Consultation:
12 min read
Flux’s Response to Ofcom’s Consultation on “A Safer Life Online for Women and Girls” Draft Guidance
Last month, Flux submitted a response to Ofcom’s consultation on draft guidance for providers on how to reflect the safety of women and girls when carrying out their obligations under the Online Safety Act (you can read our original Explainer here). We welcome the focus on the safety of women and girls online; as Ofcom outlines in their consultation document and draft guidance, women and girls face disproportionate harms in some areas of online life.
In our response, we recognise the value of a guidance approach that sets out how providers can take these harms into account as part of their duties under the OSA, while also providing additional support for going beyond these requirements to further enhance the safety of women and girls. We also encourage Ofcom to continue their focus on pro-active measures, which should serve to prevent harm before it occurs, rather than relying on reactive remedies for when harm has already been done. While it is vital to address any harmful activity after the fact, this should complement and support prevention, rather than be an alternative.
Clear guidance is essential to support compliance with legal obligations by ensuring that providers understand this landscape of potential risks and the measures that can help to mitigate them. We therefore ask Ofcom to ensure that good practice case studies include more analysis of risks and benefits, and that they consider the unique nature of games in online spaces. To this end, we have also outlined the necessity of ensuring that recommended actions are technically feasible and reflective of the way in which games operate. Finally, noting the breadth and diversity of business models and sizes within the games industry, we urge Ofcom to take a flexible approach when assessing the uptake of best practice steps, recognising variances in the ability to implement some of these above-and-beyond approaches.
Read our consultation response in full
Author: Dr Celia Pontin and Veronica Perez