Collective Shout welcomes the opportunity to contribute to Online Safety legislative reform. We support intentions to consolidate and harmonise current laws and to ensure streamlining and consistency in a range of digital offences. We are especially pleased to see plans for an expansion of protection against cyberbullying, cyber abuse, image-based abuse and seriously harmful content. As the digital landscape is in a constant state of flux, new opportunities arise – and with them new dangers. This necessitates updated legislation to ensure a safer online environment prioritising human rights and community welfare.

*Content warning- this content may be distressing*

Child sexual exploitation material, or child sexual abuse material, refers to sexually abusive images of children. It may include photographic or video evidence of the rape, sexual abuse and torture of children and infants.

Virtual or computer-generated child sexual exploitation material is produced without the use of living children, depicting fictional children. Under Australian law, this content constitutes illegal child sexual exploitation material. The Commonwealth Criminal Code prohibits the sale, production, possession and distribution of offensive and abusive material that depicts a person, or is a representation of a person, who is or appears to be under 18. This includes virtual or animated representations of children, as well as child sex dolls.

Women working in food services are prone to sexual harassment.  The 2018 National Survey on Workplace Sexual Harassment report found that people employed in accommodation and food services - 60 per cent of whom were women - were "overrepresented as victims of workplace sexual harassment”.  A 2019 survey of Shop, Distributive and Allied Employees’ Association members - a group made up primarily of employees from the retail, fast-food and warehouse sectors - showed that nearly half of women had experienced workplace sexual harassment.

Last week KFC gushed about its partnership with icare for a staff-education program aimed at equipping staff with skills to de-escalate customer abuse and reducing its prevalence. Background data confirms that for workers in the fast-food sector, customer abuse is the norm, and is experienced more widely by female workers than male workers.

We know that abuse is borne out of disrespect, and so it’s reasonable to view customer abuse - abuse that tends to affect women more prevalently than men - as another symptom of societal-level disrespect for women. When other research confirms that gender stereotypes and sexually objectifying representations of women in media and advertising diminish our view of and value for women, we’re hard-pressed to understand why - at the same time it invests in employee empowerment - KFC would use casual sexism to flog chicken. 

icare’s pilot program involving KFC reportedly resulted in a 48% reduction in cases of customer abuse. But in the wake of KFC’s cataclysmic advertising fail, do young, female employees in KFC outlets have reason to feel empowered at work? KFC has sent the message to men and boys everywhere that ogling a woman’s breasts - an act of sexual harassment - is just a natural, normal thing to do. The message to women and girls? To borrow a pun from another KFC ad campaign, ‘Bucket. Why not?’ - just go with it. This is the antithesis of the message of respect-based, anti-harassment training programs which instruct victims and onlookers to speak out against harassment. 

It is always good to provide workers with skills to manage the spectrum of customer misconduct, but young women should not be expected to absorb the consequences of a nationwide ad campaign where sexual objectification and sexual harassment of young women is the punchline. 

How can young women feel respected by their employer when KFC is contributing to the very problems they are trying to solve with a "respect and resilience" program? Will they be safe at work when men like this walk through the door?

If KFC has - as it claims - genuine interest in the well-being of young people and empowering its staff, it will retract the ad and commit to marketing its products without endorsing sexual harassment and perpetuating antiquated sexist narratives that contribute to a culture of disrespect for women. 

See also:

Attitudes shape behaviour: men defend sexist KFC ad with onslaught of misogynistic abuse

KFC issues non-apology over sexist ad

KFC serves up buckets of sexism

Sexist grooming of boys - brought to you by KFC

Submission on National Inquiry into Workplace Sexual Harassment

(Addressed to Instagram Global Head of Policy)

December 4, 2019

Widespread predation of underage girls on Instagram 

We have identified and collected hundreds of comments posted by men on the Instagram pages of underage girls between August and the time of writing. These include grooming-style comments, sexually harassing comments, requests for sexualised content (including nudes), requests for direct messages and for images to be sent via DM. Large numbers of comments are porn-themed. Men describe in explicit detail sexual abuse fantasies involving the underage girls whose identities and locations are often exposed, placing them at risk of further sexual exploitation. (We have compiled some of the most graphic comments here.) 

