National implementation report for sms billing and mobile payments in slovakia

National
Implementation
Report
Slovakia — National Code for mobile operators on safe use of mobile
services
April 2010

European Framework Report: Slovakia 1
Contents
Executive summary 2
Introduction 3
Implementation of national code of conduct 5
Access control mechanisms 5
Raising awareness and education 6
Classification of commercial content 8
Fighting illegal content on mobile community products or the Internet 9
Other 10
Stakeholder cooperation on child protection 11
Conclusion 14
Annex I - European Framework for Safer Mobile Use by Younger Teenagers and Children 15
Annex II - National Code for mobile operators on safe use of mobile services 18

Executive summary
The European Framework for Safer Mobile Use by Younger Teenagers and Children (the
“Framework”) is a self-regulatory initiative of the European mobile industry. It contains
recommendations designed to ensure that younger teenagers and children can safely access content
on their mobile phones. As of April 2010, there are 83 signatory companies implementing the
Framework through the roll-out of national voluntary agreements (Codes of Conduct). A further
eight mobile operators have only signed up to a national code of conduct but as such are still
participating in the initiative. Codes of conduct are currently in place in 25 EU Member States and
under development in the remaining two. This means that around 96 per cent of all mobile
subscribers in the European Union benefit from the Framework.
This report has been prepared by mobile operators as part of a third review of the implementation
of the Framework in the European Union, with a particular focus on how they have implemented the
provisions of their national code of conduct. In the case of Slovakia, the report tracks compliance in
relation to the National Code for mobile operators on safe use of mobile services.
All of the Slovak operators report compliance with their code of conduct. The code, signed in January
2008, included an implementation deadline of 31 December 2009. In terms of access controls, all
have systems in place to block access to adult content on their portals. In the case of Orange
Slovensko and T-Mobile Slovensko, this system can be activated by the customer sending an
“18STOP” message free of charge from their handset, or via the WAP page. All operators reported
that contracted content providers are required to sign undertakings committing themselves to
compliance with the code of conduct.
As regards education and awareness-raising, all three operators have developed specific web pages
on their websites dedicated to child protection. Orange Slovensko is now in the second year of its
project which sends internet safety advisers into schools to discuss issues with children, including
children of primary school age. Telefonica O2 reported that trained staff were available in each of its
stores to advise on child protection issues, and T-Mobile Slovensko has prepared a range of
materials and training aimed at children, parents and teachers for use in its partnership with
eSlovensko (projects: Zodpovedne.sk , Stopline.sk, Pomoc.sk and ovce.sk).
All operators classify their own content, where provided, and have signed contracts with their third
party content providers to ensure that they classify their content. With regard to illegal content,
Orange Slovensko and T-Mobile Slovensko reported that they had (in October and November 2009
respectively) introduced a technical solution that blocks URLs known to host illegal child abuse
content on the Internet. Orange Slovensko provides a dedicated hotline number and notification
form to allow customers to report suspected illegal content. All companies cooperate with the
national authorities in the fight against illegal content, and Telefonica O2 and T-Mobile Slovensko
have participated in the establishment of the national hotline for reporting illegal content and
conduct online – Stopline.sk (operated by eSlovensko).

Introduction
This report has been prepared by mobile operators as part of a third review of the implementation
of the European Framework for Safer Mobile Use by Younger Teenagers and Children (the
“Framework”) in the European Union.
The Framework is a self-regulatory initiative of European mobile operators, which puts forward
recommendations to ensure that younger teenagers and children can safely access content on their
mobile phones. It was issued in February 2007 following the consultation of child protection
stakeholders in the European Commission’s High Level Group on Child Protection. A reproduction of
the Framework is available in Annex I of the report.
Fifteen signatories at group level (55 national mobile operators) initially signed up to the Framework
on Safer Internet Day, 6 February 2007. As of April 2010, there are 83 signatory companies
implementing the Framework through the roll-out of national voluntary agreements (“codes of
conduct”). A further eight mobile operators have only signed up to a national code of conduct but as
such are still participating in the initiative1
.
The recommendations of the Framework cover the following areas:
 Classification of commercial content — mobile operators’ own and third party commercial
content should be classified in line with existing national standards of decency and
appropriateness so as to identify content unsuitable for viewing by younger teenagers and
children.
 Access control mechanisms — appropriate means for parents for controlling access to this
content should be provided.
 Education and awareness-raising — mobile operators should work to raise awareness and
provide advice to parents on safer use of mobile services, and ensure customers have ready
access to mechanisms for reporting safety concerns.
 Fighting illegal content on mobile community products or the Internet — mobile operators
should work with law enforcement agencies, national authorities and INHOPE or equivalent
bodies to combat illegal content on the Internet.
The Framework recommendations are not prescriptive. Mobile operators have implemented them
in different ways to reflect the diversity of their services and marketing models, as well as to cater
for national societal norms and values. National codes of conduct are currently in place in 25 EU
1
An overview of signatories per EU Member State is available at
http://www.gsmeurope.org/documents/List_of_signatories_Dec_09.pdf

