Good to know my blogs can prompt responses. I have a few suggested additions to my list of unanswered questions or topics that need further examination or thought.
- This is tied up with aspects of eCommerce and payments systems. We know a little about what is happening with grown ups. We know that many kids are hoodwinked into buying things they didn’t really want or into buying things they did want but on terms they did not properly understand. But what about straightforward cases of defrauding a child of their hard earned pocket money or savings?
Trafficking and travelling sex offenders
- Particularly as the internet starts to take off in the developing world there is a growing concern about the role it might already be playing or that it will play in the growth of trafficking children or in helping travelling sex offenders to find new victims.
- It is notoriously difficult to obtain evidence in this area, which is precisely why more effort is needed to map out the current state of play. Necessarily this will involve close co-operation with the police in general and Interpol in particular.
Peer to peer networks and file sharing sites
- Again this issue has specific relevance to the growth of the internet in the developing world but what is happening in the UK and Europe to combat the growth of peer to peer networks and file sharing sites as a means of distributing child abuse material?
Speed and change 1
- There is no doubt that as technological innovations occur business models can change. But are there not a set of unchanging values which ought to underpin any and every offering on the internet? Those companies that adhere to them we can call “good” and those that do not we can call “bad”. Won’t those values look pretty much the same as the ones we treasure in the real world?
- For example, are there now or will there ever be any circumstances where it is OK for a company to pick up and use an individual’s personally identifiable data without having first obtained their informed consent? And what extra steps should companies take to ensure they are collecting and handling children’s data in an appropriate way?
- Even if a company is 100% and genuinely certain it is in that adult’s best interests for them to have their personal information, isn’t there still a duty on the company not to take liberties but to go through the painstaking business of actually getting the person so see things the same way and give consent? Where the subject is a child the need for proper processes and engagement by the parents becomes of paramount importance.
- One of the arguments that emerged in the debate around COPPA which many found to be both circular and curious went something like this
If you introduce rules which, admittedly, would be likely to have a positive impact on the child safety side of the equation, but nonetheless were more onerous for companies, this would likely lead to fewer resources being created for young people, and this would be undesirable.
Another way of putting that would be
You need to cut companies some slack. If they can’t make a buck they won’t generate new stuff for kids. And they won’t be able to make a buck if they have to go through all these extra safety oriented steps which ‘interrupt the user experience’ and thus cause a higher drop out rate or which are costly but produce little by way of a financial return.
- The idea of an “interruption to the user experience” is a relative term. If such things were accepted as the norm by everyone who mattered there wouldn’t be an alternative easy option to which people could point.
- Diving down to the lowest common denominator or refusing to interrupt the user experience is not what this area of policy should be about. When it comes to children, compromising on safety in return for higher revenues or membership levels should not be acceptable. There have to be other and better ways of producing sites and services that youngsters will want.
- Remember the saying “If you’re not paying for it, you are the product”. Should that really be the governing idea in the children’s space? Funding innovation or further technical development through lower standards of care does not sound like an instantly appealing or attractive option to me.
Speed and change 2
- For all that it is true companies can bring out new products and services at an astonishing rate, getting them to change anything about those same products can take forever. This is when they start to speak about the importance of evidence, of broader industry engagement and that kind of thing.
- If a company spots a chance to make money they charge ahead and do it. That gets a round of applause for being enterprising and courageous. We raise actual or potential issues and we are branded as whining worriers who just want to spoil the party.
- Why should we always have to catch up after the event to prove that harm is happening? Why shouldn’t companies have a positive duty to show they have considered the child safety implications of all of their products in advance of bringing them out? Should companies be expected to complete a “child safety audit” which they could either publish at launch or be able to produce for inspection later if called upon?
- Despite the claims made for it, does self-regulation in fact produce any noticeable advantages over the more traditional means of public policy-making? Is there any evidence that self-regulation is any more effective? From where I’m sitting it certainly does not seem to be any quicker.
Speed and change 3
- When people express worries about the “chilling effect on innovation” of this or that potential or actual decision aren’t they really saying something like this
We do not want to be constrained by this potential or actual decision of a court, regulatory code or legislature because it might stop us doing things that we may want to do in the future. We’re not sure what those things are yet and even if we were we probably couldn’t say because that would alert our competitors so, please, just trust us. We know what we’re doing.