Eurochild contributes to Ireland’s first binding online safety code
In early September, Eurochild provided input to the Coimisiún na Meán, the Ireland’s Regulator for Broadcasting, On-demand and Online Safety, on the country’s first binding Online Safety Code for Video-Sharing Platform Services (VSPS)
The Code would cover online services where users can share videos and engage with a wide range of content and social features, excluding private messaging. The Code would contribute to the transposition of the revised Audiovisual Media Services Directive (AVMSD) to Ireland’s regulatory framework, especially Article 28b. The Irish regulator opened a consultation with civil society to give input on the scope of the Code and the different elements to include.
The drafting of this Code is a key opportunity to crucially foster online child safety given the high amount of platforms established in Ireland. Therefore, this Code must go beyond harmful and illegal content and pay close attention to harmful contact, where there is less established tools and good practice among VSPS. This is especially important since recent data released by the National Center for Missing & Exploited Children (NCMEC) shows that reports of online grooming increased by 82 % in 2022.
The Code should encourage mechanisms such as recommender systems, terms & conditions, reporting and flagging tools, to be child friendly and respect the full spectrum of children rights, including both their right to protection and privacy. Child Right Impact Assessments (CRIAs) should be central to any reporting obligations and due diligence requirements included in such a code.
Overall, Eurochild encourages the Coimisiún na Meán to incentivise provisions that empower children as digital citizens. It is key that the Code focuses on expanding ‘safety-by-design’ features that prevent harm. Companies must design digital services that cater for vulnerabilities, needs, and rights of children by default.