Big tech accountability? Read how we got here in  The Closing of the Net 

In 2009, Vodafone lobbied the EU for the right to restrict the Internet. Now it uses deep packet inspection (dpi) to implement  content censorship.


---Updated on 17 January 2011 - please see below.---


 On Christmas Eve my Blackberry was reset by an automated security update which wiped  the functionality and left me with a white screen saying ‘app.error'. This chance situation led me to uncover a censorship system which Vodafone has put in place without informing me.


As  a  Vodafone customer of  some 15 years, I had a  polite conversation with the call centre operator who took my call. But  as a policy analyst, her responses to my questions about traffic management policies gave me cause for concern.


A little investigation afterwards revealed that Vodafone has put in place a ‘content control'  system which is a form censorship, because it  puts restrictions on the content where the decision to restrict has been taken by a third-party and not by me. The fact that it is a corporate administrator, and not the State, is irrelevant. The system has been developed  outside of European jurisdiction,  by a company which has no accountability to European policy-makers and which appears to be implemented via 

 an underlying traffic management system, using deep packet inspection (dpi).


I had called Vodafone to ask for help in sorting out the security update, but also to complain about it. I pointed out that these updates are beginning to interfere with my use of the Blackberry, for example, wiping off data if I was in the middle of something when the update commenced.


I took the opportunity to ask  what is  Vodafone's traffic management policy? The young woman, who told me she was the first line of technical support, did not know what a ‘traffic management policy' is, but she sort-of understood what I was getting at.


She told me that Vodafone do not put restrictions on Blackberry applications (those which can be downloaded from the Blackberry store), nor on Vodafone Live applications. "Other than this, we would not know if they were trusted and safe", she said.


I picked up on the ‘trusted and safe' line and eventually she revealed that I have ‘content controls' on my service. She informed me - for the first time in the two years that I have had the Blackberry - that content controls are implemented be default. When I asked what is blocked by these services she it was adult content, and banking and finance services.


I asked for more details - who decides what content is blocked? What are the criteria for taking that decision? How would they handle content which is legal and available in British supermarkets but still may fall into an ‘adult' category, such as the  so-called  ‘lads mags'? She did not have an answer, but told me to look at Vodafone's website.  


She offered to remove the ‘content  controls' for me, and did so immediately. It was a friendly conversation, she was bright and efficient.


The restrictions don't really affect me at the moment, but  I am nevertheless  concerned that Vodafone  is putting in place restrictions without telling me.


European law - the Telecoms Package - requires Vodafone to inform its customers of its traffic management policies, and of any restrictions to the service. Vodafone itself lobbied for these provisions - that is, Vodafone lobbied for the right to impose restrictions on its subscribers, and the outcome was a provision which says they may restrict as long as they tell us, but there is no other regulatory barrier to them doing it. Vodafone worked together with the UK regulator, Ofcom, on this provision. 


After the call, I took the opportunity to investigate. Here's what I found.


On a page entitled "What content and services will be barred by Content Control?" Vodafone's website says that  Content Control limits access to (among other things) the mobile internet outside of the Vodafone live! portal.


That is a very wide description, which means that Vodafone could restrict access to anything it chose to - and  with the Wikileaks saga in mind, this is a very dangerous situation for free speech.


Vodafone's website also says that  Content Control works on websites containing adult content - eg gambling, erotica, chat and dating services and violent games. Websites containing adult material are categorised through a web filtering system.


It does not say anything about banking, payment or finance sites, so if the call centre operative is correct, they Vodafone is hiding information from us - Vodafone, please clarify.


But here's  the real point of my story. Vodafone's web page invites you to to third-party web page  "for more information".


This page gives no information at all about the criteria or the blocking system, but a logo suggests that the provider of the ‘content control' system is a  Californian company called BlueCoat Systems. 

BlueCoat Systems is  a vendor of sophisticated filtering systems, based on deep packet inspection (dpi) systems. Here are some claims from BlueCoat Systems' PacketShaper product line:

 "Unmatched auto-detection of both applications and Web content categories makes Blue Coat PacketShaper a complete visibility and control solution for today's Web-heavy traffic. PacketShaper lets you measure network application performance, categorize and manage Web traffic based on its content, guarantee quality-of-service (QoS) for preferred applications and content, and contain the impact of undesirable traffic."

 "Discover and monitor more than 700 applications with deep Layer 7 deep packet inspection for an accurate picture of application traffic, plus tens of millions of Web sites by content category. Standard on all PacketShaper models."


Web Content Assessment - Measure and report on all Web traffic in 80 content categories, such as gambling, job search, web advertisements, and pornography.


The latter  appears to be what Vodafone has installed as its default for all customers: It is called K9 Web Filtering , a subisidiary of BlueCoat, also based in California. We do not know who draws up the  blacklists nor the  criteria. But it makes the following claim:

"Blue Coat's Web filtering technology enables you to block entire categories of content, such as pornography or gambling, or block specific Web sites, such as Facebook."


So... Filtering is the Internet method of  censorship.  'Content controls' block content and make judgements as to what is 'legal' and what it not legal. Operators of the websites which it is blocking have a right to know if they are being blocked, and users have a right to know what they cannot see.


Why should people in Britain be censored by a company in California, which is  not accountable to British citizens or policy-makers?  And why should Vodafone, or any other operator, have the right to put censorship software onto their subscribers, with no accountability to the regulator or to the citizens?


Post-script. The Blackberry was bought back to life very quickly by the call centre operator. 


Correction and update 17 January 2011

I have been contacted by Blue Coat Systems.   Vodafone  does use a system for content control which is supplied by Blue Coat Systems  but its method of operation is different from that which I have described above. The system operated  by Vodafone does not include the PacketShaper product, nor does it use the K9 system.

The system is installed as the default for all Vodafone users unless they ask for it to be de-barred. It works on the basis of URLs. The system does classify content on the basis of a database of websites held and compiled by BlueCoat Systems. I’m even advised that iptegrity is in this database and am awaiting further information.  


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This article is licensed under a Creative Commons Attribution Non-commercial-Share Alike 2.5 UK:England and Wales License. It may be used for non-commercial purposes only, and the author's name should be attributed. The correct attribution for this article is: Monica Horten (2011), How Vodafone censors your Internet 6 January 2011 . 



Iptegrity in brief is the website of Dr Monica Horten. I’ve been analysing analysing digital policy since 2008. Way back then, I identified how issues around rights can influence Internet policy, and that has been a thread throughout all of my research. I hold a PhD in EU Communications Policy from the University of Westminster (2010), and a Post-graduate diploma in marketing.   I’ve served as an independent expert on the Council of Europe  Committee on Internet Freedoms, and was involved in a capacity building project in Moldova, Georgia, and Ukraine. I am currently (from June 2022)  Policy Manager - Freedom of Expression, with the Open Rights Group. For more, see About Iptegrity is made available free of charge for  non-commercial use, Please link-back & attribute Monica Horten. Thank you for respecting this.

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