Online Safety Bill

Written evidence submitted by Action for Primates and Lady Freethinker (OSB13)

Online Safety Bill

Written Evidence to the House of Commons Public Bill Committee


The objective of the Online Safety Bill is to establish a new regulatory framework to increase the accountability of online technology companies and protect users from harmful online content.

The current draft of the Bill does not include explicit reference to the disturbing and escalating online social media content depicting extreme and deliberate cruelty and violence inflicted upon non-human animals.

The easy accessibility of this material puts people, particularly children and other vulnerable groups, at risk and is likely to cause them considerable psychological damage and harm.

The explicit inclusion of animal cruelty content in the scope of the Bill would not only protect children and adults from harmful and illegal content but would further advance the government’s animal welfare agenda. [1]

Action for Primates is a UK based project and Lady Freethinker is a US based organisation. Both work on animal protection issues and have been campaigning against the dissemination of animal cruelty content on the internet and the role of online platforms. They are also supporting members of the Asia for Animals (AfA) Coalition, which has an extended network of hundreds of NGOs, including many of the leading animal protection organisations in the world.

Animal cruelty content – the extent of the problem

1. Most animal cruelty content [2] is produced specifically for sharing on social media, often for profit through the monetisation schemes offered by platforms like YouTube. Examples include animals being beaten, set on fire, crushed, or partially drowned; the mutilation and live burial of infant monkeys; a kitten intentionally set on by a dog, another stepped on and crushed to death; live and conscious octopuses being eaten; and animals pitted against each other in staged fights.

2. Animals deliberately placed into frightening and dangerous situations from which they cannot escape or are harmed to be 'rescued' on camera, is increasingly popular on social media. For example, kittens and puppies are ‘rescued’ from the clutches of a python. Such fake 'rescues' not only cause immense suffering to animals, but they are also fraudulent in that viewers are often asked to donate towards the ‘rescue’ and care of the animals.

3. Another area of cruelty content is "monkey hatred", which focuses especially on baby monkeys. For example, there are monkey hatred channels on YouTube that exist solely to promote and post videos of monkey suffering, with videos showing baby monkeys being injured, abused, tortured and killed.

4. Asia for Animals Coalition set up a working group, the Social Media Animal Cruelty Coalition, which in August 2021, published a report ‘’Making Money from Misery: How Social Media Giants Profit from Animal Abuse’’ on the nature and volume of animal cruelty content available on three major social media platforms. [3] Several dozen of the 5,480 cruelty content videos they documented were filmed in the UK, and several hundred were uploaded from the UK (second only to Indonesia and the USA). At the time the report was published, the videos had collectively been viewed 5,347,809,262 times.

Harm caused to people, especially children

5. The fact that online animal cruelty content is easily available and accessible by children and other vulnerable groups has been demonstrated by several studies:

a. In 2013, Netmums, the parenting Website, carried out a survey in which more than 800 children, aged seven to 16, and 1,127 parents were interviewed. [4] It found that more than a quarter of British children had seen distressing videos of animal cruelty online. Moreover, shocking content showing animals being hurt was deliberately listed as something benign, such as "cute puppy", on sharing sites such as Tumblr, to lure unsuspecting viewers.

b. In 2018, the RSPCA found that 23% of schoolchildren aged 10-18 years had witnessed animal cruelty or neglect on social media. [5] In response to this finding, the RSPCA concluded that "young children are being exposed to horrific incidents of animal suffering online in ways previous generations have simply not experienced."

c. In 2021, the Mirror reported on concerns by the RSPCA about the graphic and cruel nature of the animal cruelty footage young people are being exposed to and sharing online ‘for likes and kudos’. [6] It was revealed that the charity received 431 reports of people posting shocking and graphic visuals of animal cruelty in 2020, up from 157 in 2019. The footage included animals being beaten, tortured and abused, with dogs kicked, cockfighting and birds thrown in front of traffic.

6. Children admit to being upset by animal cruelty content, emphasising the need to include such content in any societal efforts to secure the online safety of children. Research was carried out in 2013 by the UK Council for Child Internet Safety, in which 24,000 children were asked questions about Internet use, including "have you ever seen anything online that has upset you?" [7] It found that British children are as upset by violent videos on YouTube that feature animal cruelty or beheadings, and by insensitive Facebook messages from divorced parents, as they are by online bullying and pornography.

