07 October 2021


Written evidence submitted by 5Rights Foundation (OSB0205)



David Slater, Commons Clerk

Joint Committee on the Draft Online Safety Bill

FAO Damian Collins MP

House of Commons

London, SW1A 0AA



Dear Committee Chair Damian Collins MP and Committee members,             

I would like to thank you again for inviting me to give evidence to the committee on behalf of the 5Rights Foundation, and to take this opportunity to summarise three key points I raised in relation to the Bill.


  1. The definition of “regulated services” must bring into scope all services that create risks for children.


Children have a right to protection wherever they are online. All services, whatever their size, business model or nature, including services that may not fall under the definition of a user-to-user or search service, that are “likely to be accessed” by children, must be in scope of this Bill. This can be achieved by adding “services likely to be accessed by children” to clause 3 paragraph 2 under the meaning of regulated services. It would provide regulatory harmony with the Age Appropriate Design Code, which, as acknowledged by both the ICO and Ofcom, is imperative to aid compliance and enforcement.


  1. Minimum standards for services likely to be accessed by children must be mandatory and set out in a statutory code of practice to meet the safety objectives and policy intent of the Bill.


Services likely to be accessed by children must be required to meet minimum standards of safety by design, published terms, age assurance, moderation, reporting and redress (and others as the regulator sees fit), to be set out in a single statutory code of practice for child online safety prepared by Ofcom. As our Pathways research and the recent leaks of Facebook’s internal research show, it is not sufficient to leave tech companies to create their own rules of the road.


  1. The Bill must address all types of harm in relation to its safety objectives, not only harmful user-generated content.


The language of ‘content and activity’ should be reinstated whenever the Bill refers to content, and the definition of harmful content should be amended to simply a definition of “harm”.



I also raised the issue of transparency and oversight of algorithms and automated decision-making systems, in response to which Lord Black of Brentwood asked if I would submit proposals for a comprehensive AI oversight regime. Please find 5Rightsproposal for such a regime in the accompanying paper, with corresponding amendments for the Bill.


I have looked at the Bill in great detail with my colleagues here at 5Rights, and draw the committee’s attention to our fourteen key issues and related amendments. Each of these would provide a level of protection for children that has been promised by the government and I hope the committee will take the opportunity to ensure that the Online Safety Bill will live up to those promises. I would be happy to answer any further questions at your convenience.


Yours Sincerely,

Izzy Wick             
Director of UK Policy, 5Rights Foundation


8 October 2021








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