Food can be delicious, but certain foods can cause people physical pain or, in some cases, death.

In most parts of the civilised world, governments have food safety laws. They mandate how to properly prepare, store, label, and serve food.

In the UK, the laws are onerous for a large food manufacturers because we recognise that introducing pathogens into the supply-chain could cause mass harm.

But even small food shops are subject to food safety regulations. They have to show that their staff are trained to keep customers safe because, again, mislabelled food can kill.

What about if you're cooking for yourself - do you need to have a food hygiene certificate? No. You are trusted to look after yourself and your family.

How about if you invite friends round for dinner - are there any laws governing that? Again, no. It's probably sensible to ask about allergies, but there aren't any regulations about serving friends undercooked burgers.

Having a big BBQ? Here's some general guidance which is easy to follow if you want to keep people safe.

What about starting to get a little bigger? Want to do a lot of cooking for a charity event? You don't need to register as food business nor do you need a hygiene certificate, but you do need handle food safely.

Serving food to a vulnerable group? You need to take special care - especially around pathogens and common allergies.

And, as you start to professionalise and sell food, you'll need to register and consider food safety training.

That all sounds pretty sensible, doesn't it? Food can cause harm. You can do what you like domestically, but ought to take care. If you start interacting with the public, there's some basic guidance, when you get bigger there's more admin because there's more risk. Food Safety is important.

So let's talk about Online Safety.

Ofcom are now charged with regulating online safety in the UK and they've started to produce guidance about what that means.

Can online material cause harm? Yes. Anyone who has seen distressing images knows how frightening and upsetting they can be. Violent threats might be from someone with no intention of acting upon them, but the threat itself is terrifying and you have no way of knowing whether it will lead to physical harm. Some content is specifically designed to give people dangerous eating disorders. Society at large is harmed when young people are radicalised into violent ideologies. Some websites encourage suicide.

Online harms are real harms. It's easy to make jokes about the police arresting people for memes, but the reality is much grimmer than the headlines. So - for better or worse - the government are trying to reduce the harms present in online spaces.

If you accept that certain online activity can have a detrimental effect on people, what guidance and regulations would you create?

The official guidance is vast⁰ and seems daunting. Some people are freaking out. But the prosaic reality seems much less terrifying. And, in many ways, similar to food safety laws.

Running your own website just for yourself? Basically there doesn't seem to be a problem. You probably shouldn't do anything to harm yourself. If you're publishing other people's comments, you probably moderate them anyway to prevent spam and, hopefully, you're not publishing the ones with illegal images.

Starting to get a bit bigger, maybe running a forum? You need to think about what risks you face. Are people likely to upload dangerous content? What steps could you take to prevent that? It's probably a good idea to set an acceptable use policy and document how you'll respond if one of your users does something which might be harmful. These sorts of things are pretty standard, so hopefully not a big imposition.

Dealing with lots of user generated content? You're going to need a big "report abuse" button near it. But, again, if you've been running a service for any length of time, you've probably already done that. People post stupid stuff all the time and users are always reporting each other to a moderator.

Do you have user-to-user private communications on your site? What will you do if someone complains that they are being groomed, threatened, harassed, or otherwise made to feel unsafe? Sorry if I sound like a broken record on this but, again, this is the basic sort of community hygiene most sites should have already implemented.

Primarily targetting children? Again, I hope that you already have processes in place to ensure that they're not being exploited to unwittingly exposed to content that may harm them.

I'm not going to lie; there is a lot of documentation to review. Far too much for a small site to cope with¹. There's a basic checker to see if your service is in scope but not much else yet. Having started to grind through it, there's very little that seems unreasonable to a small website owner like me.

In many ways, I liken it to GDPR. When that came in to force, lots of sites said that they were simply unable to comply with the regulatory burden. I don't doubt some of them closed, but do you really want to interact with a site which won't protect your email address and other data? That's a bit like choosing to eat a kebab from a restaurant which doesn't keep its raw and cooked meat separately.

