comecesecretariatcontribution-openpublicconsultation
Dieses Dokument ist Teil der Anfrage „Kommunikation mit Religionsgemeinschaften zum VO-Vorschlag zur Prävention und Bekämpfung des sexuellen Missbrauchs von Kindern“
Ref. Ares(2023)1356243 - 23/02/2023
Commission of the Episcopates
of the European Union
Public
consultation
on
Child
sexual
abuse
online
-‐
detection,
removal
and
reporting
Integration
to
the
contribution
of
the
Secretariat
of
COMECE
(Commission
of
the
Episcopates
of
the
European
Union)
The
COMECE
Secretariat
would
like
to
complete
its
answers
with
the
following
elements.
With
regard
to
the
types
of
child
sexual
abuse
online
and
related
activities
that
are
most
concerning
and
should
be
tackled
in
priority
(Question
1.a.1.)
All
types
of
child
sexual
abuse
online
and
related
activities
indicated
at
Question
1.a.1.
are
relevant,
as
all
these
factors
drive
a
cycle
of
offending
behaviour
whereby
those
with
an
interest
in
sexual
abuse
of
children
access
online
material.
They
learn
how
to
groom
children.
This
leads
to
further
abuse
of
children
which
is
then
made
available
online
(D&C)1.
With
regard
to
the
current
gaps
in
the
fight
against
child
sexual
abuse
online
and
the
outcomes
that
the
new
legislation
should
aim
to
achieve
in
priority
with
regard
to
child
sexual
material
and
online
grooming
(Question
1.a.3.)
Particular
emphasis
should
be
placed
on
reducing
the
number
of
instances
of
online
grooming
of
children;
and
on
reducing
the
amount
of
sexual
material
self-‐generated
by
children
distributed
online.
Self-‐generated
content
can
include
child
sexual
abuse
content
which
has
been
made
in
a
child’s
own
home
by
the
child
who
has
been
coerced/groomed
to
share
(D&C).
In
its
recent
contribution
to
the
consultation
in
view
of
the
EU
Strategy
on
the
Rights
of
the
Child,
COMECE
expressed
concern,
inter
alia,
on
child
self-‐generated
content,
particularly
sexually
explicit
one,
supporting
the
18
November
2020
Statement
of
the
Council
of
Europe
Secretary
General
on
risks
associated
with
sexual
images
and
videos
self-‐
generated
by
children.
1
The
parts
of
this
document
marked
with
the
acronym
"D&C"
refer
to
the
elements
provided
by
the
Safeguarding
Office
for
the
Diocese
of
Down
&
Connor,
based
in
the
UK,
but
part
of
the
Irish
Bishops'
Conference,
which
covers
the
entire
island
of
Ireland.
COMECE | Square de Meeûs 19 – BE-1050 Brussels | Tel. +32 2 235 05 12 | Email sg@comece.eu
Website: www.comece.eu | Facebook & Twitter @ComeceEu
With
regard
to
the
current
gaps
in
the
fight
against
child
sexual
abuse
online
and
the
outcomes
that
the
new
legislation
should
aim
to
achieve
in
priority
with
regard
to
tackling
child
sexual
abuse
in
general,
including
prevention
and
victim
support
aspects
(Question
1.a.4.)
The
Catholic
Church
would
advocate
any
initiatives
and
the
planning
of
such
initiatives
to
take
a
victim
centric
approach
which
upholds
the
principle
of
the
needs
of
children
as
the
primary
consideration
(NB)2.
It
is
particularly
important
to
improve
prevention
of
child
sexual
abuse
(D&C).
With
regard
to
areas
of
improvement
in
the
cooperation
between
civil
society
organisations
and
law
enforcement
authorities
in
the
fight
against
child
sexual
abuse
online
We
believe
that
the
protection
of
children
online
is
a
public
health
issue,
which
requires
a
multi-‐agency
approach
involving
law
enforcement,
social
services,
education
and
other
key
faith-‐based,
voluntary
and
community
stakeholder
agencies
(NB).