7. Another survey carried out in Europe, asked 10,000 9-16-year-olds what bothered them most about what they see online. [8] The authors concluded that "what particularly upsets children are images that portray vulnerable victims – animals, disabled people and victims like themselves, i.e. children."

8. The failure of the tech platforms to self-regulate is putting people – particularly children and young adults – at risk of being adversely affected by exposure to animal abuse. Psychological development can be negatively affected by witnessing animals being harmed and abused. A study published in 2017, found that "There is emerging evidence that childhood exposure to maltreatment of companion animals is associated with psychopathology in childhood and adulthood." [9]

9. According to Dr Angharad Rudkin, a clinical child psychologist: "Traumatic images are quite hard to get rid of once you get them in your head. It depends on the young person but it could be really quite disturbing and the images could come back to the child’s mind when they don’t want them to." [10]

10. There is also the established link between cruelty to animals and violence toward humans. Children who witness animal abuse are at greater risk of becoming abusers themselves. [11] [12] Individuals who witness abuse or other violence become desensitised to it. Research shows that the more often someone is exposed to a certain situation, the more comfortable that person becomes with it. [13] Criminal psychologists acknowledge that participating in or viewing acts of repeated cruelty towards animals desensitises the perpetrator and the spectator. [14] Animal cruelty destroys respect for life. [15]

Including Animal Cruelty Content within the Bill

11. Placing obligations on service providers to remove animal cruelty content not only falls within the spirit of the current Bill, but possibly within the scope. The scope of the Bill is to place duties on service providers to remove illegal and harmful content, placing particular emphasis on the exposure children have to both of these. Animal cruelty content is both a depiction of illegality and causes significant harm to children and adults.

12. Despite this, unless some amendments are made to the current draft, there is a risk that damaging animal cruelty content may be overlooked. This concern is already evidenced by the types of illegal content that is described in schedule 7 which fails to include animal welfare offences, this needs to be rectified. There is also a concern that, because the content is often filmed abroad there may be confusion as to what the position is. In addition, many of the terms and scope of the Bill are to be defined through later guidance and regulations. It is, therefore, important for some amendments to the wording of the current draft of the Bill to ensure that the type of animal cruelty content of concern can fall within its scope and the relevant stakeholders will be included in those discussions.

Illegal Content

13. To ensure animal cruelty content is included within the definition of priority illegal content and therefore subject to additional safeguards, such as systems to prevent individuals from encountering priority illegal content and to minimise the length of time for which any priority illegal content is present, amendments would need to be made. Along with child abuse and terrorism offences, Schedule 7 lists other offences that constitute priority illegal content. There are currently not any animal welfare offences listed in Schedule 7. To rectify this the following should be included within that Schedule:

Animal Welfare

23 An offence under any of the following provisions of the Animal Welfare Act 2006-

(a) section 4 (unnecessary suffering);

(b) section 5 (mutilation);

(c) section 7 (administration of poisons);

(d) section 8 (fighting);

(e) section 9 (duty of person responsible for animal to ensure welfare).

24 An offence under any of the following provisions of the Animal Health and Welfare

(Scotland) Act 2006-

(a) section 19 (unnecessary suffering);

(b) section 20 (mutilation);

(c) section 21 (cruel operations);

(d) section 22 (administration of poisons);

(e) section 23 (fighting);

(f) section 24 (ensuring welfare of animals).

25 An offence under any of the following provisions of the Welfare of Animals Act

(Northern Ireland) 2011

(a) section 4 (unnecessary suffering);

(b) section 5 (prohibited procedures);

(c) section 7 (administration of poisons);

(d) section 8 (fighting);

(e) section 9 (ensuring welfare of animals).

26 For the purpose of paragraphs 24,25 or 26 of this Schedule, the above offences are

deemed to have taken place regardless of whether the offending conduct took place

within the United Kingdom, if the offending conduct would have constituted an offence under the provisions contained within those paragraphs

14. In addition, the current section 52 could also be amended to make it clear that a relevant offence under (4)(d) i.e. an offence which would be caught by other illegal content and therefore require some safeguards in place, such as inclusion in a risk assessment and a duty on service providers to remove such content if alerted to it, includes where the victim or intended victim is an individual (or individuals) including both human and non-human animals.

