POSR0011

Written evidence submitted by Match Group

Summary

• Match Group welcomes the Online Safety Bill as a landmark piece of legislation that will help position the UK as the safest place in the world to be online.
• Match Group has previously engaged with Ofcom officials to help ensure the timing of the implementation of the Bill is reasonable and takes into account Ofcom’s capacity.
• Match Group continues to work with officials and is looking towards how to support Ofcom on the implementation of the Online Safety Bill following Royal Assent.
• The Online Safety Bill has a suitably expansive scope to reflect the wide range of threats posed to users online.
• Match Group agrees that it is right that every part of the digital ecosystem is addressed by the Bill to ensure that the UK’s online safety regime is robust, holistic and fair.
• Match Group has advocated for this broad definition and welcomes the fact that the Bill recently addressed the gap of app store regulation.
• Match Group has worked closely with Parliamentarians towards the introduction of an amendment which brings app stores into the scope of the Online Safety Bill.
• Understanding that this will increase Ofcom’s workload, the amendment was designed to work within practical parameters and a reasonable timeline of implementation.
• This amendment comprises a two-stage process, including an extended period for Ofcom to gather necessary information on how app stores implement age assurance measures and whether these stores present a material risk to a significant number of children for access to age-inappropriate content, before the Secretary of State would then implement the review’s recommendations.
• Match Group supports measures that ensure Ofcom is prepared for implementation and that Ofcom has necessary funding to expand its capabilities and capacity.
• Match Group encourages Ofcom to work closely with organisations and officials, including those abroad, to ensure collaboration and compliance across the tech sector.

About Match Group

Match Group operates online dating services across the globe, including Tinder, Match, PlentyOfFish, OkCupid, OurTime, Meetic, and Pairs. Through our portfolio of trusted brands, we provide tailored products to meet the varying preferences of our users. We currently offer our dating products in 42 languages across more than 190 countries (Group official website: http://mtch.com), including in the United Kingdom where some of our main brands are widely used.    

Match Group is proud to have worked closely with Ofcom and the other members of the Digital Regulation Cooperation Forum (DRCF), including the Competition and Markets Authority (CMA) and the Information Commissioner’s Office (ICO). This has included contributing to several previous consultations, such as Ofcom’s call for views on their workplan in February 2023, the ICO’s Children’s Code guidance in May 2023 and Ofcom’s call for evidence on the protection of children online in March 2023.

In addition to this, Match Group has liaised on several occasions with the Government, policymakers, and relevant parliamentary committees to discuss vital issues facing the digital ecosystem ranging from online safety to fraud and digital competition. This includes providing evidence to the Communications and Digital Committee and the Public Bill Committee on the Online Safety Bill, and to the Public Bill Committee on the Digital Markets, Competition and Consumers Bill. Our support of this legislation is widely recognised, and we have been privileged to work with a variety of stakeholders to promote safety, fairness, and innovation in the UK’s digital ecosystem.

We are delighted to continue our collaborative relationship with Ofcom and to provide evidence on the subject of categorisation within the scope of Ofcom’s online regulation preparedness. We continue to be grateful for the opportunity to support Ofcom in being a world-leading independent regulator and we thank you for your consideration of this evidence. 

Ofcom and the Online Safety Bill

The Online Safety Bill is a landmark piece of legislation that will deliver vital improvements to the UK’s online spaces, putting the safety of children at the heart of the online experience. Match Group commends both Houses of Parliament for passing the Bill. We look forward to the online safety regime becoming enshrined in law as it completes its Parliamentary journey.

Following years of intensive debate, comprehensive expansions and ground-breaking amendments, the size and scope of the Online Safety Bill has evolved drastically from what was first outlined in the 2019 Online Harms White Paper. These updates were necessary to bolster the UK’s online safety regime, ensure that challenges across all layers of the digital ecosystem were being addressed, and achieve the Government’s manifesto commitment of making the UK the best place in the world to be online.

However, as the National Audit Office (NAO) report has correctly observed, the substantial changes in the scope and the content of the Bill have resulted in Ofcom being tasked with vast responsibilities related to upholding an ambitious and thorough online safety regime across an array of sectors and services. The report estimates that more than 100,000 services will fall under the purview of Ofcom as a result of this legislation, which will require the production of more than 40 regulatory documents and codes of practice.

Match Group commends Ofcom for the proactive preparations it has made in advance of the new online safety regime coming into force, including amending its organisational design and recruitment targets to reflect the new scope of its work.

In particular, as Ofcom works towards drafting the several new guidance documents required to assist firms in navigating through the new online regulatory regime, Match Group is pleased to see deliberate efforts to invite feedback and collaboration from the private sector.

