Please help us protect children in your new role

Ms Nadine Dorries MP
Department of Digital, Culture, Media, and Sport

Dear Secretary of State,

Welcome to your new role as the Secretary of State for Digital, Culture, Media and Sport. Please join me in supporting the NSPCC’s Wild West Web campaign to end child abuse online. The Draft Online Safety Bill is a real milestone in being one of the first countries in the world to tackle preventable online abuse. You have the chance to make sure it does everything it can to protect children from harm online. Before the Bill is introduced to Parliament, the NSPCC is calling on you to make the following improvements so that legislation does everything it can:

Make tech companies work together to tackle the cross-platform nature of risks

Harmful content and behaviour spreads rapidly across platforms, and child abuse is rarely siloed on a single site. Groomers are easily able to exploit the design features of social networks to make contact with children, before migrating them to encrypted messaging and livestreaming sites. In the Online Safety Bill, platforms need to be given a legal duty to address the cross-platform nature of risks, with clear expectations them to meet their safety duties by considering how their sites contribute to wider online risks, and cooperate on the threat response with other companies.

Ensure children are protected from seeing harmful content on any site likely to be used by them

The draft Bill sets out that companies will only have to protect children from harmful content if they have a ‘significant’ child user base. If the threshold for sites to demonstrate this is too high, it risks pushing harm on to smaller less regulated services that do not have to actively protect children from harm. The Bill must recognise that even if certain sites aren’t intended for children, tech companies should know that children are using them and put measures in place to protect them. The government must be much stronger on this in the Bill otherwise legislation risks displacing not removing risks to children.

Properly hold senior managers to account for product safety

The proposed sanctions in the Online Safety Bill are welcome, but they will not go far enough to embed child safety at tech companies or deliver the cultural change required. Fines won’t always be enough to bring companies in line and could simply be costed into the price of doing business in the UK. The Bill must properly hold to account the senior managers who decide how safely their sites are designed. I am calling on you to introduce a Named Persons Scheme, which will make an individual at a tech company personally liable when they fail to uphold their safety duties. This happens with senior managers in the financial services sector, and protecting children online is no less important. For the most egregious systemic failures that put children at risk of illegal harms, criminal sanctions are needed to act as a strong deterrence.

Create a powerful voice for children in regulation

Children need to have a strong voice with a powerful champion to represent them. Statutory user advocacy arrangements, funded by an industry levy, would create a level playing field for children and ensure Ofcom adopts a child centred approach when taking regulatory decisions. It will also provide effective counterbalance to well-resourced and powerful interventions from the tech firms. Funded user advocacy arrangements are a part of many other regulated sectors, from postal services to transport. Children are potentially the most vulnerable of all users and deserve a regulatory settlement that recognises this.

We need the government to deliver an Online Safety Bill that keeps children safe online. These changes will ensure the government’s ambition translates into legislation that will make the UK the safest place in the world to go online.

Thank you.