Member States and under development in the remaining two2
. This means that around 96 per cent
of all mobile subscribers in the European Union benefit from the Framework.
This report sets out how mobile operators have implemented their national code of conduct in
Slovakia, namely, the National Code for mobile operators on safe use of mobile services. A
reproduction of the code is available in Annex II of the report. The Slovakian code was signed in
January 2008. The signatories of this code are: Orange Slovensko, a.s., T-Mobile Slovensko, a.s., and
Telefónica O2 Slovakia, s.r.o.
The report’s contents are based on information gathered from the signatories, as well as a child
protection stakeholder, on the basis of a questionnaire in the period February-March 2010. The first
part of the questionnaire addressed compliance with the recommendations of the national code of
conduct. The second part of the questionnaire posed questions to a third party, concerning mobile
operators’ role in protecting children in their country of operation. The main findings are presented
below. Two third parties responded: Ms Mária Tóthová Šimčáková (professional guarantee and
supervisor of the Orange Slovensko project ‘Children & mobile telecommunication technologies’),
and for the NGO eSlovensko, Mrs. Marcela Alzin.
2
Austria, Belgium, Bulgaria, Cyprus, Czech Republic, Denmark, France, Germany, Greece, Hungary, Ireland,
Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain,
Sweden and UK. The codes can be downloaded at http://www.gsmeurope.org/safer_mobile/national.shtml.

Implementation of national code of conduct
This part of the report contains information on how individual mobile operators have implemented
the provisions of the Slovakia National Code for mobile operators on safe use of mobile services It is
subdivided into five sections, which correspond to the four high level areas of the Framework and
other recommendations of the national code of conduct that go beyond the scope of the
Framework.
Access control mechanisms
The recommendations of the Framework relating to access controls are as follows:
1. Mobile providers should not offer any own-brand commercial content which would be
classified as only suitable for adult customers in equivalent media, without providing
appropriate means to control access to such content under parental control.
2. Appropriate means to control access to content should also be applied where content is
supplied by contracted providers of third party commercial content which would be classified
as only suitable for adult customers in equivalent media.
3. Additionally, individual mobile providers should offer capabilities which can be used by
parents to customize access to content by children using mobiles. These may include specific
services, phones, barring or filtering, and/or billing control.
The relevant provisions of the national code of conduct on access controls are as follows:
"5.1) The Contracting Parties undertake that after signing this Code they will not offer without
securing the possibility of controlling access, via methods of controlling access determined in this
Code, any of their own commercial mobile content that is according to the Common classification
of content determined only for adults. 2) The Contracting Parties undertake to use the methods
for controlling access determined in this Code also in relation to commercial mobile content that
is according to the Common classification of content intended only for adults and that the
contractual suppliers of mobile content supply. 3) If a Mobile operator provides or enables access
to commercial mobile content intended only for adults, it is obliged to also provide the option of
controlling access to it via suitable methods for controlling access. 4) Suitable methods for
controlling access to commercial mobile content are regarded as being only such methods that
within the scope of their use clearly verify the identity and age of the subscriber or the user
communicating in the matter of controlling access to services intended only for adults...7) This
Code does not order mobile operators in any case to use a specific method for controlling access
and it does not prevent the adoption of wider technical measures for controlling access to
commercial mobile content. Each mobile operator can choose for fulfilment of the commitments
according to this Code various technical and organisational solutions for controlling access to
content.”
Mobile operators have implemented these provisions as set out below.

O2 Telefonica O2 Slovakia reported that it did not currently offer any own-brand adult
commercial mobile content. However, on customer request, Telefonica O2 can deny
access to third party adult content providers.
Orange Orange Slovensko reported that it provided access controls to restrict access to adult
content on its portal to only those who have been verified as being over 18. When a
customer tries to access this type of content, he will meet a screen which requires
him to enter his phone number and a 4-digit code, which is assigned only on
production of valid ID in a store, and then posted to the home address. Orange
Slovensko customers can also block mobile adult content by sending an “18STOP”
SMS message free of charge. Premium-rate numbers can also be blocked.
T-Mobile T-Mobile Slovensko reported that mobile adult content can be blocked by sending an
SMS instruction “18STOP”; the customer can block all branded adult content on the
SIM card. This service is free of charge. Customers can also access this service via the
WAP page or by contacting customer service, and confirmation will be received by
SMS. Customers can also just block all commercial content to the handset from
contracted partners by sending a free SMS “18STOP PARTNERS” or by clicking on the
WAP page. Customers can also call customer services free of charge to activate these
services from the handset to be blocked. This will be done within 72 hours.
Unblocking the handset, however, can only be done in person in a store.
Contracted content providers are required to sign supplements to their contracts
requiring them to comply with the national code of conduct and EU rules. Instead of
labelling or providing disclaimers, they are required to implement the SMS blocking
system described above, provide information on all their communication materials
(print, web, TV etc) about how to block their own or their partners’ adult services,
and on request by T-Mobile, to block their or their partners’ adult services when the
customer wishes to block all third party services. This is then implemented via an
automatic process.
All child protection tools are monitored regularly on the basis of online reporting
tools and weekly customer feedback. There is a dedicated member of staff assigned
to supervise these activities as part of his key performance indicators.
Raising awareness and education
The recommendations of the Framework relating to awareness-raising and educational activities are
as follows:
4. Mobile providers should provide advice and effective access to information regarding the use
of mobile phone services and measures which can be taken by parents to ensure safer use by
their children.
5. Mobile providers should encourage customers who are parents to talk to their children about
how to deal with issues arising from the use of mobile services.

