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Implementation Questionnaire

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Introduction

Notes/instructions on completing this template

• Please complete all sections and all questions as far as possible

• Where a question or section is not applicable, please mark as N/A

• Where is overlap – or no change – to information previously submitted in company statement of commitments, please simply enter “refer to self-statement”

• URLs or screenshots (with links) are particularly useful in illustrating individual points

• Please add any additional information/data relevant to the submission at the end of the appropriate Principle

1. Name of the company on whose behalf this submission is made:

Vodafone Group Plc

2. Country or primary markets where products/services are offered (in EU) to which this submission applies. In which European markets does your company operate?

• Albania

• Czech Republic

• Germany

• Greece

• Hungary

• Ireland

• Italy

• Portugal

• Romania

• Spain

• UK

3. Product(s) or services included within the terms of this submission

• Mobile and fixed line internet services

• Cloud storage

• TV services (not all markets)

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4. Nature of activity

☐ Manufacturers of desktop and laptop computers, mobile phones, tablets, TV set top boxes and gaming consoles X Network operators and connectivity providers

☐ Online content provider X Online service provider

☐ Other (please specify): ......................................................................

5. Person(s) completing the report

Name: Moira Thompson Oliver

Position: Senior Manager, Human Rights

Email: moira.thompsonoliver@vodafone.com

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Principle 1 – Content Commitments Signatories should: • Indicate clearly where a service they offer may include content considered not to be

appropriate for children and display prominently options which are available to control access to the content. This could include, where appropriate for the service, tools to manage access to certain content, advice to users or a recognised system of content labelling.

• Display prominently and in an easily accessible location the Acceptable Use Policy, which should be written in easily-understandable language.

• State clearly any relevant terms of service or community guidelines (i.e. how users are expected to behave and what is not acceptable) with which user generated content must comply.

• Ensure that reporting options are in the relevant areas of the service. • Provide notice about the consequences for users if they post content which violates

terms of service or community guidelines. • Continue work to provide innovative solutions able to support child safety protection

tools and solutions.

1. Do you provide a mechanism for consumers to provide feedback, report an issue or file a complaint about the appropriateness of a piece of content?

X Yes

☐ No

☐ Not applicable (please explain): ............................................................. Vodafone is a technology communications company. Our primary business is operating

mobile and fixed internet and telecom services for which we don’t generate content or provide

a platform for user-generated content.

We do however provide services to prevent children from accessing inappropriate material on

our networks (see Principle 1, Question 2) and provide customer care channels in each market

for consumers to raise any concerns or complaints. For example:

Vodafone Spain

Customer care channels can be accessed via the website Contact | Vodafone Private

Assistance.

We also encourage customers to report any content that they feel should be restricted, or that

they feel has been unnecessarily restricted. For example:

Vodafone UK

Reports can be made by contacting contentclassification@vodafone.com.

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2. Do you offer a means for restricting / blocking access to potentially inappropriate content for users of your service or product?

X Yes

☐ No

☐ Not applicable (please explain): ............................................................. If yes, please provide details of mechanisms in place: Vodafone offers services to block and restrict access to inappropriate content across its

markets for mobile and fixed internet and telecom services.

For example:

Vodafone SecureNet

Vodafone SecureNet (available in Portugal, Italy, Romania, Germany, Ireland, Greece, Spain,

Turkey, Albania and the UK) is a mobile security product that includes options to apply age-

appropriate content filters and block unwanted websites.

Vodafone UK

Vodafone UK provide an age-restricted content bar to block content and websites that aren’t

appropriate for under 18s.

Age-restricted content settings - Community home (vodafone.co.uk)

Vodafone UK also provides information on content classification - How to block 18+ content | Vodafone. UK mobile operators published a code of practice for the self-regulation of content on

mobiles. The full code is available on the mobile UK website - Codes of Practice | Mobile Network Operators | Mobile UK

Vodafone TV

Vodafone TV services (available in Czech Republic, Ireland, Germany, Greece, Hungary, Italy,

Portugal, Romania and Spain) offers multiple settings to control content. For example:

- Option to block age-rated content through parental controls and hide it from the user

interface

- Pin control to restrict access to content as well as access to features that require

additional spend

- Option to entirely block channels

- KIDS zone, which restricts content and enables parents to define how and when their

children watch television.

