Singleton Park Swansea West Glamorgan SA2 8PP Phone: 08454786390 Email: jonathan.bishop@glamorgan.coop Saturday 18 August 2012 Dear Geraint Davies, Firstly, thank you for communicating on my behalf with regards to the Defamation Bill. I am writing to you as the lead researcher at the Centre for Research into Online Communities and ELearning Systems at Swansea University, and director of Jonathan Bishop Limited, based in Swansea also. I am writing to you now about my views on the Online Safety Bill. I would first like to say that is is badly written. It proposes to give OfCom new powers, without amending the Communications Act 2003 (Section 4); It also proposes new rules on pornography (section 1), but doesn't amend the Obscene Publications Act. If it is not an amending Act it will make it difficult for those in the IT law like myself to easily refer to the provisions. With regards to Sections 2 and 3, I regard these to fall within Article 34 of the EU Treaty as a measure having equivalent effect of inhibiting cross border trade. I believe they fall outside the 'rule of reason' for 'consumer protection' or 'public health'. Even if it did not apply to other EU countries it would put UK technology firms, like mine at a disadvantage, and could put us in a position where we would have to breach Article 101 of the EU Treaty by entering into exclusive distribution agreements in order to meet the obligations. I would say that Section 2 on filtering is best dealt with through anti-virus software. I for instance use Kaspersky and this blocks out all the undesirable content referred to in the Bill. It should be public choice as to which service the public use and not force manufactures to tie software to their systems, which was found illegal in Commission v Microsoft in the case of firms falling within Article 106 of the EU Treaty. Equally Section 3 would pose an unfair burden on technology firms like mine. I think this also falls within Article 34 and outside the rule of reason and is disproportionate to what is trying to be achieved. I run a website called the Trolling Academy, which provides a directory of all the online safety websites that people can access: http://www.trollingacademy.org/category/learning-resources/the-trolling-guide-and-unwritten-manual/ http://www.trollingacademy.org/how-we-can-help/ It should not be for legislation to create a nanny state that undermines the work of the independent charities in this area, who can offer support beyond a 'Help' page provided by a technology firm. It would also be more bureaucracy and red tape that the Government promised would not be levied on SMEs like my technology firm.
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