This is Ofcom’s second major consultation as part of the Online Safety Act.
It focuses on how online services should approach their new duties under the Act relating to content harmful to children.
We welcome the speed with which Ofcom has assumed its duties to identify harms and establish its regulatory approach to protecting children. The scale of the challenge is significant. Alongside the draft Illegal Harms proposals, again we lend our support to Ofcom in its effort to establish a safer online world for children. In particular, the draft Children’s Register of Risks (Volume 3) a strong piece of work. We will offer our own up-to-date evidence on the nature of the risks/harms that children experience, including differences by age, gender, vulnerability and other characteristics.
Internet Matters conducts an extensive research program which is designed to provide us with insight into families’ experiences of digital platforms and technologies. This data has been used to inform our response to this consultation. The data comes from two main sources:
Children of all age groups surveyed report exposure to primary priority content (only asked to age 13+). This includes eating disorder content (13%), pornography (12%), self-harm content (6%), pro-suicide content (4%) or sharing/receiving nudes or semi-nudes of adults (3%).
Children also report exposure to priority content: dangerous stunts or challenges (19%), online bullying (16%), hate speech (16%), harmful body image content (16%), violent content (12%), violent animal abuse (5%) and content from radical or extremist groups (2%).
Some harms are more likely to impact certain genders. We find that girls are significantly more likely to experience content featuring unrealistic or altered bodies than boys (19% cf. 14%). Meanwhile, boys are more likely to be exposed to content featuring dangerous stunts and challenges (21% cf. 16%) and violent animal abuse (6% and 4%).
We also ask 2,000 parents (not necessarily of the same household) a corresponding set of questions about their children’s experience of online harms. From this, we are able to draw comparisons around children’s actual experiences of harmful content and parents’ reports of their children experiencing harmful content.
For instance, whilst 13% of 13-17 year olds report exposure to eating disorder content, only 9% of parents are aware of their child experiencing this.
The tracker also asks children to rate the effect that online harms had on them on a scale of 1 to 7, where 1 is no impact and 7 is a significant impact. The harms which have the greatest impact on children are shown below in the graph.
And similarly for priority content:
We define vulnerable children as those who receive special education needs (SEN) support, who have an Education, Health and Care Plan (EHCP) indicating a significant level of SEND, those who have a mental or physical health need which requires professional support. We find that vulnerable children frequently face more harm online than non-vulnerable children.
Children exist within families – and for online safety regulation to have real-world value, it should be delivered in ways which are practical and reflective of most children’s everyday experiences. We think that it is a significant risk to children’s safety if the role of parents is not acknowledged by Ofcom’s regime in a meaningful way.
Parents are a key protective force in children’s online lives. The overwhelming majority of children (84%) learn how to stay safe online by speaking to a parent.
Among children who have experienced a harm online, the greatest proportion spoke to a parent (45%) and/or asked a parent take action on the device (30%).
Parental tools and controls are a key means by which parents can supervise their children’s safe use of online service, blocking access to harmful content, limiting who can communicate with their child, and setting time limits on devices.
It is disappointing that Ofcom have decided not to recommend use of parental controls in the draft Code, citing limited evidence about the effectiveness and uptake of these tools. Despite the key protective factor that parental controls can play in children’s online experiences, our most recent tracking data indicates that:
Our qualitative research with parents on attitudes to smartphone and social media use finds that parents see value in parental controls but there are challenges around accessibility.
“Sky has parental control, so it pops up when you’re starting your internet package, they tell you all the features. It tells you that you can have your parental controls on then as well. … but I don’t think a lot of people actually put them in place.” – Parent, Internet Matters focus group, June 2024
Our own research into children’s use of online platforms supports Ofcom’s findings that underage use of social media is widespread. Our most recent (May 2024) Tracker Survey found that significant numbers of children are using platforms below the minimum age requirement.
This is despite a majority of both children and parents thinking that major social media platforms should not be accessible to under-13s. This is a challenge that Ofcom must address through the Protection of Children Code.
Many children who experience harm online do not report issues to the platform. In our most recent Digital Tracker survey, we find that just 24% of children who had experienced a harm online reported it to the platform where the issue happened – either themselves or with the help of a parent / caregiver.
Among children who experienced a harm and reported it to the platform, over half (56%) asked a parent to report the issue and around a third (36%) reported the issue directly to the app or platform where the issue happened themselves.
Overall, among children who have experienced an online harm, just 8% reported the issue directly to the platform themselves. Children are far more likely to seek help offline, choosing to speak to a parent or friend. The reasons behind this are varied and complex, and include:
Child-on-child harm that doesn’t meet the threshold for illegality, such as bullying and harassment, can also have a devastating impact on victims and their families. While physical bullying can be more easily recognised by teachers, online bullying and harassment outside school hours can be more challenging for schools to identify and address.
For this reason, it is critical that platforms play their part in protecting children from child-perpetrated harm – with the provision of bespoke reporting routes for this behaviour.
For instance, online bullying is experienced by around 1-in-6 children (16%) with the highest incidence among children aged 11-12. Furthermore, over a quarter of vulnerable children have experienced bullying (compared to 14% of all children). It is the most impactful form of PPC/PC experienced by children with 16% of these children who have experienced online bullying describing it as causing “serious distress, upset or harm”.