For example – Vodafone Ireland - Get help with your Vodafone TV service | Vodafone

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3. Do you provide any information, educational resources or advice for users in any of the following areas? (tick as many as apply)

X Content classification or labeling guidelines X How to block or restrict access to content X How to report or flag content as inappropriate X Safe searching X Information about your company’s content policy in relation to children

☐ Not applicable (please explain): ............................................................. If yes, please provide details including the format of any material provided (video, text, tips, games, FAQs, etc.): Vodafone Group provides detailed resources for child online safety, including specific

reference to the tools and controls available to children and their guardians to restrict and

block inappropriate content: Useful resources for child online safety (vodafone.com).

Vodafone also provides educational resources and information on safe internet usage across

our markets. For example:

Vodafone Czech Republic

DigiParent tutorials and information are available on the website covering topics such as safe

searching, browsing and games: Tutorials - Vodafone.cz.

Vodafone Greece

Vodafone Greece BeSafeCoach website provides articles, information and links to content on

online safety, covering topics such as how to restrict content and support child online privacy.

Παιδιά και Ψηφιακή τεχνολογία - Οδηγός γονέων για ασφαλές Διαδίκτυο (vodafone.gr).

Vodafone Hungary

Information on safe search settings and an application to help promote healthy online habits.

Protection | minors Vodafone

Vodafone UK

Vodafone UK provides information on content classification - How to block 18+ content | Vodafone. UK mobile operators published a code of practice for the self-regulation of content

on mobile devices. The full code is available on the mobile UK website - Codes of Practice | Mobile Network Operators | Mobile UK. As described in Principle 1 Question 1 and Principle 1 Question 2, we also provide information

to customers on how to block or restrict access to content (How do I change my age-restricted content settings? - Additional help topics | Vodafone UK ), and how to report or

flag content as inappropriate (email our team at contentclassification@vodafone.com).

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4. Where is your company’s Acceptable Use Policy (AUP) located?

Several markets host AUPs on their website within the terms and conditions pages. For

example:

• UK - Vodafone

• Germany - General Terms and Conditions (GTC) and Prices (vodafone.de)

• Spain - Políticas de uso Particulares y Autónomos | Vodafone particulares

• Greece - Vodafone < Greece contracts | Vodafone.gr

• Ireland - general-fixed-and-broadband-terms-and-conditions-from-7-dec-2020.pdf

(vodafone.ie)

5. Does the AUP or separate give clear guidelines with which user generated content must comply (including details about how users are expected to behave and what is not acceptable)?

☐ Yes

☐ No X Not applicable (please explain): ............................................................. If yes, please identify relevant policy: N/A. Vodafone do not provide platforms to host user generated content, however we do

stipulate other behaviours that we classify as unacceptable within our AUPs (see Principle 1

Question 4).

6. Do you provide notice about the consequences for users if they post content which violates terms of service or community guidelines?

X Yes

☐ No

☐ Not applicable (please explain): ............................................................. If yes, please identify relevant policy: As per Principle 1 Question 5, consequences for customers where usage falls outside the

acceptable usage policy are detailed within the policy. For examples the below is extracted

from the Vodafone UK AUP:

What happens if your usage falls outside the acceptable usage policy?

If we suspect you’re not adhering to our Acceptable Use Policy, we reserve the right to impose

further charges on you and/or disconnect your SIM card or contract at any time. We may also

restrict access to just one part of your service (for example, restrict your use of our text service

if we believe you have sent text messages that are in breach of this policy). We’ll attempt to

contact you if we need to disconnect your service.

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Principle 2 – Parental Controls Commitments Signatories should assist parents to limit their children’s exposure to potentially inappropriate content and contact.

• Manufacturers should optimise hardware design to provide products which simply and clearly help parents to set appropriate levels of control on devices.

• Network providers should provide necessary tools and settings across their services to enable parents to set appropriate levels of control.

• Service and content providers should make available the necessary tools and settings across their services to enable parents to set appropriate levels of control

1. Please outline the availability of any parental control tools and settings across your product or service that allows parents to set appropriate levels of control? Include relevant links/ screenshots where available:

Vodafone Group includes information on parents’ controls and tools on its website to help

children have a safer online experience. Useful resources for child online safety

(vodafone.com).

As detailed in Principle 1 Question 2, SecureNet is a mobile security product offered by

Vodafone in 10 markets. This service allows parental controls to be implemented, including

age-appropriate content filters and the ability to control access to website categories.

Vodafone Secure Net

Vodafone UK

Vodafone UK implements an age-restricted content bar as standard on its networks to prevent

customers under the age of 18 accessing potentially inappropriate content. For more details

please see Age-restricted content settings - Community home (vodafone.co.uk).

Several parental toolkits and web resources are also available - Parental Controls & Filtering

Advice | Vodafone.

