Institutional Framework for Child Online Protection

Child Online Protection is the concern of various ministries and departments, parliamentarians, National Human Rights Institutions (NHRIs), educators, civil society organisations, industry and parents and transcends national boundaries.

Federal Investigation Authority (FIA)

The Federal Investigation Agency is Pakistan’s main national-level agency for investigating federal crimes. These include transnational organized crime, human trafficking, migrant smuggling, cybercrime, money laundering, terrorist financing, intellectual property rights, and electronic and physical bank fraud.

Cyber Crime Wing (CCW)

The Cyber Crime Wing (CCW) of the Federal Investigation Agency is guided by the PECA 2016, which addresses the growing threat of cybercrime. CCW was established in 2007 to identify and curb the phenomenon of technology misuse in society. The FIA receives direct complaints about cybercrimes and takes legal action against those who commit such crimes. The FIA received 84,764 complaints related to cybercrime in 2020 (FIA 2022). Most of the cases the FIA dealt with concern financial fraud. The FIA operates a cybercrime reporting helpline at 1991 and there is an online reporting portal at https://complaint.fia.gov.pk/. Fifteen (15) dedicated Cyber Crime Reporting Centres (CCRC) operate in six different zones of the country. Each circle or CCRC is headed by a Deputy Director who oversees the work of the CCRCs, forensic laboratories and the legal branch, and is supported by a team of investigators, prosecutors, cybercrime analysts, law officers, forensic experts and other support staff. CCW also has a Cyber Alert Service (CAS) to educate the public about cybercrime via SMS. It provides preventive tips on how to combat cybercrime.

The Unit Counter on Online Child Abuse (UCOCA) is a reporting centre set up by CCW as a specialised and dedicated unit to combat online child abuse within CCW Islamabad. UNOCA has designated focal persons in all 15 Cyber Crime Reporting Centres. It also acts as a focal contract for referrals from other countries on OCSEA. UNOCA is also engaged in processing and investigating high priority CyberTipline reports. Due to the high volume of CyberTipline reports, priority criteria are set by specialised investigators based on the CyberTipline reports. INTERPOL’s Child Sexual Exploitation (ICSE) database, is a tool used to advance child exploitation investigations through global information sharing by specialised investigators. FIA is in process to gain access of the database. INTERPOL has completed the initial assessment in 2023 and an MoU has also been signed between the CCW of FIA and INTERPOL.

Police

The mandate of the police is to ensure the safety and welfare of children in their jurisdiction. This includes the prevention, investigation and prosecution of crimes and offences against children. With the recent amendments to the PECA 2016 in 2023, the police in Islamabad and all provinces can now take cognizance of cybercrimes under Section 30. This is an important development as the FIA is not present in all districts of Pakistan. However, the police are obliged to refer the matter to the FIA for a technical opinion and investigation.

Cyber Crime Investigation Unit

In response to the amendment of PECA 2016 in July 2023, Islamabad Police, which can now independently register cybercrime cases, opened its Cyber Crime Investigation Unit at F-6 Islamabad in January 2024 to combat cyber, aiming for a safe digital environment for residents.

Pakistan Telecommunication Authority (PTA)

The Telecom Reorganisation Act, 1996 established the Pakistan Telecommunication Authority (PTA) as the regulatory authority for the telecommunications sector to regulate the establishment, operation and maintenance of telecommunications systems and the provision of telecommunications services. Under the PECA 2016, PTA has been mandated to block or remove unlawful content on the internet and ensure that the provision of telecommunication services is free from content that is harmful to children. PTA for facilitation in instant lodging complaints by public and Government organizations has developed state of art user-friendly complaints lodging mechanism E-Portal & CMS. Access of E-Portal has been given to government organizations including FIA for lodging complaints as per their mandate/areas of expertise whereas for lodging complaints related to Child Online Sexual Abuse “Child Abuse” category has been added in its Complaint Management System (CMS). Also provided emails to lodge complaints about nudity and pornographic content at content-complaint@pta.gov.pk and child pornography at reportchildporn@pta.gov.pk. In 2016, the Pakistan Telecommunication Authority (PTA) had launched a crackdown on pornography on the orders of the Supreme Court and tasked internet service providers with a list of 429,343 domains to be blocked to control the distribution of pornographic material. By December 2023, the PTA successfully blocked 983,089 pornographic or indecent content.

