Online Safety Act Network

Responses

Response to JCNSS Call for Evidence on "Defending Democracy"

The OSA Network submission to the call for evidence from the Joint Committee on the National Security Strategy to inform its inquiry into “Defending Democracy” can be found as a PDF at the bottom of this page.

Response to the Government's Pornography Review Call for Evidence

Our submission to the Pornography Review Call for Evidence is provided as a PDF below. Our response focuses on the regulatory, legislative and enforcement context for the Government’s review of Pornography. While we we know that there is a line drawn between the scope of the Online Safety Act and the interests of this Review, we would recommend that it is not taken as read that the OSA will deliver the step change envisaged in the online environment – at least not in the short-to-medium term - and we would encourage Baroness Bertin and the review team to consider where gaps remain.

Response to Ofcom's consultation on guidance for providers publishing pornographic content

Our full response to Ofcom’s consultation on its draft guidance for service providers publishing pornographic content is available as a PDF at the bottom of this page and summarised below. This is the guidance that will support regulated services’ compliance with part 5 of the Online Safety Act. There are a number of concerns that we raise below that have relevance to those we flagged in our response to Ofcom’s Illegal Harms consultation - in particular, the approach to proportionality and the focus on costs.

Response to Ofcom Illegal Harms Consultation

Our full response to Ofcom’s first Online Safety Act consultation on illegal harms has been submitted. It is available as a PDF below, along with some of the supporting material we have also submitted. It is to Ofcom’s immense credit that this first consultation (“Protecting people from illegal harms online”) was produced so quickly after the Online Safety Act received Royal Assent. The protracted passage of the Bill through Parliament undoubtedly afforded much time to prepare in some areas – for example, undertaking calls for evidence and commissioning research, recruiting staff and building up expertise.

Response to Ofcom's Proposed Plan of Work 2024/5

Ofcom’s proposed plan of work for 2024/5 does not mention any engagement with civil society organisations in its Online Safety deliverables (indeed, there is no mention of “civil society” within the whole document), nor does it seem to take account of the work and related resourcing requirements arising from the consequential, iterative work on its first codes of practice that will be required in the light of the first consultation on illegal harm.

Response to DSIT consultation on the OSA super-complaint mechanism

The response available as a PDF below is from the Online Safety Act Network, in conjunction with the Molly Rose Foundation, and reflects inputs from other civil society partners with an interest in this area. The response sets out how we are concerned that the effect of the eligibility criteria will significantly limit the number of expert organisations who might otherwise enter the super-complaints mechanism and that the impact of the procedural requirements on the number of super complaints that Ofcom can consider at any one time will further weaken the regime’s effectiveness.

Response to the Digital Regulation Cooperation Forum call for input on its 2024/5 workplan

This is the response submitted by the OSA Network to the Digital Regulation Cooperation Forum (DRCF) call for input on its 2024/5 workplan which can also be downloaded as a PDF below. We welcome the opportunity to provide input to the DRCF’s workplan for 2024/5. The Online Safety Act Network has been set up to continue the work that Carnegie UK took forward on the online harms agenda, in particular providing policy development and advice to civil society organisations and convening discussions on priority issues arising from the Ofcom consultation programme.

Response to Ofcom call for evidence on categorisation

This is the response submitted by Carnegie UK to Ofcom’s call for evidence on categorisation. In addition to the proforma submission, which can be downloaded as a PDF below, the following additional points were made. Additional evidence Some smaller platforms should be seen as part of a network of harm. This is in two directions: as a seed or catalyst, generating harmful content (such as a nudification app service, racist or suicide memes) which are amplified/distributed on larger platforms or in the opposite direction as an extreme destination to which people are teased from larger services.