Written evidence submitted by Jodie, Image-Based Abuse Survivor-Campaigner [IIA009]

Police Response to Those Reporting NCII

In 2021, I was alerted to an alternative pornographic website, where someone had published a number of fully clothed images of me stating: “Fake my nasty student: my student XXXXX makes me so horny… never done this before, but would LOVE to see her faked… Happy to chat / show you more of her too… :D”. He also states: “who wants to trib / fake her next? So many more pics of her to share…” and “starting a kik group about her right now. If you want in my kik is [username redacted] - message me there…” Beneath these posts, I discovered images and videos featuring my face on someone else’s body. I was having sex in every one of them. Some featured my image in the classroom, wearing a schoolgirl outfit and being raped by a teacher, and others featured me fully “nude” being aggressively anally raped from behind, on the sofa, and on the floor. The utter shock and devastation of seeing these images still haunts me to this day. Knowing I would have to explain them to my partner, family, and friends; forced to have challenging conversations, promising it wasn’t really “me”.

He was also posting images of me asking for users to comment, referring to me as a “slut”, and sharing images of me with captions such as: “my student is begging to be cocked”. There were also group photos of me and my friends (fully clothed) asking things to other users such as: “facial or creampie?”, “foot, blow, hand?”, and “fuck, marry, kill?”. There were also images of his wider friendship group, with captions such as “Choose 2 of these sexy sluts I know for a blowjob, and I’ll show you more pics of your choices… Go!”

When I first reported the abuse and synthetic NCII to the City of London Police, I spent three hours detailing the horrific and humiliating abuse and identifying the person I believed was responsible. The officer I spoke to took no notes, and I was not asked to provide a formal statement. The next day, I received a call stating they did not believe a crime had been committed. Instead, I was advised to contact the pornographic website directly to request the images be removed. No psychological or practical support was offered.

Determined that a crime had been committed, I reported the abuse to the Metropolitan Police. This time, they recognised the criminal nature of the incident, took a formal statement, and initiated an investigation. However, their treatment of me and the 14 other women targeted was appalling. Despite the perpetrator knowing our names, addresses, workplaces, and posting identifying information about us - including our names and where we lived - on the pornographic website, none of us were assigned a liaison officer under the "threat, risk, and harm" guidelines. We were also denied Independent Sexual Violence Advisors (ISVAs) because the crime was not deemed "sexual in nature."

I repeatedly told officers that I felt overwhelmed, anxious, stressed, and suicidal. Despite this, the police offered no meaningful support. Instead, I had to work with the other victims to compile 60 pages of evidence. This process required us to sift through hundreds of explicit images, identifying faces we recognised; a deeply traumatising experience. For me, it also meant revisiting five years of previous online abuse to demonstrate the escalating severity and sinister nature of the perpetrator’s actions. The police did not assist in collecting this evidence; I had to deliver it on a USB stick to the station because the file size was too large to email.

After submitting this evidence, which contained manipulated images of me, I heard nothing for weeks at a time. When I followed up, communication from the police was vague, unsympathetic, and often retraumatising. One officer remarked, "this is not our only job," while another said, "he’s really remorseful; I know he’s really sorry for what he’s done."

I only learned my perpetrator had been charged after he admitted to the allegations, months after I first reported the crime. The notification came via a phone call at 10 p.m. on a Sunday, demonstrating a profound lack of sensitivity regarding the traumatic nature of this news, especially as it involved my “best friend”.

The PC also denied our request to read out victim impact statements in court, something that was our right as victims of a crime. Following conversations with the court and CPS, we were then allowed to read our statements, but were advised by the PC that we may not wish to attend as “his parents would be there” and “they might find it upsetting”.

The entire process left me feeling entirely unsupported and helpless. Following the sentencing, whereby we did attend and read our victim impact statements, no follow-up support was offered by the police or courts. I received no documentation outlining the offences he had been charged with or the details of his conviction. Months later, I received a £100 cheque in the post as compensation - a gesture that felt deeply insulting given the severity of the abuse and its lasting impact on my mental health.

The reluctance of the City of London and Metropolitan police to pursue the case was clear from the start, and I often felt like I had to convince them to take it seriously. I had to chase for updates repeatedly, and their communication was dismissive at best. After the trial, one officer even expressed satisfaction with their work, seemingly unaware of how deeply their mishandling of the case had impacted me and the other survivors. Their perception of “success” was completely disconnected from our lived experience, highlighting just how out of touch the system is with the needs of survivors.

The language used by the Metropolitan police throughout the investigation reflected a profound lack of understanding about abuse and trauma. They spoke to me and other survivors as if we were a burden, and their tone often suggested we should be grateful they were even considering the case. The dismissive and disrespectful language left me feeling dehumanised and underscored their ignorance about the severity of the abuse I endured.

The lack of resources, empathy, and training among police dealing with NCII cases underscores a system ill-equipped to address this form of abuse. Survivors like me are left to navigate the process alone, retraumatised by the very institutions that should protect us.