Vodafone Italy

Vodafone Italy offers a Digital Privacy & Security service, which includes parental controls, and

the ability to block specific websites. A ‘Digital Coach’ service is also available and provides

educational content for parents and minors: Digital Privacy & Security | Vodafone.

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2. If applicable, please describe the features offered by the parental controls? E.g. restricting web access, customization, monitoring, other restrictions…..

Vodafone’s SecureNet service includes the following features:

Child Safe Browsing

Child safe browsing is a feature enabling customers to block access to certain categories of

websites for their child. There are 12 categories to choose from: Adult (over 18), Violence,

Racism, Sex Education, Malicious sites/identity theft, Chat, Social Network and

Communications, Games, Dating, Classifieds, Shopping, Webmail.

Parents can assign profiles to their child, such as ‘school-aged’, ‘pre-teen’, ‘teenage’, ‘custom’

and ‘none’. Each profile has pre-set categories assigned to them for blocking and, if selected,

these categories will be shown as automatically blocked but parents can add or delete more

categories from the pre-set list and save this as ‘custom’.

Quiet Time

1. Quiet time is a feature that allows parents to manage mobile data access of their child during

set times. They can restrict mobile internet access a) during scheduled times (eg: school time,

every week day from 08:00-16:00) or b) start a timer and restrict access for a specific time (eg:

1 hour during dinner).

App Notification

If a parent turns on app notification, they will be notified by an SMS of new apps that their child

has downloaded, such as an inappropriate app (rated as mature).

Further details of the Vodafone SecureNet service can be accessed here Vodafone Secure Net

and within specific market Secure Net FAQs.

3. In relation to parental controls, which of the following educational and information resources to do you offer? (tick as many as apply)

X Company policy in relation to use of parental controls X Guidance about how to use parental controls X Educational or awareness-raising resources about the use of parental controls

☐ A promotional or marketing channel for the uptake of parental controls X External links to educational material/resources about the use of parental control [Please provide details including links or screenshots as relevant] Vodafone provides resources and educational information both at Group level and across the

markets. Some specific examples related to parental controls are listed below:

Vodafone UK

Vodafone UK include details of parental controls within the Digital Parenting section on the

website, some links to relevant articles and content are included below:

Get the latest advice on parental controls | Digital Parenting (vodafone.co.uk)

Spying On Your Kids’ Online Activity is Not the Answer | Digital Parenting (vodafone.co.uk)

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Parental Controls & Filtering Advice | Vodafone

The Vodafone UK ‘Digital Family Pledge’ provides a toolkit to empower families to discuss

technology and the internet including topics such as parental controls and how to set their

digital “house rules” together.

Vodafone Czech Republic

Vodafone Czech Republic include information on digital parenting and specifically

recommended parental controls based on a child’s age.

How to protect your children online? - Vodafone.cz

Digital Parenting - Vodafone.cz

The Vodafone Secure Net services include a digital coach to provide further information on

parental controls.

4. Please outline any additional safety tools or solutions not detailed above that relate to parental controls, including any planned implementation of new features or procedures?

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Principle 3 – Dealing with abuse/misuse Requirements Signatories should:

• Provide a clear and simple process whereby users can report content or behaviour which breaches the service’s terms and conditions.

• Implement appropriate procedures for reviewing user reports about images, videos, text and other content or behaviour.

• Provide clear information to users on all available report and review procedures.

• Place and review regularly links to these reporting options in appropriate areas of the service (e.g. where users view user-generated content or interact with other users) and provide guidance on what to report.

• Place links to relevant child welfare organisations or specialist providers of advice (e.g. about anorexia or bullying) and other confidential helplines/support services in appropriate areas.

• Ensure that moderators who review user reports are properly trained to determine or escalate content or behaviour presented to them

1. Please provide details of company policy relating to abuse and misuse (involving images, videos, text and other content or behaviour) on your product or service.

Vodafone provides telecommunications services including mobile and fixed networks, and as

such is not a content creator. Vodafone has customer care channels across all markets where

concerns about content or behaviour can be reported.

As per Acceptable Usage Polices (detailed in Principle 1, Question 4) we state customer

behaviour expectations related to abuse and misuse of our services.

For example, below is an extract from the UK AUP:

“You must not use our services or SIM cards for fraudulent or criminal purposes, or in a way

that in breach of law (including making calls, sending messages or posting or downloading

content which is, offensive, defamatory, indecent or a nuisance.”

2. Please describe the process or mechanism available for users to report abuse/misuse (involving images, videos, text and other content or behaviour) on your product or service).