Small restaurants need to protect their customers from food-based harm.

Small organisations need to protect their users from data-privacy harm.

Small websites need to protect their users from online-related harm.

As a website owner, at what level do you think people need protecting from your actions?

But.

OK, that's the most positive spin I could put on it. How do I really feel?

Well, look. Most of this is a massively over-engineered piece of crap. You can see where every possible policy objective was crammed in with no thought about the holistic experience. The way this has been (mis)communicated has been terrible - and that isn't helped by the lack of concise guidance and available tooling.

Seriously, if your policy can only be expressed in dozens of PDF files then something has gone seriously wrong. When individuals have to take time to create a usable summaries, that indicates a massive failure in process.

There's a whole bunch of stuff around pornographic services which troubles me. Not because I produce any² but because porn has been a traditional "over-reach" subject. Sex education, especially in the QUILTBAG community, is often treated as pornographic rather than educational.

I'm quite annoyed at both age "verification" and CSAM scanning requiring site owners to pay large commercial companies to provide these services. If something is mandatory, there should be a publicly provided option.

While I don't think small sites should be completely exempt - it would be far too easy for a deliberately harmful site to use that as an excuse - there needs to be more recognition that the Web isn't just Facebook and TikTok. Most of this seems to be written for large organisations. Which means small organisations are scrambling to understand what it means for them - join the Promising Trouble community to find out more.

The Web isn't the "Wild West" - it has been an established platform for decades. All the "crying wolf" about government censorship makes our industry look ridiculous - but it is easy to see why it happens when policies are this badly communicated.

Frankly, it was irresponsible for Ofcom to launch all this guidance without providing the tooling to help users understand which parts of it are necessary to them³. And I'll bet they didn't do any user testing before publication.

So we're at a stage where everyone is losing their minds over what should be a simple codification of existing best practice.

The cumulative effect of legislation mandating data protection, accessibility, security, and protection from harms is probably a good thing. I don't want a web which leaks my information, hurts my disabled friends, causes a DDoS, and exposes people to content they don't want to see.

But, to return to my original analogy, this guidance is rather like telling every home-baker that they now need to comply with all the rules pertaining to an industrial slaughterhouse.

(Skip the background and jump to the survey)

Background

Way back in the mists of time - 2004 - Ofcom decreed that "Voice over Broadband" was going to be the next big thing. VoB (which is like VoIP, but specifically tied to a broadband line) would receive the prefix 056.

In that document, they suggested a price cap of 5 pence per minute - considerably lower than other services - in order to stimulate the market. It was big news at the time:

Nowadays, 056 numbers are known as Location Independent Electronic Communications Services. If you sign up for a VoIP / SIP service you can probably get one for free. But no one knows how much they cost to call.

Ofcom say that 056 numbers are prohibited from revenue sharing, so they should be cheaper to call than, say, 070 numbers.

Mind you, they also say:

Take-up of 055 and 056 remains low and the numbers are rarely seen

Ofcom's National Numbering Plan doesn't set any "Applicable tariff principles and maximum prices" for the range. Their "Call costs guide" doesn't even list 05 as a valid code.

This has led to a slightly strange situation where costs to call 056 numbers are really hard to find.

GiffGaff are the only company I could find which make it easy to see the costs - 8p/minute. And they're not included in bundles.

EE charge 40p/minute on PAYG. There's no info on contract prices.

O2 list all 05 numbers as 55p/minute.

Three rather vaguely say they're 10.2p to 15.3p/minute. But, again, nothing on contract.

BT list it as a "g21" call which is 36p/minute.

Vodafone's advisors thought it cost 65p connection charges and 55p/min. Then said premium rate. But were unable to point me to a published price guide.

In the end, I spoke to Vodafone, EE, and Three - none of them could confirm how much an 056 number costs to call!

