Gaps and Challenges- COP

Given the dramatic increase in the number of children using information and communication technologies, there are a large number of children who are at risk from technology facilitated violence against children. This requires a good understanding of the issues involved and timely solutions to address OCSEA including a number of challenges that require the attention of key stakeholders.

Generational and Knowledge Gap between Parents/Adult Caregivers and Children

The generational gap in internet use between children and parents/adult caregivers is very large. The biggest challenge with the increase in online activity is that children are participating in things online and doing things at home that many parents/adult caregivers do not know about or are not familiar with. There are many new games, apps, websites, social networks, etc. There is concern that increasing access to internet and use of social media is having harmful effects100. This becomes serious when parents are no longer able to understand their children’s experiences or protect and support them effectively.

Lack of Literacy and Digital Gender Gap

Another significant challenge in addressing OCSEA is the lack of literacy, including digital literacy, particularly among women. The digital gender gap makes it difficult for parents and adult caregivers in monitoring their children’s online activities and providing adequate support. According to a report by the World Economic Forum, the digital gender gap refers to the disparity in access to and usage of digital technologies between men and women. In Pakistan, this gap persists, with women having limited access to new technologies and fewer opportunities for digital skill development. As a result, parents and caregivers, especially women, may struggle to understand and navigate online platforms and tools, making it challenging to effectively monitor and protect children from online risks and exploitation.

Covid-19 Increased the Risks of Children’s Addiction to ICT

Children spent hours at home in front of the screens of tablets, smart phones and computers playing electronic games during covid-19 pandemic. There is no doubt that the sudden change in children’s lifestyle during the Covid-19 pandemic has led to serious consequences and the addiction of ICT. Moreover, many schools and parents in Pakistan had to make arrangements for online classes where children sat in front of screens for hours. As a result, the screen time of school children also increased. While parents were busy with their work and other activities, it was not possible for parents to monitor children’s activities during classes, leaving children more vulnerable to OCSEA.

Changing Patterns of Usage of Technology

The fact that many activities that were formerly performed on fixed computers are now frequently performed on mobile devices with internet access further limits parents’ ability to protect their children. Parents are less able to supervise their children’s activities, implement filtering or blocking measures, or regulate the level of Internet access when children have access to such phones, which is the case for a growing number of kids. This changing pattern of use presents fundamentally different challenges that need to be considered when introducing protection or prevention strategies.

Cultural Barriers

In a traditional society like Pakistan’s, parents and teachers find it difficult to talk about issues such as sex, molestation, and sexual abuse of children because the subject is often tainted with shame and stigma and considered inappropriate. As a result of their silence, children remain vulnerable to OCSEA because they do not know how to cope and react when the perpetrators approach them. It is a common concern that children do not report cases of OCSEA because they are afraid of being blamed or not taken seriously. This is a serious problem that needs to be addressed to ensure that children receive the support and protection they need, instead of facing secondary victimisation. The other dimension of the cultural barrier is that many parents and family elders cannot come to terms with the fact that technology is eroding the traditional boundaries of the family. A father shot dead his 18-year-old daughter in Vano Ghari village in Sardaryab, Khyber-Pakhtunkhwa, after a video of her dancing went viral on social media. So when there is no communication between children and parents and no proper supervision, children can engage in activities that are unacceptable to many in the family.

Unaware of the Harms and Risk sharing Personal Information Online

Clear boundaries used in the physical world to delineate different aspects or contexts of life do not necessarily exist or function in the same way online. Research from around the world has found that young people often feel safer disclosing highly sensitive personal information or engaging in sexualised behaviour online than they do offline. Online platforms, on the other hand, whether chat rooms, blogs, online games or social networks, deconstruct the traditional boundaries of privacy. Children conversing in the privacy of their own bedrooms may knowingly or unknowingly expose themselves to an unknown global audience, which can increase the risk of harm and exploitation. 

Anonymity of Users

Many of the risks children face online stem from the fact that they cannot verify their age and that users remain anonymous on digital platforms. This causes two major problems: first, children interact freely with users of all ages without being aware of the age difference between them and the people they interact with. Secondly, minors may have unrestricted access to content that is inappropriate for their age, such as pornographic or violent content. UK regulator Ofcom warned in October that adult websites with explicit content are not doing enough to protect children. Few bother to do more than ask visitors to self-declare that they are over 18.