Vodafone customer care channels across all markets are available for customers to report any

abuse or misuse from our services.

We encourage customers to report abuse/misuse to specific groups best set up to respond

such as the IWF or INHOPE organisations, please see examples from our markets below:

Vodafone Ireland

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Vodafone Ireland provides information on what to do if a customer is concerned an image may

be illegal and how to report it anonymously. This is in its ‘Information for Parents’ section on

its website and directs users towards the hotline.ie reporting service. Security information for

parents | Vodafone

Vodafone UK

Vodafone UK actively support the Internet Watch Foundation (IWF) which focuses on online

child sexual abuse and are also members of the Government-led UK Council for Child Internet

Safety. Vodafone UK’s digital parenting magazine provides information on where to report

concerns with main online service providers. Customers are also encouraged to report images

to IWF, the National Crime Agency or ParentPort and are directed to the websites.

vfcon095783.pdf (vodafone.co.uk)

3. Where is the reporting button/ mechanism located? (tick any that apply)

☐ On each page of the website/service

☐ Close to the point where such content might be reported

☐ In a separate location such as a safety page

☐ In a browser extension

☐ In a separate app for a connected device X Other (please specify): .......................................................

Reporting details can be found within specific webpages on market child online safety pages

and resources. For example, Vodafone UK’s digital parenting magazine provides links to

reporting sites, as per Principle 3 Question 2.

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4. Who may use such a reporting mechanism? (tick any that apply)

☐ Only registered user/profile in which content is located

☐ All registered users of the product/service? X Everyone including non-users, e.g. parents/teachers who are not registered for the service

☐ Other (please explain): .......................................................

5. Which of the following kinds of content can users report?

Users are able to report any complaint or issue to our customer care teams; reporting to other

external mechanisms (e.g. IWF) are stated on their website.

6. Which of the following information do you provide to users? (tick any that apply)

☐ Advice about what to report

☐ Advice about how to make a report

☐ Pre-defined categories for making a report

☐ How reports are typically handled

☐ Feedback to users X Other website/external agency for reporting abuse/ misuse content? X Other (please specify): .............................................. As per the examples provided in Principle 3 Question 2, Vodafone provides links to other

external reporting mechanisms, as well as our own customer care channels that are available

via ‘Contact us’ pages on market websites.

7. Please provide details of any other means, in addition to a reporting button/icon, to report content or behavior which breaches your service’s terms and conditions

Customer care channels across all Vodafone markets are available to report any kind of

complaint or behaviour.

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8. Please outline briefly any other procedures or programmes offered by your service not detailed above that relate to abuse /misuse,

Principle 4 – Child Sexual abuse content or illegal contact

Requirements Signatories should:

• Co-operate with law enforcement authorities, as provided for in local law, regarding child sexual abuse content or unlawful contact.

• Facilitate the notification of suspected child sexual abuse content to the appropriate law enforcement channels, in accordance with existing laws and data protection rules.

• Ensure the prompt removal of illegal child sexual abuse content (once it has been confirmed as illegal by the relevant public authority) in liaison with national law enforcement.

• Provide relevant additional information and/or links to users so they can make a report or obtain information about appropriate agencies or organisations that users can contact about making a report or obtaining expert advice, at national and EU level (e.g. law enforcement agencies, national INHOPE hotlines and emergency services).

1. Which of the following mechanisms are provided on your product or service to facilitate the notification or reporting of suspected child abuse content? (tick any that apply)

☐ Company-own hotline reporting button or telephone number X Link or button for external national or regional INHOPE hotline

☐ Emergency services X Law enforcement agency

☐ Other external agency (please specify): ............................................................

Markets across the Vodafone group provide links to report illegal content in addition to links to

support those who want to seek help. Vodafone Group engages with several industry groups

on this topic, including the Internet Watch Foundation, GSMA and the We Protect Global

Alliance. Examples of notification/reporting mechanisms from specific markets are:

Vodafone Ireland

Vodafone Ireland provides information on what to do if a customer is concerned an image may

be illegal and how to report it anonymously. This is in its ‘Information for Parents’ section on

its website and directs users towards the hotline.ie reporting service. The hotline.ie service is a

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member of the INHOPE association and was set up by the Internet Service Provider Association

of Ireland (ISPAI) of which Vodafone is a member. Security information for parents | Vodafone

Vodafone UK

Vodafone UK actively support the Internet Watch Foundation (IWF) which focuses on online

child sexual abuse and are also members of the Government-led UK Council for Child Internet

Safety. Vodafone UK provide a contact email address for customers who have accessed a site

that should be classified as restricted. How to block 18+ content | Vodafone. Customers are

also encouraged to report images or get support from IWF and are directed to the website.

