These questions were received from ISPs potentially interested in
participating in the ISP live Pilot to be completed in the first half
of 2009.
Click on the question or scroll down to view the answer to each question.
1. If this Pilot is run as a voluntary opt in service for the
Pilot, how can we guarantee numbers in the timeline you are
requesting?
2. Considering that many vendors are not willing to hold exchange
rate or quotes for extended time, is it expected that we provide a set
quote?
3. For capital expenditure, are the funds available prior to
commencement of the trial?
4. Can an ISP participate without the involvement of actual
customer accounts? For example, would it be possible to only provide
Enex TestLab with filtered and unfiltered test accounts?
5. We understand that the cornerstone of any live internet
filtering trial should be the testing of network degradation and the
ability of a solution to scale. While the current framework allows for
speed degradation testing for a single user or a small group of
filtered users, how is it proposed to measure performance and network
degradation over an entire customer base?
6. Is it the Department's plan to extrapolate performance results
from a very small group of users to a base of several million? If so,
what sort of methodology is planned to perform such an extrapolation?
7. We understand Enex Test Lab has conducted tests for DBCDE on the
alleged extent of over-blocking using IP addresses rather than URLs.
Is the Department prepared to release these findings and the related
methodology?
8. How will complaints from websites claiming they have been
inappropriately blocked (i.e. over-blocking) be managed and by whom?
9. The Pilot includes the assessment of end users' filtering
experience. This will involve a survey of a sample of ISP customers
following their consent. Please elaborate on the form of this survey
and what correspondence/interaction there will be between Enex and ISP
customers. Also, will ISPs get the opportunity to approve this
correspondence?
10. Would ACMA be providing the survey/questionnaire, the draft
seems to indicate we will draw up a survey?
11. We can guarantee delivery of the survey to the participating
customers, however we cannot guarantee the numbers of completed
surveys returned. Therefore, is the funding in anyway tied to numbers
of completed customer surveys returned?
12. Is the Commonwealth prepared to offer a statutory 'safe harbour'
protection or contractual indemnity to participant ISPs who might
otherwise be exposed to litigation risk (including from any over
blocking or wrongful blacklisting)?
13. What assurance can DBCDE provide as to the confidentiality of
commercially sensitive information or customer information ISPs might
provide as part of the Pilot?
14. What are the requirements around security and confidentiality of
the ACMA blacklist?
15. Is the ACMA blacklist in a form that potentially could expose
ISP staff to websites containing child abuse or other illegal content?
If so, what safeguards will be put in place?
16. Will we be able to see the blacklist prior to committing to the Pilot?
17. Does the requirement for prior Departmental approval of
marketing/publicity activities of participants related to the Pilot
also relate to ad hoc media inquiries? Also what will this requirement
involve?
18. Will DBCDE share trial outcomes with participants and consult on
draft conclusions flowing from the Pilot prior to their public
release?
19. At a minimum, a Pilot ISP is to implement the ACMA blacklist,
which is a list of approximately 1300 specific URLs?
20. At a minimum, as part of the Pilot, the only protocol to filter
is web traffic that is exclusively HTTP over TCP port 80?
21. A successful Pilot ISP will receive a copy of the ACMA
blacklist, where the means of implementing the filter is entirely up
to the ISP? It is understood that receipt of the blacklist will
require both successfully joining the Pilot program, and the signing
of some form of confidentiality agreement with the ACMA?
22. At a minimum, is the Department interested in understanding the
impact on internet services that are both filtered and not
filtered...(see more)
23. What is the expected behaviour of an internet service that
attempts to reach blocked content...(see more)
1. If this Pilot is run as a voluntary opt in service for the Pilot,
how can we guarantee numbers in the timeline you are requesting?
The timeline outlined in the Request for Expression of Interest is
indicative and is provided to ISPs to assist them in their decision
making. The Department will discuss with individual ISPs their
requirements, including the timelines needed to participate in the
Pilot. The Department is happy to discuss with ISPs how they propose
to engage their customers in the Pilot.
