Dear Minister,

Full disclosure – I work for the Government Digital Service but am replying here purely in a personal capacity.

This is my considered response to the consultation “Child Safety Online: Age Verification for Pornography“.

To briefly summarise – I agree with the principle of the consultation, that legally offensive material should be prevented from being access by minors, but disagree with the proposed methods of implementing this.

I am replying in this method partially as I feel that the subject deserves a long-form response but also because the online response questionnaire for this consultation is of extremely poor quality. I urge the Minister to work with content specialists in GOV.UK for similar matters in the future.

Firstly, thank you for introducing me to the work of the UK Council for Child Internet Safety (UKCCIS). The list of members of this council makes interesting reading. I see a number of politicians, academics, representatives of child safety groups and internet providers and well as NGO advocate groups (e.g. the Internet Watch Foundation) and even specific businesses active in this area (e.g. Parentzone) but no-one from counterbalancing free speech organisations such as the Open Rights group or Liberty.

I also see no indication of the consultation openly reaching out through appropriate mediators, such as schools or organisations such as the Boy Scouts or Girl Guides, to gather feedback from those most directly impacted by this consultation, namely minors themselves.

One of my first reactions on reading the report is my surprise at definitive statistical statements from American internet tracking company comScore without including specific references to allow checking of the numbers in question. Statements such as “in May 2015 1.4 million unique visitors under 18 accessed adult sites from their desktop” imply that either an unnamed statistical method is being used to generate this figure or that some kind of online tracking mechanism is being surreptitiously to collect the browsing habits of under age citizens. Either of which requires further explanation.

I applaud the government’s work to reduce the depictions of child abuse found online and the work that has been done with various groups to increase the use family internet content filters. The latter of which demonstrates a much better method of working to resolve the issues raised in this consultation – more of which I will discuss later.

A general “national block-list” raises significant concerns. These are not just limited to the secrecy surrounds such a list, leading to things like the Open Rights Group’s site-blocked checking website but to inevitable issues around who gets to decide what is blocked, differing cultural norms, sites blocked in error, etc.

Page 11 of the consultation first brings up suggestions of age verification mechanisms. Without fail all of these have significant drawbacks. Work related to the national digital identity system, GOV.UK Verify, continues to find issues related to citizens that do not have a recorded credit history or otherwise find it difficult to establish a credible identity footprint. Such users potentially find themselves shut out of access to legal services due to an inability to establish their identity online.

The consultation document itself goes on establish that the vast majority of free-to-access pornography sites are hosted outside of the UK and therefore would not be impacted by any requirement the government puts into place to include mandatory age verification mechanisms.

Your own research paper supplied with the consultation –  Identifying the Routes by which Children View Pornography Online – is far from supporting of the proposals. Quotes:

  • “All members of the expert panel agreed that they could think of no policy interventions that would offer a large-scale reduction in the viewing of pornographic images online. As one of the expert submissions put it, ‘…there is not going to be a complete technological solution that will provide a safety shield for young people, whether from extreme sexual material, or from extreme violence, hate or radicalisation. An effective policy solution needs to consider not just ‘how to limit children’s access’ but should also deal with the repercussions of their inevitable exposure to and uses of such sites.'”
  • “One area where interesting possibilities are emerging is online age verification. Discussion of such a possibility has been raised previously in child protection policy reviews but has always been dismissed as insufficiently effective (European Commission 2008; Internet Safety Technical Taskforce 2008).”
  • “However whilst major websites are stable and easy to block, there exist many smaller, more specialised sites that would require much greater effort to index manually for inclusion in a filtering scheme.”
  • “It might be expected that most sexual images would be viewed via pornographic websites. However, recent UK and EU surveys suggest that this is not the primary route, and that traditional mass media still play an important role in children’s exposure. Indeed the 2010 EU Kids Online survey results revealed that mass media such as films and magazines were then a more common source of viewing sexual images.”
  • “To this extent, it is important to consider what the actions of frustrated teenagers might be if their desired access to pornographic web content is hindered by stronger filtering. If ever more rigorous filtering of home content makes teenagers and young people feel overly-surveilled, then there is a risk that they will just turn to other access routes which are far harder for parents or carers to detect. Similarly, as noted in earlier sections, blocking or banning certain services such as illegal peer-to-peer sites may just redirect users to even riskier sites.”
  • “PSHE requires improvement in 40% of schools. The situation appears to have worsened over time, and young people consistently report that the sex and relationships education (SRE) they receive is inadequate.”


The children themselves are asking for information on these topics to be part of their school education.

Overall I believe that the expansion of blocking, especially in the limited way described by this recommendation, will always be ineffectual at best and likely to have negative impacts at worst due to being overly broad.

Instead my strong opinion is that the way to address issues related to extreme pornography and access to pornographic material by age inappropriate minors is through the dual mechanisms of continuing to empower parents and to address the issue directly with the children in question.

For the former I would consider a national awareness campaign highlighting the use of existing ‘family filters’ on internet connections. A hopeful side-effect would be to help overcome the traditionally British issue of parental embarrassment when speaking to their children about sexual matters. This could, in turn, lead to a related drop in teenage pregnancy and sexually transmitted diseases.

In terms of direct approach to minors that would be effected by pornography, my preferred method would be via personal, social, health and economic (PSHE) in schools. This is why I am deeply disappointed in the government’s decision not to adopt compulsory sex education in schools despite urging from four parliamentary select committees, five teaching unions, the Children’s commissioner, the Chief Medical Officer, the Association of Police and Crime Commissioners, two royal societies and  six medical royal colleges.

A stated desire to engage with sex issues related to minors while, at the same time, blocking going forward with methods advised by expert consensus does leave one with with troubling questions regarding the government’s balance of objectives.


David Durant