Communication from the Commission to the Council, the European Parliament, the Economic and Social Committee and the Committee of the Regions - Intermediate evaluation of the implementation of the multiannual Community action plan on promoting safer use of the Internet by combating illegal and harmful content on global networks
Date: 2001-11-23
Institutions: European Commission
Subjects: Internet, action programme, child protection, information technology, technical regulations

COMMISSION OF THE EUROPEAN COMMUNITIES

Brussels, 23.11.2001
COM(2001) 690 final

COMMUNICATION FROM THE COMMISSION
TO THE COUNCIL, THE EUROPEAN PARLIAMENT,
THE ECONOMIC AND SOCIAL COMMITTEE
AND THE COMMITTEE OF THE REGIONS

Intermediate evaluation
of the implementation of the multiannual Community action plan on promoting
safer use of the Internet by combating illegal and harmful content on global networks

1.

INTRODUCTION

This Communication concerns the intermediate evaluation of the multiannual Safer
Internet Action Plan. The evaluation was carried out by a company1 contracted on
the basis of an open call for tenders issued by DG Information Society in the
summer of 2000. The evaluation was carried out during the period November 2000
to April 2001. The executive summary of the evaluation report2 is annexed to this
Communication.

2.

BACKGROUND

The aim of the Safer Internet Action Plan (henceforth the Action Plan) is to ensure
the implementation of the various European Union initiatives on how to deal with
undesirable content on the Internet. To this end, the Action Plan has been designed to
support a range of non-regulatory measures. The Action Plan's objectives, specified
in its European Parliament and Council Decision3, are to:

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incite the actors (industry, users) to develop and implement adequate systems
of self-regulation;

pump-prime developments by supporting demonstrations and stimulating the
application of technical solutions;

alert and inform parents and teachers,
associations;

in particular through their relevant

foster cooperation and the exchange of experiences and best practices;

promote coordination across Europe and between the actors concerned;

ensure compatibility between the approach taken in Europe and elsewhere.

The Action Plan covers a period of
31 December 2002 with a budget of 25 million euro. The Action Lines are:

four years from 1 January 1999 to

(1)

(2)

Promotion of self-regulation4 and a European network of hotlines5 to achieve
a high level of protection (especially dealing with content such as child
pornography, racism or anti-Semitism).

Demonstration and application of effective filtering services and compatible
rating systems that empower users and take account of cultural and linguistic
diversity.

1

2

3

4

5

Business Development Research Consultants Limited.
Intermediate Evaluation of the Internet Action Plan: Final Report, May 2001, Business Development
Research Consultants Ltd,
http://europa.eu.int/information_society/programmes/evaluation/index_en.htm#iap.
Preamble to Annex I of Decision 276/1999/EC of 25 January 1999 (OJ L 33, 6.2.1999, p. 1).
Via advice (rather than financial support) to self-regulatory bodies.
A hotline is a centre allowing users to report content that they come across in the course of using the
Internet which they consider to be illegal.

2

(3)

Promotion of awareness actions directed at users,
in particular children,
parents and teachers, to allow them to use Internet resources safely and with
confidence.

The main mechanism for implementing the Action Plan is the co-financing of
projects selected on the basis of public calls for proposals. As of 1 April 2001,
19 projects were running involving 87 organisations. Five projects are hotlines
(covering a total of 12 hotlines spanning 10 countries), five are in the field of
filtering and rating, and nine are awareness projects. The total funding of all cost-
shared projects under the 1999 and 2000 budgets is 10 030 119 euro. The average
amount of funding per project is 501 506 euro (smallest 49 650, largest 1 931 303).
The average amount of Community funding received by the 87 participating
organisations is 115 289 euro.

3.

EVALUATION OBJECTIVES

The Safer Internet Action Plan evaluation assessed the relevance of the Action Plan's
objectives, priorities and means of implementation in the light of regulatory,
technological and market developments; the effectiveness of the programme's theory
of action (intervention logic); the efficiency of the Action Plan's organisation and
management; and issues related to complementarity and sustainability. The
evaluators took into account the recent evaluation6 of the measures taken to protect
minors and human dignity foreseen by the recommendation adopted by the Council7
on this issue.

4.

