Written evidence submitted by the Internet Association (MISS0048)

1. Introduction

Internet Association (“IA”) welcomes the opportunity to provide written evidence to the Women and Equalities Committee’s Inquiry into body image.

IA represents over 40 of the world’s leading internet companies[1] and is the only trade association that exclusively represents leading global internet companies on matters of public policy. IA’s mission is to foster innovation, promote economic growth, and empower people through the free and open internet. In 2018, IA established a London office to constructively engage in the internet public policy debate in the UK.

We are firm believers in the benefits that technology brings to everyday life and the economy, and for the potential that internet innovation has to transform society for the better. IA economic analysis shows that the internet sector contributes £45 billion to the UK economy each year, and is responsible for nearly 80,000 businesses and around 400,000 jobs.[2] IA polling found that 82 percent of British people believe that the internet had “made their lives easier and more enjoyable.”[3]

IA believes that the internet sector needs a balanced policy and regulatory environment to continue, and grow, its contribution to the UK economy, consumers, and society in the future. The internet will drive 21st century prosperity, and we believe that policymakers should focus on enabling the internet sector to: 1) drive UK economic growth; 2) provide services that people value highly; and 3) make a positive contribution to society.

IA notes the Committee’s focus on “what causes poor body image and how people’s body image is impacted by companies, adverts, social media and Government policy” and in this evidence IA offers some perspectives from the internet industry, in particular from social media companies, as well as views on government policy and regulation.

2. Internet Association Written Evidence

2.1 Body Image Is A Complex Issue, Requiring An Holistic Response

Body image is a complex, multifaceted issue, affecting many different sections of society and influenced by a wide range of different factors. A 2015 report from the Government Equalities Office on its Body Confidence Campaign summed up the challenge this presents for all stakeholders, stating that “the causes of body image are complex and multi-factorial; there is no simple answer, no quick cure”.

Indeed, the Committee’s Terms of Reference note that while negative body image is widely perceived as solely a young women’s problem, more recent studies have shown this to be a wider issue, affecting for example young men, LGBT+ adults and disabled people.

It is also important to note that a diverse range of media and content have an impact on perceptions of body image. For example, this includes advertising – in a number of forms, such as television, radio, outdoor, print, online – through to editorial content – again in a number of forms, including newspapers, magazines, websites, television – as well as user-generated content on social media.

Given this complexity, IA believes that any further action to address negative body image needs an holistic response rather than a focus on one section of society or one form of media or content. On IA’s reading, the Terms of Reference for this Inquiry suggest that the Committee is focusing on two particular areas – advertising and social media content – and IA encourages both the Committee and the government to pursue a wider policy response, rather than overly-focusing on one or two areas.

Within this holistic response, it will also be important to recognise that the internet sector is not a homogenous entity, so tailoring approaches to specific types of service and/or specific types of problem is key to an effective response. It will be important to be specific, evidence-based and targeted in considering the role of a small number of key image-based platforms in this particular debate, versus the broader responsibility of the technology and social media sector.

IA of course recognises that there is an online element to these issues, and internet companies therefore take a number of actions on body image, as set out below. As a result of the differences across the sector, the industry takes a diversity of approaches to this issue.

2.2 Internet Companies Take Steps To Prevent Encouragement Of Negative Body Image And Promote Positive Body Image

Internet companies, and social media companies in particular, take their responsibilities seriously and are taking action to both promote positive body image and prevent the encouragement of negative body image.

2.2.1 Internet Companies Maintain And Enforce Strong Rules To Prevent Harm On Their Services

Internet companies have clear rules and expectations for online behaviour (see, for example, Twitter’s Rules and Policies, Facebook’s Community Standards, Instagram’s Community Guidelines or YouTube’s Harmful or Dangerous Content Policy). Many companies include specific rules intended to combat content that may lead to harm in relation to body image, for example in areas such as suicide and self-harm content or eating disorders.  And more broadly, companies maintain and enforce rules to prevent online abuse.

