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IET's response to the call for evidence for the statutory report on content harmful to children

The Institution of Engineering and Technology (IET) welcomes the opportunity to respond to this call for evidence to support the first statutory report on content harmful to children and commends the progress made already by Ofcom whilst implementing the OSA. 

Technology moves at a fast pace, affecting every aspect of life, largely for the better, and therefore managing the subsequent harms to children and other vulnerable people requires agility and constant review. We should look at safety through the lens of the technology itself instead of seeking to overly limit or restrict it. Drawing on the expertise of our members, we outline the challenges of age verification, the prevalence of unsupervised minors in virtual reality (VR) spaces, and the embodied nature of harm in these environments.

The IET recommends:

  • Wide-reaching definitions for technology: There needs to be an inclusion of a wide-reaching definition of “user”, “content” and “agency” when talking about technology. 
  • VPNs: There should be caution over general bans on VPNs when putting into effect the age limitation legislation. VPNs are an important tool for businesses to ensure cybersecurity safety; a general ban has the potential to have a knock-on effect of cyber resilience in the economy.
  • Digital Skills: Children must be protected but still develop digital skills. Policies in this area should be forward thinking, not responsive to incidents on a case-by-case basis.
  • Legislation: The UK’s OSA was a vital first step to help the UK manage technologies in a safe and regulated way. However, despite assurances that the OSA regulates to cover the metaverse, persistently, language around online safety is still too focussed on 2D interaction and not immersive behaviour. It is pivotal that further research is undertaken into immersive environments and the impact that this has for regulation. A review should be undertaken into the impact of the OSA on regulating immersive reality. (IET, 2024, Protecting children from harms online). 
  • Institutions: Professional bodies should support Ofcom in ensuring compliance of metaverse providers. Providing a safe process for whistle blowers and responding meaningfully to user complaints (IET, 2022, Safeguarding the metaverse). 
  • Choice and support: Clear and accessible information, with an easy-to-use reporting and complaints processes, is essential to the success of protecting children from online harms (IET, 2024, Protecting children from harms online, 2024).  
  • Parental controls: There should be greater support to parents to understand how to limit and control access to certain content on their devices within the home and school environment.
  • Data: There should be the ability to expunge your data from social media, for example on behalf of a child, or once the child reaches 18.