2. Considering that many vendors are not willing to hold exchange rate
or quotes for extended time, is it expected that we provide a set
quote?
To assist the Department in managing the costs associated with this
Pilot, it is preferable that applicants note in their Application Form
the period for which quotes are valid. Details of any financial
assistance provided will be discussed with ISPs. As noted in the
Request for Expression of Interest, funding is limited.
3. For capital expenditure, are the funds available prior to
commencement of the trial?
The Expression of Interest document outlines the acquittal and payment
process for grants funding. The Department will issue grants payments
no later than 30 days from receipt of a correctly rendered invoice.
4. Can an ISP participate without the involvement of actual customer
accounts? For example, would it be possible to only provide Enex
TestLab with filtered and unfiltered test accounts?
It is intended that every participant in the Pilot will involve actual
customer accounts. However, if—in addition to a live customer
component—an ISP proposes other approaches for testing particular
aspects of filtering or network performance, the Department will
consider these where they could provide useful information to
supplement that gained from the live customer component.
5. We understand that the cornerstone of any live internet filtering
trial should be the testing of network degradation and the ability of
a solution to scale. While the current framework allows for speed
degradation testing for a single user or a small group of filtered
users, how is it proposed to measure performance and network
degradation over an entire customer base?
Scalability is one of a number of variables that the Pilot will seek
to address. Consideration will be given to connection types,
connection speeds, numbers of participating users and the size of
participants' entire customer bases along with future network
expectations.
Depending on the nature of ISP participation, measurements can occur
at a number of points in the network and with the filter enabled,
disabled and removed.
Some closed on-network or lab testing in conjunction with the ISP is
also possible to validate the performance impact of the filter
solution. Where available, the Department will collect information on
historical network performance as well as that gathered over the
course of the Pilot.
6. Is it the Department's plan to extrapolate performance results from
a very small group of users to a base of several million? If so, what
sort of methodology is planned to perform such an extrapolation?
Enex TestLab will engage with each individual ISP in planning and
preparation sessions to detail and agree on the level of participation
and involvement between the parties in the Pilot and address issues
resulting from the different technical platforms and filtering methods
used.
7. We understand Enex TestLab has conducted tests for DBCDE on the
alleged extent of over-blocking using IP addresses rather than URLs.
Is the Department prepared to release these findings and the related
methodology?
Preliminary laboratory testing was conducted to assess the potential
level of over-blocking using IP addresses.
The Department and Enex TestLab will discuss the methodology and
findings of the study with ISPs that actually participate in the Pilot
and are considering using this technology platform.
8. How will complaints from websites claiming they have been
inappropriately blocked (i.e. over-blocking) be managed and by whom?
Dependent on the filtering method chosen by the ISP, mechanisms to
report over-blocking may be built into the solution. Enex TestLab will
perform accuracy and effectiveness testing early in the Pilot for each
solution. If over-blocking is detected Enex TestLab will notify the
ISP and re-test until the matter is satisfactorily resolved before
proceeding.
For participating ISPs that do not have an over-blocking reporting
mechanism, Enex TestLab will engage one-on-one with each respondent
organisation in planning and preparation sessions to discuss and
address such issues.
9. The Pilot includes the assessment of end users' filtering
experience. This will involve a survey of a sample of ISP customers
following their consent. Please elaborate on the form of this survey
and what correspondence/interaction there will be between Enex and ISP
customers. Also, will ISPs get the opportunity to approve this
correspondence?
The ISP filtering Pilot will ideally involve surveying a sample of an
ISP's participating customer base to seek information on the
customer's filtering experience.
The Department is conscious of the need to minimise any impact on both
customers and the ISP. Therefore, the survey will be kept to a minimum
and undertaken electronically where possible. It is proposed that Enex
TestLab will undertake the surveys with the end user.
The Department and Enex TestLab will discuss the survey process and
associated correspondence with participating ISPs, prior to issuing
the survey.
10. Would ACMA be providing the survey/questionnaire, the draft seems
to indicate we will draw up a survey?