EVALUATION FINDINGS

The evaluators found that the Action Plan has been successfully implemented. The
focus of its Action Lines is still highly relevant, though arrangements should be
made to track legal and regulatory developments and to monitor and assess changes
in technologies and markets. The majority of projects would not have commenced
without Action Plan funding. The report stresses that it is important for future work
to take account of newly emerging channels of access to the Internet8 and new means
of interaction between Internet users9, and to continue to cover areas of content
besides child pornography in a balanced manner.

The evaluators determined that the Action Plan has been very effective in generating
projects, though there is potential for duplication of effort within the Action Line on
awareness, and a number of participants had stated that finding suitable international
partners had proved quite difficult. The report notes the need for reflection on the
likely sustainability of the effects of projects after Community funding ceases.

6

7

8

9

COM(2001) 106, 27.2.2001.
Adopted on 24.09.1998: OJ L 270, 7.10.98, p. 48.
For example, personal digital assistants (PDAs) using third-generation mobile telephony (3G).
Such as chat-rooms and instant messaging services.

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The evaluators found that problems so far encountered during the Action's
implementation were relatively minor: there were some delays in awarding contracts,
and the application forms had been found to be too complex by some participants.
The evaluators also found that more could be done to raise the profile of both
individual projects and the Action Plan as a whole.

5.

RECOMMENDATIONS AND COMMISSION COMMENTS

The evaluation report contains fifteen recommendations10:

Content and coverage

(1)

The broad division into three main action lines in the current IAP (Hotlines &
Self-Regulation, Awareness, and Rating & Filtering) should be retained in
any future Action.

Comment: This is an important conclusion, which the Commission will bear in mind
when preparing any proposal for a follow-on to the Action Plan.

(2)

The action lines should be extended to cope with the impact of new
technology.

Comment: A workshop entitled "Safer use of new interactive technologies" was held
on 11-12 June 2001 specifically to deal with this issue. The results of the workshop
will also be fed into the decision-making process on a possible successor action plan.
Filtering projects selected under the 2001 call for proposals and projects selected
under the 2002 call will be encouraged to take account of new technology.

(3)

The Action Plan should ensure a balanced scope in terms of content
categories handled.

Comment: The Action Plan does offer scope to cover a range of issues (such as
racism and xenophobia) mentioned by those interviewed as requiring attention. The
existing calls for proposals allow projects covering such issues to be submitted, and
the forthcoming 2002 call will be so worded as to make this clear also.

Implementation

(4)

The application procedures should use simpler forms.

Comment: Work is underway to simplify the forms by concentrating on the essential
points and giving clear and brief explanations of how to complete them.

(5)

Delays between project approval and contract signing should be reduced.

Comment: Progress already made in this direction will be reinforced by:

(a)

simplifying the forms by concentrating on the essential points and
giving clear and brief explanations of how to complete them;

10

See the attached executive summary and pp. 54 et seq. of volume one of the evaluation report.

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(b)

(c)

re-designing the forms to reduce the number of errors made in
completing them;

identifying as early as possible likely areas of difficulty at contract
negotiation (in particular financial viability) and offering advice on
possible solutions.

Achieving the objective does, however, also require the project partners to contribute
by filling out the resulting forms accurately and supplying supporting documentation
promptly.

(6)

Assistance from the Action Plan with partner
considered.

identification should be

Comment: More prominence will be give to the existing online partner search
mechanism in conjunction with the work on programme visibility (see response to
Recommendation 14, below).

(7)

Efforts should be made to increase the consistency of advice provided by the
Action Plan to projects in relation to the financial application forms.

Comment: The main difficulty has been with advising partners on how to meet the
financial viability test where their financial net worth was insufficient to cover their
cost share, and the extent to which co-ordination tasks could be subcontracted. This
was under review within the Commission during the first project negotiations. It is
now clearer what advice can be given, and the advice which projects receive should
therefore be consistent throughout the process. The Commission makes a particular
effort at each stage to give information so that organisations are aware of the rules.

(8)

Projects should ensure adequate resource is given to media and press
coverage, and visibility.

Comment: This is an important point and is linked to the Commission services'
efforts on programme visibility (see response to Recommendation 14, below). The
Commission services will give advice to projects on how best to attract media
attention.

(9)

The Action should review efforts to support project sustainability.

Comment: The Commission is keen to ensure that projects that are supported
continue to produce effects once funding ceases. The Commission will see if there
are any steps that it can take to encourage this process.

(10)

The Action should consider ways to manage the potential overlap between
awareness projects.

