-regulatory regime for the Internet industry in Ireland is based.
The www.hotline.ie service was established in November 1999 and is run by the ISPAI under strict guidelines recommended by the Working Group on the Illegal and Harmful Use of the Internet.
The Hotline exists to receive reports from the public about potentially illegal material, so it may be assessed and, if considered to be probably illegal, to instigate its removal from the Internet. The Hotline can not engage in pre-emptive searching for illegal material, it can only react to reports from the public.
When the Hotline receives a report it follows a procedure which has been agreed with the Internet Advisory Board, An Garda Síochána and with the Internet Service Providers.
The www.hotline.ie service provides a secure and confidential environment where the public can anonymously report such content encountered on the Internet using one of the following methods:
- preferably via the secure website at https://www.hotline.ie
- via email to report@hotline.ie
- via "lo-call" phone service: 1890 610 710
- via "lo-call" fax service: 1890 520 720
- via post to: Unit 24, Sandyford Office Park, Sandyford, Dublin 18, Ireland
Structure
The Hotline is run as a service of the Internet Service Providers' Association of Ireland (ISPAI), a not-for-profit limited company, established by Internet Service Providers operating in the Republic of Ireland. The ISPAI is completely funded by the industry on a cost-sharing basis. A General Manager, who is an employee of the ISPAI, manages the administrative, financial and operational functions of the Hotline. The Hotline General Manager reports to the ISPAI Board of Directors.
The Internet Advisory Board, established in February 2000 by the Department of Justice, Equality and Law Reform, monitors the effectiveness of self-regulation of the Internet Service Provider industry on behalf of Government and specifically oversees and approves the operational procedures of the Hotline.
Members of the Board include representatives of the Internet service providers, An Garda Síochána, Internet users, Government, the Information Society Commission, education and child protection bodies, a legal advisor and the General Manager of the Hotline. Over the 30 month reporting period the Internet Advisory Board (IAB) has been closely involved with the development of Hotline procedures to cope with the evolving Internet environment.
Through its continued support and promotion by the IAB, the Hotline has become increasingly used by the public, as can be seen in the Analysis section [link]. The Hotline is recognised as the established service in the country to combat illegal content on the Internet.
The Hotline is very grateful for the support of the Government and An Garda Síochána who promote the Hotline through their websites and within the Garda pages in the National telephone directories.
The Hotline would not exist without the commitment of the ISPAI members. These are ISPs providing public Internet services in Ireland who take the interests of their customers and Internet safety seriously by financially supporting the Hotline.
At the time of writing there were 21 members: BT, eircom, O2, Vodafone, HEAnet, Irish Broadband, UTV-Internet, Irish Domains, Meteor, Verizon Business, NTL, Smart Telecom, EuroKom, Novara I.T., Clearwire, Blacknight, Strencom, Protocol, ICE Comms, Bitbuzz and Newbay.
The Internet Service Providers' Association of Ireland provides funding for the Hotline with the assistance of the European Commission.
External Relations
The usefulness of the Hotline would be extremely limited if it could only deal with Internet content hosted or distributed from within the Irish jurisdiction. The Hotline addresses the issue of responding to reported content that is outside the Irish jurisdiction, through two means:
1) Membership of the INHOPE Association (www.inhope.org) and,
2) An Garda Síochána contacts who liase with International police organisations such as Interpol and Europol.
INHOPE Association
The www.hotline.ie service is a founding member of the INHOPE Association (INternet HOtline Providers). INHOPE's mission is to facilitate and co-ordinate the work of Hotlines in responding to illegal use and content on the Internet. It facilitates good working relationships between hotlines and the exchange of reports by ensuring trust built on a rigorous hotline approval process.
Membership of INHOPE is vital to the Hotline's effectiveness by providing a cooperating network of trusted International partners. This is a two way process and the Hotline has also been highly involved in INHOPE's development. INHOPE interfaces with Hotlines around the World to build an increasing co-operative network. Expertise is shared through regular INHOPE meetings, where training sessions on specific aspects of the Hotline work are run and working sessions develop best practices for the operation of Internet hotlines and tracing of illegal content.
An Garda Síochána
The Hotline provides assistance to An Garda Síochána by filtering reports to determine what is probably illegal and is also located in Ireland or has an Irish dimension. This assists the Gardaí to dedicate their specialist resources to pursuing investigations within the jurisdiction by not having to deal with the majority of reports that do not contain illegal content or relate to material held in other jurisdictions.
