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Tech Against Terrorism: Submission to the consultation process for Ofcom’s Consultation on guidance for VSP providers on measures to protect users from harmful material

Submitted 2 June 2021


Until the United Kingdom Online Safety Bill – aiming to counter harmful content online and announced in a White Paper in April 2019 – is implemented, UK-established Video-Sharing Platforms (VSPs) will have to comply with a dedicated VSP regulation meant at protecting users from “harmful” content.  The UK media regulator Ofcom will be given new powers to regulate VSPs in the UK. These include ensuring that VSPs have appropriate measures in place to protect users from illegal content as well as from incitement to hatred and violence. In line with this, Ofcom published a draft guidance for VSPs on measures to protect users from harmful content and compliance with the new regulation. The draft guidance was opened for public consultation from March to June 2021.


Our arguments throughout our response can be summarised as follows:

  • Accountability and practical guidance – Governments need to provide more leadership and practical guidance in tackling terrorist use of the internet and not place the onus on private companies. Ofcom should consider supporting organisations and mechanisms with the expertise to practically support smaller VSPs with complying with the new regulation. 

  • Proportionality and consideration for smaller platforms – Smaller platforms are the most exploited by criminal actors, however, they often lack the resources and capacity needed to counter the threat. Whilst we commend Ofcom’s recognition of diversity in platforms’ sizes, this should be further emphasised and Ofcom should specify which measures are recommended according to size and resources. A robust support programme for smaller VSPs, as well as practical Guidance and tools are needed to address the problem of terrorist and violent extremist online content. 

  • Rule of Law – Counterterrorism and tackling online harms need to be based on the rule of law and pay due regard for human rights, in particular freedom of expression. Lists and definitions of proscribed content and behaviours should be detailed, and inscribed in the rule of law by clearly referring to existing law on counterterrorism and acceptable limits to freedom of expression which lay out what is considered illegal speech in the UK.

To read the full submission please see here