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Age verification consultation response: Evidence of harm

Posted at 20:59 on 14 Apr 2016 by Pandora / Blake

Tags: age verification, AV consultation, censorship, child safety, DCMS, Ofcom, politics, porn, R18 material, young people

I recently responded to a Government consultation proposing mandatory age verification for porn - not only within the UK, but worldwide. This is an expanded version of my response, the first of several posts. Before the deadline, I posted a list of key bullet points; if you want an at-a-glance view of why these proposals are a bad idea, that's a good place to start.

In this first section, I look at the evidence to see whether it supports the proposal's assertions that a lot of children are looking at online porn, and that doing so causes them developmental harm. These claims pop up again and again, often accompanied by the same shoddy statistics and debunked studies; this isn't the first time we've needed to challenge them, and sadly I don't think it will be the last. My hope is that if we share resources, it will make it easier to marshal our arguments next time.

From: Pandora Blake

To: AVconsultation@culture.gov.uk

Having responded to your online survey I wish to expand on my answers, as the space for doing so within the questionnaire was extremely limited. Government consultations usually solicit extended responses from individuals and organisations, asking open-ended questions that encourage dialogue and discussion. Your survey relies heavily on leading questions, and leaves no space for respondents to submit evidence, discuss the issues, or question the premises on which the proposed regulatory framework is based. This goes against the spirit of a public consultation, and makes it seem as if consultation is in this instance merely a pro forma exercise intended to pay lip service to soliciting the views of the public, rather than genuinely aiming to gather and consider differing viewpoints.

From the perspective of someone educated to post-graduate level, I find the proposals to be based on a flimsy, wishful reading of the evidence that does not stand up to academic scrutiny. I am also a creator of erotic media and worker in the adult industry, who stands to be personally affected by these proposals. I am responding as an individual, expressing my own views and not those of any institution or organisation.

Pandora Blake


The proposals to mandate the installation of age verification systems on websites serving adult material are unjustifiable, unworkable and unrealistic. Evidence gathered by the expert panel for DCMS in November 2015, and Ofcom's overview of the potential impact of R18 material from May 2005, show clearly that there is no robust evidence to prove that young people are harmed by encountering explicit images online. On the contrary, the evidence suggests that greater access to pornography is correlated with healthier societal attitudes towards sex and lower rates of sexual violence.

A new regulatory framework with scope to force technological compliance on websites worldwide must be based in rigorous empirical evidence. The potential harms of the proposed legislation are manifold: loss of individual privacy; credit card fraud and identity theft; increased state surveillance; misuse of data by the state or private companies; embarrassing data leaks; adults prevented from viewing legal materials; infringements to freedom of expression. The evidence simply is not strong enough to support legislative intervention on this scale, and the proposals seem to be founded more on ideology and party policy than on evidence and harm reduction.

While a case can be made for the worrying social impact of sexism in entertainment media, mainstream film and TV are far bigger culprits than online pornography, and far more likely routes for under 18s to view sexual imagery. The UK's poor record on sex education is well documented, and government time and funding would be far better spent on addressing this.

These proposals are an unrealistic, aggressive piece of posturing that seek to extend already failing attempts at censorship and control beyond UK borders. The proposed regulatory framework is not evidence-based, will not be effective at reducing harm, and will increase surveillance and censorship in the UK at the expense of privacy and freedom of expression.

Evidence of harm

Few will disagree that it is important to keep children safe online. The question is what harm reduction methods the evidence supports. Legal reform must be based on clear, peer-reviewed evidence, and not on ideology or unreliable statistics.

Child safety is an emotional issue, and it is all too easy to allow fears and strength of feeling to overwhelm the evidence and prevent a proper analysis of how best to reduce the risk of harm. If research is being used to justify legislative reform on the scale of these proposals, the methodology and conclusions must stand up to academic peer review in a way that the evidence cited simply does not.