European Commission
The Safer Internet Programme of the European Commission (EC) has been instrumental in developing the Hotline network in Europe. The www.hotline.ie service has benefited from project funding since this programme was initiated in 2000. In late 2003 the Hotline was successful in attracting continued European Commission funding, providing 50% of eligible operating costs, under the last SIAP (Safer Internet Action Plan) call for proposals. This funding ran from 1st March 2004 through to the end of this reporting period. It ends on the 28th February 2006. In the latter part of the reporting period the EC launched the SIAP+ call for proposals and ISPAI has applied for project funding for a further two years.
Work of The Hotline
The Hotline's operational process starts when a submission is received from the public or from another international hotline. The submissions are generated through electronic forms that are available on the www.hotline.ie web site, reports can be submitted completely anonymously. The "Report Online" facility on the website is the preferred method for the hotline to receive reports, alternatively reports can be sent by email, telephone, fax or letter.
When a submission is received, the Hotline will send an acknowledgement where contact information has been given. The preference is to provide this reply by e-mail.
A single submission may contain a complaint about a single item or multiple items encountered on the Internet. A report record is opened in the Hotline database for each item (or related set of items) cited in the submission.
Under the legal system in this country, only a court of law can determine that a criminal offence has been committed and that material (i.e. child pornography) relating to that offence is actually illegal. Therefore, the Hotline can only determine that something is "probably illegal" with reference to the criteria given in the Irish Child Trafficking and Pornography Act (1998). Hence this term is used throughout the report. In the case of other types of content, the criteria defined in relevant Irish laws are applied.
Once the report has been logged, a trained member of the Hotline staff will try to find the material on the Internet. Taking as an example a report of suspected child pornography, if the subject of the report is found, it will be assessed as to whether it is probably illegal under Irish law.
If it is not illegal, no further investigatory action is taken. If the content is considered to be probably illegal under this act, the next step is to determine the location of the material as accurately as possible. The Hotline staff use a suite of tools and their experience to attempt to trace and locate the source, be it a web host server, e-mail server or other Internet based service.
If the reported material is traced to a hosting service or server located in Ireland, or is found to have originated from an Internet user account provided by an Irish ISP, the ISP managing that customer is identified. The Hotline then issues notification to An Garda Síochána and simultaneously a "take down" notice is issued to the ISP, where they are a member of the ISPAI. The ISP is responsible for the timely removal of the specified probably illegal content from their servers to ensure that other Internet users cannot access the material. The decision to initiate a criminal investigation is a matter for An Garda Síochána.
If the material is located on a server in a country where there is an INHOPE hotline, then details based on the original report, including the Hotline's findings, are forwarded to the other hotline for processing.
If the material is located in a country having no INHOPE presence, the Hotline will attempt to have action taken by providing details to An Garda Síochána for transmission to the source country through international law enforcement channels.
Once this notification procedure is completed, the Hotline records the action that was taken in the database and closes the report.
Activities
In the reporting period The Hotline hired two part-time Analysts to deal with the increased levels of reporting, greater interaction with stakeholders and support of additional events to promote the Hotline to the public.
The confidentiality of the public making reports is of paramount importance to the Hotline. The Hotline has applied considerable resources to improving the security and usability of its reporting process. The reporting forms were redesigned and the security technology behind them improved. The Hotline database does not record any data about the originator of anonymous reports. Personal information when provided is erased within 90 days of their report being closed. Notices and information relevant to Internet safety are regularly updated on the Hotline's home page. The Hotline website was also transferred to a new hosting service provided by Blacknight Internet Services.
In the second half of 2004 a new phenomenon appeared on illegal web-sites to disrupt the systems of organisations combating child pornography. This required that the Hotline service completely redesign the systems used to access and trace the servers hosting illegal content.
The Hotline General Manager was elected INHOPE Treasurer for 2004/2005. The Hotline developed an application internally to record report processing and extract statistical information such as that presented in this report. This has now been licensed to INHOPE to provide to members around the World and will expedite the start-up of operations in new Hotlines.
The Hotline has run events to promote understanding of The issues and the importance of making reports to combat the prevalence of illegal content on the Internet. Seminars have been run for ISPs, An Garda Síochána, commercial associations and concerned parents. It is vital that all relevant agencies work together to promote Internet safety and protect children using the Internet. The Hotline has provided support and speakers for events run by child welfare organisations, industry associations and educational organisations. The Hotline has also provided training to staff of other INHOPE member hotlines and hosted fact finding missions from foreign law enforcement and government representatives.
