Guest Blog: We are delighted to share the work of technology and children’s online safety expert John Carr OBE. In this blog, “Please Contact Your Bank” he tells of a major new development in the field of online protection for children.
“Looking back over the period of my involvement in the world of online child protection I can quickly bring to mind a number of standout moments. Earlier this week I added another to the list. And I am delighted to say the UK Government played a decisive role in creating it.
The UK Mission to the United Nations in Vienna and the United Nations Office on Drugs and Crime (UNODC), jointly organized two meetings at the UNODC global HQ. The Home Office sent a senior representative from London.
First there was a two-day Experts’ Meeting. The second was a meeting of Member States. 71 Governments signed on to a proposal the UK had fielded. In diplomatic circles this is what they call “a big deal”. The UK proposal was adopted unanimously and more countries are expected to join later. Bravo!
The originating Concept Note and the associated Background Paper for the Experts’ Meeting can be found here. I was a consultant to the project.
CSAM removal and the prevention of reuploading
The Experts’ Meeting focused on ways of stepping up global efforts to secure the more rapid and comprehensive removal of child sexual abuse material (CSAM) from the internet and, crucially, to find ways to prevent it from being reuploaded. This latter aspect is particularly important because such a high percentage of images now circulating online are copies of ones which have already been identified as illegal, sometimes up to twenty or more years ago.
Bits of the technology which can make removal and the prevention of reuploading possible have been around for over a decade. They are tried, tested, reliable and, typically, easy and inexpensive to acquire and operate. They allow a great deal of intelligence about those doing the uploading and downloading to be garnered and handed over to law enforcement who can then, where and as appropriate, try to locate and safeguard the victims and pursue the perpetrators but without leaving images out there for an avoidable millisecond longer. Cops cannot always act fast. But in a victim-centred approach fast time is exactly what the victims need. It is a vital for safeguarding. Pursuing perpetrators and removing images are emphatically not in opposition to each other. They are complementary.
Although this was not on our agenda, we heard how, in some jurisdictions, legislatures were even considering making use of the technology referred to mandatory. They have been driven to this because, despite all manner of promises and voluntary declarations given over many years, the amount of CSAM in circulation, already enormous, is still going up. Not down. The spike in numbers which happened during lockdowns has not subsided. It’s all still heading in the wrong direction. We have to reverse this trend and start moving “Towards Zero” (which was the theme for the whole event).
New or repeats?
New or repeats, the ongoing harm the images do to the victims depicted in them is palpable, as is the the risk they pose to children as yet unharmed. Why? Because CSAM helps create, sustain or promote paedophile networks and paedophilic behaviour in every country in the world. Nowhere is exempt. Nowhere.
For those reasons alone people need to stop suggesting CSAM removal is somehow a poor relation to or a second best alternative to preventing child sexual abuse happening in the first place. CSAM removal is a form of prevention, both in respect of children as yet unharmed and very obviously in respect of those children already victimised and appearing in the images in question. For those victims removal reduces revictimization and heads off other contingent dangers. So it’s not either or. We need both because they are in fact all part and parcel of any decent holistic strategy.
By failing to act to remove CSAM expeditiously once notified of its presence on a virtual property, or by failing to take steps to prevent the same images from being reuploaded, the relevant actors in the different parts of the internet value chain become complicit in the abuse.
Harsh? Not really. The problem is very well known. Its consequences for some of the most vulnerable members of society equally are well known and entirely foreseeable. The only issue, therefore, is the degree of remoteness, meaning the degree of responsibility attaching to each actor. The platforms themselves must bear the heaviest responsibility but what about all those ancilliary service providers? The other businesses or organizations which, in effect, enable the bad platforms to operate, what about them?
The eloquence of money
One thinks instantly of the advertisers. Then there’s the hosting companies and, oh yes, payments service providers. Just look what one very large online business did when Visa and Mastercard threatened to withdraw their facilities. And by the way the company concerned managed to put everything right over a weekend.
