The first and most obvious problem is most of the content is foreign, so any south african laws cannot be enforced; they’ll just ignore your demands for “assessment”.
Tuesday, 14 April 2015
open letter to Film and Publications Board on censoring the internet in South Africa
I’ve read the above regulations. And while I can see that the interests of the children are at heart, speaking as a parent myself, I must say I think you are wasting your time and are merely going to kick up a huge amount of opposition to this legislation.
I am an ICT expert with 30 years’ experience.
Let me tell you why you cannot enforce this and will not succeed, and will end up annoying everyone rather than achieving your goal.
1. Youtube. I’ve seen figures between 120 million and 500 billion as the quantity of videos. In either case, it is not possible in a human lifetime for anyone to watch all of those to decide which have failed to pass acceptable standards of the FPB. In particular, many videos are no longer maintained by their authors, nor will their authors yield to demands to submit the material for review by FPB. Nor will you have the man-hours available, even if you hire the entire adult population of our country, to police, view or censor the videos. There is nothing you can do, short of blocking youtube as North Korea, Iran, and other similar states do.
2. Bittorrent. You cannot really stop Bittorrent. It uses randomised TCP/IP port numbers, meaning that you’d have to block all TCP/IP ports above the reserved ports to stop it. If you do this, however, web responses won’t come through and the web will stop working, since the reply to a TCP/IP request from a web browser comes in on a non-reserved port, usually in the 20000s, which is the same port range Bittorrent uses. Furthermore, Bittorrent contains encrypted portions of files, so for any packet of Bittorrent data, you cannot tell what it contains; it could be something completely legitimate, e.g. a Linux distro.
3. Games. Apple’s App Store contains over 260 000 games. Are you going to individually contact all those game developers and demand that they submit to your review? Do you have the manpower to review that many games? Suppose a person reviews 1 game every 10 minutes. Suppose they take a 1-hour lunch break, and work 7 hours a day. That means they can review 42 games per day. You will need a staff of about 6200 to review all the app store games in one day. If you want to do it within one year, you will need about 17 staff members just for that. Assuming an annual salary of R 300 000 each, your salary budget per month just to check existing games will be R 5 m. However, since the app store has existed for about 7 years, this means that about 37000 games are added per annum - so you will need an additional person per month just to keep up with the new games coming in (assuming that it’s not exponential, i.e. that the number of games is not doubling each year, which it may well be… i.e.:
app store year 1: 4062
app store year 2: 8 125
app store year 3: 16 250
app store year 4: 32 500
app store year 5: 65 000
app store year 6: 130 000
app store year 7: 260 000
app store year 8: 520 000
as you can see from the above figures, it’s quite plausible that it might be doubling every year. In which case, you’ll need 34 staff members next year, and then 68 the year after that, and then 136 the year after, etc.
Of course, you CAN just tell Apple and Google to not allow game access to South Africa unless developers explicitly approach you themselves to have their games reviewed. Since the middle class market for mobile app games in this country can’t be more than about 2m people, and assuming that only 10% have iPhones, that means that about 200 000 people will be irritated by your legislation because most apple developers won’t bother (the market is too small to care). I don’t think you want to deal with 200 000 angry phone calls.
4. Videos generated by end-users, e.g. selfies, amateur porn, etc. There’s still nothing to stop people making their own videos within South Africa and sharing them. You cannot stop this, or censor it. Almost every cellphone above a basic Nokia can do this. Are you going to remunerate Vodacom, MTN, et al., to view EVERY video and censor it if it contains porn content? You can’t tell without eyeballing it, and again, that imposes a human labour burden on the ISPs.
5. There are MANY other ways to share files without Bittorrent, e.g. Wetransfer, Dropbox, Google Drive, etc. You will have to block all cloud services, again, irritating your entire taxpayer group.
6. Proxying. Anyone who has any clue about using a computer will figure out that you simply need to route your internet through a foreign proxy server, and thereby anonymitize their data, and prevent it from being possible to tell what protocol and what content is being shared.
7. You will push hosting to overseas servers which are in fact cheaper, and damage the south african ISP industry, since people will no longer be able to host adult content inside south africa without first incurring costs to FPB. This is an easy move for people to make, requires that one doesn’t even leave one’s chair, and requires that one doesn’t expose one’s content to FPB for review. It’s just a matter of copying files to a new ISP and changing DNS. This is what local pornographers will do. You will not prevent it.
I predict your legislation will fail and will be unpoliceable due to the sheer volume of data on internet.
I believe this legislation is naive and is unconstitutional in terms of the right to privacy.
I propose, instead, that FPB offers training courses for teachers and for parents on how to recognise use of online porn in children, and where children are vulnerable to stalkers, and similar, and educate parents and teachers in how to prevent it, e.g. by regularly changing their wifi password, regularly inspecting their children’s phones, etc. If you actually want to make some money out of this problem, rather charge for training courses. I am sure many parents ARE concerned about their children accessing porn, but just do not know how to stop it.
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