Growing up in the Online World: the context and framing of the Government's consultation
In the first of this series of blogs on the Government consultation on “Growing up in the online world”, we look at the aims of the consultation, the context in which it is being launched and its framing, focusing in particular on the introduction and chapter one of the consultation document. Further blogs will follow on: the proposed interventions; compliance and enforcement; parental and other support; and what’s likely to happen next.
We will be submitting a formal response to the consultation, which will be informed by the analysis in this and forthcoming blogs, and we will publish that in due course too. The consultation closes on 26 May.
Background
The Government launched its “National Conversation” on children’s online safety on 2nd March, having announced it on 19th January. The announcement was a response to pressure from both parents and Parliamentarians, which created a pincer movement forcing the Government to act. Parental pressure came from a huge email-writing campaign, organised by Smartphone Free Childhood, calling for a ban on social media for under-16s which led to MPs from all parties raising the issue in the Commons. Corresponding Parliamentary pressure came initially from the House of Lords, where Conservative Peer Lord Nash had an amendment calling for such a ban already tabled for the Children’s Wellbeing and Schools BIll Report stage debate - which he won, on 21st January, with cross-party support. Many Peers voted to back him because they felt that the Government’s rushed announcement of a consultation was an attempt to prevent proper debate on the need for action and they wanted to send the “ban” amendment back to the Commons to force that.
The gap between the announcement of the consultation and the publication of the document underlines how much the former was a political handling strategy rather than a considered policy intervention and, as we set out below, the substance of the published consultation also exposes the fact that this was something produced at speed, under pressure, by a Department and Government that had - until January this year - successfully resisted civil society and expert calls for meaningful policy thinking on the next stage of online safety regulation over the previous 18 months.
The Government’s focus on political expediency was further exposed by the production of its own counter-amendment to the Children’s Wellbeing and Schools Bill when it returned to the Commons on 9th March in ping pong: this proposes to take a number of “Henry VIII powers” to enact the findings from the consultation, including - potentially - an under-16 ban. You can read the analysis on this approach from our expert legal adviser, Prof Lorna Woods, here. At the time of writing, the Bill had returned to the Lords - where Nash’s amendment was voted for again, with much displeasure voiced at the Government’s tactics - and is due to be back in the Commons for debate on 14th April.
(Further useful context on the legislative debates and the policy arguments for/against a ban is available in this excellent House of Commons Library briefing.)
Context
There is no doubt that action to improve children’s online safety and hold tech companies, particularly social media platforms, more strongly to account is long overdue. The successful grassroots parental campaigns are a symptom of that, particularly driven by parents of younger children who want to delay their offspring’s exposure to social media (or, in some cases, digital devices in general) and increasingly by health professionals, who are dealing with significant numbers of children and teenagers presenting with problems that have social media access and/or exposure as a contributing factor.
It is not our intention here to go through the arguments for and against a ban: the views of many of our Network partners are here, and the oral and written evidence from Prof Woods to the Science, Innovation and Technology Committee is here. Many thousands of words have been written and spoken about the proposals - from proponents and opponents - since January. We will focus on the questions posed by the DSIT consultation with regard to age restrictions (whether framed as bans, or raising the age of access for children, or preventing dangerous or risky platforms accessing children) in our next blog.
But it is important, when considering the DSIT consultation, to ask: if a social media ban is the answer, what is the question? What is the outcome that a ban on under-16s accessing social media is intended to deliver? Being able to answer that question clearly is a necessary first step if we are then able to assess whether a ban (or access restriction) is the right approach and how it would then need to be designed, implemented and enforced to ensure it delivers that outcome. This question may not matter for campaigners calling for “something to be done” - and indeed, the pressure that this seemingly simple solution (“ban children”) has created has already delivered an important result in unblocking the Government’s resistance to engaging meaningfully with calls for improved online safety and measures to strengthen the OSA and Ofcom’s enforcement of it. But it does matter if you are the Government proposing it as a policy solution and asking people to respond “yes” or “no” to it.
Framing
The consultation is not entirely clear on whether the proposals (bans or other measures) are intended to improve children’s online and/or offline wellbeing (eg improving childhood experiences and outcomes) or protect them from harms primarily associated with online environments (eg exposure to inappropriate content or activity). On the former, the consultation states on p5 that “the government is seeking views on its proposals to ensure children have enriching digital lives”; the Secretary of State in her foreword talks about what makes a “great childhood”; and the introduction talks about “time spent away from screens in healthy real-world environments”.
The introduction switches between both these perspectives and ends with a “simple ambition: to make sure that our children’s lives online are as safe and healthy as they are offline, while equipping them with the confidence, skills and support to thrive in a world transformed by rapid technological change”.
In the next chapter, the Government says they “want to deepen our understanding of how children engage with digital technologies in their daily lives to inform future government work”, with a number of paragraphs describing various uses of technology by children which “enrich” their lives, including education and learning, creativity, gaming, communication and language learning. This is then followed by a canter through the problems linked to “patterns of use” (screentime, sleep deprivation, displacement of offline activities) which may be affecting “critical parts of health [sic], happy childhoods where every child achieves and thrives” (p15) and the “features and functionalities” within platforms which “can exacerbate harm for children”.