Enex TestLab will draft the customer survey in consultation with the
ISP and the Department.
11. We can guarantee delivery of the survey to the participating
customers, however we cannot guarantee the numbers of completed
surveys returned. Therefore, is the funding in anyway tied to numbers
of completed customer surveys returned?
Funding is not contingent on numbers of completed customer surveys.
Funding assistance is related to participation in the Pilot, and
therefore involves reimbursement of some costs associated with:
* procurement of a filtering solution
* installation and configuration of the filtering solution
* costs associated with any required modifications to network
infrastructure.
12. Is the Commonwealth prepared to offer a statutory 'safe harbour'
protection or contractual indemnity to participant ISPs who might
otherwise be exposed to litigation risk (including from any over
blocking or wrongful blacklisting)?
The nature and extent of this issue will depend on the circumstances
of individual ISPs, including the nature of their contracts with their
customers and the approach to filtering proposed. The Department will
discuss this issue with each ISP proposing to participate. The
Department considers that the need for an indemnity from the
Commonwealth has not been established.
13. What assurance can DBCDE provide as to the confidentiality of
commercially sensitive information or customer information ISPs might
provide as part of the Pilot?
The draft Deed of Agreement contains terms regarding the treatment of
confidential information (see clause 7 of the Deed, and item 5 to
Schedule 1).
The Request for Expressions of Interest asks applicants to make
submissions to the Commonwealth about information that they want the
Commonwealth to treat as confidential. The Commonwealth will consider
each submission, and may agree to treat particular information as
confidential.
If the Commonwealth accepts an applicant's claim for confidentiality,
Australian Government officials are subject to a rigorous regime of
statutory obligations restricting their ability to disclose such
information. These statutory obligations include, but are not limited
to, section 13 of the Public Service Act 1999 (which establishes the
APS Code of Conduct), Public Service Regulation 2.1 (which prohibits
unauthorised disclosure by an APS employee of information gained in
the course of APS employment) and section 70 of the Crimes Act 1914
(which makes it an offence for Commonwealth officers to disclose
information in certain circumstances).
The Privacy Act 1988 would also apply to the extent that confidential
information might include personal information.
14. What are the requirements around security and confidentiality of
the ACMA blacklist?
ISPs participating in the Pilot must enter into a non-disclosure
undertaking with ACMA to obtain the blacklist.
The undertaking will acknowledge that the URLs contained on the
blacklist relate to prohibited content under the Broadcasting Services
Act 1992 and that the blacklist is provided in confidence, for the
sole purpose of allowing the participating ISP to prevent access to
the material contained in the blacklist for users of the ISP's
service.
Participating ISPs must not disclose the blacklist to anyone, or for
any purpose, not directly related to the ISP taking the necessary
steps to prevent the users of its services from accessing such
material by way of its participation in the ISP Internet Level Content
Filtering Pilot.
15. Is the ACMA blacklist in a form that potentially could expose ISP
staff to websites containing child abuse or other illegal content? If
so, what safeguards will be put in place?
Participating ISPs are not required to access the material on the
blacklist. Rather, they are required to block access to the URLs on
the blacklist. The blacklist will be provided to participating ISPs in
a password protected file.
16. Will we be able to see the blacklist prior to committing to the Pilot?
The blacklist contains approximately 1300 URLs. The blacklist will not
be provided to ISPs not participating in the Pilot.
17. Does the requirement for prior Departmental approval of
marketing/publicity activities of participants related to the Pilot
also relate to ad hoc media inquiries? Also what will this requirement
involve?
Participants in the ISP Content Filtering Live Pilot will not need to
gain the Department's approval to respond to ad hoc media queries
concerning their participation. However, participants must ensure that
confidential information is not disclosed when answering any media
queries.
Participants must obtain Departmental approval for marketing and
publicity activities relating to the Pilot, including ensuring that
any associated publicity and marketing material acknowledges the
support of the Australian Government.
18. Will DBCDE share trial outcomes with participants and consult on
draft conclusions flowing from the Pilot prior to their public
release?