6. Mobile providers should ensure customers have ready access to mechanisms for reporting
safety concerns.
7. Mobile providers should support awareness-raising campaigns designed to improve the
knowledge of their customers, through organisations such as the INSAFE3
network.
8. For these measures to work effectively, policy makers should play a role in improving
children’s awareness through updated educational material and approaches. This should
include parent and child-friendly information on safer use of mobiles and the internet.
The relevant provisions of the national code of conduct on raising awareness and education are as
follows:
“1) The Mobile Operators undertake to provide basic information and consulting about how to
use mobile electronic communications services and content services, and on measures that
parents can take to protect children for appropriate and safer use of mobile electronic
communications services.
2) The Mobile Operators undertake to secure a mechanism via which parents can inform the
Mobile Operator about their fears for the safety of the child in connection with the provision of
the mobile electronic services and content services.
3) The Mobile Operators undertake to support in an appropriate manner information campaigns
aimed at increasing the awareness and knowledge of its subscribers and end users about the
provision of mobile electronic communications services and content services.
4) The Mobile Operators undertake to, in an appropriate manner, share in improving the
awareness of children via specialised education material and approaches, which should contain
particularly comprehensible information about the safe use of mobile phones and the internet.”
O2 Telefonica O2 Slovensko has a website dedicated to child protection. The site gives
general information on the main issues. Telefonica O2 also provides phone and email
details of how to contact the appropriate NGO for specific direct advice. Every
Telefonica O2 store has trained dedicated staff to provide parental support.
Orange Orange Slovensko has carried out a range of activities to provide information and
education. For the second year running, Orange Slovensko continued their project
providing interactive education directly to schools. A team of advisors visited 113
schools between October and December 2009, of which the majority were primary
schools, to talk in an entertaining and educational manner about a range of issues
around mobile safety, such as theft, distressing text messages, use of camera phones
etc. For the younger children, key messages were conveyed using resources such as
colouring books, while older children were provided with a booklet discussing these
3
INSAFE is a network of national nodes that coordinate Internet safety awareness in Europe.

and other issues relating to safe and responsible use of the Internet.
Orange Slovensko has re-designed its website “Deti a mobily” (Children and mobiles).
This site is dedicated to child protection and discusses the risks of Internet and
mobile communications and how customers can protect their children, as well as
directing customers to other pages such as the Microsoft Family Safety pages, and to
forms for reporting illegal content. The Orange Family Guide is available to download
from the website.
T-Mobile T-Mobile Slovensko reported that it provided its customer service operators with
information and Q&A details to educate them how to deal with mobile
communication safety queries. They have also set up a web page on their site to
allow customers to report (directly and/or in writing) issues. Information on safer use
of mobiles is distributed to customers via leaflets at point of sale, customer
magazines etc. and on the company website.
T-Mobile also participated with the NGO eSlovensko, the Ministry of the Interior and
UNICEF in a local education project on Safer use of mobile phones and the internet
named Zodpovedne.sk. This involved preparing leaflets, advice sheets and booklets
for children, teachers and parents, and these were distributed at a range of public
events, including training courses for teachers and police officers and meetings with
both parents and children. Publicity was provided in a range of media. T-Mobile also
participated in the preparation of a successful series of animated stories based on
sheep (OVCE.sk) which cover mobile and Internet safety issues. T-Mobile Slovakia
started an information campaign about Stopline.sk (the Slovak national hotline
centre) in February 2010.
Classification of commercial content
The recommendations of the Framework relating to commercial content classification are as
follows:
9. Mobile providers and content providers support classification frameworks for commercial
content based on national societal standards and consistent with approaches in equivalent
media. Classification of content, whether accessible through telecommunications or not,
should be consistent with national societal standards regarding decency, appropriateness
and legislation. Classification frameworks should consist of at least two categories: content
which is suitable only for adult customers and other content.
10. Mobile providers should ensure that their own-brand commercial content is appropriately
classified based on existing national classification standards in the markets where they
operate.
11. Through their contractual relationships with professional third party content providers,
mobile providers should ensure, after consultation, that these providers classify their
commercial content under the same national classification approach.