There is not sufficient evidence to support the premise, on which the entire proposal is based, that encountering online pornography is harmful to under 18s. In 2005, Ofcom commissioned an overview of the evidence, looking specifically at the impact on under 18s of viewing "R18" classified material; that is, explicit depictions of sexual intercourse between consenting adults. This independent research was commissioned by Ofcom from Ellen Helsper, London School of Economics, with a view to investigating whether to retain the ban on broadcasting R18 content on UK television.

The report found that there isn't much evidence on the impact of this sort of content on under 18s at all. It states, "Due to ethical restrictions, there is a severe lack of research regarding the effects of exposure of minors to R18 pornography which contributes to the evidence being inconclusive." The Department for Culture, Media and Sport itself referenced this lack of evidence in the Explanatory Memorandum to the Audiovisual Media Services Regulations 2014, but goes on to say that the AVMS magically "removes uncertainty" by legislating to restrict access to R18 material despite the lack of justification for doing so.

Ofcom's 2005 report states conclusively that "there is no empirical research that proves beyond doubt that exposure to R18 material seriously impairs the mental or physical development of minors". In fact there is more evidence that availability of porn is correlated with harm reduction, healthier attitudes towards sex, and lower rates of sexual violence: Ofcom found that "there is some evidence for a positive effect of R18 material and young people; exposure to pornography at a younger age and a less restrictive parental environment seem to be related to a lower likelihood of committing sex crimes (Becker & Stein, 1991; Gebhard et al., 1965; Heins, 2001; Kelley, 1989)." Ofcom's overview clearly shows that pornography is correlated with lower rates of sexual violence, higher reporting of sex crimes, and does not demonstrably cause harm to under 18s who view it. 

The consultation's reference to one 2011 study, that found a link between adolescents deliberately seeking out violent pornography and reporting sexually aggressive behaviour, is unconvincing. A 2013 analysis which references this study found that while individuals predisposed to sexualised violence might be influenced by viewing pornography, for better or for worse, individuals without this predisposition are likely to be unaffected. The same study cited by the consultation also found no link between viewing non-violent pornograghy and sexual aggression among youth; and no link between viewing pornography and risky sexual behaviour. These facts were for some reason not considered worthy of inclusion in the consultation.

Ofcom's report concludes:

There seems to be no relationship between the availability of pornography and an increase in sex crimes in other countries; in comparison there is more evidence for the opposite effect.

Research with adults indicates no relationship between the commission of sex crimes and use of pornography at an early age. Again in comparison there is evidence for the opposite effect.

Given the lack of evidence that viewing pornography might "seriously impair" the development of under 18s, there is not sufficient justification to restrict access to it. There is no evidence that children might be seriously impaired by viewing pictures of purple bananas either, but that isn't reason to ban them. Continuing to believe that an entertainment genre causes harm in the face of evidence suggesting otherwise reveals ideological bias; in this case almost certainly rooted in inherited cultural and religious anxieties about sex.

The consultation makes frequent use of statistics that do not stand up to scrutiny. For instance, the proposal's reading of "the scale of the problem" (p7) relies on misleading statistics that have been cherry-picked from the DCMS evidence, such as:

1.4 million unique visitors under 18 accessed adult sites from their desktop. This represents c.20%, roughly one fifth of under-18s accessing the internet. 13% of children aged 6-14 visited an adult site in May 2015.

It is easy to generate high-sounding percentages of the number of children accessing pornography by tweaking the age ranges to group young children in with older teenagers. The comScore statistic of "20%" includes depictions of violence, not just sexual images, in its definition of "adult content"; it also includes older teenagers above the age of consent for sex. This deliberately gives the misleading impression that one fifth of younger children (aged 6-11) are looking at R18 equivalent material online. However, this is demonstrably untrue. 

