Online Safety Bill

Written evidence submitted by YoungMinds (OSB76)

Dear Committee,

1.0 We are writing on behalf of YoungMinds to provide suggested amendments for the Online Safety Bill, as a response to the House of Commons Public Bill Committee’s call for written evidence.

1.1 YoungMinds is the UK’s leading charity championing the mental health and wellbeing of children and young people. We put the experiences of children, young people and families at the heart of everything we do. Our insights and solutions are informed by the experiences of young people and their families, and supported by wider evidence and data. For this particular submission, we gathered evidence from children and young people on their experiences of online safety to inform our suggested amendments for the Online Safety Bill.

1.2 The stated purpose of the Online Safety Bill is to make the UK the safest place to be online. YoungMinds welcomes the steps that the Government are taking to improve the online experience for people across the country, but recognise that amendments to the Bill are needed to ensure the proper safeguarding of children and young people’s mental health and wellbeing. This submission sets out the changes we need to see to ensure that children and young people’s needs are being met.

Our research

2.0 Children and young people are best placed to explain what they need for their mental health to be safeguarded. YoungMinds carried out a surveyed 1,453 children and young people aged 11-25, and conducted two workshops with young people. The following suggested policy changes have come from what young people said they need to see change to safeguard their wellbeing online. This was supported by a Censuswide poll, carried out for YoungMinds, of 2,002 16-24 year olds in the UK. The insights gathered during the research process have informed our recommendations for the following changes to be made to the Online Safety Bill.

The online world and mental health

3.0 The online environment presents both risks and benefits to the mental health of children and young people. When YoungMinds approached young people to explore how social media impacts their wellbeing, they often reported using it as a way to unwind or relax. Others highlighted the fact that these platforms often provide a sense of community for young people, helping them to express themselves and find support if they are struggling with their mental health. [1]

3.1 However, young people told us that these benefits came with significant risks. Many young people told us they felt social media platforms encouraged addictive behaviour, and that they often felt trapped online; amongst those who took part in our research, 34% said they wanted to leave social media sites at least once a week but feel they are unable to, while 89% of young people agreed that social media can drive harmful behaviours. Although the factors behind mental health problems are often complex and multiple, the young people we consulted said that aspects of their experiences online can exacerbate or expose problems that they already struggle with, adding to anxiety or making them feel worse when they compare their lives to those of other people.

3.2 Those with pre-existing mental health conditions and those from marginalised and minority groups are particularly vulnerable to these risks. Our research has shown that black and minoritised ethnic young people experience discomfort from image editing tools disproportionately to their white peers. [2] Significantly, 79% of young people go on social media when they feel upset or distressed. [3] It is therefore clear that platforms have a discernible impact on the mental state of the user, but also have the opportunity to improve it. This Bill should provide a framework for doing so.

3.3 Our research findings from earlier this year are clear – young people do not feel in control of their online experiences, but they do feel responsible for them, and this has serious implications for their mental health and wellbeing. To address these challenges, our research has highlighted three areas where the Online Safety Bill should be strengthened – platform design; improving media literacy; and increasing youth participation in the design, implementation and monitoring of the Bill and its provisions.

Platform design

4.0 Young people told us that the design of a social media platform itself can negatively impact mental health and be seen as ‘harmful’ - regardless of whether or not the content is distressing. This includes the widespread use of image-editing apps and photo and video filters, and addictive design elements such as algorithms that encourage young people to view certain content that they otherwise may not have seen, and to spend more time than they would like online. Young people recognise that the design aspect of some of these features alone can harm their mental health, in isolation of the content it promotes.

Algorithms

4.1 In early 2022, over 60% of young people told us they’d been exposed to distressing content within the last week, with 31.1% having been exposed in the last 24 hours alone. 41% of young people did not believe they would be able to avoid such content if they wanted to. Most respondents said harmful content came from posts and posters they did not choose to engage with, such as those on the ‘explore’ function on their home page and public posts from strangers. This suggests an algorithmic bias towards harmful content, which is at risk of not being covered by the Bill, because there is an absence of an overarching duty of care framework in its current form.

Filters and photo editing

4.2 Research carried out with young people showed heavy engagement with image-centred platforms such as Instagram, TikTok and YouTube. Despite being aware of the use of filters and image editing tools in others users’ posts, the impact of image editing and filtering tools on mental health was still felt almost universally by respondents. One young person shared with us that they felt these tools "are designed to make you feel sad".

4.3 This negative impact particularly affects the online experiences of Black and minoritised young people, who explained to us that filters try to "make you look more beautiful" by suggesting edits to "make your skin lighter."

Recommended amendment:

5.0 Amend the structure of the Bill to provide a clear statement of its core safety objectives, including a statutory duty of care. This duty of care should provide an overarching framework from which all safety duties will derive.