We did not hear them say
“We take our responsibilities very seriously. But you don’t understand how these things work. It’s very difficult and technically complicated. We will move as fast as we can.”
72 hours. Done and dusted. The business continued but under new operational guidelines the payments companies found acceptable. Where there’s a will there’s a way and money talks. Loudly and eloquently. Nobody is compelled to provide a business with financial services if they don’t like the cut of their jib – if they don’t think they are behaving properly. We hear about basking in the reflected glory of someone else’s virtue. There is an opposite to that as well. If you dance with a chimney sweep don’t be surprised if you end up dirty.
A very important caveat
However, believe me when I tell you some parts of the internet value chain, those a little removed from the day-to-day management of the online businesses are, in fact, not as clued up on CSAM and online child sexual abuse as we might imagine or we might hope they would be. We need to put that right. Once they are properly up to speed I am certain good things will follow. No decent human being can sit idly by and not act when they have it within their power so to do.
Leaving credit card companies and payments services providers aside for the moment, here I am thinking in particular about banks and several other financial institutions e.g. development agencies. Why do I say that? Because thanks to this UNODC/UK initiative, Alexandra Martins of the UNODC and I were given the opportunity of speaking to them directly and at a high level. We found we were pushing at an open door. Several came to Vienna and participated fully and energetically in the discussions.
The task now is to find the right way to take things forward. See below. You have a part to play both now and as this movement gains momentum.
The Experts’ Meeting
The first of the two Vienna meetings was the gathering of experts.
But, to borrow that well known advertising jingle, these were no ordinary experts. What was unusual about them principally was their range. In fact I don’t think such a collection has ever been assembled before. Ever. Anywhere. Chatham House Rules prevent me from naming some of those who contributed both on the day and, just as importantly, in the preparatory stages in the months before.
Below is my summary of what I thought were a number of the key takeaways.
Macroeconomic costs and benefits are not well understood
In Appendix A of the Background Paper referred to above you will see how little is known about the true macroeconomic cost of child sexual abuse. It tends to get lost under more generalised headings of “maltreatment” or similar.
Unsurprisinginly, therefore, neither is there a well developed understanding of the “internet dimension” linked to the overall costs of modern-day childhood maltreatment. Experts are coming to the view, for example, that there is a subset of harms specifically linked to being a victim depicted in CSAM. Can you suffer “Post Traumatic Stress Disorder” arising from the original acts of sexual abuse if, regarding the circulation of images of your pain and humiliation over the internet, for you there is no “Post”?
Maybe we have all been looking through the wrong end of the telescope or we should be using different or additional instruments ? Money with numbers attached can clarify and speed up a lot of things. Particularly for businesses. See above. But also Governments. Yes, there is also a risk it can slow things down, but I seriously doubt that will happen here and, anyway, the truth can never hurt us.
Appeals to people to do the right thing only because it is the right thing are still important. They set normative standards, but if we have learned anything from the dismal plethora of promises and unfulfilled aspirations which have characterised internet self-regulation hitherto, it is that virtue alone is not enough to move the needle strongly enough, consistently enough or quickly enough. Enough already. Let me just remind you of the words of the Australian e-Safety Commissioner in her first statutory transparency report
“some of the biggest and richest technology companies …. are turning a blind eye, failing to take appropriate steps to protect the most vulnerable from the most predatory”.
But I digress. A little.
Getting back to economics, happily research into the macroeconomic dimension of policy in this area is now getting underway with the help of professional economists who also contributed to the data shown in Appendix B of the Background Paper.
But before turning to Appendix B here is an extract from a 2014 study entitled “The costs and economic impact of violence against children” published by the Overseas Development Unit (ODI), a UK based think-tank.
They suggested
“…. the worldwide cost of physical, psychological and sexual violence against children could be as
high as 8% of global economic output, or US$7trn….”
And concluded:
“This massive cost is higher than the investment required to prevent much of that violence”
adding
“More specific data and in-depth primary research needs to be generated on the different forms of
violence against children, particularly in low- and middle-income countries. Calculating and
reporting the economic costs will lead to stronger arguments for policy-making.”
