Internet Matters’ response to Ofcom’s consultation on age assurance guidance

We are delighted to contribute our thoughts and evidence to the consultation, in support of Ofcom in its new role as online safety regulator.

Our own research demonstrates that access to pornography is one of the areas of most acute concern for both parents and teachers – who are currently the frontline of preventing children from accessing harmful content, and handling the fallout if and when children do view pornography. Action to protect children, through robust, reliable and ubiquitous age assurance on online pornography cannot come soon enough.

there are a number of key areas where we believe that the draft guidance could be significantly strengthened, and therefore more robustly protect children from pornography. It is crucial to get the approach right, now, at the outset of the regime – to ensure compliance across the adult sector.

In this submission, we draw on our extensive research base, in particular our digital experiences tracker which is a twice-yearly survey of a nationally representative sample of 1,000 children aged 9-17 and 2,000 parents and which allows us enormous insight into the online lives of families in the UK.

• Parents and teachers are very concerned about the impact of pornography exposure on children. Age assurance measures on pornography cannot come into force quickly enough.
• It is our general observation that little – so far – has been done to ensure that children and parents are informed about what Ofcom’s regulation of online services means for them.
• There are a number of important omissions in the current guidance, including support and advice for children who attempt and fail age-checks; o continuous age checks on platform; a clear definition of ‘normally encounter’; and stronger measures around VPN use.
• More guidance is needed for the role of app stores in providing interoperable, secure and privacy-preserving age-assurance methods.
• Record-keeping duties on pornography platforms should extend to a duty to ensure that records are presented in a clear and accessible way to children and parents.