PTA regularly promotes awareness of the responsible use of technology and online safety for children through a variety of initiatives. These include writing articles and publishing public service announcements in national and international newspapers and blogs, conducting digital literacy seminars and programmes for students, teachers and parents in educational institutions, participating in TV and radio programmes to raise awareness and disseminating safety guidelines for parents, teachers and students. PTA also regularly updates its website with recommendations and guidelines for parents, promoting the use of parental control software on mobile devices to prevent cybercrime and providing a list of recommended tools for this purpose.

In September 2023 PTA signed an MoU with TikTok in September 2023 to promote digital safety in government schools across Pakistan, using a multifaceted approach. The initiative features comprehensive training programmes for teachers, parents, and students through a mix of workshops, seminars, webinars, and awareness videos. As part of the programme with TikTok, digital literacy trainings are being carried out in 100 schools across the country in the first phase. Also digital literacy books, guides and toolkits were developed for the training sessions and videos have been released emphasising the responsible use of social media, and mitigation of associated risks. In 2023, the trainings in Sindh and Gilgit-Baltistan were successfully completed.

In October 2023, PTA received recognition for its efforts under category “Enabling Child and Youth Safety Online” at the SAMENA Council International LEAD Award 2023 in the United Arab Emirates by the the SAMENA Telecom Council.

Keep Children Safe Online 

PTA and UNICEF Pakistan joined forces in Islamabad on March 28, 2023, with a commitment to creating a secure online environment for children. This partnership focuses on preventing and reporting online child abuse incidents, fostering responsible internet use through awareness campaigns, and enhancing capacities among children, caregivers, and educators through capacity building programme. As part of the collaboration, PTA implemented various measures, including designating 1121 as a toll-free emergency helpline, contributing to UNICEF’s Child Online Protection KAP survey part of UNICEF’s global ‘Disrupting Harm Programme’, and compiling themes for awareness videos. The ‘Keeping Children Safe Online’ campaign, launched by PTA, emphasised parental controls through diverse media channels.

Source: PTA

The Ministry of Information Technology and Telecommunication

The Ministry of Information Technology and Telecommunication (MoITT) is the focal ministry of the Government of Pakistan responsible for planning, coordinating and directing programmes in the field of information technology and telecommunications. The Ministry has established a Cyber Governance Policy Committee (CGPC) to enforce policy initiatives related to cyber governance and security at the national level and to provide strategic oversight on national cyber security issues.

In 2021, the MoITT launched a “National Cyber Security Policy 2021” to address the incidents related to malicious use of information and communication technologies in cyberspace, which pose a serious financial and security threat to Pakistan. The policy supports the creation of an internal framework in all public and private institutions for the protection of the cyber ecosystem, the security of national information systems and infrastructures, and the protection of all national ICT infrastructures. A major gap in the National Cyber Security Policy 2021 is that the issue of COP and OCSEA is not addressed.

MoITT raises awareness through training for children, which includes cyber safety issues, and has launched a number of digital inclusion initiatives involving vulnerable groups such as girls, children and people with different abilities. Recognising that protecting children online is a global challenge, MoITT organised a successful “ITU-Pakistan Digital Inclusion Week: Meaningful ICT for All’ from 12-13 December 2022 to promote a multi-stakeholder and inclusive approach to digital development. The event included discussions on key topics related to ICT, and two workshops were held on the topic of COP and Girls in ICT.

Child Protection Agencies (Islamabad Capital Territory and Provincial)

Each province and Islamabad Capital Territory have child protection agencies in accordance with their territorial laws to ensure that children have access to a functioning child protection system to protect children from abuse, violence, neglect, and exploitation. These include the Child Protection Institute in Islamabad, the Child Protection and Welfare Bureau in Punjab, the KP Child Protection and Welfare Commission in Khyber Pakhtunkhwa, the Sindh Child Protection Authority in Sindh and the Balochistan Child Protection Commission in Balochistan. Discussion with representatives of the Child Protection Institute and the Sindh Child Protection Bureau in December 2022 revealed that they had not been referred to any OCSEA case by the FIA, nor had they received any complaint from a victim. The Punjab Child Protection and Welfare Bureau does not provide services to the victims of online child abuse as the modus operandi of the Bureau is to first take the destitute and neglected children into its custody and only then provide services to these children.

