POSR0005
The Online Safety Bill represents a crucial step towards addressing the growing concerns regarding online safety in the United Kingdom. With an increasing number of people experiencing online harm, particularly children, the government's goal of making the UK the safest place in the world to go online is both admirable and essential. However, the successful implementation of such a comprehensive regulatory framework presents several challenges, including the need for preparedness among key stakeholders.
One of the primary challenges highlighted by the National Audit Office (NAO) report is the unfamiliarity of many online services with Ofcom and its regulatory processes. It is essential to recognize that a significant proportion of the services that will fall under Ofcom's purview have not been subject to regulation before. This unfamiliarity can lead to delays, misunderstandings, and potential non-compliance impacting the mental health of children and adolescents. To address this challenge, it is crucial for Ofcom to engage in proactive outreach and education initiatives aimed at helping online service providers understand their new responsibilities. Workshops, webinars, and clear communication channels should be established to bridge this knowledge gap effectively.
The NAO report also highlights that many online services subject to regulation do not have a UK corporate or economic presence. This raises concerns about the enforcement of penalties and sanctions in cases of non-compliance. Without a physical presence in the UK, these entities may prove difficult to hold accountable. To mitigate this challenge, the government and Ofcom should explore international cooperation and agreements with other countries, particularly where these online services are headquartered. Such agreements can facilitate cross-border enforcement and collaboration to ensure that online platforms adhere to the prescribed regulations.
The successful implementation of the Online Safety Bill will require substantial resources, both in terms of funding, personnel, and political will. Ofcom will need to significantly expand its workforce to effectively regulate an array of online services. Additionally, there is a need for advanced technological infrastructure to monitor and assess online content for potential harm accurately together with the impact of problematic use of the internet. By extension, ample resources also need to be made available to support the people tasked with screening potentially harmful content in light of the psychological burden that is paired with this task.
The Department for Science, Innovation and Technology should work closely with Ofcom to ensure that adequate funding and resources are allocated to support this endeavor. A comprehensive capacity-building strategy should be developed to recruit and train personnel proficient in digital technologies, content moderation, and legal matters relevant to online safety.
Problematic Use of the Internet (PUI), is an umbrella term referring to a pattern of excessive and compulsive internet or digital device usage that disrupts an individual's daily life and well-being. It manifests as an inability to control or limit internet use, with adverse consequences for physical and mental health, social relationships, work or academic performance, and overall quality of life. Many aspects of everyday internet use can become problematic, including gaming, gambling, social media use, pornography viewing, shopping and buying etc.
Common signs of problematic internet use include preoccupation with online activities, loss of control over the time spent online resulting in neglect of important responsibilities and persistent excessive internet use despite awareness of its detrimental effects. As much problematic internet usage exhibit characteristics akin to addiction, the World Health Organisation has officially classified two specific forms, gaming disorder and gambling disorder, as distinct mental disorders in the widely accepted 11th revision of the International Classification of Diseases. Individuals who suspect they have problematic internet use are entitled to seek professional intervention to address the issue and enhance their overall well-being.
The Online Safety Bill aims to address the compulsive, addictive or predatory business models employed by tech companies that contribute to problematic usage of the internet (PUI) and introduce safeguards for children against its adverse effects. One of the key provisions of the bill is to hold online platforms and tech companies accountable for their content and services. It introduces new duties on search engines, firms hosting user-generated content, and providers of explicit content to minimize the presence of illegal and harmful content that can be addictive or damaging to users, especially children. By regulating these platforms and requiring them to proactively tackle problematic content, the Bill aims to reduce the exposure of users, particularly young people, to addictive and harmful digital content that can contribute to PUI but does not involve any approach at tackling engagement algorithms designed for compulsive behaviours, nudging and control.
Moreover, the Bill seeks to establish a comprehensive regulatory regime for online safety, emphasizing the protection of children. It acknowledges the unique vulnerabilities of young users and aims to make the UK the safest place in the world for children to navigate the digital landscape. The Bill empowers the regulatory authority, in this case, Ofcom, to oversee and enforce safety measures, including the development of codes of practice that tech companies must adhere to. These codes are expected to address issues such as age-appropriate content, parental controls, and online advertising to children.
While there are undoubtedly challenges in implementing the Online Safety Bill, there are also significant opportunities that can be leveraged to ensure the success of the regulatory regime:
The government, Ofcom, and online service providers should adopt a collaborative approach to address online safety concerns. Engaging in regular dialogues and consultations will foster an environment of cooperation, making it easier to address issues and concerns as they arise.
The advancement of technology can be both a challenge and an opportunity. Investing in cutting-edge technologies, such as artificial intelligence and machine learning, can help automate content moderation and identification of potential harms more efficiently while reducing the burden put on the psychological wellbeing of people tasked with content moderation. Such technologies can also aid in real-time monitoring and reporting.
The black box characteristics of algorithms can make it difficult to understand how data is processed to produce the associated outcomes. Growing business use of algorithms employing artificial intelligence (e.g., to determine eligibility for services) may also increase risk of bias and discrimination against specific population groups. Creating a baseline level of required transparency in algorithms used in a digital environment of UK citizens would allow appropriate responses to be developed and deployed to mitigate and address problematic internet use that stems from predatory AI models.
