ODA response to Online Harms White Paper

The Online Dating Association (ODA) responded today to the UK Government White Paper consultation on Internet Safety.

The Government has recognised internet safety can take endless forms in a digital age. They acknowledge the need to prioritise and target the particular risks that should be addressed: those that are not already managed by laws covering e-Commerce, data protection and privacy, commercial practice and various forms of criminal and legally prohibited activity.

The ODA believe the dating sector’s work on standards and user protection are recognised by Government with no regulatory proposals specific to the sector in the White Paper. Dating services are, however, one of the endless variety of so-called “Information Society Services” (ISS) and we have responded fully to the Government’s questions in order to ensure dating services are understood and regulation and legislation that is intended to address other harms, particularly with social media platforms, do not have unintended and negative impacts on dating services and their users. Our response to the Government can be seen here.

Our top line messages are:

1. We agree further action is needed to address online harms.
2. Online harms, like harm in the physical world can take endless forms.
3. Regulation should only happen when and where necessary. It should, per Ofcom and other guidance, be objectively justified and the minimum necessary to achieve the goal set.
4. If any legislation and regulation is not to affect every provider of any kind of ISS, the Government needs to focus down on the specific goals it wishes to achieve and on the hosting and other services that relate to these harms.
5. Online dating services have a single reference in the White Paper: reflecting the specific singular purpose services provide and their irrelevance to the harms highlighted in the White Paper.
6. We think the Government right not to propose regulation specific to dating services.
7. Dating service providers will continue on a voluntary basis to apply age rules to use of their services and will continue to develop mechanics for ensuring this policy is applied.
8. An approach that prioritises the risks to be addressed by any new regime should not reach into matters already addressed by existing law and existing regulators. Any new regulatory body should focus on social media providers that host, promote and accelerate content that could cause serious offence and encourage harmful actions.
9. Targeting is critical to adding value and delivering new protections without causing regulatory conflict, overlaps, inconsistences and an approach that is contrary to existing Community law relating to providers of ISS.
10. Proportionality matters. Most members of the ODA are UK based UK-focused entities of varied but unexceptional scale. Measures that seem proportionate to global social media providers could cause severe damage to UK businesses if applied to all and sundry and in a standard format.