The EU held a consultation on the upcoming Digital Services Act. It closed yesterday. Here is a link to the document I submitted with the support of one or more children’s groups from 15 Member States. What with the holiday period, Covid and the relatively short turnaround time, that’s not a bad showing. The processes that will now follow will likely carry on for some time and in the months (years?) ahead I hope we can build on that level of engagement. It is vital that we do.
The year 2000 is ancient history
The decision-makers in Brussels-Strasbourg must understand that, as compared with 2000 when they adopted the first set of ground rules for the internet, in the form of the e-Commerce Directive, the internet has changed almost beyond recognition. Now one in five of all internet users in the EU is a child.
Children and families are therefore a major and persistent presence. They can no longer be treated as an irritating, trivial concern in a larger and more important or nobler struggle against, well, against all manner of societal and political evils. Children need to move from afterthought to always-thought in cyber policy making.
The five key recommendations
If you look at the document you will see it directs policy-makers attention to five major suggestions
- Establish a duty of care
- Create a meaningful, independent transparency regime
- Revisit the GDPR through the lens of children
- Closely scrutinise the operation of the AVMSD
- Improve the co-ordination and management of policy-making processes affecting kids
There is a separate paper, which was not submitted as part of the formal response. It acknowledges that the EU has been a major world leader in online child protection but it also details where it has not always got it right. I call it the “Consequences” document.
Desiderata 