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Our response to Ofcom’s Illegal Harms consultation

The Online Safety Act, like any other, is only as strong as its enforcement, and the spirit of collaboration that has made the Act possible must be sustained if we’re to end the abuse of Black women and girls online and achieve meaningful change in the lives of all women and girls – online and off. Therefore, effective enforcement of the Online Safety Act is of paramount importance to our work at Glitch, and we are sharing the recommendations we put forward to Ofcom, in order to ensure our communities understand the many ways we employ our expertise and engage our communities to end online abuse. 

Glitch has made clear our concerns about the ways the Act falls short when it comes to protecting women and girls – and especially Black women and girls – and the guidance and recommendations that Glitch and other civil society organisations offer will be invaluable for the implementation of the Act.

Effective enforcement of the Online Safety Act is of paramount importance to our work at Glitch, and we welcomed – and are grateful for – Ofcom’s invitation to respond to their Illegal Harms consultation, the first of three phases within Ofcom’s plan to put the Online Safety Act into action. In the spirit of our work, which is rooted in Black feminist values and practices, we are putting forward recommendations to Ofcom that would help steward more effective collaboration with civil society organisations and those vulnerable to online abuse – and sharing them publicly to ensure our communities understand the many ways we employ our expertise and engage our communities to end online abuse.

Ringfence budget to support and sustain civil society and community engagement.

In line with the Online Safety Act Network’s public statement and a letter drafted and issued on behalf of organisations working to end violence against women, Glitch is concerned that Ofcom’s consultation process is prohibitive for small charities like ours. Sustained and sustainable engagement with civil society organisations is vital for the effective implementation of the Online Safety Act, and we encourage Ofcom to ringfence budget to ensure civil society organisations can dedicate the appropriate time, talent and resources to future consultations. This request is especially salient since Ofcom is funded by the companies it regulates, and it aligns with Glitch’s calls for the government to ringfence a portion of the tax already collected from tech companies to provide funding support to interventions to end online abuse.

Improve working knowledge of intersectionality, race and ethnicity within Ofcom’s research and data analysis teams.

Throughout the Illegal Harms consultation document, there are numerous conflations of race and ethnicity, as well as an uneven application of intersectional analysis. We find this concerning, not only for the extra work it creates for civil society organisations participating in an already taxing consultative process, but for the signal it sends about knowledge gaps within Ofcom. We encourage Ofcom to explore how to better improve its teams’ working knowledge of intersectionality, race and ethnicity, by hiring in those with the experience and expertise to teach, advise and consult Ofcom’s research and data analysis teams. Community organisations are already working in this way; Ofcom needs to learn to work more like us.

Build and fund an Advisory Council to sense check and critically engage with Ofcom’s policy recommendations, research frameworks and data analysis processes.

Ofcom’s role as regulator of the Online Safety Act offers a generative opportunity to build a network of expert advisors from a range of systemically, structurally and culturally-oppressed communities to offer guidance, critical analysis and community perspectives relating to Ofcom’s policy developments and recommendations. While Glitch is prepared to do some very heavy lifting in support of Black women’s safety and joy online, we should not carry this responsibility alone. We encourage Ofcom to think with, alongside and in consultation with the communities most vulnerable to online harm by building and funding an Advisory Council. This will ensure Ofcom’s stewardship of the Online Safety Act’s implementation is emboldened by the ideas, voices and hopes of diverse communities.

As we have demonstrated throughout the life of the Online Safety Act to date, we have the will and influence to mobilise concerned digital citizens to action and we will continue to sound the alarm, hold tech corporations and government accountable, and provide tools and resources that awaken and equip digital citizens to demand the tech safety standards we deserve.

Symbolic protection is of no use to women and girls in the UK, or anywhere. The Online Safety Act is only one step towards ending online abuse for good. We are standing by to work collaboratively with Ofcom, politicians and civil servants across various governmental departments to ensure the Online Safety Act is implemented effectively, so that women and girls, and especially Black women and girls, are protected and enabled to thrive online.

We extend a special thank you to Keisha Bruce, Neelam Heera-Shergill and Furaha Asani for their time, effort and expertise in supporting Glitch to review and respond to Ofcom’s Illegal Harms consultation. We could not have done this without you. Thank you.