This submission focuses on the need for revision to the Online Safety Bill to specifically include mandatory, robust Age Verification on all pornography platforms, regardless of their functionality. This is prioritised given the strong reasons to believe it is absolutely crucial and urgent to curtail the completely unacceptable, massive costs to young people’s safety, relationships and wellbeing that free online pornography is currently causing.
This submission has been kept concise (approximately 3,700 words, excluding references). I would welcome the opportunity to give further evidence in an oral evidence session to the Committee on this issue, and other issues relevant to the Bill. Related foci of mine include online corporate surveillance (and in particular its threat to people’s, especially children’s, autonomy and ability to live in line with prosocial values), and the proliferation of child sexual abuse material online. Beyond Age Verification, other measures that there are strong grounds for inserting into the Bill include:
This submission briefly sets out the following:
Sexual harassment spotlight: We as a society are finally facing the scale of sexual harassment and abuse between young people – joining the dots between this, the prevalence of young people viewing pornography, and the longitudinal studies showing pornography’s contribution to sexual harassment (as well as the nature of online pornography and the way it operates), it is absolutely clear that their exposure must be curtailed in order to prevent this life-limiting, traumatising, and rights-violating pattern of behaviour.
I am a Clinical Psychologist and researcher with a focus on preventing and tackling abuse, and, more widely, supporting children’s and young people’s wellbeing and growth. My work has included a focus on online safety and harm since 2007, including a specific focus on the online pornography industry and its impact on young people since 2011. I was a member of the DCMS advisory group on Age Verification of online pornography, when this measure was being developed. Examples of my research and writing on these issues can be found here .
Another major focus of my attention is sexual harassment and abuse in schools. I work with schools and others in this space providing training, consultancy and research, helping them to tackle this endemic issue.
With the advance of online technology, and the libertarian approach that has largely been taken towards it, we have gone from a situation in which children were robustly protected from all sexually explicit content to one in which they are bombarded with its most ‘hardcore’ forms. I use ‘hardcore’ as a shorthand here for sex involving dominance, violence, bigotry, or transgression of ethical boundaries (that are usually upheld in other areas of social life).
As evidence of this, I share just a few salient facts and findings here. For much more evidence on what children are being exposed to and why, see:
- My report ‘Pornography and human futures’ for Fully Human, a new initiative of the PSHE Association, which maps out the business model and practices of the online porn industry and considers how it affects core parts of what it is to be human
- Large, playing video adverts including close-up footage of a girl’s anus being penetrated by a man’s penis whilst she bends over on a car, and a middle-aged man coming up behind a girl opening a fridge in her underwear (seemingly looking for food) and then without warning immediately penetrating her from behind, her expression is one of shock
- Numerous thumbnail images of films available to view upon clicking, below which are their keyworded titles such as [Titles redacted from published evidence – these refer to the ethnicity of people in the videos; a girl having sex in exchange for a phone; an ‘amateur’ girl being tested for anal sex ability; and those involving a daughter and stepdad (accompanied by picture of a girl in pigtails) and a mother]. Of the eleven first listed films, three involved ‘step sisters’. The viewer is overwhelmed with close-up footage of female sexual body parts.
- The menu bar at the top of the page lists options such as ‘fuck now’, ‘live sex’ and ‘categories’ (those listed on the page the latter leads to include ‘teen’, ‘gangbangs’ and ‘bdsm’)
See here for a full account of how this business model works.
A wealth of research comes together to reveal the significant harms that online pornography is causing to children and young people, as well as to adults. Please see my concise (3½ page) summary of this research, published last summer by the PSHE Association, and much more on its impact is contained within my Pornography & human futures report referenced above.
A few particularly salient findings are highlighted here:
Young people themselves frequently make this link – for example see Coy et al. (2013), and in the BBFC (2020) survey cited, 41% of children surveyed who were aware of pornography agreed that ‘watching porn makes people less respectful of the opposite sex’.
A large part of my work is supporting schools in tackling sexual harassment, and developing effective educational resources to support young people in developing healthy relationships. Despite this being a passion of mine, I am acutely aware of its limitations. In the face of online porn powerfully promoting abusive attitudes and behaviour, what we can offer young people honestly feels like a drop in the ocean. The lion’s share of responsibility for tackling the problem seems to be placed on schools’ shoulders (and on other things like intervention programmes for young people with harmful sexual behaviour), without due attention to its powerful, upstream causes. The old adage that an ounce of prevention is worth a pound of cure is highly relevant here.
Some argue that clauses within the current draft of the Online Safety Bill will necessarily lead to pornography platforms bringing in Age Verification. However there are reasons to fear that this will not be the case across all or even the majority of pornography platforms, and, given the scale of harms to the most vulnerable in society, any risk that wholescale implementation of Age Verification will not take place is wholly unacceptable. It is already a tragedy that a whole generation of children have had their right to develop a sexuality rooted in intimacy, respect and connection violated (alongside all the associated harms), and there can be no risk of anything but robust protection of those growing up behind them. There can be no risk that we again fail to protect our children, and no margin of error or doubt which online pornography companies seek to leverage and manoeuvre within.