The limits of the Government’s ambition are apparent in relation to one of the biggest challenges around digital technologies - whether enriching or otherwise: the business models. In the introduction, the Government refers to the fact that the consultation is “considering options to address concerns that the business model of certain apps .. designed to keep users online for longer” (p10) and there is a reference in chapter 1 to “concerns about business models that are built around driving engagement”. But there are no corresponding questions that respondents can engage with on problems from “business models”, except obliquely via tick box responses on the harm relating to lists of “addictive” or “persuasive” features and functionalities designed to keep children online for longer.
Despite the high-level overview of what the Government deems to be positives and negatives from digital technology, the simple ambition they set out in the introduction cannot be delivered upon by this consultation. It assumes that children’s “offline” lives are a quantifiable benchmark for “safe” and “healthy” and can be measured as such in isolation from their “online” lives. A “great childhood” comprises both online and offline dimensions, but the consultation is silent on the interventions that the Government would like to make to improve the “offline” aspects of childhood safety and health in tandem with the online impacts. It also assumes that digital technologies - products, services, devices - are either “positive” or “negative” depending on the content they serve up or the interactions they offer children, when the reality is very nuanced.
Excessive screentime at the expense of other activities can have a detrimental impact on a child’s development and physical health (see, for example, here, and here) regardless of whether the screen use is related to “enriching” or educational content, just as exposure to harmful activity or content can have a detrimental impact on a child’s safety or their emotional or psychological wellbeing, regardless of whether it is one-off occasion or the result of cumulative exposure. One-size-fits-all interventions - in particular bans or age restrictions aimed at a limited number of platforms and services - will not address the complexity of what a “good childhood” means, or improve “wellbeing”, particularly if the Government is unable to describe what those ambitions look like.
In short, a consultation document, rooted in evidence and structured coherently, that delivered on this simple ambition would have taken longer than six weeks to produce. This is a document that opens up a number of long-overdue conversations about children’s social media use, the design of social media platforms and the levers that the Government might have to address these issues, which is very welcome. But it risks doing no more than just test the temperature on what works and what doesn’t within the bounds of that narrow scope. Crucially, given the political context in which it was announced and launched, the Government does parents and children a disservice implying that this document can do more than this. Nearly two and a half years after the Online Safety Act received Royal Assent, it is therefore ultimately disappointing that the first consultation on how to improve it is so limited.
Regulatory and policy context
These limitations are even more disappointing given that the Government’s faith in the OSA as the “foundation” and “strong baseline” (p10) for the way forward - and its promise that “any new measures will align with this existing framework” - fails to acknowledge the problems within the structure of the Act itself.
At her first Parliamentary Questions following her appointment as Secretary of State for Science, Innovation and Technology, Liz Kendall answered a question on the effectiveness of the Online Safety Act: “I will be paying close attention to what is working and will not hesitate to go further if necessary,” she said; and, referring to the addition of self-harm material to the list of priority offences in the OSA, “I hope this shows the House my determination to take all necessary steps on this issue.”
That was on 10th September 2025: six months on, this consultation gives respondents no opportunity to put suggestions on what further necessary steps she might take to resolve the things that are not working and to strengthen the “foundations” of the Act - for all users - to ensure it will to deliver on its promise. (See our 10 Point Plan for strengthening the Online Safety Act for a list of such suggestions.)
The Government notes that “all regulatory regimes need to remain agile” and that acting “swiftly” is necessary in the “fast-moving world of technology”. There is no reference in the consultation as to where the Government - or Ofcom, its regulator - might have been more agile and swift in the two and a half years since the OSA received Royal Assent. With that in mind, we will explore in the next blog whether many of the measures the Government are consulting on here could have already been implemented by Ofcom and what that tells us about the pressures the Government are now under to act “swiftly”.
There are welcome references to “safety by design”, but again, starting from an assumption that this has already been delivered under the existing framework eg with references to the OSA “already” calling for services “to take a safety by design approach to protect children” from harmful content (p15), and an intriguing statement in chapter 3 that “Any new approaches to enforcement will build on and complement existing approaches to keeping children safe online, including existing safety-by-design duties and the Protection of Children Codes of Practice”. (While there is a statement in section 1 of the Act that “Duties imposed on providers by this Act seek to secure (among other things) that services regulated by this Act are safe by design”, this is not the same as a “safety by design” duty.) As we have consistently argued, Ofcom’s interpretation of this requirement has been lacking.
If this consultation shifts the regulator towards a greater understanding of what “safety by design” means, that will be welcome; to aid this, we will be publishing next month a code of practice on safety by design to demonstrate what good looks like.
Our next blog in this series on the DSIT consultation will focus on the proposed interventions, including bans, age restrictions and action on risky features or functionalities.
