Open Letter: Women’s safety and child protection experts call for age verification pilot

The Hon Michelle Rowland MP
Minister for Communications
PO Box 6022
House of Representatives
Parliament House
Canberra ACT 2600


Re Pilot program for age verification in Australia


Dear Minister,

We the undersigned are writing to request a re-think of the Federal Government’s decision not to proceed with an age verification system to help protect children from exposure to pornography, as recently announced by yourself on behalf of the Government.

Early porn exposure harms developing sexual templates, contributes to damaging stereotypes, the development of sexist ideas, the normalisation of violence against women and a rise in child-on-child sexual abuse. These harms were placed on the record by academics, educators, child safeguarding NGOs, and experts in child development and welfare in submissions to the Inquiry into Age Verification for Online Wagering and Online Pornography conducted by the House of Representatives Standing Committee on Social Policy and Legal Affairs. 

In its final report, Protecting the Age of Innocence (February 2020), the bipartisan committee recommended adoption of an age verification system as one obstacle in the way of children being able to access pornography. The Committee concluded:

that age verification can create a significant barrier to prevent young people - and particularly young children - from exposure to harmful online content. The Committee’s recommendations therefore seek to support the implementation of online age verification in Australia.

The Committee recommended that the eSafety Commissioner lead the development of a roadmap for implementation of a mandatory age verification system for online pornography as part of a broader approach. The previous Government accepted this recommendation and eSafety provided its report in March.

In its response, your Government stated it would not implement an age verification system, preferring industry self-regulation. It deferred to the development of industry codes which are likely years away from finalisation. In the meantime, millions more children will be exposed to pornography which frequently depicts and eroticises extreme violence against women. 

Online pornography is recognised as a threat to children in General Comment 25 of the United Nations Convention on the Rights of the Child ('On children's rights in relation to the digital environment').  The Organization for Security and Cooperation in Europe (OSCE) also recommended “implementing age verification technologies with a view to limiting the access of children to pornographic websites.” 

The Federal Government acknowledges the role pornography plays in violence against women, in its National Plan to Address Violence Against Women and Children (2022-2023).

With pornography now overwhelmingly consumed online and via mobile devices, it is both prevalent and pervasive, perpetuating sexist, misogynistic and degrading views about women. This is a serious concern in addressing the drivers of violence against women and children. (p.49)

Our Watch - the lead national organisation for the primary prevention of VAW - also identified the role of pornography in contributing to violence in its 2020 report Pornography, young people and preventing violence against women.

The influence of pornography is of concern to those working to prevent violence against women and promote respectful relationships and gender equality, because the bulk of evidence identifies both frequent depictions of violence and typically stereotypical representations of men and women in pornography. For example, studies have highlighted the high frequency of specific violent behaviours, largely directed at women, including gagging and verbally abusive language, and the more generally prevalent portrayal of male dominance and female submission. (p.4)

…content analyses have revealed frequent aggression, non-consensual behaviour and multiple forms of violence towards women in pornography. These include physical aggression (eg. hitting, slapping, gagging) and verbal aggression (eg. name-calling). The frequency and eroticisation of such depictions may normalise and condone violence against women, in sexual relationships and more generally. Pornography may encourage these views and/or reinforce them where they already exist. (p.12)

It is our strong view that the Government has allowed itself to be swayed by industry resistance to an age verification system. Vested interests should not have been put before the wellbeing of children.

The Government’s initiatives regarding respectful relationships and consent education, while welcome, cannot compete with the world’s largest department of education – the global pornography industry. 

The Government claims that age verification technologies are immature. However, age verification providers are already successfully utilised in many parts of the world. Age verification systems can be independently assessed by a formally accredited third-party certifier. We note that the Age Check Certification Scheme has robust criteria, including criteria approved by the UK’s Information Commissioner's Office, for independent assessment and certification of age verification providers.  

In regard to privacy concerns, providing age verification does not require a record of the purpose for which an age check is carried out. A double-blind approach is applied to age checks, where the age-restricted website is not given any information about the identity of the user, and the age verification provider records no data about the identity of the website seeking to confirm a user's age.