The UK has the opportunity to become a global leader in online safety regulation. By setting high standards and demonstrating effective regulation, the UK can influence other countries to adopt similar measures to protect their citizens online. This can lead to a safer digital environment not only within the UK but also on a global scale.
Based on the challenges and opportunities discussed, I propose the following recommendations to ensure the preparedness for online safety regulation:
Robust Outreach and Education: Ofcom should launch an extensive outreach and education program for online service providers to familiarize them with the regulatory framework and compliance requirements.
International Cooperation: The UK government should actively engage in negotiations and agreements with other countries to facilitate cross-border enforcement and cooperation in regulating online services without UK corporate or economic presence.
Resource Allocation: The Department for Science, Innovation and Technology should allocate sufficient resources and funding to support the expansion of Ofcom's workforce and the development of technological infrastructure.
Capacity Building: Develop a comprehensive capacity-building strategy to recruit, train, and retain personnel with expertise in digital technologies, content moderation, and legal matters related to online safety.
Technological Investment: Explore partnerships with technology companies to harness the power of AI and machine learning for efficient content moderation and monitoring. Introducing a certain level of algorithmic transparency a requirement to be able to provide services in the UK might be an alternative worth considering. Priority action points can then also be developed to protect those groups disproportionately targeted by commercial algorithms.
Algorithmic Transparency: Develop and enforce a set of transparency criteria for algorithms to allow them to be used in the (digital) context of the UK.
Global Leadership: Promote the UK's leadership role in online safety regulation and encourage other nations to adopt similar measures through international forums and alliances.
Conclusion.
As problematic usage of the Internet is a rapidly expanding and changing field of science, there is a strong need to work with researchers with expertise. Bootstrap (Boosting Societal Adaptation and Mental Health inexpert sceintists a Rapidly Digitalising, Post-Pandemic Europe; HORIZON-HLTH-2022-STAYHLTH-01-01-101080238-2) is a multi-national expert-led citizen science research programme sponsored by Horizon Europe and UK Research and Innovation (UKRI) aimed at initiating health and social policy and practice change to reduce the harmful effects of digitalization on young people’s mental health.
Bootstrap underscores the critical importance of digital safety for young people and the need for evidence-based interventions to address potential harms associated with internet usage.
The project's objectives include:
a) Creating an evidence-based suite of digital behavioral health interventions addressing vulnerability to problematic usage of the internet (PUI).
b) Testing the effectiveness of these interventions in self-management of ill-health prevention in youth.
c) Developing a policy toolkit and standards to promote digital human rights and public and private accountability to safeguard vulnerable groups from exploitation.
d) Presenting the evidence emerging from the research activities to policy makers on a regular basis.
To enable successful execution of the project, Bootstrap delivers:
The Bootstrap project recognizes that digitalization, while offering numerous benefits such as access to information and communication, also presents multifaceted challenges and risks to individuals and society. Adolescents are enthusiastic users of digital technologies, and digitalization can serve as a bridge for them to transition from the family environment to a wider peer community. However, it's crucial to acknowledge the complexities surrounding digitalization's impact on mental health. Studies have yielded varying results, with some linking frequent internet use to poor mental health outcomes and others finding positive correlations with well-being. These differences highlight the importance of considering not only the amount of time spent online but also the motivation, quality, and patterns of use, distinguishing between normative and potentially addictive behaviors.
One of the core challenges addressed by the Bootstrap project is the pervasive nature of PUI. PUI encompasses a spectrum of maladaptive internet use patterns characterized by diminished control or hazardous behaviors. Its consequences extend beyond the individual to society at large, including the neglect of normative behaviors and relationships. Adolescents, whose cognitive control is still developing, are particularly vulnerable to PUI, making it a critical marker of disrupted self-management. Severe forms of online gaming and gambling have even been classified as mental disorders in the ICD-11, termed Behavioral Addictions. Understanding the determinants of PUI is essential, as it arises from complex interactions between individual factors (such as age, mental health, and cognitive control), relational factors (including family dynamics), and societal factors (such as platform features and regulation policies).
Adolescence represents a pivotal phase in the study of digital health and online safety. This period is characterized by heightened risk, as young people navigate the complexities of digitalization and its impact on their mental well-being. Notably, adolescents with pre-existing mental health issues face an increased susceptibility to PUI, a vulnerability that has been further exacerbated by the challenges posed by the COVID-19 pandemic. Rates of PUI among European school children, for instance, have surged to alarming levels. As much as 30% of European school children have reported experiencing some form of PUI, underscoring the urgent need for comprehensive research and evidence-based interventions. The Bootstrap project is dedicated to understanding the unique challenges faced by adolescents during this critical developmental phase and developing strategies to safeguard their mental health in an increasingly digitized world.
These additional paragraphs provide a deeper insight into the challenges and objectives of the Bootstrap project, emphasizing the urgency of addressing problematic internet usage among adolescents and the importance of considering the nuanced impact of digitalization on their mental health.