If we look at the figures for younger children and older teenagers separately, we find that most of the under-18s accessing online pornography are those already old enough to have sex. The evidence presented by the expert panel for DCMS shows that in fact, only 1% of 9-10 year olds and 3% of 11-12 year olds name online porn (on video sharing platforms and in popup ads respectively) as means by which they encountered sexual images, if at all. Ofcom's report on Internet Safety Measures finds that "the majority of 5-7s and 8-11s say they spend most of the time using the internet with an adult in the room (85% and 69% respectively)"; it is also worth noting that "a majority of 8-11s (61%) say they only visit websites they've visited before". The fear that young children who are not yet ready to look at sexual imagery are frequently and accidentally stumbling across it online is unfounded.

If under 18s are looking at too many sexual images, the internet isn't even the problem; children are far more likely to encounter sexual imagery offline than online. The 2010 EU Kids Online survey of UK 9-16 year olds and their parents found that although one quarter of UK 9-16 year olds say that they have seen sexual images in the past 12 months, only 11% encountered those images online. More 9-16 year olds are seeing sexual images in films and TV, magazines and books than on the internet.

A minority of online content is sexually explicit – among 11-16 year olds, 11 per cent have seen nudity, 8 per cent have seen someone having sex, 8 per cent have seen genitals, and 2 per cent have seen violent sex. 

According to the EU Kids Online report, 2-8% is a much more realistic assessment of the number of 9-16 year olds who have seen R18 content online; and most of those teenagers are at the older end of that age bracket. This undermines the consultation's claim that 13% of 6-14 year olds have looked at online porn. 

Likewise, the consultation makes frequent claim that many under 18s are upset or worried about online pornography, citing the widely discredited NSPCC Childline statistic that "1 in 5 of children aged 11-17 surveyed said they'd seen pornographic images that had shocked or upset them". This survey was conducted by a marketing company called OnePoll, which describes itself as a specialist in commissioning "heartbreaking, random and shocking" content. It has been debunked by experts and academics for many reasons, such as lack of ethical safeguards, biased sample selection and over-reliance on leading questions.

Professionals such as OnePoll are adept at eliciting the answers required by the commissioning party. When interviewing children about sensitive topics, it’s good practice to have face-to-face interviews, safeguards to ensure privacy and an assessment of general state of mind. Not brief online surveys (most likely competed in front of parents – who are paid – but who’s checking?) filled with leading questions such as: “On average, how often do you watch porn?” or “Do you ever worry that you might be addicted to porn?”

An open letter to the NSPCC signed by over 30 leading academics, journalists and sex educators was published last year contesting the survey's methodogy and results. Hardly robust evidence that provides adequate justification for legislative reform.

By contrast, the EU Kids Online' study finds that "Overall, most children have not experienced sexual images online and, even of those who have, most say they were not bothered or upset by them", and concludes:

While public concern over online sexual content is justified, the extent of children’s exposure should not be exaggerated, and nor should it be assumed that all children are upset or harmed by such exposure – the present findings do not support some of the moral panics surrounding this issue.

Recent research by Ofcom into child internet safety found that actually, the number of children seeing shocking or upsetting things online has decreased; "The incidence of children disliking seeing things online that are too old for them, or things that make them feel sad, frightened or embarrassed, has decreased since 2012 for both 8-11s (15% vs. 23%) and 12-15s (10% vs.15%)".

The "concern" about porn shown in the studies cited in the proposal reflects adult relationships with pornography, which is projected onto young people more than it is shared by them. UK academics Dr Clarissa Smith, Dr Feona Attwood and Dr Martin Barker recently published preliminary findings on a survey of 5,490 people who look at porn. They found that:

The peak period for viewing porn appears to be older than many people assume. The peak age for extreme and high importance for viewing porn is 26-35, while the age at which it has the lowest importance is 18-25. That's really interesting! It suggests to us a generational shift in the significance of pornography.

