Safer Online Services and Media Platforms Consultation.

WHAT IS IT ABOUT?
”The aim of the review is to design and implement a new approach to content regulation that minimises the risk of harms caused by content to New Zealanders” (DIA). The changes would bring all platforms into one framework under an independent body.


Key elements to the proposal

  1. A regulatory model using ‘Codes of Practice’. “Codes of practice will set out more detailed minimum expectations for harm minimisation, user protection and transparency across services” (DIA)

  2. An independent regulator. The regulator continues amidst government changes.

  3. Removal and blocking of harmful pieces of content. The focus will be on large platforms and individual pieces of content can be reviewed, not entire categories of content.

  4. Investment in Education and Awareness

WHY IS IT IMPORTANT TO SUBMIT?
For too long parents and caregivers have assumed/hoped that the government and industry will prioritise children and protect them online. This is not the case, change is essential. This is a critical opportunity to make systemic change for future generations. Children and young people are being harmed by what they come across online, the current proposal will meet some of their needs - but not all.

Makes Sense is concerned that some illegal content will remain accessible, given the limitations of the regulator. There is scope for the industry codes to extend to some form of age verification of porn sites, however, this is not clearly stated in the proposal, and would require clear public pressure. In submitting you are helping to create that public pressure.

Five minutes of your time on this submission makes a significant impact, the DIA will be reading your submission. You can read more about the Safer Online Services and Media Platforms here.

WHAT SHOULD MY SUBMISSION INCLUDE?
Makes Sense has drafted a submission focusing on online child protection for you to copy and send.

Make a submission.

1. Email your submission to the Dept of Internal affairs, using our pre-written submission email.



OR
2. Copy and paste the below submission and email it to sosmp_consultation@dia.govt.nz

Feel free to edit it as you see fit.

Copy our
pre-written submission.

To the SOSMP Consultation team at the Department of Internal Affairs,

I am writing this submission to share my view on the Safer Online Services and Media Platforms proposed regulatory review currently being undertaken. I support this review and believe significant work needs to be done to manage the illegal content available online, to better protect children and young people. 

The easy access of child sex abuse material, bestiality and rape videos on the internet is alarming. It normalises sexual violence, illegal sexual behaviour, and is impacting the children and young people that stumble across it and those involved in the creation of it. It is imperative that New Zealand takes proactive measures to address this issue.

The following should be incorporated into online regulation:
1. Empower the regulatory body to mandate Internet Service Providers block objectionable content.
This should include, but is not limited to, mandating the Digital Child Exploitation Filter System (DCEFS), and additional filters that may be developed for objectionable content. This content is detailed under Section 3 of the Films, Videos, and Publications Classifications Act 1993.

2. Expand and improve the current DCEFS filter.
The existing filter blocks minimal Child Sex Abuse Material (527 CSAM URLs blocked, according to IRG Minutes, March 2023). The current process is dated, requires manual checking, and does not use advanced technology, such as hashing.

3. Develop a new filter or block list for rape and bestiality content.
This content is currently easily found, and it is unacceptable that our children can search for this content online and have immediate access.

4. Ensure that Industry Codes include and allow for age verification on mainstream adult porn sites.

5. Support and empower the regulatory body for swift take downs of non-compliant platforms.
A slow response allows more children access to potentially harmful content.

6. Increased funding to the following:

  • Department of Internal Affairs and/or the new regulatory body, to ensure objectionable content is managed quickly and effectively.

  • Community Educators - parents and caregivers are largely unaware of the harmful content available online and more education within the community needs to be done to prevent exposure to this. A recent social media poll showed that 39% of respondents were not aware that objectionable content was easily accessible for children and young people. 34% believed there was existing regulation of this content in place.

The majority of illegal sexual content online is entirely unregulated, this needs to be tackled. Bestiality and rape videos inflict severe physical and psychological harm on the people involved. Furthermore, the consumption of such content perpetuates a culture of violence and can have significant negative impact on children and young people viewing it. The presence of this content online undermines the principles of respect, consent and empathy that our society values.

If a child were to see an act of sexual violence on the street, we would immediately act to prevent it. This would be treated, by caregivers and professionals alike, as a traumatic incident.  It is essential that we protect children from exposure to the same acts of sexual violence online. By doing so, we can safeguard the welfare of individuals, particularly vulnerable populations, and take a stand against what we know to be criminal.

It is incumbent upon us, in Aotearoa, to act now to curb the proliferation of these destructive materials which are impacting our tamariki.

Thank you for considering my submission and taking child protection online seriously.

Kind regards,

[INSERT YOUR NAME]