UNICEF has supported child protection agencies across Pakistan to establish a child protection case management and referral system to provide support services to children, in need of protection including victims of OCSEA, or to refer them to the appropriate agencies so that victims receive appropriate care, protection and rehabilitation, in line with Pakistan’s international obligations.

National Task Force on Prevention and Control of Cybercrimes against Children 

The National Task Force on Prevention and Control of Cybercrimes against Children, set up by Wafaqi Mohtasib, played a very important role in developing strategies to counter OCSEA through two subcommittees: Legal Reforms and Awareness Raising. The Legal Reforms Sub-Committee took the lead in drafting the Criminal Laws Amendment Bill, 2022, which finally came into force in 2023. The Awareness Raising Sub-Committee implemented a strategy involving key stakeholders, education curricula inclusion and media campaigns by the PTA and others. However, the task force is currently dysfunctional and it is strongly recommended that it be reactivated.

Helplines

Helplines play a very important role where victims can lodge their complaints and get advice, and for referring cases to appropriate authorities. The FIA runs a cybercrime helpline numbered “1991”. The Child Protection Institute Islamabad, the Child Protection & Welfare Bureau Punjab, the KP Child Protection & Welfare Commission and the Sindh Child Protection Authority operate a helpline with the same number “1121”. Notably in 2023, the PTA has designated 1121 as a toll-free emergency helpline available to relevant provincial departments overseeing child protection, as well as those in AJ&K and GB.

Civil society organisations also run helplines, such as Digital Rights Foundation, which operates a free cyber harassment helpline “0800-39393”, provide legal advice, psychological counselling and a referral system. Rozan operates a Rozan Counselling Helpline (RCHL) “0304-1111741” and offers counselling services where children and adults can call and share their concerns related to emotional, sexual and reproductive health, violence against women (VAW) and girls, and child sexual abuse (CSA).

National Human Rights Institutions (NHRIs)

NHRIs such as the National Commission on the Rights of Child (NCRC) and the National Commission for Human Rights (NCHR) have a national jurisdiction. Subnational human rights institutions (SNHRIs) such as the Sindh Human Rights Commission (SHRC) focus on addressing human rights issues in the Sindh region. Both NHRIs and SNHRIs have a mandate to inquire and address complaints, including violations of children’s rights.

National Commission on the Rights of Child (NCRC)

The NCRC is a monitoring and oversight body constituted under National Commission on the Rights of Child Act, 2017 having a national mandate for matters related to the promotion, protection and fulfilment of children’s rights throughout Pakistan. The function of the Commission is to review existing or proposed laws and administrative instruments, conduct research, raise public awareness and advise on policy issues affecting children in Pakistan. The Commission investigates violations of the rights of the child and examines any factors that impede the enjoyment of the rights of the child, such as violence, abuse and exploitation, trafficking, torture, pornography and prostitution, and recommend appropriate remedial measures. Complaints can be made by telephone, email, through the website or through the Prime Minister Performance Delivery Unit.

The NCRC has been actively addressing the concern of COP, engaging key stakeholders in discussions, and advocating for robust measures to safeguard children from OCSEA across diverse platforms. This involves establishing a comprehensive knowledge base through research on COP and deploying awareness campaigns. In collaboration with PTA, the NCRC is set to conduct a Knowledge, Attitude, and Practices (KAP) survey under UNICEF’s global ‘Disrupting Harm Programme.’ Additionally, there are plans to initiate training programmes tailored for parents, teachers, and children to enhance awareness and understanding of COP.

Cultivating Digital Competence of Youth and Parents 

In 2023, Zindagi Trust, Meta, Pakistan Telecommunication Authority (PTA), Federal Investigation Agency (FIA) and the National Commission on the Rights of the Child (NCRC) collaborated to launch a digital campaign commemorating Children’s Day. The aim of the initiative, called “Cultivating Digital Competence of Youth and Parents”, was to promote youth safety in digital spaces and initiate a dialogue among youth and their parents about online safety, including reporting negative content such as online bullying, false information, hate speech and spam. The collaborative digital campaign included video messages from students talking about safety tools such as privacy check up, locked profile, hidden words, supervision tools and how to deal with false information. This holistic approach, involving various stakeholders, industry safety partners and law enforcement agencies, emphasises the commitment to keeping young people safe online and promoting a responsible digital culture.