Legal Status of NCII in the Online Safety Act

While the Online Safety Act designates NCII as a “priority offence,” it inadequately addresses synthetic NCII (“deepfake” material). In my case, the perpetrator solicited deepfake images of me - an act not explicitly criminalised under current laws, leaving the most invasive aspects of his abuse outside the scope of his conviction.

Under the Online Safety Act, platforms are only required to act if they determine reasonable grounds to infer a criminal offence has been committed, and their obligations remain tied to each specific instance of content.

These gaps highlight the urgent need for reforms that explicitly address the creation, solicitation, and possession of NCII and synthetic NCII. Until such reforms are enacted, survivors will continue to face retraumatisation in systems that fail to address the unique and profound harm caused by synthetic NCII, while perpetrators exploit these loopholes to perpetuate their abuse without meaningful accountability, and platforms are able to continue to profit from abuse via website traffic.

Synthetic NCII Regulation

My case underscores the need for specific legislation addressing synthetic NCII. My perpetrator solicited deepfake sexually explicit images using my fully clothed images from my private social media account. Despite this, the law did not fully reflect the severity of these actions, and despite securing a conviction, these images were not part of the charging decision as there was no clear legislation pertaining to the offence.

The £100 compensation ordered by the magistrates’ court was entirely inadequate and failed to address the financial burden of therapy for the PTSD and depression I developed as a result of this abuse, which led to time off work and a reliance on antidepressants and prescription medications to sleep. By contrast, my abuser was ordered to complete 40 days of rehabilitation activities and 40 sessions of a court-accredited sexual offending programme, highlighting the disparity in the support provided to him versus the lack of meaningful support offered to me and the other victims.

The financial and emotional burden of recovery has fallen entirely on me. I’ve had to fund therapy to heal from the PTSD and trauma caused by the abuse, while my abuser received court-mandated support at no personal cost. He can move forward with his life, supported by the system, while I’m left to carry the weight of the aftermath alone. This imbalance underscores how the system fails to prioritise the needs and recovery of survivors.

I am asking for:

1.           Clear laws criminalising creation and solicitation of synthetic NCII; these laws should be survivor-centred and comprehensive, to include provisions relating to “semen shots” for example, and to take into consideration potential loop holes around covering nipples.

2.           Additional civil laws to allow survivors justice and compensation outside of the criminal justice system.

3.           Accountability mechanisms for tech platforms, for example implementing an independent AI / online safety regulator, that host this content to not only be forced to remove it, but to also block material and users who are perpetrating offences.

4.           Survivor-focused tools for rapid content removal and legal redress.

5.           Prevent image-based abuse through comprehensive relationships, sex and health education.

6.           Fund specialist services that provide support to victims and survivors of image-based abuse and other forms of male violence against women and girls.

Without these critical reforms, survivors will continue to face retraumatisation by systems that fail to address the specific harms caused by synthetic NCII. Furthermore, perpetrators will be enabled to escalate their abuse against women and girls, perpetuating cycles of harm with impunity.

Additional legal considerations

Despite the conviction secured in my case, the perpetrator faced remarkably few consequences for his actions. He wasn’t convicted of an online sexual offence, which meant he escaped critical safeguards. For example, he was and still is allowed access to dating apps, raising serious concerns about the imbalance in how the system protects victims versus offenders. He is also not on the sex offenders register, which means his devices were not routinely checked for re-offending during his suspended sentence. This lack of accountability and oversight is a glaring failure in ensuring public safety and justice.

Potential Civil Law Regime for NCII

The current system provides no meaningful support for recovery when considering synthetic NCII.

A civil law regime could:

•               Provide survivors with a clear pathway to secure removal of harmful content.

•               Ensure adequate compensation for therapy, legal fees, and lost income.

•               Hold platforms accountable for hosting abusive content.

Without these measures, survivors like me are left navigating recovery without the financial or emotional resources we desperately need.

Criminal Injuries Compensation Authority Scheme (CICA)  – Ineligibility of synthetic and non-synthetic NCII

Despite opinions to the contrary, the Criminal Injuries Compensation Scheme (CICA) excludes NCII survivors from eligibility, perpetuating the misconception that online harms are less severe than physical ones.

The assertion that victims of intimate image abuse can access compensation through the CICA scheme is misleading and untrue. Survivors of NCII are routinely told they are ineligible for compensation under the current framework. Survivors of synthetic NCII are also not eligible for compensation through CICA.

This highlights an urgent need to reform the CICA guidelines to include all forms of intimate image abuse. Survivors face significant financial burdens, often paying for their own therapy and other support services to effectively heal from their trauma. This lack of financial relief compounds the trauma and reflects a failure to adequately support victims.

The psychological impact of synthetic NCII is profound. In my case, it exacerbated pre-existing PTSD and required intensive therapy, which I had to fund privately. The £100 compensation awarded by the criminal court was grossly insufficient to cover the cost of the therapy I needed, which included 12 months of weekly sessions with a private therapist, due to severe delays in the NHS system. While I was fortunate to have access to private medical insurance to cover these costs, this is not the reality for most survivors. Many are left without the resources necessary to access any form of support. Survivors of NCII must be made eligible for the CICA to ensure they have access to the financial assistance required to recover and rebuild their lives.

December 2024