These rules and guidelines are often developed in partnership with external charities, safety organisations and experts (for example, Twitter's Trust and Safety Council or Facebook and Instagram’s Suicide and Self Injury Advisory Board). Internet companies in the UK have worked with organisations such as the Samaritans, Beat, and Papyrus on issues relating to body image. This process helps companies in their efforts to strike the delicate balance of removing content that may be harmful, and allowing people to share their experience, express themselves and seek support from other people. It’s important that solutions don't inadvertently suppress helpful content from medical sources and other relevant sites that promote safe habits. Often, these sites will contain many of the same keywords as sites that might promote unsafe behavior.

Internet companies take action to remove content that violates their rules. This includes investing in human content moderation teams, responding to reports of potentially harmful content, and using artificial intelligence technology to proactively enforce these rules at scale. On Twitter, for example, 1 in 2 of abusive Tweets removed have been identified proactively by their own technology. On Facebook, in relation to suicide and self-harm content, over 97% of content removed between July 2019 and March 2020 was found and flagged before users reported it.

2.2.2 Internet Companies Provide A Space For People Affected By Negative Body Image To Have A Voice, And Enable Body Positive Voices And Organisations To Campaign

The internet provides people who have suffered or are suffering from issues related to negative body image with a forum to share their experiences, express themselves and seek support from others in their community.

Social media companies also provide a platform for charities and non-governmental organisations to campaign on issues related to body image. For example:

       The charity Changing Faces has used Twitter to drive positive and accurate representation of people with a visible difference (such as a mark, scar or condition that affects their appearance). In 2019, their #PledgeToBeSeen campaign called on companies and brands to represent more people with a visible difference, reaching 2 billion people through social media.

       Instagram has partnered with body positivity creator Chessie King on the Create Don't Hate campaign and the Cybersmile Banter Or Bullying campaign during Anti-Bullying Week in 2019, and has featured voices such as Nikki Lilly and Megan Crabbe to support body positive conversations.

       On YouTube, Cardiff teen Lara Rebecca uses the platform to break the stigma around eating disorders, and is reaching millions with her message.

More broadly, social media enables people who have historically lacked public platforms to have a voice. This Guardian article and this University of Salford research paper provide further insight and findings on the interaction between social media and improving public representation of marginalised voices, compared with traditional and established forms of media.

2.2.3 Internet Companies Signpost People To Helpful And Authoritative Information

Internet companies also direct people to helpful information and organisations if they search for terms that may indicate an issue relating to negative body image (for example, eating disorders or self-harm). For example, for queries that pertain to topics like health information that are particularly sensitive, Google has systems in place to prioritise results from authoritative sources. In 2020, Google launched health knowledge panels in the UK in partnership with the National Health Service, including panels on anorexia and bulimia. This feature surfaces authoritative information on related eating disorder queries, including on symptoms and treatments.

2.3 Media Literacy Has A Key Role To Play In Increasing Awareness And Resilience

IA believes that media literacy has a key role to play in increasing awareness of, and resilience to, issues relating to negative body image. A wide range of stakeholders provide resources to increase people’s media literacy, both in general and specifically in relation to body image.

IA is a strong supporter of media literacy, and IA member companies provide a number of digital literacy resources and initiatives, including Google’s Be Internet Legends programme, Facebook’s Digital Literacy Library, and Twitter’s partnership with UNESCO on media and information literacy.

Ofcom, for example, has a statutory duty to promote media literacy under Section 11 of the Communications Act 2003 and undertakes a significant amount of useful work on media literacy, through its Making Sense Of Media programme.

Specifically on body image, in 2019 Internet Matters published Tips To Promote Positive Body Image, and the Dove Self-Esteem Project in partnership with Parent Zone provides free PSHE Association-approved resources to help boost young people’s self-esteem and body confidence. In relation to advertising, Media Smart provides a number of resources to help people’s understanding of topics including social media, body image and influencer marketing.

The government has proposed a new online media literacy strategy under its Online Harms White Paper proposals, and IA welcomes this initiative. IA agrees that all parties should focus on improving media literacy, and believes that these efforts should receive similar levels of attention that issues around, for example, social media content and advertising currently receive. However, given the complexities discussed in Section 2.1 above, media literacy efforts should not just focus on the online element of negative body image, but also seek to educate people about a wider range of media content.