2. Please outline briefly the procedures to be followed if illegal content were to be discovered on your service.

Procedures to prevent illegal material differ from market to market depending on national

legislation. We outline below some of the broader approaches we take to any illegal content

found via our services:

Vodafone UK

Vodafone UK is a member of IWF, supporting its hotline for reporting websites hosting child

sexual abuse images and content. Vodafone UK applies the IWF block list to its fixed and

mobile internet services. If a customer navigates to a site with one of these blocks, they will

receive a splash page explaining why it is blocked as displayed below.

Our approach to accessing illegal content is reflected into our customer facing policies. The

Vodafone UK Acceptable Usage Policy instructs customers not to use our services to view

illegal content. A link to the policy is below.

Vodafone Mobile Acceptable Use Policy This is also reflected in the Business Acceptable Use Policies where violating any law is listed

as a prohibited activity. The link to this policy is also below. If a customer is found to be in

breach of our AUPs, Vodafone may suspend, terminate or restrict services.

Vodafone Acceptable Use Policy for Business Customers

Vodafone Italy

Vodafone Italy has implemented the block of access to URL/IP included into the “blacklist”

provided by the Italian National Centre responsible for the prevention of child sexual abuse.

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The block is implemented for both mobile and fixed traffic.   There is additionally a process is

in place to implement additional blocks requested by Judicial Authority following specific

investigations.

Details of reporting mechanisms for illegal content are included in the response to Principle 4

Question 1.

3. Do you provide links to any of the following to enable users to gain additional information in relation to child sexual abuse content or illegal contact? (tick any that apply)

☐ Links to relevant child welfare organizations/specialist providers of advice X Other confidential helplines/support services

☐ Law enforcement agencies X INHOPE

☐ Other (please specify): …………….. Vodafone markets work closely with organisations locally to help support children and parents

in digital awareness and safety. Some examples of this from our markets are below. At a Group

level useful resources for child online safety can be found on our website Useful resources for child online safety (vodafone.com). Vodafone UK

A blocked access screen is displayed when a user tries to access content that is illegal. The

message contains links and contact details for Stop It Now, a UK and Ireland based

confidential service to help anyone with concerns about child sexual abuse and their own

behaviour or behaviour of another adult or young person.

Vodafone UK’s digital parenting magazine also directs parents to organisations that can help

including Internet Matters and The Parent Zone vfcon095783.pdf (vodafone.co.uk). Vodafone Hungary

Vodafone Hungary provides links to the NMHH Internet Hotline that helps parents to

understand young people’s digital habits. Protection of minors | Vodafone

4. Please outline briefly any additional procedures in place within your company not detailed above to ensure that you comply with local and/ or international laws with regard to child sexual abuse and other illegal content?

Last year we assessed our approach to children’s rights by piloting UNICEF’s draft revised

Mobile Operators Children’s Rights Impact Assessment tool, this included assessing our

approach and steps we take to safeguard children. We found areas of good practice, such as

the wide range of programmes that use technology to support the realisation of children’s

rights, we are currently working to implement actions suggested from the assessment.

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Vodafone are members of the GSMA Mobile Alliance Against Child Sexual Abuse Content. The

alliance works with policy makers, NGOs and the wider telecommunications companies to

promote and help safeguard children’s rights. The Vodafone Code of Conduct is issued to all new employees joining Vodafone, and all

employees are required to do training on it every two years. This document includes a section

on ethical decision making, encouraging employees to consider ethics alongside legality in

decision making. This is also reflected in other internal policies instructing employees to not

access any illegal content.

Vodafone UK

Our approach to accessing illegal content is reflected into our customer facing policies. The

Vodafone UK Acceptable Usage Policy instructs customers not to use our services to view

illegal content. This is also reflected in the Business Acceptable Use Policies where violating

any law is listed as a prohibited activity. Both policies are available via the below links: Vodafone Acceptable Use Policy for Business Customers Vodafone Mobile Acceptable Use Policy. Vodafone Germany

Vodafone Germany offer two youth protection products that can be deployed at a customer’s

request (Vodafone Red + Kids or Vodafone SecureNet). These products include the ability to

filer inappropriate content and this also complies with the German youth protection filter

“JusProg”.

Vodafone Greece

Vodafone Greece and Greece’s other mobile communications companies have adopted the

European Framework on Safer Mobile Use by Younger Teenagers and Children by

incorporating it into the existing Code of Conduct for mobile phone value added services and

protection of minor users, a self-regulation initiative of the sector in Greece.