Inadequate tools for keeping children safe

These predatory comments exist in plain view, unmoderated and unremoved. In some cases they have remained for more than a year - including on posts of girls as young as 4-years- old. Our reports to Instagram are often dismissed as not violating its ‘community guidelines’. Recent examples of dimissed comments include: (on a 13-year-old girl’s post) ‘Omg i sooooo wanna (emoji denoting) lick your (emoji denoting) pussy n (emoji dentoing) ass’; (on a child advertising underwear) ‘Ok im going out of line you put it on i take it off’; ( on a 9- year-old girl’s post) ‘please open your legs’ + emojis including kiss-lips; (various comments on underage girls’ posts) eggplant/peach/cucumber/squirt emojis denoting sexual acts. If these comments are not deemed in violation of whatever standards you use to determine whether content you host is in breach or not, perhaps those standards need to be revised? 

There is also a serious shortcoming in Instagram’s reporting system. While comments can be reported as ‘harassment/bullying’ or as ‘violence/threat of violence’, there is no option which properly conveys the serious predatory and grooming nature of these comments. Instagram’s reporting system should include “sexualised/predatory/grooming comment directed at a minor” as its own category. 

Instagram also needs to take action to prohibit adults from using ‘live’ posts to contact minors. We have viewed a 13-year-old girl’s live posts during which she was bombarded with sexual comments including a request for sex, questions about her underwear, a man telling her he wanted her to give him an erection, another saying he would pay to meet her and others pressuring her to remove her shoes and show her feet. 

We note your statement about having “proactive technology” to keep the platform free from content that is harmful to children. Whatever methods Instagram has employed to date are insufficient for dealing with the rampant predation of children that we have documented. (Our response to Facebook’s official statement here.)

Instagram connects predators to children

Instagram is catering to the fantasy and fetishises of child predators. Through its ‘explore’ feature it directly connects predators with more underage girls. This appears to go directly against your own policies prohibiting content which endangers or exploits children . Regardless of the intended purposes of this feature, the reality is that it results in pointing predators directly to the girls they are preying on (virtually or in real life). Instagram should stop its ‘explore’ feature from promoting minors’ pages and connecting predators with children.

Parasite accounts

We have documented several Instagram pages devoted to republishing images of girls and young women in bikinis or in various modeling, gymnastics or dance poses. Posts on these pages frequently tag the child’s account with captions instructing others to follow the child. Some pages mix images of very young girls with porn-themed and pin-up style images of older teens and young women. These accounts serve as magnets for predators pointing them directly to more children. Instagram has responded to our reports of these accounts that they do not go against ‘community standards’. Instagram should properly investigate these parasite pages. Your company should also prohibit the republishing of images of children on pages that also feature pornified images of adults. 

Instagram serves as supplier for pedophile forums

We have documented the names of hundreds of underage models, gymnasts and dancers on pedophile forums. We’ve reviewed a selection of the profile pages and found that every one contains direct links to the child’s Instagram account/s. We’ve also reviewed several forum pages and have evidence that Instagram is the primary source of images shared to the forums where men write explicitly about sex-abuse acts they’d like to carry out on individual girls. We have evidence of an individual commenting on an underage girl’s Instagram post to direct others to the forums. 

Instagram accounts used to promote sale of images/videos of children

Some underage girls’ accounts are used to advertise monetised website subscriptions where men purchase exclusive photos and videos of children. Other accounts promote links to personal web pages where fans can purchase posters, calendars and photo/video packages. Underage girls also use Instagram to promote accounts on other social media platforms where sexualised content is under even less scrutiny, placing minors in further danger of being targeted by predators.  We believe that Instagram must cease acting as an advertising service for individuals selling images/videos of minors.