This overarching duty of care will ensure:

· That risk assessment and safety measures include all aspects of an online service’s delivery and function. Platform design risks must be recognised as independent risks, not merely assessed as an auxiliary to online content.

· That online platforms pay due regard to the diversity of risk experienced by children and young people from different groups, particularly those with protected characteristics, on any platform they choose to access online.

Media literacy

6.0 A previous draft of the Online Safety Bill included a legal obligation for Ofcom to improve the media literacy of users. This was removed with the justification of a pre-existing duty in the Communications Act 2003. Our research with young people, however, has made it apparent that current provisions are not enough to provide them with the education they need to navigate the online world safely.

6.1 With 87% of 12-15 year olds now using social media platforms [4] , there has never been a better time to improve educational initiatives for staying safe online. When surveyed, many young people expressed concern that current education is not meeting their needs, feeling instead that they should be offered more nuanced education at a younger age, with relevant and useful information on how to use social media safely in a way that benefits them. Frustration was also expressed at being presented outdated information on keeping personal details safe and avoiding online strangers. Furthermore, Barnardo’s have highlighted that current social media education is integrated into RSE education, which leaves out vulnerable young people who may not be attending school regularly. [5] The online world has changed significantly in the past decade, and this should be reflected in education which incorporates previous advice on staying safe, as well more up-to-date information.

6.2 Significantly, 90% of young people believe they could actually help adults to understand social media platforms better, while over 71% think young people believe they should be involved in helping adults design lessons on online safety. When polled, one respondent believed that schools should encourage older students to "converse with young students about online safety and using social media effectively."

6.3 The Online Safety Bill is thus an opportunity to arm young people with the tools they need to reap the benefits of social media and reduce the risk it poses to their wellbeing.

Recommended Amendment

6.4 Reinstate and strengthen a clause in the Bill to oblige the government to provide relevant and effective media literacy education for children and young people. The enactment of this clause should be carried out in consultation with children and young people.

Participation

7.0 Children and young people are best placed to say what they need for their mental health and wellbeing to be safe online, yet they have had little input in designing the provisions set out in the Online Safety Bill. According to our research, 80% of young people we spoke to have never heard of the Online Safety Bill, despite 90% believing they hold knowledge that could help adults understand the online world better. The fact that young people’s expertise – as a significant user base of online platforms – has not been sought in the drafting of the Online Safety Bill, has resulted in a Bill that is falling short of its objective.

7.1 For the Bill to be fit for purpose, young people must have meaningful involvement at every stage of the process, from the design, implementation and monitoring of its provisions.

Recommended amendment

7.2 The Online Safety Bill must include a clause that creates a youth advisory board where children and young people are meaningfully consulted and involved in the implementation and monitoring of the provisions set out in the Bill, and any subsequent secondary legislation to follow.

Conclusion

8.0 The Online Safety Bill is an opportunity to put measures in place to assert certain principles that will safeguard the mental health and wellbeing of children and young people, giving them back control over their online experiences.

[1] Recommendations

1. Amend the structure of the Bill to provide a clear statement of its core safety objectives, including a statutory duty of care. This duty of care should provide an overarching framework from which all safety duties will derive.

2. Reinstate and strengthen a clause in the Bill to oblige the government to provide relevant and effective media literacy education for children and young people. This obligation should be carried out in consultation with children and young people.

3. The Online Safety Bill must include a clause that creates a youth advisory board where children and young people can be meaningfully consulted and involved in the design, implementation and monitoring of the provisions set out in the Online Safety Bill and any subsequent secondary legislation to follow.

If you would like to discuss any of the points raised in this submission, then please do not hesitate to get in contact.

Yours sincerely,

Nazifa Choudhury (she/her/hers)

Nazifa.choudhury@youngminds.org.uk

Policy and Research Officer

Eleanor Davies (she/her/hers)

Eleanor.davies@youngminds.org.uk

Policy and Public Affairs Officer

10 June 2022


[1] Barnardo’s; Left to their own Devices: Young People, Social Media and Mental Health (2019) https://www.barnardos.org.uk/sites/default/files/uploads/B51140%2020886_Social%20media_Report_Final_Lo%20Res.pdf accessed 9th June 2022

[2] YoungMinds; Online Safety Bill Workshops (2022)

[3] YoungMinds; Online Safety Bill Survey (2022)

[4] OfCom, Children and Parents: Media use and attitudes report 2020/2021 (2021) 9th June 2022 < Children and parents: media use and attitudes report 2020/21 (ofcom.org.uk)> accessed 9th June 2022

[5] Barnardo’s; Left to their own Devices: Young People, Social Media and Mental Health (2019) accessed online on 09th June 2022 <https://www.barnardos.org.uk/sites/default/files/uploads/B51140%2020886_Social%20media_Report_Final_Lo%20Res.pdf>


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Prepared 14th June 2022