12. For these measures to work effectively, policy makers, trade associations and other
interested parties should support mobile provider initiatives to ensure commercial content
providers classify their content against national societal standards.
The relevant provisions of the national code of conduct on the classification of commercial content
are as follows:
"7 1) The Mobile Operators and contractual suppliers of mobile content have agreed on
introducing common classification for mobile content of an erotic nature…..2) The common
classification framework is comprised of two categories: a) mobile content intended only for
adult customers, an b) other mobile content. 3) The Mobile Operators will ensure that common
classification of content is also applied when classifying content supplied by contractual suppliers
of mobile content...”
General All of the signatory mobile operators in Slovakia classify their own content and
require their content providers to classify their content according to a common
national framework appended to the code of conduct. This requires that all adult or
nudity content must be marked as suitable only for 18+. This is enforced through
supplements to contracts between operators and content providers.
Fighting illegal content on mobile community products or the Internet
The recommendations of the Framework related to combating illegal content on mobile community
products or on the Internet are as follows:
13. Mobile providers will continue to work with law enforcement authorities in executing their
legislative obligations regarding illegal content.
14. Mobile providers will support national authorities in dealing with illegal child images and,
through the INHOPE4
hotline network or equivalent approaches, will facilitate the
notification of this content where hosted on mobile community products or on the internet.
15. Mobile providers will adopt, or support the creation of, appropriate legally authorized
national take-down procedures for such illegal content, including a commitment to liaise
with national law enforcement.
16. For these measures to work effectively there should be legal clarity on the nature of content
which is illegal and law enforcement authorities (or delegated organizations) should be able
to confirm where individual items of content are illegal. This will require the allocation of
proportionate law enforcement priority and resources. National governments’ support for
this is vital.
The relevant provisions of the national code of conduct on fighting illegal content are as follows:
4
INHOPE is the International Association of Internet Hotlines.

"8. 1) The Mobile Operators declare that they will continue to co-operate according to their
possibilities with government authorities in fulfilling their obligations relating to the fight against
illegal content. 2) The Mobile Operators declare that they will continue to support the pertinent
government authorities and non-profit sector organisations during their activities connected with
the fight against illegal depiction of children and youth and will facilitate the reporting of such
content, communicated via mobile electronic communications networks. 3) The Mobile
Operators undertake during discussions with contractual suppliers of mobile operators, as well as
during the duration of contractual relations with them to adhere to and apply the principles and
rules of safe use of mobile services at least at the level agreed on in this Code."
O2 Telefonica O2 Slovensko has established a partnership with eSlovensko, the national
Safer Internet node. Through this, they are able to actively raise awareness and
provide information to schools, children and parents. Together they have created a
national centre for complaints and reporting illegal content, threats or abuse
(Stopline.sk), which cooperates with the government authorities.
Orange Orange Slovensko reported that it had introduced in October 2009 a technical
solution that blocks URLs on the open internet which figure on the Internet Watch
Foundation list. This solution applies to all customers, and is network-based, so there
is no possibility to turn it off. There is currently no national register of illegal URLs and
this is why the UK’s IWF list is used. Orange Slovensko will incorporate any future
such list into its technical solution. Orange also provides its one dedicated hotline
number (905) to allow customers to report inappropriate or suspected illegal
content, as well as providing a reporting form on its website.
T-Mobile T-Mobile Slovensko reported that it cooperates closely in project zodpovedne.sk with
the Ministry of the Interior, the Government council for criminality, the Secretary of
State and Ministry of Education, and the Secretary of State and Ministry of Culture. T-
Mobile is also a partner of Stopline.sk (see above), alongside the Ministry of the
Interior, the police (internet criminality police) and UNICEF/the national helpline for
children. T-Mobile Slovensko also introduced in November 2009 a technical solution
that blocks URLs on the open internet which figure on the Internet Watch Foundation
list. This solution applies to all customers, and is network-based, so there is no
possibility to turn it off. There is currently no national register of illegal URLs and this
is why the UK’s IWF list is used.
Other
This section addresses compliance with the recommendations of the national code of conduct that
go beyond the scope of the Framework. These provisions are as follows: N/A
Mobile operators have implemented these provisions as set out below: N/A