I also tried finding the costs out from a bunch of MVNOs, none of them published the prices, nor could their customer service reps tell me. This is almost certainly in breach of term C2 of Ofcom's General Conditions.

Except Smarty - who say that they're out of bundle 12.9p/minute.

I emailed Ofcom who, in fairness, replied back quickly:

I should clarify that the cost for calls to 056 numbers are charged at a non-standard rate, so we cannot advise about the cost. However, we would expect providers to be able to tell you what they would charge for calls to certain number ranges.

If you are unhappy with the information given to you by your provider about the call costs, I recommend taking the steps outlined within their complaint’s procedure.

A Crowdsourced Experiment!

Would you care to take part in an experiment? I'd like you to give me a call on:

+44 560 34 789 34🔗

It should play one minute of music and automatically hang up. If you could please tell me how much it costs to call, what network you're on, and whether you're contract or PAYG. It might be the case that 056 is counted as one of your inclusive minutes - that would also be useful information.

Stick your network and costs in the comments section please, or fill in this form:

THANKS GANG!

These are my notes on the session. I've applied the Chatham House Rule - mostly because I can't remember who said what, rather than any backroom skulduggery. Any errors are mine and mine alone.

Neither Vodafone nor EE have signed up to the Network Neutrality pledge. O2 have.

(Disclaimer, I work for Telefonica, these thoughts are my own.) The Open Internet Code of Practice is the Government’s non-regulatory approach to net neutrality.

It basically says that ISPs will not discriminate between services, and if they do they can't call their product "Internet Access". It's all fairly sensible but O2 is the only mobile ISP who have signed up. This means the vast majority of 4G providers could start to block or degrade services which they think don't fit their business model.

Indeed, EE say they don't ban VoIP but want the right to filter such OTT services.

Ed Vaizey's form of "free market" capitalism states that because we have such good competition in the UK, people will be free to switch to other services which don't break the net. This conveniently ignores the fact that customers are tied in to 18 month long contracts (24 months if they want EE's 4G) and so are not able to easily switch.

Net Neutrality also offers some other interesting questions. VoIP and TVoIP have vastly different needs when it comes to latency - is it acceptable to prioritise a constant VoIP stream? Yes - assuming all streams of a similar nature are treated equally.

Of course, if those services are encrypted it could be very hard to tell which services are which.

Finally, emergency service calls are prioritised on the radio access and given network priority. Is that discrimination? Yes - but broadly acceptable in a net neutrality context.

Speed of Rollout

The 4G rollout is expected to be quick - much quicker than the 3G deployment. This is due to a number of factors.

• The auction has been brought forward.
• With EE having a head start, other operators will have to compete rapidly.
• Spectrum is expected to be much cheaper than the 3G bands. This means there will be more money for masts and networking kit.
• Mast sharing and relaxed planning permission should make setting up the network much more efficient.

Transco

There is only one electricity grid. One water network. One set of gas pipes. Yet different companies can sell different services at different prices across them. This idea is known as "Transco".

In the UK we effectively have only two mobile networks. EE (T-Mobile and Orange - who share with Three) is one, Vodafone/O2 is the other (they share masts, not spectrum and network kit).

All the major providers have outsourced the running of their network to NSN or Ericsson (an idiotic idea, but there we are).

Each company has to bid billions for new spectrum and spend millions on new masts and networking kit. Wouldn't it be more sensible if there were a national mobile network with O2, Vodafone, EE etc just acting as MVNOs? Each could buy wholesale access (and still run their own customer databases etc) at a vastly reduced cost and the public should benefit from improved coverage.

There seemed to be a lot of sympathy in the room for this idea. Apparently the Netherlands is investigating "National Roaming" which would allow your phone to roam on to a competitor network if you didn't have any signal.

One other point of interest - Ofcom apparantly want to see a non mobile operator in the 4G space. Perhaps someone selling wholesale or M2M access.

Speed

There are serious worries around real world speeds - as noted by EE claiming only 12Mbps downlink speed. Given the hype around the speeds is not likely to be met by real-world experience, this could deter customers.