Comment: Projects have been asked to include work packages on collaboration with
other projects and also have to report back to the Commission services regularly.
Projects were informed as soon as they were selected of the existence of other
awareness projects, and encouraged to contact them to discuss possible collaboration.
These contacts were reinforced by a meeting in January 2001 attended by all the
awareness projects. The Safer Internet Awareness Exchange has been specifically
designed to assist the awareness projects and others interested in safer Internet

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awareness-raising. This offers a degree of flexibility in organising both face-to-face
and online meetings and the use of the web and electronic mail to share information
and awareness resources, exchange experience, share good practice and publicise
project results and news items. The need to avoid overlap will be given particular
attention under the 2002 call for proposals.

(11)

Projects funded under the Action should be structured in such a way as to
allow the formal measures of success to be evaluated.

Comment: The Commission will ensure that wherever possible the work programmes
of projects include specific measurable targets and that project deliverables are
clearly defined. It will require that periodic management reports by contractors give
information on the achievement of targets (and reasons for failure to achieve them, if
that is the case). The Commission will ask for project reviews carried out by external
experts to include specific comments on the quality of information supplied under
this heading and the conclusions to be drawn from that information (or lack of
information).

Regulatory, technological and market trends

(12)

(13)

The Action Plan should consider putting into place formal arrangements to
track legal and regulatory developments.

The Action Plan should consider putting into place formal arrangements to
monitor and evaluate technological and market developments.

Comment on 12. and 13.: Tracking of relevant legal and regulatory developments has
been put in place in the context of support for self-regulation. Relevant technological
and market developments and their socio-economic impact on safer use of the
Internet will be reviewed through reports, forums or workshops.

Wider issues

(14)

The Action Plan needs to have a higher profile and gain wider awareness
itself.

Comment: Work is underway to increase the visibility of the Action Plan. The
Commission services have targeted relevant conferences to seek speaking slots and
to distribute documentation. A new website11 has been launched to make activities in
the field more accessible, and a leaflet published in 11 languages. A list of journalists
specifically interested in the Commission’s activities in the fields of the Information
Society and in safer Internet issues has been drawn up in collaboration with the
Commission’s Spokesperson’s service.

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http://www.saferinternet.org.

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(15)

The Action Plan should consider more links to activities and organisations
outside the EU.

Comment: A particular effort will be made to set up such links on a reciprocal or
multilateral basis, and to include expertise from outside the European Union in the
reports, forums or workshops mentioned in the comment on 12 and 13 above. The
Action Plan's legal base specifically mandates the Commission to ensure that the
international nature of the Internet is taken into account. The Commission has closely
followed developments in other parts of the world, and has both organised and
attended a number of important meetings with European and worldwide coverage.
The Commission is also taking part in the negotiations for the Council of Europe's
convention on cybercrime. Certain projects already have an international component
and a network of links outside Europe.

6.

CONCLUSION

The Commission takes full note of the findings and recommendations of the
intermediate evaluation of the Safer Internet Action Plan. In the light of the
Commission's responses to the evaluators' report, it invites the European Parliament,
the Council, the Economic and Social Committee and the Committee of the Regions
to:

(1)

(2)

(3)

(4)

take note that
implemented so far;

the Safer

Internet Action Plan has been successfully

support the Commission in its drive to simplify administrative procedures,
enhance the effectiveness of projects, increase dissemination of project results
and stimulate public debate on safer Internet issues;

assist the Commission in its work of increasing the visibility of the Action
Plan;

support the Commission in its activities to consult all interested parties and to
examine possible follow-on activities,
to deal with new
technologies and new categories of digital content and to examine the scope
for broader coverage of issues affecting safer use of the Internet.

in particular

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ANNEX

Executive Summary

This document is the final report of the intermediate evaluation of the Safer Internet Action
Plan (IAP). The analysis, conclusions and recommendations are based on information
gathered from IAP source documents, telephone and face-to-face interviews conducted with
Commission experts, project participants and stakeholders, and documentary research in the
legal, regulatory and technology fields. These conclusions are discussed in greater detail in
section 10.

• Taking into consideration the views of participants and stakeholders, it is apparent that all
three action lines are still highly relevant to the aims of the IAP and thought to be very
worthwhile.

• Rating and filtering is an emerging technological area, and it is important that future
projects take into account the fact that they should work in the context of new channels
of access (e.g. the ability to have full internet access from 3G PDAs).

