Read the Submission (PDF)
The Global Network Initiative (GNI) welcomes the opportunity to engage with the government of the United Kingdom on its Online Harms White Paper, which proposes a regulatory approach for responding to abuses of information and communications technologies (ICTs) while protecting users’ rights.
GNI shares the government’s concerns about the need to preserve and improve the safety of Internet users, especially children. However, the approach outlined in the White Paper could create significant threats to users’ freedom of expression and privacy. The proposal’s intentionally broad scope (both in terms of the range of “companies” and the nearly two-dozen potential “harms” covered), the lack of clear transparency and accountability mechanisms for a proposed regulator (who is newly empowered with significant enforcement powers), and the unclear application of a “duty of care” could create a climate of legal uncertainty and concern for liability. This climate is likely to incentivize companies to proactively monitor their users and err on the side of restricting any content that could conceivably run afoul of the regulator’s judgment.
The UK strives to establish a global leadership role in crafting regulations for an Internet that is both safe and free, and it is therefore critical that the approach is grounded in globally recognized laws and principles set out in the international human rights framework.
Read more in the full submission.