UK Policy work


Online Safety Act 2023

After six years of debate, the Online Safety Bill finally became an Act of Parliament, receiving Royal Assent and becoming law on 26 October 2023. This was a pivotal moment, as the Act, among other requirements, holds tech companies to account for the systems and processes they have in place to detect illegal content, such as child sexual abuse, through an independent regulator, Ofcom. Listen to our podcast, with Natalia Greene from PA Consulting, on the next steps following Royal Assent.

Throughout 2023, we had tracked and influenced the passage of the Bill through the House of Lords, after it had reached its final stages in the House of Commons in January. 


Second Reading (House of Lords), 1 February  

Lord Vaizey Online Safety Bill Speech

Baroness Healy Online Safety Bill Speech.


At the Bill’s Second Reading in the House of Lords, both Baroness Healy and Lord Vaizey continued to carry our message from the House of Commons stages about the need for Ofcom to work with third parties like the Internet Watch Foundation (IWF) to deliver regulation of the online space effectively. 

Lord Vaizey said it was important to remember that the internet has traditionally had many governors – civil society, business, non-profits, and charities – all of which must continue to play their part. 

Baroness Healy said Ofcom “faces a formidable challenge in policing companies to adhere to its terms and conditions about content moderation. Heavy fines would not be enough. Ofcom will need guidance in setting codes of practice, from not only the three commissioners but NGOs such as the Internet Watch Foundation and an advocacy body for children to advise on emerging harms.” 


Committee Stage (House of Lords), April and May   

Baroness Benjamin Speech (Olivia’s story).


The Bill’s Committee Stage in the House of Lords took place over several sittings in April and May.  

On 16 May, Lord Clement-Jones, the Liberal Democrats spokesperson for Science, Innovation and Technology, tabled an amendment to the Bill, supported by former Digital, Culture, Media and Sport Secretary of State, Baroness Morgan, encouraging Ofcom and the government to co-designate the IWF with the purpose of assisting Ofcom in regulating child sexual abuse and exploitation online. 

IWF’s Parliamentary Champions were out in force during the debate, with Baroness Benjamin giving an impassioned speech recalling Olivia’s story from our 2018 annual report launch and the Labour opposition front bench Baroness Merron also speaking to the amendment, alongside formidable children’s rights campaigner Baroness Kidron and Chair of the Lords Digital and Communications Committee, Baroness Stowell. 


Report Stage (House of Lords) July

Tim Clement Jones speech on Online Safety Bill.


During a debate on 17 July, Lord Clement-Jones once again raised the issue of “regulatory interlock”, referencing how the relationships between the large regulators Ofcom, the Information Commissioner, Competition and Markets Authority and Financial Conduct Authority had been formalised through the Digital Regulation Cooperation Forum. 

He also referenced the working relationship between Ofcom and the Advertising Standards Association and was pleased to hear of progress being made on a memorandum of understanding between Ofcom and the Internet Watch Foundation and hoped to see that collaboration continue. 


Third Reading (House of Lords) 6 September  

IWF CEO Susie Hargreaves OBE speaks outside No10 following a roundtable at 10 Downing Street with Science, Innovation and Technology Secretary Michelle Donelan. Credit: UK Government, Department for Science, Innovation and Technology. Licensed under the Open Government Licence v3.0.


As the Bill neared its final stages to becoming an Act of Parliament, in a process informally known as ‘ping-pong’ when the House of Commons and House of Lords consider amendments each has made, we partnered with the NSPCC to hold two drop-in sessions to explain the importance of retaining the use of technology notices for child sexual abuse and exploitation. 

Our CEO, Susie Hargreaves OBE, also attended a roundtable hosted by then Home Secretary Suella Braverman, and Science, Innovation and Technology Secretary Michelle Donelan at Downing Street. 


Working with Ofcom

The IWF continues to work to finalise a memorandum of understanding (MoU) with the new online safety regulator, Ofcom. The MoU builds on previous discussions between the two organisations, focusing on how to handle illegal content, developing codes of practice, support to business and supervision and enforcement. 

These were all areas recommended by the joint committee that was appointed to scrutinise the draft Bill. 

In November, Ofcom published their draft Code of Practice for Child Sexual Exploitation and Abuse, alongside its risk register, risk profiles and draft guidance on how to assess risk. This consultation will inform how the regime will be implemented in practice and shape the secondary legislation which will follow in early 2024. 

IWF looks forward to continuing to work and build upon our relationship with Ofcom in 2024 and playing our part in making the UK the safest place in the world to go online. 



Artificial Intelligence Safety Summit fringe meeting

In June, Prime Minister Rishi Sunak announced that the UK would host an international summit focussed on safety in artificial intelligence. In the same month, the IWF started receiving its first reports from members of the public of child sexual abuse material that had been created using generative artificial intelligence (AI). 