All outcomes arising from a particular ISP's participation in the
Pilot will be shared with that ISP. All conclusions drawn from the
outcomes of a particular ISP's participation will be shared with that
ISP. The Department has no authority to share outcomes in relation to
one ISP with another ISP.
The final report of the Pilot will not attribute particular outcomes
to a specific ISP.
19. At a minimum, a Pilot ISP is to implement the ACMA blacklist,
which is a list of approximately 1300 specific URLs?
At a minimum, an ISP participating in the Pilot must implement ISP
filtering mechanisms that will filter access to the ACMA blacklist,
which currently contains approximately 1300 URLs.
URLs consist of any single page or image of web content that is
classified as prohibited. Where a particular page(s) or image(s) must
be blocked, other pages or images on that site should not be blocked
where they have not been classified as prohibited.
20. At a minimum, as part of the Pilot, the only protocol to filter is
web traffic that is exclusively HTTP over TCP port 80?
At a minimum, participating ISPs will implement ISP filtering to block
access to URLs that are classified as prohibited and are on the ACMA
blacklist. This consists of page(s) and image(s) of HTTP content. This
requirement does not specify any port for filtering, although it is
acknowledged that TCP port 80 is the normal port for HTTP traffic.
21. A successful Pilot ISP will receive a copy of the ACMA blacklist,
where the means of implementing the filter is entirely up to the ISP?
It is understood that receipt of the blacklist will require both
successfully joining the Pilot program, and the signing of some form
of confidentiality agreement with the ACMA?
Yes.
Upon entering into a Deed of Agreement with the Department to
participate in the Pilot, the ISP will also enter into a
Non-Disclosure Agreement with ACMA to obtain the blacklist. The
undertaking will acknowledge that the URLs contained on the blacklist
relate to prohibited and potentially prohibited content and that the
blacklist is provided in confidence, for the sole purpose of blocking
access to the material contained in the blacklist by the ISP's
customers.
Participating ISPs must not disclose the blacklist to anyone, or for
any purpose, not directly related to the measures taken by the ISP by
way of its participation in the ISP Internet Level Content Filtering
Pilot to ensure that its customers have no access to such material.
22. At a minimum, is the Department interested in understanding the
impact on internet services that are both filtered and not filtered.
This is to include:
1. 'Speed' of services between dial-up (56 Kbps) and 12 Mbps
(broadband), in terms of throughput and latency (delay / lag)?
2. Filtering infrastructure scalability in terms of traffic
volumes, number of customers, and size of the blacklist (entries on a
logarithmic scale: 10^3, 10^4, 10^5, 10^6, etc)?
3. False positive and false negative, expressed as a ratio or
specific hit count?
4. Perceived effort required to bypass or otherwise circumvent the filter?
Ideally, a participating ISP will apply a filtering solution to a
sample of their customer base. Enex will then obtain a sample filtered
service and, simultaneously, a sample unfiltered service from the same
ISP. If this is not feasible, an ISP could provide a 'before
filtering' and 'after filtering' approach using a single connection.
As outlined in the Technical Testing Framework, ISP filtering
solutions will be assessed against a comprehensive range of criteria
including network performance, accuracy, circumvention, user
experience of filtering (including privacy/security issues), costs
associated with introducing ISP filtering, scalability and, where
relevant, effectiveness of additional filter functionalities.
The range of 56 Kbps to 12 Mbps is an indicative range. ISPs can
propose alternative ranges, noting the intention of the Pilot is to
test a range of typical customer access speeds.
23. What is the expected behaviour of an internet service that
attempts to reach blocked content, should:
1. A page showing 'content blocked by filter' or equivalent be
displayed, which would leak the contents of the ACMA list to users?
2. The page to not load, which would probably prompt the end user
to call the ISP's technical support?
3. The attempt to reach blocked content be logged?
4. Something else or a combination of the above happens?
Enex TestLab intends to engage one-on-one with each participating ISP
to agree on the appropriate response. Item c) is not required within
the scope of the trial.