2.4 The ASA’s Regulatory Framework For Non-Broadcasting Ads Is Effective

The regulation of non-broadcast advertising (which includes online advertising) is overseen by the Advertising Standards Authority (ASA), which enforces the UK Code of Non-broadcast Advertising and Direct & Promotional Marketing (the “CAP Code”).

Rule 1.3 of the CAP Code specifies that “Marketing communications must be prepared with a sense of responsibility to consumers and to society”. The ASA therefore plays an important role in ensuring compliance with this social responsibility duty, and it has a strong track record of taking action against ads that may have a negative impact on body image (e.g. Prettylittlething.com, BoomBod Ltd, Omega Pharma Ltd).

In 2019, the ASA introduced new rules and guidance on gender stereotyping in ads, following an extensive review. The new Rule 4.9 of the CAP Code provides that ads “must not include gender stereotypes that are likely to cause harm, or serious or widespread offence”.  The ASA also published additional guidance on potentially harmful gender stereotypes, stating that “advertisers should ensure that they don’t portray particular body types in an irresponsible manner, imply people can only be happy if they look a certain way, or present an unhealthy body image as aspirational”.

In IA’s view, the evidence of ASA enforcement action against irresponsible ads, as well as the introduction of new rules addressing gender stereotyping, demonstrates that the ASA is playing an effective role in this area.

2.5 Further Policy Should Be Developed Through Joined Up Cross-Government Work, Rather Than Through Future Online Harms Legislation

The Inquiry’s Terms of Reference ask: “Would proposals in the Online Harms White Paper protect people from potential harm caused by social media content in regard to body image?”.

As set out in Section 2.2 above, internet companies, and social media companies in particular, take their responsibilities seriously and are taking action to both promote positive body image and prevent the encouragement of negative body image.

The internet industry has also engaged constructively with the government’s Online Harms White Paper, which proposes a duty of care on companies that provide services or use functionality on their websites which facilitate the sharing of user generated content or user interactions, for example through comments, forums or video sharing.

Internet companies are committed to working with government to achieve our shared goals of keeping people safe online and ensuring that the internet continues to deliver benefits to the economy and society. IA continues to have concerns about a number of the proposals, in particular the scope of regulation and the treatment of legal but potentially harmful content. While content relating to “body image” is not explicitly listed in the Online Harms White Paper, user-generated content relating to appearance could fall potentially in the unclear area of legal but potentially harmful content, which is the subject of ongoing policy and regulatory discussion.

However, as discussed in Section 2.1 above, body image is a complex and multifaceted issue, covering a wide range of people, media, civil society organisations and the government. IA therefore believes that further policy relating to body image should be developed through joined up cross-government work which takes into account this complexity, rather than by focusing on one element of the issue (i.e. online harms). Previous UK governments have had success in this area with cross-cutting strategies, for example the Body Confidence Campaign in the early 2010s, and IA encourages both the Committee and the government to also pursue an holistic policy response, rather than overly-focusing on the online part of the issue.

3. Conclusion

IA welcomes the opportunity to provide written evidence to the Women and Equalities Committee’s inquiry into body image.

In this evidence, IA has outlined the action the internet industry takes to prevent the encouragement of negative body image and promote positive body image. IA also believes that media literacy has a key role to play in increasing awareness of, and resilience to, issues relating to negative body image. These are complex issues, and we encourage future policy on body image to be developed through an holistic response, rather than by overly-focusing on one section of society or one form of media or content.

In relation to regulation, IA believes that the ASA’s regulatory framework for non-broadcasting ads is operating effectively, and we caution against the idea of attempting to specifically tie solutions to address concerns about negative body image into the scope of future Online Harms legislation, instead advocating a joined up cross-government approach to the issue.

IA hopes that this evidence is useful to the Committee as it undertakes its inquiry.

July 2020




[1] IA Member Company List: https://uk.internetassociation.org/our-members/

[2] https://uk.internetassociation.org/publications/measuring-the-uk-internet-sector/

[3] https://uk.internetassociation.org/internet-association-launches-uk-presence-with-poll-showing-overwhelming-public-backing/