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As a contribution to ongoing deliberations of the House of Lords on the UK Online Safety Bill (the Bill), the Global Network Initiative (GNI) writes to share key considerations and concerns. As this legislation moves toward finalization, GNI encourages the Lords to prioritize amendments which ensure an appropriate and proportionate scope of substantive obligations, oversight and enforcement authorities, penalties for noncompliance, and privacy safeguards, including vis-a-vis end-to-end encryption.

GNI has been engaged throughout the Bill’s evolution, first providing input on the consultation on the White Paper in July 2019. Following the government’s response to this consultation, GNI held a multistakeholder roundtable in September 2020 with key actors in the UK. GNI has continued to maintain dialogue with UK policymakers on the bill, including through evidence presented to the Foreign Affairs Committee of the House of Commons in November 2021. 

As we emphasized in our initial submission, GNI shares and appreciates the UK Government’s commitment to the safety of individuals online, especially children, and we acknowledge  the limited references to freedom of expression and privacy in various provisions in the Bill. However, notwithstanding the narrowing of the scope of companies and content covered by the bill over time, significant digital rights risks remain. As drafted, the Bill is likely to place undue pressures on ICT companies to restrict the rights to freedom of expression and privacy in the UK and undermine existing commitments to responsible company decision making

We stand ready to engage with the Lords throughout the Committee stage deliberations in support of such amendments and we welcome opportunities to share GNI’s multistakeholder perspective in support of rights-respecting content regulations.