Source: Zindagi Trust

Ministry of Federal Education and Professional Training (MoFEPT)

The Ministry of Federal Education and Professional Training is the federal ministry mandated to develop national cohesion in educational policies and reforms, set educational standards, promote equity and cohesion, achieve universal literacy, coordinate academic assessment across Pakistan, etc. The National Curriculum Council (NCC) was established in 2015. The ministry is leading the development of a National Curriculum for Pakistan (formerly known as the Single National Curriculum) that covers four aspects of a quality curriculum, including standards, textbooks, teacher training and examination reforms. The curriculum focuses on life skills and pays some attention to child protection, and the MoFEPT plans to include cyber-bullying in the curriculum (ACTED 2022). Overall, the Ministry has a very important role to play and the curriculum must include the topic of COP, which should also address OCSEA and provide a reporting mechanism and training modules for teachers to teach students about safe and responsible online behaviour. The Ministry should also raise public awareness about the importance of online safety for children.

Federal Ministries and Provincial Departments

The Ministry of Interior is the administrative ministry of the FIA and the Islamabad Capital Territory police. It is primarily responsible for internal policies, the security of the state, the administration of the internal affairs of the state and the support of the government in territorial matters.

The Ministry of Human Rights at the federal level is the parent Ministry of the Child Protection Institute, mandated to establish and strengthen the necessary institutional mechanisms for the protection and promotion of human rights. The Ministry of Human Rights has launched a five-year National Action Plan on Human Rights and Business (2021-2026), which includes specific actions related to children’s rights, but does not specifically address the issue of OCSEA.

Provincial departments such as Home Department, the Department of Social Affairs and the Department of Human Rights are important stakeholders in the administration of law enforcement and child protection agencies and have overarching roles and responsibilities.

eSafety Commissioner 

The eSafety Commissioner (eSafety) is Australia’s independent online safety regulator with a shared goal of making the online experience safer and more positive for Australians. It is the world’s first government agency dedicated to keeping people safe online. It began operations in 2015 as the Children’s eSafety Commissioner and is now at the forefront of the fight against online risks and harms faced by both adults and children. The eSafety team consists of educators, investigators, lawyers, policy analysts, technology experts, digital specialists and other professionals.

UN Agencies

United Nations Children’s Fund (UNICEF)

UNICEF is mandated by the United Nations General Assembly to advocate for the protection of children’s rights, to help meet their basic needs and to expand their opportunities to reach their full potential. UNICEF advocates for online safety and advocates for necessary laws and regulations, and promotes the use of acceptable safety measures to protect children from violence, abuse and exploitation in the digital world.

In Pakistan, UNICEF is playing a leading role in the fight against OCSEA. UNICEF is implementing a five-year country programme 2023-2028, in which COP is one of the priority areas. With a multifaceted approach, UNICEF has contributed significantly to the legislative reforms which led to amendments of the PECA 2016. In collaboration with key institutions such as the Pakistan Telecommunication Authority (PTA) and the National Commission on the Rights of Child (NCRC), UNICEF is involved in developing a knowledge base and raising awareness through different mediums. At provincial level, the organisation works with child protection authorities to establish a child protection system tor case management and referral system. UNICEF is also supporting the telecommunications company Telenor in Pakistan with capacity building and awareness-raising initiatives to promote online safety among children.

International Telecommunication Union (ITU)

The International Telecommunication Union (ITU) is the United Nations specialised agency for ICT. ITU supports all relevant stakeholders in their efforts to create a safe and empowering online environment for children and young people, enabling them to fully exercise their rights. COP is an initiative launched by the ITU in November 2008 as part of the Global Cybersecurity Agenda (GCA) to protect children worldwide from cyber threats89. ITU supports States in developing, adopting and implementing national frameworks and comprehensive strategies to COP, conducts research and provides awareness and capacity building for stakeholders.

International Criminal Police Organization (INTERPOL)

The International Criminal Police Organization, commonly known as INTERPOL, is an intergovernmental organisation with 195 member countries designed to facilitate the widest possible mutual assistance among all law enforcement agencies and to ensure that police services around the world can communicate securely with each other.

