Internet Watch Foundation

 

At the CAI working Group meeting it was agreed that in order to allow non-members the opportunity to license the CAI service, certain checks and balances will need to be made to help ensure that the potential licensee is a “suitable” company or organisation to have access to this sensitive data.

 

It is also accepted that although the data is time limited, the deliberate or unintended release of the data to the public, could undermine confidence in the service and damage the reputation of the IWF. The data is currently delivered by secure electronic means but where the recipient body is unable to electronically convert the data into a filtering system without human intervention then a risk of leakage is conceivable if the person so employed abuses their position of trust.

 

To minimise the risks, the working group proposed that the IWF undertakes a due diligence process in order to assess any company or organisation that seeks to license the service.

 

For UK licensees, the companies or organisations will have to pass the following tests:

1)                 That the company or organisation is a registered corporate body in the UK and is registered at Companies House, with the charity commission, or with other recognised bodies.

2)                 That the company has filed annual audited accounts (for a minimum of two years trading) and that those accounts are made accessible to the IWF if requested.

3)                 That, where possible and practicable, a representative of the IWF or other nominated person will meet with representatives of the company or organisation to verify their location and suitability.

4)                 That the directors, managers or similar officers can be identified and verified

5)                 That the company or organisation is prepared to enter into the agreement to take the CAI service.

6)                 That the company or organisation has no ties (see note 1 below) to the UK or overseas sex industry, or to any other form of activity that may be considered incompatible with the objectives of the IWF.

7)                 That the company or organisation can identify and name an individual who holds a trusted position and who will handle the data if it is to be manipulated by human intervention.

 

For overseas organisations or companies the following tests will apply:

 

1)                 That the company or organisation will provide certificates, registrations, authorisations or licences to operate.

2)                 That the company will provide annual audited accounts (for a minimum of two years trading) and the office details of where they are filed for corroboration.

3)                 That the directors, managers or similar officers can be identified and verified.

4)                 That the company or organisation is prepared to enter into the agreement to take the CAI service.

5)                 That the company or organisation has no ties (see note 1 below) to the UK or overseas sex industry, or to any other form of activity that may be considered incompatible with the objectives of the IWF.

6)                 That the company or organisation can identify and name an individual who holds a trusted position and who will handle the data if it is manipulated by human intervention.

 

Additional due diligence may be performed on any company or organisation that is deemed by the IWF executive to warrant further investigation before entering into any agreement.

 

Any company or organisation, which has approached the IWF to obtain the list but is deemed unsuitable following the due diligence process, will be informed of the decision and reason for refusal.

 

When the IWF executive is unable to decide upon the suitability of an organisation or company the matter will be referred to an IWF Board sub committee to decide.

 

Any company or organisation whose initial application is refused will be permitted to address their failings and re-apply.

 

Any company or organisation that fails the due diligence process may appeal to the IWF Board. If the decision to refuse an application was made by a Board sub committee then Board members associated with that refusal will be disqualified from participating in the appeal process. The Board decision will be final.