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Google Australia Level 18, Tower 1 Darling Park 201 Sussex Street Sydney NSW 2000

Tel: 02 9374-4000 Fax: 02 9374-4001 www.google.com.au

millions of individual videos are viewed every day). This makes it practically impossible to pre-vet each piece of content prior to its upload on the site.

Second, most Internet services are provided other than on payment of a fee by the access seeker and accordingly do not require establishment of a billing relationship with a customer or associated customer service functions or capability. Any access- control system or other administrative requirement that is imposed upon Internet service providers is likely to constitute a new financial and administrative burden that will impact in a significant way in a manner that would not constitute such a burden for mobile service providers or commercial Internet service providers.

Mobile service providers currently carry a current regulatory burden of complying with ‘know your customer’ requirements that were imposed in respect of both prepaid and postpaid services principally for national security reasons. Providers of ‘for payment’ Internet services already have in place credit card verification procedures (that also involve identity assurance as part of the verification) and customer support capabilities to support their billing processes. In other words, billing of customers for provision of internet services (whether one-off or subscription) necessarily involves development of processes, systems and customer support capabilities that are simply not necessary for provision of ‘free’ Internet services. The financial and administrative burdens imposed by implementation of the currently proposed RAS will therefore be entirely different for providers of ‘free’ Internet services from providers of mobile serve providers and operators of ‘for payment’ Internet services.

In summary, there are a number of two main scenarios where a RAS may need to operate:

  • commercial services (services provided to the public either on payment by the access seeker of a subscription or for particular content), where the CSP has a more direct financial relationship with a customer (i.e., through one-off payment or subscription).

  • non-commercial (as defined in Schedule 7) services, where the CSP does not collect financial or other details about customers (and therefore any requirement to collect such information is a new operational burden on the provider).

Many of the elements of the proposed RAS (such as the requirement to seek documentary evidence of age and to implement a capability for subsequent verification) may be broadly consistent with existing practices and processes for commercial services (such as age restricted mobile content services where a customer’s age details are verified at the time of subscription to the mobile service or the individual content service).

In contrast, in the case of non-commercial internet sites (such as user generated content sites), it is not necessary for a user to subscribe to the site to view content. Rather, it is only generally necessary for users to subscribe or to create a user account if they wish to post content to the site. In this circumstance, there may not be any actual relationship or technical ability between the CSP and the user to enable pre- assessment of a customer’s age prior to that customer’s entry to the site. Instead, alternative means are used to control access. For example, YouTube’s existing practices are based on technical processes to assess a user’s age at the time that a user

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