INTERPOL’s Child Sexual Exploitation Database 

INTERPOL’s child sexual exploitation image and video database is an intelligence and investigative tool that enables specialised investigators to share data on child sexual abuse cases. By analysing the digital, visual and audio content of photos and videos using image and video matching software, investigators can instantly make connections between victims, abusers and locations. The database avoids duplication and saves valuable time by letting investigators know if a series of images has already been discovered or identified in another country, or if it has similar characteristics to other images. It also allows specialised investigators from more than 68 countries to exchange information and share data with their colleagues around the world. This database contains more than 4.3 million images and videos and has helped identify more than 30,000 victims worldwide (Interpol 2022).

Civil Society Organisations

NGOs, INGOs and the media play a very important role in promoting COP and children’s safety agenda. They are not only watchdogs, but also raise awareness about the harms and dangers of ICT on children. The Digital Rights Foundation, for example, is a research-based NGO that focuses on ICT to support human rights, digital governance and democratic processes. Sahil monitors child sexual abuse cases, including victims of OCSEA. Zingadi Trust conducts digital safety workshops in schools and has also organised seminars to raise awareness on safe internet use. There are other examples of good work being done by different CSOs in Pakistan.

ECPAT is one of the leading INGOs working internationally on COP. Other organisations include Child Rights Connect, Save the Children, International Centre for Missing and Exploited Children (ICMEC), Terre Des Hommes, Plan International, etc.

WeProtect Global Alliance

The WePROTECT Global Alliance is an international alliance that works globally to end the sexual exploitation of children online. The Alliance is registered as an independent organisation. It brings together governments, law enforcement agencies, civil society organisations and private sector companies to share information and coordinate efforts to identify and protect victims and prosecute perpetrators. A Model National Response (MNR) developed by the Alliance helps countries establish and implement a coordinated national response preventing and tackling online child sexual exploitation.

A Model National Response (MNR)

South Asia Initiative to End Violence Against Children (SAIEVAC)

Pakistan is a member of the South Asia Initiative to End Violence Against Children (SAIEVAC), a regional network of government agencies, civil society organisations and other stakeholders working to end all forms of violence against children in South Asia, including child sexual abuse and exploitation.

Private Companies

There are a number of companies providing information and communication technology services, including mobile operators, internet service providers, telecommunication companies, user-generated content and social media providers, data hosting companies, etc., that play an important role in the field of COP.

Telenor, one of the leading telecommunications companies in Pakistan, partnered with UNICEF in 2022 to promote safe and responsible internet use among children, caregivers and educators through awareness raising and capacity building and plans to train 750000 individuals using a hybrid training module.

Facebook, Google, Microsoft, Yahoo, Tiktok, etc. have blocked hundreds of keywords related to child sexual abuse material on their platforms. Social networks, messaging platforms and search engines such as WhatsApp, Facebook, Twitter, Instagram, Flickr, MySpace and Google block and report offensive and abusive material through filters, privacy settings and complaint mechanisms. Since 2011, many social media platforms have used Photo DNA technology to scan every uploaded photo and control the spread of child sexual abuse material. Search engines such as Google, Yahoo and Bing also block searches for illegal material to control the distribution of such videos, photos and content, and use splash pages to warn users when they are about to access illegal or harmful content.

In 2021, Apple had announced a plan to scan photos stored by users in iCloud for CSAM. The tool was meant to be privacy-preserving and allow the company to flag potentially problematic and abusive content without revealing anything else. But it soon came under criticism because the surveillance capability itself could be abused to undermine the privacy and security of iCloud users around the world. In early September 2021, Apple announced that it would pause the rollout of the feature. However, in December 2022, company says it is discontinuing the CSAM detection tool for iCloud photos in response to the feedback and advice it has received. Instead, Apple is now focusing its anti-CSAM efforts and investments on its “Communication Safety” features to stop child exploitation before it happens or becomes entrenched, and reduce the creation of new CSAM.

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The objective of this portal is to provide authentic information on the issues and challenges faced by children in Pakistan, especially to key stakeholders on the impact and magnitude of the problem, institutional arrangements and recommendations for action. >>more

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