• There is a clear priority to focus on protecting children,

in the form of child
pornography. However, participants and stakeholders alike take the view that other areas
of content are also very important and should also retain a high profile in the work of the
IAP.

• Implementation of the objectives of the IAP is manifest in the application and selection
procedures, and the ongoing support provided to successful projects. In as much as a range
of projects have successfully applied for funding, this demonstrates that implementation is
working.

• However, feedback from participants does indicate that the implementation could be
made easier and more ‘user friendly’, with the result that the process would become
faster and less ‘bureaucratic’.

• It is also true that the delays noted by participants in the contract process do have a

significant impact on them in financial and staffing terms.

• The implementation of the action plan has also been hindered by project participants
receiving conflicting information from the IAP in response to queries arising from the
application and financial forms.

• Yet all participants praise the IAP for its responsiveness and support.

• Based on our discussions with participants and stakeholders, the Action is currently very

effective in generating working projects in all three action lines.

• However, it is apparent from questions relating to awareness about the IAP that there
could be more done to raise the profile of the Action Plan as a whole, and thereby raise
interest and enquiries from additional potential projects.

• It was noted during the research process that there is potential for significant duplication of

effort by projects within the Awareness action line.

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• A number of participants noted that finding partners who were acceptable to the IAP
was quite difficult. And the delays incurred through the loss of a partner during the
application process can have a significant effect on the success of a project.

• It is clearly desirable for projects to have a sustained impact and operation after funding
has ceased. In this respect, project participants representing a majority of projects stated
that their work was unlikely to have commenced without IAP funding. In this respect,
there is a direct causal
link between funding being provided, and project work
commencing.

• There is considerable impetus towards the harmonisation both of substantive and
procedural law in relation to all forms of cybercrime, including those relating to harmful
content. The main locus has been the Council of Europe Cybercrime Convention, but there
have also been activities at G8.

• The main problems regarding harmonisation have centred around law enforcement wishes
in relation to data interception and retention capabilities and how these interact with the
European Convention on Human Rights and Data Protection legislation. In fact, the more
gradual approach by the Commission and the Council’s framework decision of May 2000
may actually bring more rapid results.

• Throughout the Community there is a desire that ISPs and telecommunications companies
continue to roll out very low cost or “free” services and “always on” broadband services.
To an extent, the pressures on ISPs and others to keep tariffs low may make it difficult
for them to take on the financial burden of such desirable policies and content
filtering and moderation of chat rooms.

• Chat rooms and Instant Messaging Services have both grown extensively in popularity
since the IAP started; Chat rooms in particular give concern because of the potential for
participants to take on wholly false identities; in both cases self-regulation and law
enforcement measures, although possible may be quite limited, which means that
there may need to be a greater emphasis on education and awareness actions.

• The Report also looks at certain emerging technologies such as peer-to-peer, WAP,
I-Mode, Interactive TV and 3G. None of these are thought to have an immediate effect on
the second half of the current IAP, though the Action will need to continue to monitor
events.

Based on these conclusions the evaluators have made the following recommendations. These
recommendations are discussed in greater detail in section 11.

Action Lines

(1)

(2)

(3)

The broad division into three main action lines in the current IAP (Hotlines &
Self-Regulation, Awareness, and Rating & Filtering) should be retained in
any future Action.

The action lines should be extended to cope with the impact of new
technology.

The IAP should ensure a balanced scope in terms of content categories
handled.

9

Implementation

(4)

(5)

(6)

(7)

(8)

The application procedures should use simpler forms.

Delays between project approval and contract signing should be reduced.

Assistance from the IAP with partner identification should be considered.

Efforts should be made to increase the consistency of advice provided by the
IAP to projects in relation to the financial application forms.

Projects should ensure adequate resource is given to media and press
coverage, and visibility.

(9)

The IAP should review efforts to support project sustainability.

(10)

(11)

The IAP should consider ways to manage the potential overlap between
awareness projects.

Projects funded under the Action Plan should be structured in such a way as
to allow the formal measures of success to be evaluated.

Trends in Law and Technology

(12)

(13)

The IAP should consider putting in place formal arrangements to track legal
and regulatory developments.

The IAP should consider putting in place formal arrangements to monitor and
evaluate technological and market developments.

Wider Issues

(14)

The IAP needs to have a higher profile and gain wider awareness itself.

(15)

The IAP should consider more links to activities and organisations outside the
EU.

10