Areas
requiring
improvement
with
regard
to
cooperation
between
civil
society
organisations
and
law
enforcement
authorities
are:
a)
Agreed
definitions;
b)
The
sharing
of
advanced
technologies
and
improved
investigative
techniques
that
help
to
identify
victims
and
offenders
which
will
disrupt
child
sexual
abuse
(D&C).
With
regard
to
areas
of
improvement
in
the
cooperation
between
civil
society
organisations
and
service
providers
in
the
fight
against
child
sexual
abuse
online
We
believe
that
the
protection
of
children
online
is
a
public
health
issue,
which
requires
a
multi-‐agency
approach
involving
law
enforcement,
social
services,
education
and
other
key
faith-‐based,
voluntary
and
community
stakeholder
agencies
(NB).
There
is
also
the
need
for
improvement
in
the
sharing
of
best
practice
and
education,
advanced
technology
for
detection
(D&C).
With
regard
to
striking
an
appropriate
balance
between
the
rights
of
victims
and
the
rights
of
all
users
(e.g.
privacy
of
communications)
The
Catholic
Church
would
advocate
any
initiatives
and
the
planning
of
such
initiatives
to
take
a
victim
centric
approach
which
upholds
the
principle
of
the
needs
of
children
as
the
primary
consideration,
above
the
rights
of
all
users
(NB).
The
focus
on
privacy
laws
is
also
making
it
more
difficult
to
detect
offenders
and
victims
(D&C).
2
The
parts
of
this
document
marked
with
the
acronym
"NB"
refer
to
the
elements
provided
by
the
National
Board
for
Safeguarding
Children
in
the
Catholic
Church
in
Ireland.
COMECE | Square de Meeûs 19 – BE-1050 Brussels | Tel. +32 2 235 05 12 | Email sg@comece.eu
Website: www.comece.eu | Facebook & Twitter @ComeceEu
2
With
regard
to
the
current
situation
and
challenges
in
actions
to
fight
against
child
sexual
abuse
online
There
is
a
need
for
education
for
all
to
prevent
children
being
abused
online.
This
includes
parents,
social
care
providers
to
identify
those
most
vulnerable,
schools/charities/voluntary
sector,
as
well
the
justice
sector
and
governments.
To
ensure
that
those
most
vulnerable
to
abuse
are
supported
with
the
aim
of
prevention.
Any
intervention/policy
should
be
from
a
victim’s
perspective
and
ensure
the
voice
of
the
child
is
considered
and
listened
to
(D&C).
With
regard
to
the
online
service
providers
that
should
be
subject
to
the
legal
obligation
to
detect,
remove
and
report
child
sexual
abuse
online
in
their
services
(Question
1.b.1.)
We
consider
that
all
efforts
to
detect,
remove
and
report
should
be
a
priority
on
all
platforms
(NB).
During
discussions
at
the
COMECE
Legal
Affairs
Commission,
particular
concern
was
expressed
on
new
trends
in
child
abuse
methods,
such
as
live
streaming.
Among
the
key
items
identified
in
this
regard:
broad
territorial
scope
to
cover
third
countries;
measures
to
ensure
tracing;
importance
of
international
cooperation.
With
regard
to
the
online
service
providers
that
should
be
included
among
those
that
are
allowed
to
take
voluntary
measures
to
detect,
remove
and
report
child
sexual
abuse
online
in
their
services
(Question
1.b.2.)
There
appears
to
be
a
lack
of
clarity
around
standards
to
manage
abuse
of
children
online.
If
these
standards
exist
there
appears
to
be
a
reticence
to
respond
in
a
way
which
puts
the
best
interests
of
children
as
the
primary
consideration.
Given
the
cases
of
absence
of
these
standards,
we
do
not
believe
that
voluntary
measures
would
be
sufficient
to
protect
children
online,
any
measures
should
be
underpinned
by
law
(NB).
Brussels,
14
April
2021
COMECE
Secretariat
COMECE | Square de Meeûs 19 – BE-1050 Brussels | Tel. +32 2 235 05 12 | Email sg@comece.eu
Website: www.comece.eu | Facebook & Twitter @ComeceEu
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