5Rights response to Ofcom’s draft guidance on violence against women and girls in digital environments
5Rights has responded to a consultation by the UK’s online safety regulator, Ofcom, on its new guidance under the Online Safety Act. The guidance outlines how tech companies should adopt safety by design principles to protect women and girls from the disproportionate harm they face online and it focuses on four particular sets of harm to women and girls, including online misogyny, harassment, domestic abuse and image-based sexual abuse.
In our response, we welcome Ofcom’s focus on safety by design principles. This marks a noteworthy change to its codes of practice, a move long advocated by 5Rights and its Children’s Coalition for Online Safety. In particular, we welcome the guidance’s recommendations on abusability testing for features and functionalities, and the implementation of safer default settings for women and girls.
In our response, we recommend:
- Recognising service design as a harm that disproportionately impacts women and girls, including design features that impact the wellbeing of girls, such as beautification filters;
- Requiring companies to understand and assess the risks to women and girls within their supply chains, ensuring that they take responsibility for all aspects of their services – including third-party features and functionalities;
- Ensuring that reporting on the uptake of the guidance is published in a timely manner, rather than waiting until the proposed date in 2027. An earlier report would provide a baseline understanding of what companies are currently doing and the measurable impact of the guidance on the online experiences of women and girls.
It is crucial that, when enforcing and implementing the online safety regime, Ofcom ensures that the guidance is embedded within the wider actions it takes – during risk assessments, transparency reporting, information-gathering and supervisory relationships.