Detection of Technology Facilitated Violence against Children is Difficult

Moreover, violence against children perpetrated through the use of technology is more difficult to detect and combat than traditional forms of violence against children. It is challenging for law enforcement agencies to detect suspicious activities, identify perpetrators, investigate and prosecute illegal activities against children when these activities are committed using ICT. This is because technological advances allow internet users to surf anonymously on Tor network based websites and conduct electronic transactions with virtual currencies that cannot be easily regulated by existing laws and regulations.

Additionally, distributors and consumers of the CSAM have developed sophisticated, cross-platform strategies to avoid detection. They often use the most popular platforms to find a community of child abusers to whom they can offer the material in encrypted language. They share links on platforms to material that is visible to everyone, using encrypted language to evade the companies’ detection tools. They then direct interested consumers to more private channels where they can access the material, often via encrypted messaging apps or poorly monitored file-sharing services.

Limited Research and Evidence on OCSEA

Available research on OCSEA is limited in Pakistan. There appears to be no effort to collect systematic, regular and comprehensive data on the magnitude and nature of online and offline child sexual abuse, taking into account the new forms of online threats that children face today. Existing data available from FIA does not reflect the full scale of the problem, as it only focuses on cases reported online.

Inconsistent Application of Security Protocols by Technology Companies

The standards and security protocols of different technology companies are often applied differently. There are new platforms, start-ups and new technologies, for example social gaming and Metaverse. The most important goal for these new platforms is to grow and gain a market foothold. The same applies to new businesses. To achieve this, companies try to attract as many users as possible to their platforms. Therefore, the entry barriers to join the platform are kept as low as possible to ensure a smooth sign-up process. If too many hurdles are added, users will find the cost of trying with uncertain satisfaction levels too high and simply go elsewhere. For this reason, they keep the enrolment process as smooth as possible and forgo pre-screening measures such as parental consent assurances in the background.

Age ratings for apps are inconsistently enforced

The findings of Reviewing the Enforcement of App Age Ratings in Apple’s App Shop and Google Play, conducted by the Canadian Centre for Child Protection (C3P) as part of an analysis of child safety in the two largest mobile app stores, show that app stores are not delivering on their promises to keep young users safe. Age ratings for apps are
inconsistently enforced. For example, on Apple’s App Store, a 13-years old can download apps with a 17+ age rating simply by clicking on a popup window to confirm they are 17+, even though Apple knows the user is 13 based on the age entered in their account. YouTube is rated 17+ on Apple, 13+ (“Teen”) on Google Play and 13+ in YouTube’s terms of service. Both app stores have not been transparent about how they set age ratings for apps, and the content of is inconsistent. For example, in Apple’s App Store has several content descriptions, including “Infrequent/mild sexual content and nudity” and “frequent/intense mature/ suggestive themes”, while Google Play’s content descriptors for YouTube are “user interact” and “digital purchases”

Canadian Centre for Child Protection (2023)

Self Regulation and Voluntarily Measures are not Sufficient

Measures to prevent and detect harmful and explicit content have largely been left to the self-regulation of digital service and platform providers. Voluntary measures to combat OCSEA are fraught with difficulties. Removal of content by social media is usually the result of either an automatic filter or users of a service flagging content they deem inappropriate. Shortcomings in the definition of ‘harmful content’ have led to inconsistent application of terms of use and standards by digital service and platform providers within and between countries. In some cases, human moderators are used to decide whether something should be removed, even though it would be virtually impossible for them to go through every single post on a social network. It may also happen that a moderator cannot determine whether or not a flagged CSAM photo is actually a minor or an adult. In this case, moderators may assume that the subject is an adult. 


Social media platforms are not doing enough

The Centre for Digital Democracy (CDD) finds that social media platforms are still not doing enough to protect children, despite a flood of new safety features in its latest report released in November 2022. The CDD researchers have analysed the strategies of the technology industry. These companies have introduced a flood of new tools, default navigation systems and AI software to improve protection against child sexual abuse material, problematic content and disinformation. However, technology platforms have been careful to ensure that the new safety systems do not significantly interfere with advertising practices and business models that target the lucrative youth demographic. The report concludes that security measures are fragmented and inconsistent. Most of the operations within these social media companies remain hidden from the public, leaving many unanswered questions about how the various safety protocols and youth-friendly policies actually work.

