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 3