We called on the Prime Minister to make this issue a priority at the summit, to be held at Bletchley Park in November, and on 30 October, two days before the summit began, we hosted a joint event alongside the Home Secretary and the Home Office to discuss the risks and opportunities AI presented in tackling child sexual abuse online. 


Speaking at the AI Safety Summit side event were, from left, IWF CEO Susie Hargreaves OBE; IWF CTO Dan Sexton; Ian Critchley, National Police Chiefs' Council; Chris Farrimond, NCA; and Shailey Hingorani, WeProtect Global Alliance & 25.


The event led to 33 signatories signing a joint non-legally binding statement to tackle the rise of AI-generated sexual abuse images. Signatories to the statement included IWF Members Snap and Tik Tok, strategic partners such as OnlyFans, the National Centre for Missing and Exploited Children (NCMEC), the Canadian Centre for Child Protection and the National Society for the Prevention of Cruelty to Children. 

The statement was also backed by UK, Italian and South Korean law enforcement with support also coming from the US, Australian and German governments and academics. 

During Home Secretary Suella Braverman’s speech, she said the IWF was: “A critical partner in our efforts to eradicate child sexual abuse online” and thanked our organisation for its “tireless efforts to ensure that images and videos of children being abused are removed from the internet.”  


From left, Dr Elissa Redmiles, Georgetown University; David Wright, SWGfL CEO; Rachel Vogelstein, Special Assistant to the President and Deputy Director, White House Gender Policy Council; Michelle Donelan, UK Secretary of State, DSIT; Susie Hargreaves OBE, IWF CEO; Michelle DeLaune, NCMEC CEO; and Dr Rebecca Portnoff, Thorn, at the White House roundtable.


Hot on the heels of the UK’s AI Safety Summit and the US administration’s Executive Order on Artificial Intelligence, our CEO, Susie Hargreaves OBE, attended a high-level roundtable discussion at the White House in partnership with the UK’s Department for Science, Innovation and Technology to discuss the risks and opportunities of generative AI for image based sexual abuse. 



APPG on Online Safety on Social Media

In May 2023, the All-Party Parliamentary Group (APPG) on Social Media, which we run as part of the UK Safer Internet Centre, held its Annual General Meeting, and a new Chair, Vicky Ford MP, was elected. Ms Ford is a longstanding supporter of the IWF and brings vast experience as a former MEP and Chair of the Internal Market Committee in the European Parliament and a former Children’s Minister in the UK Government. 



End-to-end encryption (E2EE)

The IWF continues to be concerned about child sexual abuse material being undetected in certain environments online. The headline figures contained in our annual report tell us what our analysts find on the open, publicly accessible parts of the internet, but we do not report on material found in private messaging environments or on the dark web. 

We are, however, concerned that platforms and applications that currently use end-to-end encryption or plan to move to this technology are not taking sufficient steps to protect their users from child sexual abuse material. 

Many of the solutions these companies deploy focus on metadata, which will not be enough to ensure that we can prevent victims’ images from circulating in future. 

IWF E2EE explainer video.


This year we partnered with the Home Office to write to Meta founder Mark Zuckerburg to urge him to think again about his plans to encrypt Facebook and Instagram messenger services. Reports from Facebook and Instagram to NCMEC in the US totaled over 26 million in 2022 and we remain concerned that if these services were to be encrypted, we would lose a sizeable amount of intelligence related to child sexual abuse online, and the ability for children to be rescued from harm. 

We also launched a new resource aimed at educating parents about the danger that end-to-end encrypted applications pose to children. 

We further briefed the Home Secretary as part of her visit to Kent Police to launch the campaign about how our hashing technology prevents child sexual abuse from spreading and our work on the Government’s Safety Tech Challenge Fund to help prevent the spread of known child sexual abuse material on tech platforms. 



UKSIC Safer Internet Day

In February, we hosted a drop-in session in Parliament to celebrate Safer Internet Day and introduced several MPs to our UK Safer Internet Centre Digital Leaders.   

And in Europe, we contributed to a panel discussion hosted by new IWF Member Discord, with representatives from the European Commission, European Parliament, Member States and industry, on steps that could be taken to improve child safety online. 

We also participated in a roundtable discussion with long-standing IWF Member Microsoft, about children and young people’s experiences online in 10 different countries from around the world. 


Midlothian MP Owen Thompson, centre, meets the young Digital Leaders at the UK Safer Internet Day 2023 with Childnet’s Danielle Antha, far left.

Stourbridge MP Suzanne Webb, left, with IWF Director of Communications and Co-Director of the UK Safer Internet Centre, Emma Hardy at the UKSIC Safer Internet Day 2023.