15. It is not completely clear whether the current draft of the Bill covers content that is created overseas that would constitute an offence if it took place in the UK. Animal cruelty content is often filmed abroad. The optimal protection would be to have illegal content include offences that would be illegal in either the UK or the country it took place in, regardless of whether it took place in the UK. This should be made clearer.

Harmful content for children and adults

16. There is currently not a duty on the Secretary of State to consult anyone other than OFCOM ahead of making regulations to determine harmful content to children and adults under section 53 and 54. To ensure the harms caused by animal cruelty content receives the appropriate scrutiny, it is important for campaigning groups to be consulted when regulations are made. As such an addition in section 55 should state (amendments underlined):

(5) The Secretary of State must consult OFCOM and other stakeholders, including organisations that campaign for the removal of harmful content online before making

regulations under section 53 or 54.

OFCOM Codes of Practice

17. OFCOM must produce a Code of Practice offering guidance on how regulated services can comply with their duties. Compliance with the Code is deemed compliance with the law. It is therefore vital that the harm caused by animal cruelty content is caught within the Code of Practice. Schedule 4 includes the objectives that must be followed by OFCOM when creating the Codes, the objective of ensuring there are adequate safeguards to monitor cruelty towards humans and animals should be included under paragraph 4 and 5 of that schedule.

18. In addition, it is important to ensure that campaigning groups are included in the consultation process for the Code of Practice under section 37 by requiring that OFCOM also consult organisations that campaign for the removal of animal abuse content

Super complaints

19. Under section 140, there is a power for eligible entities to make complaints to OFCOM if a regulated service is causing harm. To ensure campaigning groups can flag the serious concerns caused by animal cruelty content, ‘harm to any human or animal’ should be included as features that can be flagged under subsection 1. Subsection 4 could also make it clear that a particular group that campaigns for the removal of harmful online content towards humans and animals can constitute an eligible entity.

Protecting animal cruelty exposure in the public interest

Public interest

20. It is important that the Bill does not make it illegal to use images and video footage depicting animal cruelty if the purpose of that use is to inform or educate the public about an issue. There are currently only minimal safeguards to protect such content, such as vague freedom of expression protections, and protections for journalism and content of democratic importance for category 1 user to user services. It is therefore important to try and ensure a general public interest exemption for both user to user and search services. This could be achieved by expanding on the freedom of expression protections under section 19 and section 29 by explicitly stating that freedom of expression includes ‘the expression of watchdog organisations acting in the public interest.’

21. In addition, category 1 user to user services are required to protect journalistic content and content that is important for democracy. Currently, it is possible that photos and footage from campaigning groups intending to inform would not be captured by the exemption for journalism or democracy. To help clarify this it should be made clear that section 15, which safeguards content of democratic content, includes where ‘the content is or appears to be in the public interest or specifically intended to contribute to democratic political debate in the United Kingdom or a part or area of the United Kingdom.’

22. Section 16 which safeguards journalistic content should specify that it includes where ‘the content is generated for the purposes of journalism, including by campaign groups acting as public watchdogs.’

Contact for further information:

Action for Primates


Web site:

Lady Freethinker

Web site:

May 2022

[1] As stated by the Secretary of State for the Environment, Food and Rural Affairs in the Animal Welfare Action Plan (2021), "The way we treat animals reflects our values and the kind of people we are. We will continue to raise the bar, and we intend to take the rest of the world with us."

[2] The term ‘animal cruelty content’ refers to videos or similar visual media showing gratuitous cruelty to animals, where the cruelty was perpetrated with a view to the footage being shared online on social media platforms, for ‘likes’, ‘shares’, or even for financial reward. This should exclude images and video footage depicting animal cruelty that is used to inform and educate the public, such as showing illegal treatment of animals or to expose those responsible for cruelty to animals. It is, therefore, important for the Bill to have a general public interest exemption for both user to user and search services.















Prepared 25th May 2022