Adolescence is a high-risk period for Problematic Usage of the Internet (PUI), and this vulnerability has been exacerbated by the profound effects of the COVID-19 pandemic and its ongoing aftermath. Globally, approximately 1 in 7 adolescents grapple with mental health problems, yet these issues often go unrecognized and untreated. This unique neurodevelopmental stage is marked by significant physical, emotional, and social changes, all of which contribute to an increased susceptibility to various mental health problems, including PUI. Multi-level psychosocial and physiological changes, including extensive exposure to the internet, make adolescents more prone to PUI. The digital realm, often used as a coping mechanism for personal difficulties and negative emotions, offers newfound freedoms to engage in digital activities. However, the incomplete maturation of cognitive control mechanisms in adolescents makes them particularly vulnerable to the allure of the internet.
Understanding the impact of PUI on adolescents during this critical developmental phase is paramount. PUI can act both as a consequence and a causal factor for a multitude of individual and relational health and well-being issues. These encompass impaired mental health, physical health, family and social interaction, academic and occupational performance, and broader societal issues such as the proliferation of misinformation and conspiracy beliefs. Investigating the intricate interaction of these factors over time is essential for identifying causal relationships and risk determinants as the foundation for effective interventions. Given that adolescents with PUI and associated mental health problems are particularly vulnerable to social exclusion, discrimination, stigma, and educational difficulties, interventions to support their mental health are urgently needed. Early detection and intervention are vital to prevent the progression of PUI to addiction and other forms of ill-health or harm. Personalized self-management interventions applied on a broader scale within the school setting hold promise as a less stigmatizing and cost-effective approach. However, the development of effective health and social policy recommendations necessitates a comprehensive understanding of the causes, effects, health economic costs, and burdens associated with PUI. Currently, such comprehensive understanding is hindered by methodological inconsistencies in the research base, including reliance on cross-sectional approaches and the use of self-report tools that are susceptible to bias.
The objectives outlined in the Bootstrap project closely align with and contribute significantly to the UK policy framework, particularly in the realm of health and social well-being in the digital age. The European Parliament Scientific Foresight Unit has recognized the pressing need for community and clinical interventions to facilitate early detection and prevention of PUI among adolescents. Given the current lack of evidence-based interventions, the project spearheads efforts to establish standardized research approaches and data collection methods. It seeks to establish a comprehensive knowledge base concerning the extent, determining factors, and impact of healthy versus harmful internet use among adolescents, thereby laying the groundwork for preventive interventions, practice changes, and policy improvements.
Alignment of Online Safety Bill with the Bootstrap Project: A Holistic Knowledge Base
Bootstrap's first objective is to develop a comprehensive knowledge base about the determinants and impact of internet use in adolescence. By identifying key determinants reliably predicting healthy versus unhealthy internet use at the individual level, the project contributes valuable insights for preventive interventions. This objective aligns with the European policy goal of promoting mental well-being and digital empowerment in health literacy, which are central to the Bootstrap concept. Through standard and machine learning analysis, the project aims to create models differentiating vulnerability to specific types of PUI, thereby contributing to personalized interventions. The project also seeks to provide a gold standard approach for detecting PUI and assessing the risk of PUI development in adolescents. These outcomes directly support European initiatives focused on mental health and personalized prevention, as outlined in the Recovery Plan for Europe and Work Programme Health '21-'22.
Alignment of Online Safety Bill with the Bootstrap Project: Personalized Preventative Interventions
The second objective of Bootstrap focuses on developing and validating preventative interventions for promoting healthy self-management of internet usage and well-being, using personalized approaches. This objective aligns with the European policy framework's emphasis on personalized prevention. Bootstrap aims to adapt evidence-based preventative self-management interventions for digital use, making them accessible through the 'BootstrApp.' The project will also develop an algorithm predicting the optimal preventative intervention for each individual, taking into account personalized markers determining their response to the intervention. This personalized approach aligns with the policy direction of tailoring health interventions to individual needs, improving cost-effectiveness, and fostering feasibility for widespread implementation. Bootstrap's work directly contributes to Destination 1: Staying healthy in a rapidly changing society within the European policy framework, as it strives to promote healthy internet use via practice and policy change, emphasizing mental health and digital empowerment in health literacy. It aligns with the overarching goal of creating a more sustainable Europe through improved health and well-being.
By incorporating the Bootstrap project's objectives and methodology into the evidence submission, the real-world significance of effective online safety regulation, especially concerning young people's mental health and well-being, will be more fully realised. This additional context can help the Committee understand the broader implications of the Online Safety Bill and the need for thorough preparedness.
The Online Safety Bill represents a significant step towards ensuring the safety of internet users, particularly children, in the UK. While there are challenges in its implementation, including the unfamiliarity of many online services with regulatory processes and the lack of UK corporate presence, there are also opportunities to lead in online safety regulation through international cooperation and technological advancements. By taking proactive measures to address these challenges and leverage opportunities, the UK can achieve its goal of becoming the safest place in the world to go online.
Thank you for considering this evidence submission on the preparedness for online safety regulation. I hope that these insights contribute to the effective implementation of the Online Safety Bill and the protection of internet users in the UK.
October 2023