The mobile industry may also be overselling capacity. ADSL suffers from insufficient backhaul - domestic ISPs bank on users only using the internet in short burst so don't buy enough connectivity. If we're all streaming movies all the time - speeds will suffer.

Price

Will customers pay?

There has been much derision over EE's pricing as being far too high and restrictive. Considering how long it took to build up a 3G customer base, can the industry attract customers to 4G when the coverage is patchy, phones are expensive, and battery life is worse? If they do - can they convince them to pay a premium for it?

Consider domestic ISPs. Pipex offered dial-up internet access for 50p a day back in 1996. Today, 16 years later, that £15 per month will get you "superfast" 24Mbps Internet access.

Technology brings prices down - even if they blip up temporarily. No doubt when other players enter the 4G market, prices will tumble.

Finally...

What will people do with 4G? Most people expect "The same, but faster". Can we find new services, or are we stuck with better speed, lower latency?

That's not a bad thing to be stuck with, but I wonder what the "killer app" will be that makes people want a 4G phone in their pocket... We all thought that 3G's killer app would be video calling. How wrong we were!

So you can avoid the situation where a number is spoken on a show, or in a song, and everyone tries to call it - much to the annoyance of the owner of the number.

That's the US - did you know the UK also has a similar set of reserved numbers?

OfCom have a list of numbers suitable for for use in drama. They're numbers which will never be connected - and therefore are suitable for use as "demo numbers" in an app.

For mobile numbers, the range is 07700 900000 to 900999.

Why Use Them?

I'll tell you a story from waaaaaaay back when I used to work at Vodafone. We'd recently put a site live which asked people for their phone numbers when they registered. Within an hour of go-live, our engineer's phone started ringing. And ringing. And ringing. He'd stuck his number in as an example.

Guess what, people call numbers. People are - basically - stupid.

So, the engineer changed it. To what he thought was a completely random number. That's when we can a call from "upstairs". The "random" number was a string of consecutive numbers - 1234567 etc. That's a "memorable number" and, consequently, was sold for thousands of pounds. The trade in mobile numbers is similar to those of car vanity plates. So, we had a chap who was spending thousands of pounds with us pissed off because his number was plastered all over the web.

Lesson learned! If you need to use an example number, pick 07700 900123 or similar.

"[Blog posts are] a tale told by an idiot, full of sound and fury, signifying nothing."

Today Ofcom published the responses it had for its consultation on plans for the BBC to encrypt its HD broadcasts.

The blogosphere went nuts! DRM? Not on our watch.  Boing Boing mobilised its army of commentators, the BBC published two blog posts which quickly filled up with comments, Facebook statuses were updated and all these links were retweeted until our fingers were worn to their nubs.

No doubt Ofcom has collapsed under the weight of public opinion. How can the BBC possibly hope to get away with their fiendish plans with such a backlash?

90 People

Ninety.  Less than one hundred.  Smaller than the viewing figures for BBC Three.  That's how many people could be arsed to type a few dozen words to Ofcom, spell check them, then hit send.

More people signed a petition asking for a Yorkshire sign to be erected on the M1 than responded to this consultation.  Now, maybe my finger is off the pulse, but I haven't seen major blogs crying foul over Yorkshire's lack of signage.

On The Plus Side

You can read my response on their site.  Like all the others I've read, it's against the proposals.  I haven't read every response, but the twenty or so that I downloaded were all against the plans.

I know that there's typically low turn out to consultations of this kind.  Organisations know that for every person who bothered to complain, there's more waiting in the wings quietly seething.

But only 90 people?  I realise that the power of retweeting helped free Iran from a stolen election, but sometimes you actually have to do something.  You don't even need to get off your computer.  Find an email address, write a few sentences and let those in charge know how you feel.

This will help get you started.

• List of government consultation websites
• Public Consultations in your area
• Ofcom Consultations