Stakeholder cooperation on child protection
This part of the report presents the views of relevant stakeholders, concerning mobile operators’
role in protecting children in their country of operation. Two third parties responded: Ms Mária
Tóthová Šimčáková (professional guarantee and supervisor of the Orange Slovensko project
‘Children & mobile telecommunication technologies’), and for the NGO eSlovensko, Mrs. Marcela
Alzin.
The following questions were posed to the stakeholder:
1. How do you think the national code of conduct signed by mobile operators has helped in
the pursuit of safer mobile use by children?
Ms Mária Tóthová Šimčáková: “The role of the parent is to give good advices to its child and
warn him against the dangerous and unsuitable usages of mobile phones and whenever
there is a possibility to avoid (verbal restrictions) that the child will seek for unsuitable
content on internet or experiment with his mobile phone. Initiative of this Code I welcome
because it gives children the possibility to keep rules and did not motivate them to search for
unsuitable web pages and their content.”
Mrs. Marcela Alzin (eSlovensko): “Having signed the National Code of Mobile Operators on
Safer Use of Mobile Services the Slovak mobile operators have formally expressed their
commitment to attend to child protection online via awareness raising schemes, educational
programmes, mechanisms for control of content created or provided by children or adopted
from third parties and also via classification of commercial content and reporting of illegal
content. T-Mobile Slovensko has embraced this commitment in full complexity and became
partner of NGO eSlovensko which operates the Safer Internet Centre in Slovakia under EC
Safer Internet Programme. T-Mobile Slovensko has played an active role in eSlovensko’s
educational activities for the general public and simultaneously launched its own control
mechanisms. eSlovensko is a member of the European network of Safer Internet Centres
INSAFE and has applied for full membership in the international network of internet Hotlines
INHOPE which fight against illegal content online. T-Mobile Slovensko is a founding member
of the Slovak internet Hotline – National Centre for Reporting of Illegal and Inappropriate
Content and Conduct Online, operating under the name Stopline.sk. T-Mobile Slovensko is
also a member of Stopline.sk Council which oversees the Centre’s activities and co-designs its
policy.”
2. Are you aware of any educational/awareness-raising initiatives on this issue by the mobile
operators in your country?
Ms Mária Tóthová Šimčáková: “From the side of mobile operators in Slovakia I do not know
about the any other project which would have such integrated character, was designed to
children and youth, parents, teachers and also for the general public as exactly is the project
of Orange Slovensko. It offers the printed version of brochure, supportive material, videos on

internet www.oskole.sk. Equally it has active interactive character directly in schools and it
immediately offers activities and discussions for children, youth, teachers during the teaching
process.”
Mrs. Marcela Alzin (eSlovensko): “In early 2009, T-Mobile Slovensko became major partner
of Zodpovedne.sk project, run by NGO eSlovensko.sk. The project is based on EC Safer
Internet Programme and its main goals include raising awareness about safer internet use
among wide public, operating Helpline which assists victims of cyberbullying, grooming and
other forms of online harassment, and National Centre for Reporting Illegal and
Inappropriate Content Online. Zodpovedne.sk is the most complex awareness raising and
educational programme on safer internet in Slovakia with strong links to relevant European
and international organizations (INSAFE, INHOPE, other Safer Internet Centres throughout
Europe). T-Mobile Slovensko plays an active role in the project, one representative of the
company attends bi-weekly coordination meetings of the project team and is also member of
the project Advisory Board. In this capacity T-Mobile Slovensko has a profound impact on the
shape of the wide range of awareness raising activities, which include preparation of leaflets,
advice sheets and hand-books for children, teachers or parents and their distribution to the
target groups; events for the public, including trainings for teachers, policemen, lectures for
parents and, of course, meetings with children; publicity – entries in all kinds of media;
development of a successful series of sheep-themed animated stories OVCE.sk which cover
prevailing internet-related topics like grooming, paedophilia, racism, and xenophobia, as well
as misuse of personal information or photographs. Apart from that, T-Mobile Slovensko
supported the campaign in the wake of the launch of Stopline.sk, as well as Safer Internet
Day. Further, the company launched an internal campaign in which employees were trained
about the safer internet use. Customers have been informed about this topic through the
official website of the company and in the regular newsletter.”
3. What do you think are the key child protection priorities for the ICT sector for your
country?
Ms Mária Tóthová Šimčáková: “Technical conveniences of this era such as mobile phones
and internet have their own justification for children and youth because they expand their
possibilities forward. On the other hand we have to teach them to use this technology in
suitable and right way a help in establishing the new teaching subject, which starts to
develop on Slovak schools – media education. In first place for children and youth are still
responsible their parents. That is why is so important warn parents about the risks their
children might encounter and what parents should do in advance, warn their children. Not
least priority should be the development of ethics in making phone calls and by using the
internet already by young people.”
Mrs. Marcela Alzin (eSlovensko): “From T-Mobile Slovensko’s perspective, it is vital to do
awareness raising activities among the general public and to focus on the question how to
use mobile devices and online technologies safely. This requires a diversified approach

towards children, parents and teachers. Educational activities for all of these groups should
be supported, as well as introducing safer internet issues in school curricula. However, one of
the most powerful tools which T-Mobile Slovensko offers its customers is an efficient filtering
service that can be turned on, on their children’s mobiles and thus prevent them from
accessing websites with indecent or otherwise inappropriate content”

Conclusion
Slovak mobile operators have reported generally good compliance with the code of conduct and
have carried out a range of own-initiative projects to increase awareness and improve the safety of
children using mobile phones.
The national code of conduct commits the operators to regularly revise and update the 2008 code in
the light of changing social needs and technological developments. The operators have agreed to
consult with each other over compliance with the code and the need to revise code commitments.
Any of the signatories can initiate a consultation process if they believe another operator is failing in
its obligations under the code.