Conclusion

The evidence we have gathered demonstrates the sexual exploitation of underage girls on Instagram. Your company is allowing predators almost unfettered access to them.  Content hosted on your platform violates their right to grow up free from activity that harms them (United Nations Convention on the Rights of the Child, Article 36). Because of how common predatory behaviour has now become on Instagram, girls learn to think of it as normal which sets them up for even more harm.

We urge Instagram to prioritise this issue and act in a way that places the wellbeing of vulnerable young people above the interests of predators and reflects accepted standards of corporate social responsibility and ethical behaviour.

Recommendations

• Revise ‘Community Standards’ so that all sexualised, predatory and grooming-style comments (text, slang, short-hand, hashtags, emojis and graphics) qualify as violations.
• Add ‘sexualised/predatory/grooming comment directed at a minor’ as a reporting category. 
• Prohibit adults from using ‘live’ posts to contact minors.
• Update Instagram’s system used to detect and remove sexualised, predatory comments.
• Recognising that Instagram serves as a supply source of images of children for web-based pedophile forums, update all relevant policies, guidelines and help documents (including ‘A Parent’s Guide to Instagram’) so that users are properly informed of the risks of sharing images of children to the platform.
• Stop the ‘explore’ feature from promoting minors’ pages and connecting predators with children.
• Investigate parasite pages that are exclusively devoted to republishing photos of minors, deleting pages where children are sexualised, harassed, groomed or where any type of predatory comments/behaviour is displayed.  
• Prohibit the republishing of images of minors on Instagram pages that also feature porn-style images of adults. 

See also:

No Facebook, you're not doing enough to protect children.

Why is Instagram letting men share sexual fantasies about 7 year old girls?

Predators Paradise: girls are sexually exploited on Instagram

I was so concerned about porn-themed portrayals of young girls on Instagram I reported to police

eSafety commissioner backs Collective Shout's call for Instagram overhaul

A day of the girl on Instagram: posed, exposed and at risk

‘Sexy girl’: How Instagram allows the offering of young girls as fetishised flesh

Collective Shout has called on Australian cinemas not to screen the children’s movie Show Dogs over concerns the film grooms children for sexual abuse.

In response to the global outcry from parents and child advocates, the production company withdrew the film, promising to re-cut it to remove the offending scenes. However, the film has been re-released with only a minor portion of the troubling scenes removed. This is not good enough, so now we’re calling on Australian cinemas to take a stand against child sexual abuse and refuse to screen the film. 

At this stage, the film is being promoted by Hoyts, Event Cinemas, Palace Cinemas and Wallis Cinemas. The film is currently not listed on Cineplex, Village Cinemas, Dendy Cinemas, Grand Cinemas and ACE Cinemas websites.

So far, we’ve had responses from several cinemas. 

Hoyts has claimed the film “has not confirmed its release date for Australia” and that they do not have any information about the film being shown on their screens yet- however, the film is currently being advertised on the ‘Coming Soon’ section of Hoyts’ website with a release date of 5^thJuly.

Dendy responded as follows:

Show Dogs has not been confirmed for any of the Dendy Cinemas sites. We are not planning on showing the film at this stage. 

We need your help.

Help us keep the pressure on, and let these cinemas know you don’t want them to screen Show Dogs.

Contact your local cinema here, and let us know if they respond.

We are writing to you in regards to the children’s film Show Dogs, due for release 5 July. Upon its release in the US, it attracted substantial criticism from parents and child advocates over concerns of “grooming” children for sexual abuse.

The film tells the story of a police dog going undercover at a dog show. There are reportedly several scenes in which the dog, Max, has to have his genitals inspected. When he is uncomfortable and wants to stop he is told to go to a ‘zen place’. When he submits and allows his genitals to be touched, he is rewarded by advancing to the next level of the show.

In response to the global backlash, the production company withdrew the film, promising to re-cut it to remove the scenes in question. The film has been re-released, however the scenes remain, with only the encouragement to ‘go to a zen place’ (essentially, to dissociate) being removed. The meaning remains intact, that unwanted sexual touching is to be endured and may be rewarded.