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Principle 5 – Privacy and Control Requirements Signatories should:

• Manage privacy settings appropriate for children and young people in ways that ensure they are as safe as is reasonably possible.

• Offer a range of privacy setting options that encourage parents, children and young people to make informed decisions about their use of the service and the information they post and share with others online. These options should be easy to understand, prominently placed, user friendly and accessible.

• Take steps, where appropriate and in accordance with legal obligations, to raise user awareness of different privacy controls enabled by services or devices and enable users to use these as appropriate.

• Make reasonable efforts to raise awareness among all parties, service, content, technology and application providers, including public bodies, of industry good practice in relation to the protection of children and young people online

1. Please provide details of your company’s published privacy policy in relation to access, collection, sharing and further use of data from minors under the age of 18 when utilizing your product or service? Vodafone does not directly sell services to children and has a customer relationship only with

adults (over 18 years old).

The Vodafone Group Privacy Centre details our approach to privacy and the privacy

commitments including openness and honesty, balance, accountability and privacy by design.

- Privacy centre (vodafone.com)

Our privacy management policy explicitly refers to the protection of privacy of children,

requiring that privacy rights of children are appropriately taken into account in the design and

delivery of Vodafone products and services. This commitment is also highlighted on the

Vodafone Group Child Rights webpage Child rights and online safety (vodafone.com).

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For specific products or services designed to be used by children we provide a separate privacy policy. For example, our Neo smart children’s watch - Neo, The smart kids watch Privacy Policy (vodafone.co.uk).

2. Are distinct privacy settings deployed to prevent access to information for users under the age of 18?

☐ Yes

☐ No

X☐ Not applicable (please explain): ...................................................... N/A as Vodafone only contracts with adults. Default settings are applied as per the privacy

policy in Principle 5 Question 1. Vodafone does not target children for any marketing purpose.

If yes, please briefly outline available age-appropriate privacy settings (Provide details including relevant links/ screenshots on your website) Please identify default settings for each age category of under 18s, as relevant: Please identify any steps you have taken to ensure that these settings are easy to understand, prominently placed, user friendly and accessible.

3. Where are users able to view and change or update their privacy status? tick any that apply)

☐ On each page of the website/service

☐ At each point where content may be posted X In separate location such as a settings/safety/privacy page

☐ In a browser extension

☐ In a separate app for a connected device

☐ Other (please specify): ......................................................... Customers are able to amend their settings within their account details, which can be

accessed by logging into ‘My Vodafone’ and going to ‘Manage my settings’ or contacting the

customer care teams. As an example, this is detailed on the Vodafone Ireland Privacy Centre.

Details for controlling cookies are included on the Vodafone Group website, see the link for

more information - Our privacy policy (vodafone.com).

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4. Which of the following information, resources or help features (if any) are provided to encourage users to make informed decisions about their privacy or the information they share?

☐ Tips/advice to users at the point of setting privacy options X FAQs

☐ Help or educational resources in a separate location of service

☐ Links to any external NGO agencies offering education or awareness-raising related to privacy

☐ Links to governmental or EC agencies (Office of Data Protection Commissioner, ENISA etc.) in relation to privacy and data protection

☐ Other (please specify): ...................................................... Vodafone provides detailed information on our approach to privacy on the Vodafone Group

Privacy Centre website. This includes links to a FAQs document and a video explaining data

collection, how it’s used and what this means for customers.

Privacy centre (vodafone.com)

5. Please outline briefly any additional policies or activities (existing or proposed), not detailed above, to ensure that personal information is protected, using reasonable safeguards appropriate to the sensitivity of the information.

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Principle 6 – Education and Awareness Requirements Signatories should:

• Educate children and young people and give them up to date information to manage their access and settings in relation to content, services and applications, adding support where possible to existing initiatives and partnerships.

• Provide advice about features of the service or functionality that are available to allow parents to improve the protection of children, such as tools to prevent access to certain types of content or service.

• Provide links to other sources of relevant, independent and authoritative advice for parents and carers, teachers, and for children.

• Provide access to information that will help educate parents, carers, teachers and children about media literacy and ethical digital citizenship, and help them think critically about the content consumed and created on the internet.

• Encourage parents and teachers to use this information and talk to their children/pupils about the issues arising from the use of online services, including such topics as bullying, grooming and, where relevant, cost management

1. Does your company provide its own educational resources aimed at any of the following groups?

X Younger children, i.e. under 13s X Teenagers <18s X Parents and carers X Teachers and other adults

☐ Others (please specify): ................................................ Vodafone actively support many child safety initiatives across our markets. A brief overview of

some of these initiatives can be found on the Vodafone Group website Our child online safety

initiatives (vodafone.com).

