UK Government Online Harms White Paper - Initial thoughts from SWGfL

UK Government Online Harms White Paper - Initial thoughts from SWGfL

The Government wants the UK to be the safest place in the world to be online; no mean aspiration given the long,and often tortuous, history of what we now regard as our “online lives”.

For the last 20 years, we at SWGfL have been at the heart of shaping strategies that have had significant impact on the online landscape, particularly for schools, children, young people and families. So we welcome the publication of the DCMS Online Harms White Paper  today that attempts to globally address a comprehensive spectrum of online harms in a radical way.

Whilst many of us will be aware of the current work to manage illegal online content by organisations such as the IWF and CTIRU, this paper seeks to establish mechanisms to limit the impact of additional online harmful content eg abuse; bullying; propaganda; misinformation and addictive behaviours.

Its proposals cover:

  • Regulation of industry service providers

  • Clear and accessible “Terms & Conditions”

  • Effective reporting and complaints processes

  • Transparency

  • Safer mechanisms to protect users

  • Media Literacy strategy for all

It will be interesting to monitor how these plans fall out into practice over the coming months, not least being industry’s response to the proposals. We thought we would familiarise you with the main proposals and share some initial thoughts. More detail will emerge in coming weeks.

Regulation of Industry Service Providers

Much of the excellent, progressive work done so far by organisations working in this space has been through close co-operation and dialogue with industry itself. SWGfL has built successful support services (Professionals Online Safety Helpline and Reporting Harmful Content Online platform) on exactly these relationships and they have proved their value. But the Government wants more speed and consistency in approach. The Online Harms White Paper outlines the intention to formalise its engagement with industry through a more rigorous framework of legislation.

This includes:

  • A new regulatory framework to set clear safety standards addressing harmful content

  • Legislation outlining “statutory duty of care” for services, compliance for which will be overseen by an Independent Regulator

  • Codes of Practice to ensure industry providers meet their duty of care

  • Direct regulation for illegal serious harms eg incitement to violence; illegal sales of goods; terrorism; child sexual exploitation

As yet it is unsure who this regulator might be; whether it is an existing body or an office that will need to be created.

Terms and Conditions

We welcome this aspect. The majority of provider’s T&C’s are unfathomable for most users; They are lengthy (often tens of pages) and use complex vocabulary and phrasing (typical T&C’s require a graduate reading age). The recent work by the Children’s Commissioner in the report “Growing Up Digital” gave social media provider’s T&C’s to the law firm Schillings to interpret for children. When children read the simplified language, they were angry at what they were required to allow.

SWGfL has long campaigned for alternatives to T&C’s that are more easily understood…something along the lines of nutritional food labelling and are implementing this concept as part of our work for the UK Safer Internet Centre.

Effective reporting routes and complaints procedures

If you have ever had to report an issue to your social media provider, it can be a complex and time-consuming process that is further complicated by each service provider’s community guidelines. SWGfL’s helpline services and Reporting Harmful Content platform have helped expedite that process, but it is still not a route many see as a resolution for issues they face.

These must :

  • be within an appropriate time-frame

  • be easy to access

  • ensure fair treatment

  • have opportunities for independent review for disputes

  • be overseen by the regulator

  • be resolved with regards to the regulatory framework requirements


Developing a culture of transparency trust and accountability will be a critical component of the new regulatory framework. This follows in the wake of this year’s parliamentary review on the impact of social media on UK democratic processes and the polarisation of political opinions e.g. “filter bubbles”.

This will include:

  • Annual transparency reports published online

  • Information on the impact of social media algorithms in selecting content

  • Allowing independent researchers access to data to ensure they are compliant

Media Literacy Education

The government will develop a new online media literacy strategy. This will be developed in broad consultation with stakeholders, including major digital, broadcast and news media organisations, the education sector, researchers and civil society. This strategy will ensure a coordinated and strategic approach to online media literacy education and awareness for children, young people and adults.

Building resilience, knowledge and skills in users to ensure they flourish with online technology has been at the heart of SWGfL’s mission since our inception so we welcome a consistent approach to this aspect of education for everyone.

A huge amount of work has been done in this area already, culminating in the publication in February 2018 of the UKCIS framework “Education for a Connected World”. SWGfL was a key partner in the framework’s production and it now forms the basis of the new Media Literacy EVOLVE platform we are creating for all adults working with children and young people to use for free, We intend to build momentum with these national resources and offer our strategy to inform Government planning.

Over the coming weeks we will look in more detail at these proposals to build a useful commentary for professionals as to how they might impact on their engagement with children and young people.

It’s a bold plan from the Government. We have yet to see Industry’s response.

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