‘Ofcom and Government should not reinvent the wheel’ - IWF stands ready to help regulator stamp out online child sexual abuse material

Published:  Fri 17 Dec 2021

Written by:  By Michael Tunks, Senior IWF Policy and Public Affairs Manager

This week, the Joint Committee published its comprehensive report on the Draft Online Safety Bill.

The Government must now act on the Committee’s recommendations to make sure this legislation brings in the strong and effective safeguards we need to keep children safe online.

But the legislation needs to be effective and practical from day one to prevent child victims from falling between the cracks. This is why, as the report suggests, the IWF must be part of the regulatory framework brought in to tackle the spread of child sexual abuse online.

The report notes that working with child sexual abuse material is “far outside Ofcom’s normal duties”, and that the Committee expects Ofcom to “work closely with experts like the Internet Watch Foundation, to develop and update the child sexual exploitation and abuse Code of Practice; monitor providers to ensure compliance with the child sexual exploitation and abuse code; and during investigations relating to child sexual exploitation and abuse content.”

At the IWF, the UK’s body for combatting child sexual abuse material on the internet, we have skills and expertise – curated over 25 years – which can benefit Ofcom.

The report says the Committee expects Ofcom to work with a range of organisations. This could be through co-designation, partnerships, MoU’s, forums or networks.

For IWF, it is imperative we ensure the success of the Bill when it comes to tackling child sexual abuse material. That is why we are pleased the report calls on the Government to provide clarity on the role we can play through formal co-designation. There are five areas that IWF stands ready to offer support on:

  • Developing the Code of Practice for Child Sexual Exploitation and Abuse (CSE/A)
  • Transparency Reporting
  • Mandatory Reporting
  • Monitoring Compliance
  • Investigations

This Bill has been coming for five years. We must get this world leading legislation right and we must ensure that the regulatory regime for illegal content is effective from day one. To do that, it must build on current best practice to further enhance that response.

For the legislation to be effective in tackling child sexual abuse, it will require Ofcom to have strong relationships with Government, Industry and Law Enforcement.

Ofcom and Government should not reinvent the wheel; they are clearly going to need help and support - which we stand ready to offer.

When the issue of co-designation was raised by Lord Clement-Jones in relation to the IWF, Dame Melanie Dawes responded by stating: “It is something that is a really big part of our strategy-broader partnerships work I would call them.” Before stating that the final decision will rest with the Secretary of State under the provisions in the Contracting Out Act (1994).

Whilst Ofcom Policy Director, Richard Wronka, confirmed they had held “pretty extensive conversations” with the IWF, he said nothing had been agreed at this stage.

The IWF, over 25 years, has reduced the amount of illegal child sexual abuse content hosted in the UK from 18% in the year the IWF was founded, to less than 0.1% last year. It has been less than 1% ever since 2003.

We’ve increased our analyst headcount, created new technology to support the mission, and we provide a growing number of tools, services and datasets for technology companies to use in their work to keep their platforms safer.

The Independent Inquiry into Child Sexual Abuse recently concluded “The IWF is a genuine success story” and “a large part of the reason comparatively little child sexual abuse material is hosted in the UK.”

Article 9 of the Bill sets out the requirements on companies to deal with illegal content. It states companies must do four things:

  • Minimise the spread of illegal content
  • Minimise the length of time it is available for
  • Minimise the dissemination of illegal content
  • Ensure the swift removal of content one notified

The IWF already enables this to happen. We already have the effective mechanisms and partnerships in place to fulfil these obligations.

We have some of the fastest times for the removal of this content anywhere in the world - under 2 minutes is our record. We have an MoU with the National Police Chiefs’ Council (NPCC) and Crown Prosecution Service (CPS) that governs our operations.

We are also the only non-law enforcement body with access to the UK’s Child Abuse Image Database (CAID), and we’re currently hashing two million images to share with industry which will further help minimise the spread and dissemination of illegal content.

As the report makes clear, the Government now needs to provide greater clarity on how co-designation could be achieved, what the criteria would be for those it was seeking to co-designate and the timescales for implementation.

We stand ready to help, and effective co-designation is key to getting this right.

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