Annex I
European Framework for Safer Mobile Use by Younger Teenagers and
Children
February 2007
European mobile providers and content providers have developed national and corporate initiatives
to ensure safer use of mobiles including by younger teenagers and children. These already cover
most EU Member States.
Signatory European mobile providers, with support from signatory content providers, now propose
an EU-wide common framework to reflect these developments and to encourage all relevant
stakeholders to support safer mobile use. This framework will be subject to national
implementation by signatory providers.
We recognize:
 mobile services offer an additional way to consume content (still and video images, music,
chat, etc.) already offered in other ways - typically by the same providers.
 the importance of parental oversight: accordingly, mobile providers should endeavour to
empower parents with information and tools to facilitate their oversight.
 any initiatives to classify content should be based on national societal standards regarding
decency, appropriateness and legislation.
 a framework-based approach to industry self-regulation will be effective in adapting to the fast
moving environment of mobile technology and services – it will be future proof.
European Mobile Providers – A Responsible Approach
It should be noted that:
Mobile providers only control commercial content they produce themselves or which they
commission from professional third parties.
They exert indirect and retrospective control over commercial content in certain other situations,
provided there is a contractual relationship with professional third parties.
They are not in a position to control content which is freely accessible on the internet, since there is
no relationship between the mobile provider and the content provider.
However, as responsible companies, mobile providers recognise the need to work with customers,
parents and other stakeholders, including child protection organizations, in order to promote the
safety of younger teenagers and children using mobile services.

Mobile providers offer content which may use pre-pay, post-pay or hybrid approaches to billing.
This framework is intended to provide for safer mobile use by younger teenagers and children across
different billing approaches.
Recommendations on Safer Mobile Use
Access Control Mechanisms
1 Mobile providers should not offer any own-brand commercial content which would be
classified as only suitable for adult customers in equivalent media, without providing
appropriate means to control access to such content under parental control.
2 Appropriate means to control access to content should also be applied where content is
supplied by contracted providers of third party commercial content which would be
classified as only suitable for adult customers in equivalent media.
3 Additionally, individual mobile providers should offer capabilities which can be used by
parents to customize access to content by children using mobiles. These may include
specific services, phones, barring or filtering, and/or billing control.
Raising Awareness & Education
4 Mobile providers should provide advice and effective access to information regarding the
use of mobile phone services and measures which can be taken by parents to ensure safer
use by their children.
5 Mobile providers should encourage customers who are parents to talk to their children
about how to deal with issues arising from the use of mobile services.
6 Mobile providers should ensure customers have ready access to mechanisms for reporting
safety concerns.
1 Mobile providers should support awareness-raising campaigns designed to improve the
knowledge of their customers, through organisations such as the INSAFE network.
7 For these measures to work effectively policy makers should play a role in improving
children’s’ awareness through updated educational material and approaches. This should
include parent and child-friendly information on safer use of mobile and the internet.
Classification of Commercial Content
8 Mobile providers and content providers support classification frameworks for commercial
content based on national societal standards and consistent with approaches in equivalent
media. Classification of content, whether accessible through telecommunications or not,
should be consistent with national societal standards regarding decency, appropriateness
and legislation. Classification frameworks should consist of at least two categories: content
which is suitable only for adult customers and other content.
9 Mobile providers should ensure that their own-brand commercial content is appropriately
classified based on existing national classification standards in the markets where they
operate.
10 Through their contractual relationships with professional third party content providers,
mobile providers should ensure, after consultation, that these providers classify their
commercial content under the same national classification approach.

11 For these measures to work effectively policy makers, trade associations and other
interested parties should support mobile provider initiatives to ensure commercial content
providers classify their content against national societal standards.
Illegal Content on mobile community products or on the Internet
12 Mobile providers will continue to work with law enforcement authorities in executing their
legislative obligations regarding illegal content.
13 Mobile providers will support national authorities in dealing with illegal child images and, through
the INHOPE hotline network or equivalent approaches, will facilitate the notification of this
content where hosted on mobile community products or on the internet.
14 Mobile providers will adopt, or support the creation of, appropriate legally authorized
national take-down procedures for such illegal content, including a commitment to liaise
with national law enforcement.
15 For these measures to work effectively there should be legal clarity on the nature of content
which is illegal and law enforcement authorities (or delegated organizations) should be able
to confirm where individual items of content are illegal. This will require the allocation of
proportionate law enforcement priority and resources. National governments’ support for
this is vital.
Implementation, Stakeholder Consultation & Review
16 Signatory mobile providers and signatory content providers will work towards
implementation of this common European framework through self-regulation at national
level in EU Member States. The target for agreement of national self-regulatory codes,
consistent with this framework, is February 2008
17 Mobile providers will regularly review child safety standards on the basis of the
development of society, technology and mobile services in cooperation with European and
national stakeholders such as the European Commission, INHOPE and INSAFE.

Annex II
National Code for mobile operators on safe use of mobile services
Orange Slovensko, a.s.
T-Mobile Slovensko, a.s.