The current draft of the Online Safety Bill is inadequate in:
How we raise children in our society is meant to be governed by the principle of their best interests. The way in which we have left the online porn industry to run rampant in their lives is a complete dereliction of duty. We have a fantastic opportunity with the Online Safety Bill to right this wrong, putting the interests of children before those of the porn industry. There must be no risk that this opportunity is missed; there must be no wriggle room for the industry.
Some argue that Age Verification is a blunt tool and will be ineffective, for example by pushing adolescents to seek pornography on the dark web. These arguments were aired when Age Verification was first debated and the conclusion of the UK government then (as it should be now) was that on balance, it would be protective. The decision at a later point to delay or stop Age Verification (it was unclear which) was without good rationale and does not appear to have been because evidence of its likely ineffectiveness came to light.
There is widespread concern that instead this decision was due to certain voices being louder than children’s, and certain interests being pursued above theirs. I would welcome the opportunity to speak on the potential impacts of Age Verification at an oral evidence session. In short, a wealth of research, in particular in the field of public health, evidences the intuitive fact that when you make something harder for people to do, fewer people do it. Age Verification provides a vital, necessary ‘bump in the road’, and in doing so also communicates to children and young people that we as a society do not accept pornography as normative, safe or ‘neutral’ for them to view. Children and young people, consciously and unconsciously, constantly look to adults for guidance around where the lines between safety and risk lie.
On a personal note, I first started researching the impact of pornography in 2011 (this was within a role I held at CEOP, the child exploitation and online protection centre, now part of the National Crime Agency). At this point my eldest child, my son, was one years old. As I became increasingly concerned by what I was reading, when it came to my own children I reassured myself that by the time they reached the tweens and teens, robust regulation would be in place – this being so clearly necessary and part of our duty of care. But now my son has just started secondary school and yet still no regulation is in place, so it is likely that soon he will be exposed to this toxic material despite my best efforts as a parent to protect him. Indeed I have had parents of his friends start to disclose to me (as their children hit the age at which first exposure tends to occur) the distress, trauma and confusion experienced by their children unexpectedly coming across it. Every day and every week children are being inculcated into the dystopian world and values of online pornography, with insidious effects on their lives, now and into the future.
The UK Government’s statutory safeguarding guidance (Working Together, 2018) includes within its definition of child sexual abuse, ‘non-contact activities such as involving children looking at, or in the production of, sexual images’. And therefore, at present, children’s exposure to bombarding and extreme sexually explicit material without any attempts to protect them by government constitutes their abuse and neglect by us as a society.
3 November 2021
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 I use this term to mean measures that prove that a user is of over 18 years old to a high level of confidence (for example, involving identification documents or credit card checks) – not the lower level ‘age assurance’ measures.
 See for example, https://fullyhuman.org.uk/issues/pornography/autonomy-and-self-determination#porn-and-the-autonomy-of-women-and-girls ; I also speak on this issue in a BBC Scotland documentary on the corporate online surveillance of children due to be shown at 19.30 on 4th October. I am a member of the End Surveillance Advertising to Kids coalition and am a signatory on that evidence submission to yourselves.
 See for example, https://www.researchgate.net/publication/337114034_'Losing_track_of_morality'_Understanding_online_forces_and_dynamics_conducive_to_child_sexual_exploitation and
 In this submission I use the term ‘children’ to refer to all those under 18 years of age.
 PornHub accessed from the UK on 28th September 2020. Note that this content is viewed immediately, within seconds, without clicking on anything on the site.
 The term ‘girl’ here is used to describe a female who looks young, teens or early twenties, and is most probably placed in the site’s ‘teen’ category.
 BDSM (bondage, dominance and sadomasochism) pornography mostly comprises violent or dominating sex, with men usually in the dominant position. Themes of humiliation and degradation are common. Not readily visible within BDSM porn are the themes of consent, safety and trust that many who practice BDSM in real life would see as central.
 Brown & L’Engle, 2009; D’Abreu & Krahe, 2014; Dawson et al., 2019; Thompson & Morrison, 2013; Tomaszewska & Krahe, 2018; Ybarra et al., 2011; Ybarra & Thompson, 2018
 Peter & Valkenburg, 2009b; Peter & Valkenburg, 2014; Doornward et al., 2014
 See for example https://www.nytimes.com/2020/12/04/opinion/sunday/pornhub-rape-trafficking.html
 See for example https://www.theatlantic.com/business/archive/2016/04/pornography-industry-economics-tarrant/476580/