ࡱ> 9;8q 0bjbjt+t+ ">AA+]222H\\\ppppp |p$ :\\\\\pp\\\\\\ V|HppDH 7 May 2004 Commissioner Erkki Liikanen Commissioner for Enterprise and Information Society European Commission Rue de la Loi 200 Brussels B 1049 Dear Commissioner Safer Internet Plus Proposal for a decision of the European Parliament and the Council on Establishing a multiannual Community programme on promoting safer use of the Internet and new online technologies COM (2004) 91 final Save the Children is an international childrens rights NGO working globally in over 100 countries world wide. We have been active for many years in raising awareness about the issue of child abuse and providing direct help to children who have suffered sexual abuse. In recent years the sexual exploitation of children via the Internet has increased. Six Save the Children organisations currently operate hotlines, five of which are partially funded by the European Commission and are active members of INHOPE, the international association of internet hotlines. Save the Children is also active at EU level working with the institutions to promote the rights of the child at EU level. We are writing to give our comments on the recently launched Safer Internet Plus Action programme. First Save the Children welcomes the programme as an important continuation of EU activity in this area, we also welcome the consultative process that took place to draft the programme. It has played an important role in stimulating the development of hotlines in countries where they did not exist, raising awareness amongst the public and end-users about internet opportunities and risks, and has enabled important dialogue to take place between different stakeholders in the debate. We have a number of specific comments on the proposal:- Childrens participation Recent research has shown that although many households contain one or more computer-literate parents, children consider themselves more expert in using the internet. Although parents may be catching up, young peoples willingness to experiment may make this a lasting reversal of the generation gap. Furthermore, interviews conducted by Save the Children Norway show that children, and in particular teenagers, often use the internet alone or together with friends. Most teenagers say that they do things on the net that their parents do not know of or would not approve of. The children are frustrated by their parents lack of understanding and knowledge, especially when it comes to chatting. Many of the informants show a careless attitude to their own online safety. For instance they claim to protect their own identity, while still giving out their mobile phone number after just a couple of chatting sessions. The teenagers interviewed by Save the Children Norway would not tell teachers or parents if they experienced something negative whilst chatting or when meeting a friend from the net. To ensure that messages on how to use chat rooms safely reach the target groups, Save the Children, as a working principle, includes children in the development of preventative measures and communicative tools. In Norway, children have been asked to create safety rules and identify various messages that would make other children aware of the dangers related to meeting strangers after internet chatting. The safety rules, as well as a set of gadgets with safe chat themes chosen by the children, have successfully been used in a safe chat campaign. Children's own experience and opinions also constitute a basis for the material targeted towards parents and teachers about safer internet and the success of the material is undoubtedly linked to the information and advice given by the "experts" themselves. The draft Action Programme however contains no explicit reference to the active participation of children themselves in the programme and in the different strands of the programme. Meaningful consultation with children themselves is a vital part of policy development in this area and children cannot be simply seen as passive end users. Increasingly policy makers and Governments are recognising the importance and value of childrens contributions to policy and childrens right to participate according to their age and maturity is included in Article 12 of the Convention on the Rights of the Child. Save the Children has substantial experience in childrens participation and would be happy to assist the Commission in developing work around this area. Focus on the End User Save the Children, whilst welcoming the new programme is concerned about the exclusive focus on the end user and the lack of focus on dealing with the issue of the production of child pornography. We do not think that this can be left to other areas of the Commission (eg the AGIS programme or the European Forum on Cyber Crime), a focus in the Safer Internet plus action programme is necessary. It is also important to recognise the horrific reality that in a minority of cases it is parents themselves who are exploiting children. German police estimate that 130.000 children in 1993 were forced by parents or other acquaintances to participate in the production of pornography. Similarly UK police state that a significant proportion of those looking at pornography are active abusers producing the material themselves, often using their own children, their neighbours children or in rare cases by luring strangers. Police found one man who had wired webcams into his daughters bedroom so that he could share video images of his abuse with other peer-to-peer file sharers. Secondly focussing on children as end users does little to tackle the situation of those who are actually being abused during the production of child pornography. Whilst focussing on children as end users will reach children who are at risk of being