1. Contracting Parties
Prievozská 6/A, 821 09 Bratislava, Slovakia
Company ID No.: 35 697 270
Represented by: Ing. Pavol Lančarič PhD., member of the board of directors and managing
director
The company is recorded at Companies registry of District Court Bratislava I , Section Sa, File
No. 1142/B
Vajnorská 100/A, 831 03 Bratislava, Slovakia
Represented by:
Ing. Milan Vašina, managing director and holder of procuration
Ing. Ivan Bošňák, financial director and holder of procuration
The company is recorded at Companies registry of District Court Bratislava I, Section Sa, File
No. 1238/B
Viedenská cesta 5, 851 01 Bratislava, Slovakia
Represented by: Ing. Juraj Šedivý, managing director and executive head
The company is recorded at Companies registry of District Court Bratislava I, Section Sro, File
No. 27882/B
(hereinafter referred jointly as “Contracting Parties” or “Mobile Operators” and independently as
“Operator” or “Mobile Operator”)

2. Preamble
Whereas the Contracting Parties regard it as important to state the following:
mobile phones have already become a common means of communication in the whole
population of Slovakia too, including children and youth;
mobile services of operators enable for the most part only another method of access to
already existing content (pictures and video, music, debating circles etc.), which is offered by its
providers in more ways;
mobile operators control only commercial mobile content, thus the content that they
themselves produce and provide to subscribers or that they take over from third parties; they
implement indirect and retroactive control of other content only under condition of a contractual
relationship existing with third parties;
mobile operators are not in a position from which they could control content that is freely
available on the internet because no relations exist between the mobile operator and the supplier
of such content;
mobile phone provides the benefits of modern communication to all users, whilst the wide
spectrum of its functions (colour display, camera, internet browser etc.) enable access to a wide
variety of content;
mobile operators are interested in all of their subscribers and end users having access to
all information about how to use a mobile phone and its functions, as well as access to
information about the risks and possible misuse of such functions;
mobile operators as responsible companies acknowledge the need to work with
customers, end users, parents and other interested parties, including organisations for the
protection of children, in order to primarily support the security of children using mobile services;
and therefore the Contracting Parties have agreed on this national Code of secure use of mobile
services (further referred to as “Code”):
3. Scope
1) This Code relates only to commercial mobile content that mobile operators themselves provide
to subscribers or that they take over from contractual suppliers of mobile content (third parties).
2) Mobile operators are responsible for the mobile content within the scope according to valid
generally binding legislation and this Code.
3) Mobile operators are not responsible for third party content if in relation to such content they
act only as a provider of access or connection to mobile electronic communications network (e.g.
content available on the internet).

4. Definitions
1) “Child” for the purposes of this Code is a person younger than 15 years old.
2) “Adult” is a person that has reached the age of 18 years, unless according to the law it has
reached adulthood earlier.
3) “Minor” is a child or youth.
4) “Youth” for the purposes of this Code is a person who has reached the age of 15 years old but
has not exceeded 18 years.
5) “Commercial mobile content” is content made accessible in Slovakia exclusively via one or
more mobile public electronic communications networks. Commercial mobile content for the
purposes of this Code is understood as being particularly content made accessible via short
numbers, released beyond the numerical scope regulated in the Numbering Plan, issued by the
Telecommunications Office of the Slovak Republic .
6) “Control access mechanism” is a method enabling the blocking of access to commercial
mobile content intended only for adults, either for individual subscribers or individual telephone
numbers based on the subscriber's (adult's) request or enabling of access blocked for all
subscribers based on the subscriber's (adult's) request. In both cases the subscriber's request has to
be clearly identified based on verification of his/her identity and age.
7) “Commercial mobile content intended only for adults” is commercial mobile content ranked in
common classification of content from class CS1.4 to class CS10.
8) “Common classification of content” is classification of commercial mobile content focused on
erotic, common for all contracting parties, applied in Slovakia. Its wording is contained in an
annex to this Code.
1. Control Access Mechanisms
1) The Contracting Parties undertake that after signing this Code they will not offer without
securing the possibility of controlling access, via methods of controlling access determined in this
Code, any of their own commercial mobile content that is according to the Common classification
of content determined only for adults.
2) The Contracting Parties undertake to use the methods for controlling access determined in this
Code also in relation to commercial mobile content that is according to the Common
classification of content intended only for adults and that the contractual suppliers of mobile
content supply.