Limited Engagement of Child Protection Agencies

Child protection agencies exist in all provinces of Pakistan and are mandated to respond to and provide support to children who are at risk or in need of protection. Child protection agencies have a very important role to play especially when children come into contact with the law. From discussions with various child protection agencies, it appears that unfortunately there is limited liaison and coordination with the CCW FIA when it comes to cases of OCSEA and that the issue of COP is not yet on their radar. Child protection agencies lack knowledge regarding this issue of online safety, are also significantly understaffed, and face budgetary constraints that deeply affect their work. Many times, they are dependent on support from development partners. 

Poor Awareness and Understanding of OCSEA among Key Stakeholders

Awareness and understanding of the scale and severity of the OCSEA problem remains limited among key stakeholders. The main reason for this is that it is a new area for FIA and child protection workforce in Pakistan. Many people are not at all familiar with the issue, have a poor understanding of the legal framework and do not know how to prevent and respond and what role to play in combating OCSEA. This also applies to lawyers, prosecutors, and judges. The subject is technical and one-off training sessions are not enough. A full fledge multi-sectoral capacity building program is required.

Limited Effectiveness of Helplines

In addition to the “1991” FIA cybercrime reporting helpline, there are a number of other helplines in Islamabad Capital Territory and provinces. The findings show that helplines are poorly linked to the FIA and other referral systems, making it very difficult for them to effectively help victims of OCSEA. Moreover, helplines are often understaffed, have limited access to trained staff and lack the financial resources to be effective.

Mandatory Requirement for Physical Verification

One significant challenge is the mandatory need for physical verification. Although there is an online option to initiate the registration of the complaint, individuals wishing to pursue the complaint need to visit the FIA office in person to have it verified (FIA 2023). This requirement discourages many people from pursuing their complaint. Compounding the issue is the FIA offices have limited geographical coverage, making the process cumbersome for complainants who have to travel outside their city to lodge a complaint. This discourages reporting of incidents at early stages. Efforts should be made to simplify the process of registering complaints and remove barriers that may prevent individuals from seeking justice for online offences of OCSEA.

Lack of Reporting by Victims and/or Families

Discussions with FIA and civil society organisations revealed a general reluctance to report OCSEA. One of the reasons for this reluctance is the shame and stigma associated with child sexual abuse, fear of retribution by the perpetrator, parents, caregivers, family and community members. Many victims and their families prefer to remain silent (FIA 2022). Other reasons cited are the mandatory requirement to verify complaints, lack of confidence in the effectiveness of the reporting system and in the criminal justice system (Digital Rights Foundation 2022), as investigation, and prosecution of child sexual exploitation and abuse cases risks re-victimisation of children if it relies heavily on child victims and their testimony in court and participation in criminal proceedings. This leads to cases not being reported or charges being withdrawn and statements recanted.

The FIA shared with the NCRC details of a case in which a man was arrested for financial fraud (FIA 2022). During a phone search, it was found that the arrested man had repeatedly sexually abused his minor relative and made videos of her. Further investigation revealed that the man had sold these videos on the internet. However, when the case was discussed with the victim’s family, they did not want to press charges as this would bring shame to the family.

Number of NCMEC Cases Investigated is Low

Electronic service providers (Facebook, Google, etc.) refer OCSEA cases to NCMEC and NCMEC forwards these cases to the relevant law enforcement agency for necessary action.

The table illustrates the dramatically low number of OCSEA cases investigated per year in Pakistan, India and the Philippines. In all these three countries, a total of 2,380 cases of OCSEA were investigated per 100,000 reports submitted by NCMEC. This basically shows that a significant number of NCMEC reports on OCSEA seem to disappear into an unregulated, unlawful and uninvestigated black hole. Additionally, each country applies its own national laws when assessing the reported content. It also shows that the FIA is probably unable to cope with the sheer volume of reports it receives.