Thanks to the Porn Research project we also have recent evidence on the subjective experience of the minority of under 18s who do deliberately seek out and view porn. 97 respondents to the Porn Research survey (1.8%) identified themselves as being in the "under 18" age bracket, although under 18s had not been been directly targeted in the research. Young people cited "because I feel horny" as the most common reason for searching out porn, and were less likely than older age groups to look at porn frequently, or consider it have importance in their lives; "I don’t take it seriously but it’s pretty nice" was a common reaction. Reasons for looking at pornography varied widely within the under 18 respondents, from "It’s too soon for a sexual relationship" to "I’m just curious and still exploring myself".

Dr Clarissa Smith takes issue with the tendency to view under 18s as vulnerable and indiscriminating viewers who might easily be harmed by looking at porn. Some young respondents reflected and mocked this rhetoric with satirical answers, playing knowingly on the discourse that sees porn as damaging, and themselves as helpless victims. Smith writes,

Even if a proportion of our respondents gave these 'defiant' and 'rejecting' answers, they do so at some length, indicating a real desire to have their say on the topic. In this, these challenging answers correspond with the majority of the responses we received from the under-18s - far from being unthinking, uncritical and unreflexive 'victims' of pornography, these young people gave lengthy responses, demonstrating their own awareness of themselves as engaging in sexually explicit materials, how those materials might fit with their experiences in this stage of their lives and their understanding of themselves as often excluded from discussion on the basis of their supposed lack of experience.

Despite the lack of evidence, the consultation makes repeated assumptions about the "harms" of porn. For instance it claims, "When young people access this material it risks normalising behaviour that might be harmful to their future emotional and psychological development." (p4)

This is only provably true if increased openness to sexual activity is defined as harmful. Ofcom's overview of the evidence (2005) unpacks this: "There is some evidence that indicates that sexual material influences the moral development of young people under the age of 18. In other words, that through exposure to pornography young people become more cynical towards traditional relationships (marriage) and become sexually active at a younger age." It is perfectly possible for young people to engage in sexual activity in a consensual, healthy way. Defining sex positivity and cynicism about marriage as evidence of "developmental harm" is rhetoric that belongs in a religious tract, not evidence-based legislative policy.

The consultation is rife with loaded language. Dr Martin Barker highlights the use of the word "exposed" in rhetoric about pornography as revealing a series of deeply embedded assumptions, citing 66 uses of this wording in the UK Children's Commissioner's Rapid Evidence Assessment on the state of research into children's experiences of pornography (Horvath et al, 2013). The phrase appears 27 times in the consultation, carrying unsubstantiated implications of an escalating, corrupting relationship with pornography which is not borne out by the evidence. Barker writes:

The fact that such a way of conceiving how people encounter sexual or indeed any other kinds of materials was long ago questioned passes them by completely - an ignoring nicely in line with the REA's dismissive attitude towards research which showed that, where young people do look at pornography, the motives for doing so range from 'masturbation', to 'wanting to know more about sex', to 'curiosity', and 'boredom'. Such motives for looking don't fit well with the working model of cumulative effect, corrupting influence, and slippery slope to doom, all of which is set in motion by that word 'exposed'. (Barker, forthcoming)

Shoddy statistics and exaggerated claims have always been at the heart of panics about pornography. The reliance of the proposed regulatory framework on rhetoric over evidence is indicated by conclusions from the DCMS report, which finds insufficient proof of harm, but makes it clear that the UK Council for Child Internet Safety have no intention of letting lack of evidence get in the way of implementing a Conservative Party manifesto promise:

The policy position underpinning this project specification is that pornography causes harm to children and we understand that we are not expected to challenge this. [emphasis mine] However, we would like to emphasise that the relatively limited academic evidence of harm means that any policy interventions should proceed on the basis of a precautionary principle, namely seeking to avoid possible risks in the absence of certainty.

The very evidence commissioned by this project shows that online porn is not the primary route by which under 18s access sexual images; when they do find it, they are mostly not distressed or concerned by it; and there is no proof that it causes harm. The evidence cited by these proposals therefore does not support its conclusions: the proposed regulatory framework is an example of policy informing evidence, rather than evidence informing policy.

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