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Seminar European Parliament: Commission proposal not in line with recommendation experts

On October 23, 2023 we spoke in the European Parliament about the Commission's regulatory proposal to combat the online sexual abuse and exploitation of children. The seminar was organized by the European Data Protection Supervisor (EDPS) and you'll find our contribution below.

Our input

Like the Commission, Bits of Freedom isn't a child protection expert. But we do know how to listen to them. So when this proposal was introduced, one of the first things we did was a review of recommendations issued by leading Dutch experts over the past couple of years. We found four commonalities.

First, most recommendations focus on prevention. The Dutch rapporteur on trafficking in human beings and sexual violence against children, for instance, argues for the importance of sexual education, including an emphasis on the positive aspects of sexuality.

Second, we noticed that hardly any of the measures are technical by nature. For instance, one recommendation by the Sexual Assault Center is to improve care for victims and coordination within the care system. Although the SAC doesn't specifically detail why tech won't solve this problem, we also haven't spotted any tech solutions in the Commission's proposal that will.

The third commonality we found is the importance of evidence-based measures. The Netherlands Institute for The Study of Crime and Law Enforcement, and the Dutch Rapporteur, both point to the fact that of the 40+ teaching methods in use, only one has proven to be effective. It's easy to see which improvement could be made there.

Finally, experts stress the importance of interventions with little or no negative side effects. And this is difficult stuff. Take for instance awareness campaigns on sexting. The Netherlands Institute for The Study of Crime, again, points to research arguing that these campaigns often focus on dissuading young people from sexting altogether, and that this can lead to shame and victims not reaching out for help.

To conclude, what experts say we need are evidence-based, non-tech, preventive measures without negative side effects. We think it's safe to say the European Commission seems to have taken the exact opposite approach.

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