According to eSafety research, more than three in four Australian adults support government implementation of age assurance for online pornography. In its report, eSafety recommended (p.8): “Trial a pilot before seeking to prescribe and mandate age assurance technology.”

We request that at minimum, this recommendation be adopted.

In its response to eSafety’s roadmap report, the Government concluded: “The first duty of any Government is to protect its citizens from harm.” Actioning eSafety’s recommendation regarding a pilot program would demonstrate your Government is sincere in its stated concerns about the protection and safeguarding of our most vulnerable citizens.

We urge the Government to re-evaluate its decision and proceed with a pilot program.

Yours sincerely,

Robert Fitzgerald AM, Patron, Survivors and Mates Support Network

Jess Hill, award winning author, 'See What You Made Me Do' 

Professor Michael Salter, Scientia Fellow and Associate Professor of Criminology, UNSW

Jon Rouse APM, leading child sexual abuse investigator

Grace Tame, CEO, The Grace Tame Foundation

Chanel Contos, CEO, Teach Us Consent

Katherine Berney, Executive Director, National Women's Safety Alliance

Nicole Lambert, A/Chairperson, National Association of Services Against Sexual Violence

Verity Bennett, CEO, North Queensland Domestic Violence Resource Service

Angela Lynch, Executive Officer, Queensland Sexual Assault Network

Kathryn Fordyce, CEO, Laurel House (North and North West Tasmania Sexual Assault Support Service)

Allan Ball, National Director, White Ribbon Australia

Sonya Ryan, Founder and CEO, The Carly Ryan Foundation

Madonna King, author, 'Saving Our Kids'

Gillian Calvert AO, inaugural NSW Commissioner for Children and Young People 

Joe Tucci, CEO, Australian Childhood Foundation

Alison Geale, CEO, Bravehearts

Daniel Morcombe Foundation

Hetty Johnston, founder, Safeguarding People Australia

Katrina Lines, CEO, Act for Kids

Professor Michael Flood, Queensland University of Technology.

Professor Daryl Higgins, Director, Institute of Child Protection Studies, Australian Catholic University

Anna Bowden, CEO, International Centre for Missing & Exploited Children Australia

Clive Hamilton, Professor of Public Ethics

Dr Michael Carr Gregg, adolescent psychologist

Steve Biddulph AM, psychologist, author, parent educator

Susan McLean, Cyber Safety Solutions

Maggie Dent, author, educator, parenting & resilience specialist

Holly Ann Martin, Managing Director, Safe4Kids

Tim Costello AO, Director, Ethical Voice

Cathy Crawford, The Women's Centre Townsville

Vicki Condon AM, CEO, Raise Foundation

Maha Melhem, Lawyer and Child Safeguarding Specialist

Dany and Cynthia Elachi, The Heads Up Alliance

Professor Elizabeth Handsley, Adjunct Professor of Law, La Trobe University and Western Sydney University

Associate Professor Helen Pringle, University of NSW

Dr Caroline Norma, Senior Lecturer, RMIT University

Dr Emma Rush, Lecturer, Charles Sturt University

Professor Debra Miles, JCU Respect Academic Lead 

Dr Ryl Harrison, JCU Respect Strategy

Dr Chris Pam, JCU Respect Facilitator

Dr Nonie Harris, Adjunct Associate Professor Social Work, College of Arts, Education and Social Sciences, JCU

Coalition Against Trafficking in Women Australia (CATWA)

Harrison James, Your Reference Aint Relevant

Marshall Ballantine-Jones, DigiHelp Publishing

Daniel Sih, author, Raising Tech-Healthy Humans

Jayneen Sanders, children's author, Educate2Empower

Neil Milton, General Manager, ChildSafe Australia

Mark Watt AM, CEO, Big Brothers Big Sisters

Melinda Tankard Reist, Movement Director, Collective Shout: for a world free of sexploitation 

Tuesday Sep 19, 2023

CC The Hon Anthony Albanese, Prime Minister

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