Safety-Net Foundation was not the first Internet hotline to be created; other initiatives appeared
in Norway (Save the Children) and The Netherlands (Meldpunt)733 about the same time as nongovernmental
organisations. The Safety-Net Foundation was renamed Internet Watch
Foundation in November 1996 and was subject to governance and funding reforms in the
following years so as to represent not only the UK Internet industry but wider sectors of society.
Some non-industry actors were involved from the very beginning of the hotline via the IWF
Policy Board.
The initial policy addressing Usenet newsgroups was not proactive. Once a posting in individual
newsgroups was reported to the IWF, the image was assessed and, if considered potentially
illegal, the company hosting the newsgroup was notified about the material. Nevertheless, this
approach was only partially effective, because after removal, the material was posted again in
another newsgroup. Because the IWF staff were only allowed to examine and act in relation to
individual postings which had been reported to them by a third party, there was nothing that
could be done; they had to wait until the new posting was reported again. This situation led to a
policy of automated monitoring which was widened in 2002 so as to implement the removal of
the entire newsgroup if proved that an image had been found there on a regular basis, or if there
was a suggestion of paedophilia content in the groups’ name.734 Around 2002, the use of Usenet
newsgroups was fading in importance in the UK and child pornographic content was
increasingly accessed via public websites hosted domestically or overseas.
Generally, from 1996 to 2002, the IWF recommended UK online intermediaries to remove
alleged child pornographic content by notice and this was in line with the general framework for
the criminal liability of online intermediaries established via the 2000 EU Directive on
Electronic Commerce.735 Overall, the notice and take down (NTD) regime implemented by the
IWF was considered a successful initiative in removing child pornographic content hosted on
UK servers. For example, since 2002, less than 1% of child pornographic content reported to the
IWF has been found available on websites hosted in the UK.736 Nevertheless, these figures took
into account only the UK public websites reported to the IWF and thus, it may be suggested
that, these numbers night be higher than reported, because many websites or other online
repositories hosted in the UK, be they public or closed, might go unreported on the hotline. In
addition, these figures excluded child pornography available via other Internet applications