Vodafone group also provides information for adults on how children behave online, linking to

articles from the Vodafone news website and resources from external organisations on topics

ranging from screen time to downloading and copyright. Useful resources for child online

safety (vodafone.com)

Vodafone UK

Vodafone UK has a long running and wide-reaching digital parenting programme in place. The

UK launched its Digital Parenting magazine 10 years ago; all editions can be found in the

SmartLiving hub on the Vodafone website and hard copies can be ordered by schools free of

charge. Nine million magazines have been sent to schools and community organisations in

the UK since 2012. In 2021 a series of eBooks ‘fairy tales for the digital age’ were launched

providing parents, carers and teachers a fun way to bring online safety topics to a younger

audience.

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Smart Living - Vodafone UK News Centre

A fairytale for the digital age | Vodafone Digital Parenting

Be Strong Online

This initiative was developed by The Diana Award and Vodafone, designed to be delivered by

young people for young people – encouraging older children to pass on their knowledge.

Several Vodafone markets link to the ‘Be Strong Online’ resources, including modules on

digital detox, gaming, social media, critical thinking, cyberbullying, online group pressure, self-

esteem and social media. Be Strong Online is available in English, Czech, German, Greek,

Italian, Portuguese and Romanian.

Be Strong Online (antibullyingpro.com)

Spain - BeStrong against Cyberbullying | Vodafone individuals

Vodafone Italy

Vodafone Italy have ‘Coach Digitale’ resources available on their website, with articles and

information available for ages 0 – 6, 7-10, 11-13, +14.

Digital Coach: a guide for parents Digital Coach (vodafone.it) Vodafone Czech Republic

Vodafone Czech Republic have a range of resources focused on Digital Parenting. Specific

stories on technology aimed at young children have been developed for parents to read with

their children and learn key lessons about digital and online safety.

Tutorials - Vodafone.cz

Vodafone Hungary

Vodafone Foundation Hungary developed an elearning platform, e-skola for children, parents

and teachers on online safety and security. This covers the topics of personal data and privacy,

hackers, phishing, secure downloading, social media and digital footprint.

https://e-skola.vodafone.hu/course/view.php?id=7

2. Which of the following topics are included within your own company educational materials? (tick any that apply)

X Online safe behaviour X Privacy issues X Cyberbullying X Download and copyright issues X Safe use of mobile phones X Contact with strangers

☐ Other topics (please specify) ................................................ See Principle 6 Question 1 for examples.

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3. With reference to any educational material you provide, which of the following methods do you use? (tick any as apply)

☐ Documentation provided with product/contract on purchase/first registration

☐ A required presentation by salesperson completing sale

☐ Displays/leaflets positioned prominently in stores

☐ Notification by email / on-screen statement / other means when product or contract is purchased or first registered X Prominent notifications, resources or pop ups on website

☐ Helpdesk (telephone or online) X Other (please specify): We provide child online safety pages on our websites, social media, direct communications

with schools, internal communication to colleagues who are also parents etc.

4. Please provide details of any links to other external organisations, or relevant, independent and authoritative advice for parents/carers, teachers, and for children?

Vodafone works with several external organisations across our markets, some examples are

below.

Vodafone Germany

Vodafone Germany provide links to several external partner organisations, fragFINN, klicksafe,

JusProg and Freiwillige Selbstkontrolle Multimedia-Diensteanbieter (FSM). These organisations

provide education materials for a wide range of different age groups.

Unsere Partner in Sachen Jugendschutz bei Vodafone

Vodafone Greece

Vodafone Greece provides sponsorship to the Hellenic Police-Cyber Crime Prosecution

Division for the implementation of conferences, trainings and teleconferences, to raise

awareness on Internet and cyber crime issues among students, citizens and organisations.

https://cyberalert.gr/e-learning/

Vodafone Greece also partnered with Parentzone for the development of two online fairy

tales.

https://issuu.com/parentzone/docs/fin_parentzone_ks1_greek

https://issuu.com/parentzone/docs/fin_parentzone_ks2_greek

5. Please provide details of any campaigns, or active involvement in industry partnerships on specific topics to raise public awareness of digital safety for children and young people?

Vodafone Group contribute to the following multi-stakeholder groups to help us address risks

to children and keep pace with developments; WeProtect Global Alliance, GSMA Mobile

Alliance and the ICT Coalition. Vodafone Group are also members of IWF - Vodafone Group Services Ltd | IWF Membership | IWF.

