Civil Society Organisations Welcome the European Commission’s Proposal to Prevent and Combat Child Sexual Abuse: Open Letter to the European Union

On May 11, the European Commission released a proposed Regulation laying down rules to
prevent and combat child sexual abuse. It is timely and historic, not just for Europe but for
the world. When passed, this legislation has the potential to make an impact far beyond the
EU and help advance the global fight against child sexual abuse in both the offline and
online worlds.

Focusing on the online dimension of child sexual abuse, EU Commissioner for Home Affairs
Ylva Johansson emphasizes that there has been a 6000% increase in reports of child
sexual abuse online in the EU in the last ten years alone. Most of the images and victims
remain hidden, their abuse unseen and unreported. But even the tip of the iceberg is
enormous: the National Center for Missing and Exploited Children received close to 85
million files containing child sexual abuse material in 2021. In the previous year, that
number was 65 million. Over 62% of online child sexual abuse material (CSAM) worldwide is
hosted on servers based in the EU. It will take collaboration between citizens, institutions,
policymakers, tech companies, and nonprofit organizations to tackle a problem at this
scale.

We, as a collective of organisations that strive for children’s rights, safety, and security
online and offline, support the European Commission’s proposal as a critical step toward
better protection of children’s rights. The proposed Regulation presents a vision of a
responsible internet where children are free to be curious and explore online spaces safely.
It aims to ensure that technology is developed and used in conformity with European Union
values and in accordance with fundamental rights, with particular attention paid to
protecting children.

The current legislative frameworks vary greatly across EU Member States. They rely on
voluntary actions by online service providers and do not look to address the problems that
could arise as technology and societal engagement with it evolves. The Regulation lays out
a harmonised, binding, and future-proof framework which will allow us to tackle known
CSAM, new CSAM, and grooming for sexual exploitation, for years to come. Therefore:

● We support the strong safeguards this Regulation will put in place to ensure that
online service providers and the technology used respect the fundamental rights of
all users, including children. Among other things, technologies will need to be
assessed by the European Data Protection Board and not being able to extract any
other information than what is strictly necessary to detect the abuse. Their use will
be subject to a balancing of fundamental rights by an independent authority and
any user affected will have the right to effective redress.

We welcome the proposed EU Centre as an independent institution with strong ties to the
existing ecosystem. This will serve as a vital pillar to fighting CSAM. Similar centres exist in
various jurisdictions around the world and have demonstrated their value and utility in
coordinating efforts to fight child sexual abuse. With a strong mandate to ensure action by
online service providers, support prevention efforts, and provide crucial victim redress, the
success of the new centre will require sustained collaboration from all sectors from the
start. We offer our knowledge and support to aid in its formation.

● We also commend the general obligation to assess risks and adopt prevention
measures as laid out by the proposed Regulation, hence supporting safety by
design. Creating a new system of transparency between technology and users will
foster meaningful and measurable action to tackle CSAM.

● We have learned over time that voluntary actions alone will not solve this problem.
In addition to these efforts, the mandatory use of safe technologies ordered by an
independent authority is a welcome initiative to tackle this crime at scale.
As with any Regulation, getting the details right will be of paramount importance to its
success in bringing about sustainable outcomes for children. We welcome the
Commission’s proposal and look forward to working with all interested parties to share our
unique expertise to create a safer online environment. Our coordinated response against
online threats to children is the only way to turn the tide on child sexual exploitation and
abuse online.

For more information or to add your name and organisation to the list please contact
emily.slifer@wearethorn.org