By actively engaging in partnerships and dialogue, Ofcom can help ensure compliance and alignment with the evolving standards and practices across the tech sector. This approach not only bolsters user safety but also promotes a harmonious and secure online environment for all. Match Group is eager to contribute to these efforts and work collaboratively towards a safer online world.

Match Group and the Online Safety Bill

Match Group is proud to be an industry leader in online safety, and we invest millions of dollars and thousands of hours into our trust and safety features, with over $125 million going towards our content moderation and user safety features in the last year. Safety is a top priority for us, and we encourage our users to immediately report any behaviour that violates our policies or terms of guidelines. Our safety features use a combination of machine learning and automation, and human oversight and moderation, to ensure the best results and a constantly adapting approach to trust and safety.

Match Group has been pleased to engage with stakeholders and policymakers on the Online Safety Bill and to support both the Government and the Opposition in ensuring that the UK’s online safety regime is robust, holistic and fair. We have been proud to work with both Ofcom and the Competition and Markets Authority and have engaged extensively with political and third-sector stakeholders across the UK with the goal of supporting a safer and fairer digital ecosystem in the United Kingdom. This is a goal we passionately support and we are fully meeting our responsibilities as a service provider operating in the UK.

Central to our engagement with the Online Safety Bill has been successfully advocating for the introduction of an amendment that moves towards imposing child safety and illegal content duties on application stores. Match Group believes that to prevent minors from being exposed to adult content, it would be most efficient to check users’ ages at the distribution layer, in addition to the checks developers already undertake, which means directly in the app store or on the web browser. Doing so would prevent the risk posed by such a large part of the digital ecosystem that is currently poorly regulated and therefore ensure that all levels of the digital economy are holistically co-ordinated. 

Match Group is aware that this amendment marks a substantial expansion of the scope of the Online Safety Bill, broadening the online safety regime into a new layer of the digital ecosystem entirely separate from the user-to-user messaging services and social media firms that form the traditional focus of the Bill.

We are also fully aware that this expansion will entail a heightened workload for Ofcom, and thus, we have crafted the amendment with practicality and a reasonable implementation timeline in mind. This approach includes a crucial step of review before actual implementation, allowing Ofcom the necessary time and resources to adapt effectively.

Moreover, we have maintained an active partnership with officials within Ofcom and the Department for Science, Innovation, and Technology to ensure that the language and intent of the amendment align seamlessly with Ofcom's existing powers and responsibilities. This alignment streamlines the process for Ofcom, reducing any additional steps required to implement the amendment effectively.

Match Group is also keen to visualise our relationship with Ofcom once the Bill is passed. We are particularly interested in engaging with Ofcom to discuss the supervisory function that Ofcom is in the process of establishing in time for the commencement of the online safety regime. This includes working with officials to contribute to Ofcom’s understanding of services, systems and processes to greater ensure user safety once the online safety regime is implemented.

In keeping with our commitment to fostering a safer digital environment, Match Group wholeheartedly supports measures aimed at ensuring that Ofcom is well-prepared for the upcoming changes and that it receives the requisite funding to bolster its capabilities and capacity. By doing so, we can collectively work towards the successful execution of the Online Safety Bill's expanded provisions, safeguarding online spaces for all users.

Conclusion

Match Group reaffirms its commitment to collaborative efforts aimed at ensuring the effective implementation of the Online Safety Bill. Our engagement with Ofcom officials on multiple occasions underscores our dedication to fostering a safer online environment for all users.

The Online Safety Bill represents a landmark piece of legislation that positions the UK as a global leader in online safety. Its expansive scope, addressing a wide array of online threats, rightly places Ofcom at the forefront of regulating the digital ecosystem.

We commend the recent inclusion of app store regulation within the Online Safety Bill, an amendment that we worked closely with parliamentarians to introduce. Recognising the added workload this entails for Ofcom, we have designed the amendment with practicality and a reasonable implementation timeline in mind, ensuring that the regulatory body can adapt effectively.

In the spirit of collaboration, Match Group fully supports measures which enable Ofcom to be adequately prepared for the Bill's implementation, including securing the necessary resources to enhance its capabilities and capacity.

Furthermore, we encourage Ofcom to continue its close collaboration with organisations and officials, both domestically and internationally. Such partnerships are vital in ensuring collaboration and compliance across the tech sector, ultimately contributing to a safer and more secure online environment. Together, we can make the UK the safest place in the world to be online, and Match Group stands ready to contribute to these vital efforts.

October 2023