targeted by sex offenders through the grooming process, it does nothing to reach those already being abused. Save the Children recommends that the programme should emphasise this area of work more, in particular through for example work around victim identification projects as well as through specific projects in the Safer Internet Forum. This will be a particularly important area to address with the new member states participating in the programme as evidence suggests that many of these countries are source countries for child pornography. Children as end users should be reached not only via their school environment but also in non-schooling settings: associations, sport clubs, internet cafs, etc. In some countries only a minority of schools have computer and internet access and multiple channels will increase the reach of any action. Link With Child Trafficking Child pornography is also linked to sex tourism and trafficking where seizures of child pornography have confirmed the children's accounts of being abused in such circumstances. Many of the detected sex tourism cases include seizures of child pornography. Digital cameras and video cam recorders have made life easier for abusers who wish to make a record of their criminal behaviour for private entertainment or commercial gain. This record of the crime can then be used for their own gratification when they return home or can be exchanged with other sexual abusers as means of gaining acceptance in child sexual abuse networks. It can also be used as a commercial commodity to be sold to other sex offenders and as a means of gaining other abusive images. This often compulsive collecting behaviour usually means however that there is evidence that law enforcement agencies can use. One of the most alarming new developments in the area of child pornography on the internet is the growth of what appears to be organised crime involvement. Commercial web sites selling child pornography videos exist, many of which appears to have their origins in Eastern Europe. The potential for links with child trafficking and child prostitution are obvious further areas for concern. Dealing with this requires a major investment of law enforcement resources, at an international level and must be regarded as a high priority. Given that the children that seem to be involved in this material appear to come from economically disadvantaged regions, a focus on the identification of children in those locations must also be of the highest priority. Save the Children recommends that Member States and the Commission take steps to further investigate the linkages between child pornography and child trafficking both in the Safer Internet Plus programme and in the monitoring of the implementation of the Framework decision on combating the sexual exploitation of children and child pornography and in the work currently being carried out on child trafficking in the Commission. Focus on New Media Save the Children welcomes the extension in the programme to new media which is extremely important. This is particularly true of personal mobile devices which will constitute mobile platforms to access internet everywhere and at any time. This will mean that the opportunities and risks that internet has given and posed will be transferred and present on the third generation of mobile phones. Although their penetration has been slower than expected and very different from country to country, action is needed in order to prevent the problems and risks rather than reacting to them afterwards. We particularly welcome the statement in Annex 1 about taking into account the effect of new technologies at the design stage and would urge that childrens active participation is sought within this. Racist Content and Child Pornography The programme proposes to extend the work of the hotlines to racist content. Save the Children agrees with the analysis in the programme that different mechanisms and different expertise may be required to deal with other areas such as racist content. We think that it is important that the vital work on racist content and on child pornography which require different areas of expertise are not made less effective by combining them. Although we note with concern that Annex 1 states that financial limitations might mean that not all work in these two important areas could be funded (page 17). Other issues The extension of the programme to the new member states is welcome (as is the continued participation of the EEA states), however given the relative lower penetration of internet in the accession states, considerable effort will need to be invested in capacity building and training. Save the Children believes that the budget of 50 Million Euro is necessary, given the participation of the 10 new states, especially as they are at a much lower level of development than many of the current EU members. Finally, continuous financial support in developing filtering tools appears to be slightly outdated given that in the past programmes this area of intervention produced limited viable results. Save the Children looks forward to continuing to work with the Safer Internet Plus programme and will be actively following its progress through the European institutions. Yours sincerely Diana Sutton European officer  UK Children Go Online listening to young peoples experiences Sonia Livingstone and Magdalena Bober  The Guardian Newspaper, 4 November 2003  Max Taylor and Ethel Quayle, Child Pornography, An Internet Crime, Brunner-Routledge, 2003, p. 207    h$$$F&Y&~),, ...//0 0I0J0h0000J5B* 0J6B* j0JU-au   >$-au   >?jkfg}~ -.!!$$E&F&Y&Z&(()))),,,,/-0- . ...////////0I0000 T>?jkfg}~ -.!!$$E&F&Y&Z&(H$7$8$(()))),,,,/-0- . ...////////0I0000H$7$8$ /R . 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