According to the FIA, apart from the number of cases it receives from the NCMEC, there are also real complications in investigations. For example, when the ECP reports a case to the NCMEC, in many cases the content is removed from the website. The users who uploaded and shared the content are often blocked. This is done from a fake account that is already closed. It is extremely difficult to track down the person. Another problem is that in most cases there is no complainant and it is difficult to find a victim, who in most cases reside outside Pakistan. FIA is in process to gain access to INTERPOL’s ICSE database, which will be useful in investigating OCSEA cases (FIA 2024).

Capacity Issues of Law Enforcement Agencies (FIA and Police)

The first problem is that the FIA has its offices in 15 cities of Pakistan. When cases are reported from outside these cities, it is not very easy for the FIA to act immediately and effectively because of the limited number of officials. The staff is already overburdened with the ever-increasing number of cases. The second problem is that many investigators do not have the necessary expertise or experience to deal with child-sensitive investigations (Digital Rights Foundation, 2022). Technology is constantly evolving, and investigating electronic crimes is a challenge. Therefore, there is a need to strengthen the investigative units under CCW of the FIA, which should provide regular training and orientation sessions for FIA staff and other officials involved in investigations. It is also important to address the issue of vicarious trauma experienced by FIA personnel, which is an important aspect of law enforcement officers’ mental health.

Although 2023 legislative amendments to the PECA 2016 empower the police to take cognizance of OCSEA cases, there is a major challenge – a lack of adequate manpower and expertise within the police force. To effectively combat OCSEA, it is imperative that the police invest significantly in developing the personnel and expertise required to thoroughly investigate and prosecute in this critical area of COP.

Gaps in Laws Enforcement

It is important to note that Pakistan has made significant progress in criminalising various forms of OCSEA, however there are serious gaps in the enforcement of the law. Viewing child pornography is not expressly punishable under law. The deficits lie in systemic challenges with overall weak child protection systems and institutional structures that struggle to effectively coordinate responses to OCSEA. Furthermore, the development of deepfake technology is an example of the need for legislation to constantly evolve as the tools people use to create and share CSAM change.

Lack of a Child and Gender-Sensitive Justice System

A child and gender-sensitive justice system is one that is specifically tailored to the unique needs and perspectives of children, who may have different experiences than adults. Various laws in Pakistan provide for exclusive courts for children in contact and conflict with the law. However only few children’s courts are notified and are not properly equipped to provide effective support and justice to children in accordance with Pakistani laws and acceptable international standards. These include, for example, court procedures that are too complex for children, separate hearings, a lack of specialised resources for child victims and witnesses, and a general lack of sensitivity to the special needs of children in the justice process. The recent amendment to the Qanoon-e-Shahadat Order, 1984 has allowed admissibility of testimonies taken by the court using modern equipment or techniques, but it remains to be seen how and when the court system will actually enforce this. Overall, a system needs to be created that provides child victims with access to justice that respects and effectively protects children’s rights. Whilst very positive and successful examples of specific child courts have been piloted in the country, such models are yet to be consolidated and upscaled. Furthermore, it is necessary to address the issue of vicarious trauma experienced by justice actors involved in child-sensitive cases. They are significantly impacted when confronted with distressing cases of OCSEA without adequate psychological support.

Issues with Jurisdictions and Multiple Legal Systems

Dealing with OCSEA cases is challenging because they are rarely confined to one country or one area to which a particular legal system applies. Determining whether a crime has been committed inside or outside Pakistan’s territory is not straightforward. In complex cases, there may be multiple perpetrators, multiple victims, and multiple platforms, all located in different countries. Crimes, by their very nature, are committed across numerous jurisdictions. This makes the investigation and prosecution of OCSEA crimes particularly challenging, as it raises the question of which country’s laws will be applied to hold perpetrators accountable and what mechanisms should be used to prosecute them. Inconsistencies at both international and national levels in the definitions of OCSEA and the application of terms of use of service providers and platforms have made it difficult to identify and prosecute perpetrators. While some international and national laws and mechanisms exist to establish jurisdiction, the various forms of OCSEA would need to be clearly defined as crimes at the national level and the countries concerned would need to cooperate with each other in prosecuting OCSEA-related crimes.

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