*UPDATE: CNN has reported the film will undergo edits to remove the objectionable content!* 

Child advocates have accused new kids film Show Dogs of sending “a troubling message that grooms children for sexual abuse”. The film was released in the US last week, and is not scheduled to be released in Australia until July.  

The film follows the story of a police dog going undercover at a dog show. There are reportedly several scenes in which the dog, Max, has to have his genitals inspected. When he is uncomfortable and wants to stop he is told to go to a ‘zen place’. When he does this, he can advance to the final round of the dog show.  

National Center on Sexual Exploitation has called on distribution company Global Road Entertainment to halt the distribution of Show Dogs in movie theaters and recut the movie:

“The dog is rewarded with advancing to the final round of the dog show after passing this barrier. Disturbingly, these are similar tactics child abusers use when grooming children — telling them to pretend they are somewhere else, and that they will get a reward for withstanding their discomfort.

“Children’s movies must be held to a higher standard, and must teach children bodily autonomy, the ability to say ‘no’ and safety, not confusing messages endorsing unwanted genital touching.”

From News.com.au:

Reviewers, too, have expressed their discomfort over the scenes in question.

Slate writer Ruth Graham called it “unsettling on several levels”.

“First, this is a children’s movie in which the protagonist’s success depends on withstanding a stranger touching his genitals even though it makes him uncomfortable,” she wrote.

“The movie’s solution to Max’s discomfort with the inspection is not to empower him to escape it somehow; it’s to have him learn to checkout mentally while he endures it, and to make no outward sign of his humiliation. It is not paranoid to say that this is a bad message for kids.”

Writer Jenny Rapson echoed those sentiments in a blog post on For Every Mom: “Max’s success is riding on whether or not he lets both his partner (for practice) and a stranger (the competition judge) touch his private parts. IN A KIDS MOVIE. WHAT??? Newsflash, folks: THIS IS CALLED GROOMING and it’s what sexual predators do to kids!”

Writer Terina Maldonado wrote on family film blog Macaroni Kid that “during the movie, I kept thinking, “This is wrong, it doesn’t need to be in a kids movie. Everything else in the movie is good fun except for this.”

In response to the outcry, Global Road Entertainment, co-producers of the film released a statement to CNN:

“The dog show judging in this film is depicted completely accurately as done at shows around the world; and was performed by professional and highly-respected dog show judges,” the statement said in part. “Global Road Entertainment and the filmmakers are saddened and apologise to any parent who feels the scene sends a message other than a comedic moment in the film, with no hidden or ulterior meaning, but respect their right to react to any piece of content.”

One of the writers of the film has spoken out against the scenes in question, claiming that they were written into the script by of the “13 other writers” who worked on the movie.

“[I] didn’t get to see the film until it was in its final stage of completion, and had zero say in creative choices the second I signed away the rights to my work.”

“I absolutely condemn any suggestion or act of non-consensual touching in any form, as well as disassociation as a coping mechanism for abuse of any kind. I understand and empathise with the parents’ and groups’ concerns regarding the message the movie may impart,” he said.

Children’s charity Bravehearts is also calling for a ban on the Australian Classification Board to ban the film:

Bravehearts is responding to reports this children’s film contains multiple scenes where a dog character must have its private parts inspected and manhandled. When the dog feels uncomfortable and wants it to stop is then told to just go to a ‘zen place’ and is later rewarded for his consent by being advanced to the final round of the dog show. This message is not only wrong, but it promotes acceptance of grooming and goes against the very basic principles of child protection.

The charity asked supporters to urgently contact the board at enquiries@classification.gov.au and Senator, The Hon Mitch Fifield at Minister@communications.gov.au.

Cineplex Theatres have already pulled the film:

Be sure to follow our Facebook page for further updates.

Content Warning: Some content including in this post may be distressing, but it is content the ASB is promoting to your children.

If an adult gave your child a Hustler magazine, what would you do? Perhaps contacting the police might be an appropriate response.

But what if the adult was the Advertising Standards Board, and the pornographic magazine was the address for a hardcore porn website, complete with prostitution services featuring young women engaging in live sex shows, including being penetrated with objects?