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Vodafone markets take part annually in Safer Internet Day (8th February). Examples from

markets are available below:

Vodafone UK - Safer Internet Day

Gaming: Can you keep your kids safe? (vodafone.co.uk)

Vodafone Foundation - Safer Internet Day 2022 | Facebook La Giornata Mondiale della Sicurezza in Rete - Articoli, recensioni app, video tutorial, suggerimenti, quiz, cos'è (vodafone.it)

6. Please provide details of any partnerships with NGO, civil society or other educational agencies or campaigns to raise public awareness of digital safety for children and young people.

Local external partnerships are agreed by markets depending on the local requirements and

key issues. Some examples of ongoing partnerships are included below:

Vodafone Ireland

Vodafone Foundation Ireland have a strategic partnership with the Irish Society for the

Prevention of Cruelty to Children (ISPCC), working towards a joint vision of keeping children

safe by keeping them connected.

Our Partners | Vodafone Foundation

Vodafone UK

Vodafone UK have an ongoing partnership with Digital Awareness UK, with links to digital

awareness resources and expert advice from the organisation. For example, the expert advice

section of the website features a video with Charlotte Robertson, co-founder Digital Awareness

UK, sharing her top three tips for parents thinking about giving their child their first phone. Expert advice (vodafone.co.uk)

Vodafone Spain

Vodafone Foundation Spain have an ongoing partnership with Save the Children - The

Vodafone Spain Foundation presents the program 'DigiCraft Vulnerable Childhood' together

with the Red Cross Youth and Save The Children | Save the Children.

7. Please outline briefly any of your own company initiatives in media literacy and ethical digital citizenship, designed to help children and young people to think critically about the content consumed and created on the internet. Vodafone and The Diana Award developed the ‘Be Strong Online’ programme (as per Question

1), which includes modules on critical online thinking and digital life.

As part of critical thinking online, users learn skills to recognise types of information online

and understand what is true through activities and discussion.

Be Strong Online (antibullyingpro.com)

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8. Please provide details of any advice and supports to encourage parents or teachers to talk to their children/pupils about the opportunities and risks arising from their use of the internet. Vodafone markets have numerous resources available for parents and children on digital life

(as per Principle 6 Question 1). Some specific examples that encourage conversations are

included below:

Vodafone UK

Vodafone UK launched an interactive Digital Pledge tool in 2020, designed to help empower

families to have positive conversations about using technology and the internet. This activity

helps families to set up house rules on how to use tech and behave online. It covers the

following topics:

• Quality screen time

• Being kind online

• Healthy social media

• Happy gaming

Digital Family Pledge Tool | Vodafone

Vodafone UK’s digital parenting magazine frequently includes articles addressing both the

risks and opportunities of children’s use of the internet. The most recent edition features an

article on fake news and teaching children to spot this.

Vodafone Italy

Vodafone Italy’s digital coach has information on setting “good intentions” at the beginning of

the year as a family, including suggestions for children of different ages and parents and

guardians.

Famiglie digitali: 10 buoni propositi per il 2022 - Articoli, recensioni app, video tutorial, suggerimenti, quiz, cos'è (vodafone.it)

9. Please outline any additional activities or initiatives not detailed above that relate to education and awareness-raising offered by your service or product.

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In addition to information submitted related to implementation of the ICT Principles, the following supplementary information supplied in either written form or in discussion with companies provides valuable context and information about the functioning and effectiveness of child safety provision.

1. In respect of ICT Principle 1, that companies should “continue work to provide innovative solutions able to support child safety protection tools and solutions”, please elaborate on company investment in child safety measures, including research. Elaborate also, where possible, on planned future implementations.

2. Any further data that companies may be able to provide regarding the functioning of child safety features would be an extremely valuable outcome of this assessment. Where possible, please provide any available summary data in respect of the following elements. (Stipulate where data should only be presented in anonymised form).

Take up or frequency of use of parental control tools on your product or service? Incidence of reporting use/misuse, categorization and frequency of reports on your product or service? How many? By whom? Which problem? Kinds of actions taken by the provider for different categories of reports. What was the outcome? How do you evaluate the effectiveness of response to reports? Privacy settings: the percentage of children who have private profiles, and those who have changed default privacy settings (and how/what did they change), by age, gender and country Use of location-based services by children Take up and use of education and awareness raising activities undertaken for your product or service?

3. Please detail any additional measures adopted to evaluate the effectiveness of child safety features.