3) If a Mobile operator provides or enables access to commercial mobile content intended only
for adults, it is obliged to also provide the option of controlling access to it via suitable methods
for controlling access.
4) Suitable methods for controlling access to commercial mobile content are regarded as being
only such methods that within the scope of their use clearly verify the identity and age of the
subscriber or the user communicating in the matter of controlling access to services intended only
for adults. The identity and age of such a person are regarded for the purposes of this Code as
verified
a) in the case of written communication or in the case of electronic communication with
electronic signature if it states at least 1. name and surname, 2. address, customer number
or telephone number and 3. signature (or electronic signature) of the subscriber,
b) in the case of personal communication, if the subscriber who is communicating in the
matter of controlling access to services intended only for adults proves its identity to
operators with a commonly accepted proof of identity,
c) in the case of communication via means of electronic communication (voice calls,
SMS messages etc.), if a subscriber communicating in the matter of controlling access to
services intended only for adults states at least two personal details of a confidential
nature (birth certificate number, customer number etc.).
Meanwhile it is not critical whether the verification is done by the operator, a person
acting on its behalf (e.g. business representative) or a third party (e.g. post office).
5) The Operator decides at its own inclination about to what extent within the securing of
methods for controlling access to
a) block access to services intended for adults for individual subscribers or end users or telephone
numbers based on verification of request by subscriber, and to what extent
b) block access to services intended only for adults for all subscribers and in individual cases
frees it up based on verification of request of the subscriber (adult).
6) Information of the content provider about its suitability only for adult customers, possibly also
in combination with unverified declaration by the user about his/her age (disclaimer) is not
regarded as a suitable method of controlling access. However, it may be used beyond the
framework of methods for controlling access individually in cases when access to the given
service intended only for adults is not blocked for all subscribers.
7) This Code does not order mobile operators in any case to use a specific method for controlling
access and it does not prevent the adoption of wider technical measures for controlling access to
commercial mobile content. Each mobile operator can choose for fulfilment of the commitments
according to this Code various technical and organisational solutions for controlling access to
content.
1. Awareness and Education
1) The Mobile Operators undertake to provide basic information and consulting about how to use
mobile electronic communications services and content services, and on measures that parents
can take to protect children for appropriate and safer use of mobile electronic communications
services.
2) The Mobile Operators undertake to secure a mechanism via which parents can inform the
Mobile Operator about their fears for the safety of the child in connection with the provision of
the mobile electronic services and content services.

3) The Mobile Operators undertake to support in an appropriate manner information campaigns
aimed at increasing the awareness and knowledge of its subscribers and end users about the
provision of mobile electronic communications services and content services.
4) The Mobile Operators undertake to, in an appropriate manner, share in improving the
awareness of children via specialised education material and approaches, which should contain
particularly comprehensible information about the safe use of mobile phones and the internet.
1. Common Classification of Content
1) The Mobile Operators and contractual suppliers of mobile content have agreed on introducing
common classification for mobile content of an erotic nature. When choosing common
classification of content, corporate standards of administration were taken into consideration
along with usual approaches in means of mass communication, as well as in accordance with
generally binding legislation valid in Slovakia.
2) The common classification framework is comprised of two categories:
a) mobile content intended only for adult customers, and
b) other mobile content.
3) The Mobile Operators will ensure that common classification of content is also applied when
classifying content supplied by contractual suppliers of mobile content.
4) Common classification of content comprises an integral part of this Code, and also in a
simplified version intended for the public as well as in the full version intended for mobile
operators.
Co-operation of Mobile Operators after Signing the Code
1) The Mobile Operators declare that they will continue to co-operate according to their
possibilities with government authorities in fulfilling their obligations relating to the fight against
illegal content.
2) The Mobile Operators declare that they will continue to support the pertinent government
authorities and non-profit sector organisations during their activities connected with the fight
against illegal depiction of children and youth and will facilitate the reporting of such content,
communicated via mobile electronic communications networks.
3) The Mobile Operators undertake during discussions with contractual suppliers of mobile
operators, as well as during the duration of contractual relations with them, to adhere to and apply
the principles and rules of safe use of mobile services at least at the level agreed on in this Code.
1. Implementation, Consultations and Revisions
1) The Mobile Operators undertake that at the latest by 31 December 2009 they will take on and
demonstrably fulfil all obligations to which they committed in this Code.
2) No later than within 1 month from the date of signing this Code by the last of the Contracting
Parties, the Mobile Operators will publish the text of the Code on their websites and will ensure
that it is sent to GSM Europe. They will publish the text on their website with a version of
common classification of content for the public.
3) Either of the Contracting Parties is authorised in the event of doubts about adherence to or
fulfilment of obligations stated in this Code to communicate with the other Contracting Party to
the Code and to begin consultations in the given matter.
4) The Contracting Party that the consultations relate to is obliged to give the necessary
explanation within it without unnecessary delay.
5) The other Contracting Party to this Code can proceed to consultations at any time too.

6) The result of consultations is after agreement by all parties to the consultations binding
between those parties.
7) The Mobile Operators undertake that with regard to changing social needs, as well as to the
technical development of mobile services and changes to their content, they will base on mutual
agreement regularly revise and update this Code. Revisions and updates are also possible based
on the result of consultations.
Bratislava, 31 January 2008
On behalf of Orange Slovensko, a.s.
Prievozská 6/A
821 09 Bratislava, Slovakia
Company ID No. 35 697 270
[signature] VAT No. SK2020310578
Ing. Pavol Lančarič PhD.
Managing director and member of the board of directors
Bratislava, 2008
Vajnorská 100/a
831 03 Bratislava, Slovakia
Company ID No. 35705019
Ing. Ivan Bošňák,
Financial director and holder of procuration
Bratislava, 31 January 2008
On behalf of Telefónica O2 Slovakia, s.r.o.
[signature]
Ing. Juraj Šedivý
Chief Executive Director and statutory representative

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