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Image © Dr. Faith Gordon on behalf of Catch 22

'Acceptable use' and regulation

November 2021

Key Recommendations - 7 'R' Framework


Research is essential to generate evidence and insight and for the development of vital new knowledge. Given how rapidly platforms and technologies are evolving, investment and transparency are essential to ensure that research is up to date.

One such example in this study is the view of representatives from the tech profession, who stated that research is essential for the importance of defining what “harm” is. As outlined above, CYP in this study describe harm as unwanted content, unwanted contact, unwanted surveillance and collection of their data, as well as the clear lack of redress.

More transparency and engagement on the part of companies is needed. Collaborations with independent academics can create new knowledge, generate more data on the capabilities of tech and therefore better enable society to gain more insight.

ACTION: All reforms need to be based on evidence. For those that affect CYP, children and young people should be effectively consulted.Evidence about CYP should come from CYP.

ACTION: Given how rapidly platforms and technologies are evolving, resources need to be dedicated to independent research that is fully participatory and includes transparent input from tech companies.

When the United Nations Convention on the Rights of the Child 1989 (UN CRC) was drafted and adopted, we did not have the digital environment that we do today. It is an ever-evolving space and new and emerging technologies are constantly being introduced into our lives. In recognition of this, the United Nations General Comment No. 25 on children’s rights in relation to the digital environment was formally adopted by the United Nations Committee on the Rights of the Child in February 2021.

It was clear from the discussions with CYP in the focus groups that what they often referred to as being important for them in their online interactions and use, were clearly linked to their rights under the UN CRC. For example, their right to participate and be listened to (Article 12), to engage in play (Article 31), to find and share information (Articles 13; 17) and their right to have their privacy protected (Article 16).

CYP also have several other rights which relate to issues that have emerged in the research findings in this report, including the right not to be exploited (Article 36).

ACTION: The United Nations General Comment No. 25 on children’s rights in relation to the digital environment makes clear recommendations.
The United Kingdom needs to engage more with the international children’s rights instruments and embed the international children’s rights frameworks into proposed reforms.


Regulation and the creation of a regulatory framework has been the central focus throughout the discussions and debates in the United Kingdom. The proposed legislative framework of the draft Online Safety Bill, includes details of an independent regulator.

Regulation however is not a panacea. It will not address each and every aspect of online harm. It is one aspect in an array of required measures, including education, the need to address social inequalities, the need for transparency by companies and partnership work.

ACTION: Legal but harmful content should be recognised in future legislation and the need for a clear duty of care.

ACTION: For regulation to be successful, emphasis needs to be placed on areas such as education and development, addressing social inequalities, and the need for transparency by companies.


CYP felt that balancing freedom of expression, access to information and safety from exploitation was a major challenge for companies, the government and wider society. CYP placed a lot of emphasis on the responsibilities of companies and felt that they should be held accountable for inaction. They felt that an independent oversight body would be an effective monitor on companies and could hold them to account.

A statutory duty of care placed on social media service providers as regards their users, was proposed by Professor Lorna Woods, William
Perrin and Maeve Walsh, as part of the work of the Carnegie UK Trust. The authors argue that this proposed framework, supported by a code of practice that is drawn up with expert stakeholders, has the potential to assist with protecting CYP online.

ACTION: Companies should be responsible for the creation and maintenance of safe spaces online and they should be held accountable for inaction in addressing concerns.

ACTION: An independent and transparent oversight body is required for overseeing regulation, which can ensure that companies and individuals are held accountable. CYP need to be made aware of its existence and role, and all information and complaints processes need to be accessible for CYP.

ACTION: Research demonstrates lack of knowledge on the part of adults in relation to age requirements for platforms and games and more effort needs to be put into educating adults.

ACTION: In relation to age verification, CYP suggested a more rigorous process for their age group, as well as for adults. Suggestions included asking people for their passports as a form of ID, using secure apps and advocating for digital passports, which have been officially verified.

ACTION: Young people suggest that companies should be using the technology that they have, to assist with the monitoring and removal of harmful content before users are affected by it.


During this research, most CYP stated that this was one of the first times that they had been asked about their experiences online and what interventions they could suggest. CYP want more opportunities to express their opinions and for their suggestions to inform change. They also want opportunities to engage with those who design, maintain, and regulate online spaces.

ACTION: Policymakers, legislators, practitioners, and industry need to create greater opportunities for CYP’s opinions, from a diverse range of backgrounds to be heard. They need to ensure that CYP’s experiences inform change in areas such as online safety, accessibility and in the education design and delivery space. Australia’s ‘Safety by Design’ approach is an example worth considering.

ACTION: CYP want to be part of the design and delivery of education programmes. They want to be part of panels that tech companies, platforms, and gaming designers consult with when designing, developing and updating new products.


CYP have said that responses from companies following a complaint often go unaddressed or there are delays. The delayed responses, often automated, were referred to as retraumatising and made CYP relive the original harmful experience.

A small number of CYP mentioned experiences of having their mobile phones taken away by the police for evidence-gathering purposes for months at a time, in response to serious incidences. For less serious incidences, professionals’ approach was too often about CYP ‘getting offline’, which denied their access to the digital environment.

ACTION: CYP and their advocates want to see quick, appropriate, effective, and proportionate responses to online harms. They want personalised - not automated - responses and want to feel that companies are acting on complaints.

ACTION: CYP want law enforcement to outline from the outset how long they will require their phones and devices for, and they want swifter processing and better updates from law enforcement.

ACTION: Frontline professionals must be trained and prepared for responding to instances of online harms and divert CYP towards embracing the opportunities digital worlds can present.


There have been notable challenges for those working in education and safeguarding, in particular the impact of the blurred boundaries between online and offline spaces, the rapid need to adjust and transfer to educating CYP online during lockdowns, as well as engaging with already stretched external agencies such as the police, victim support and child protection services.

This research has demonstrated that educators and safeguarding professionals feel that the lack of resources to respond to the rise in incidents of online harms, leave them feeling overwhelmed and concerned for the safety, health and well- being of CYP.

ACTION: More resources are needed for those working in education and safeguarding and also adequate funding needs to be available for the provision of victim support to address harms originating online.

ACTION: CYP want reforms to PHSE education to include online behaviour, and professionals want to see more education on how to ‘self- regulate’, identify harmful behaviour and report such incidents too.

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