In correspondence with one of the principal authors of the ODI report it was confirmed:
“we didn’t consider the internet, as it wasn’t such a major factor for children… when we wrote the
paper, and there wasn’t much data or evidence published in regard to it. It is very alarming how
quickly it is becoming a major factor.”
Quite so.
Low and middle income countries
With internet take up levels in many OECD Member States already in the high 80s and 90s, moving ever closer to 100%, globally the fastest rate of recruitment of new internet users in the coming period will be in low and middle income countries.
The problem is many of these jurisdictions lack either the necessary legal framework, or the right level of technical and other resources to face what is coming down the track. Sadly we know from years of experience, child sex abusers are highly adept at identifying locations where their chances of being caught or constrained are minimal. Thus, absent countervailing measures, prompted by the new, fast connections provided by the large scale availability of the internet in their country, sex tourism to these territories is highly likely to increase. Live-streaming of the sexual abuse of local children is likely to increase and locally-based servers and domains will become the popular choice of CSAM collectors and distributors. The reality therefore is low and middle income countries stand to be disproportionately impacted. You can see why the UNODC is on the case and why others should be joining them.
Microeconomic costs are becoming better understood
Thanks to US Federal laws and to the outstanding work of two sets of law firms in the USA, headed respectively by James Marsh and Carol Hepburn, we are beginning to get a better idea of the nature and financial costs associated with being an individual who is a victim depicted in CSAM which is then distributed over the internet.
The numbers are set out in Appendix B of the Backgound Paper referenced earlier. Doubtless these data will feed into and help shape the macroeconomic research which lies ahead. Nevertheless I urge you to have a look at those numbers now. 11 cases are presented. Elements of the data supplied were left out but even so the total assessed costs shown came out at US$ 82,846,171. Look too at some of the individual categories e.g. the medical costs for a single individual are assessed at US$ 4.7 million. Then think about all the victims who are not “fortunate enough” to be able to connect with James Marsh or Carol Hepburn or one of their counterparts.
That open door
I mentioned earlier how Alexandra Martins of the UNODC and I were able to meet with development agencies and people from a high level in the banking world.
What can I say? No doors were slammed in our faces. On the contrary. The exact opposite was true. But here’s the thing. There was one phrase which stuck with me. When we spoke to one particular high-level insider, after laying out the problem, our version of the solution, and our hopes for how banks and other financial institutions could help. He simply said
“This is not a novel proposition. I can see it fitting very easily alongside or probably within the same inter-bank machinery which already exists to address money laundering”.
Other financial actors mentioned the positive work they did both on their own behalf and with their customer base in relation to climate change, anti-slavery, child labour, and other issues that put the “S” in ESG.
Banks are enablers and facilitators
To put that slightly differently, banks know they are enablers, facilitators. They know they have due diligence and KYC (Know your Customer) obligations. And they also know they do not want to be associated with businesses seen as persistent offenders. That is in terms of failing to do all that is reasonably possible to identify. It includes deleting CSAM expeditiously and prevent it from being reuploaded. But up to now, the unvarnished truth is nobody asked them or brought the matter directly to their attention. Or at least not in the way we have done through this UNODC/UK initiative.
Here is one of the challenges we face then. To devise a way of ensuring the banks and other financial institutions have access to reliable information. Information about which businesses, their actual or potential customers, are not doing the right thing. Information about customers who need to up their game. In that connection the presence in Vienna of, in particular, the Canadian Centre for Child Protection, NCMEC, the IWF and hotlines from the INHOPE network was really important.
Here’s where you can help straight away. Contact your bank. Ask them what policies or processes they have in place to ensure they are not providing banking facilities to businesses that are demonstrably failing children in respect of CSAM removal. And ask them, if this is the first time they are having to think about this, would they nevertheless be happy to explore it further?
You know how to get hold of me. And watch this space.
#CSAMunbanked.” First published here.
