133 civil society groups call on the EU to withdraw the CSA Regulation and pursue alternative measures that are more likely to be effective, sustainable and fully respect EU fundamental rights. The open letter's signatories include organisations working on children's digital rights, children's health, support for victims of online abuse, as well as the empowerment of girls and women.
Increasing awareness of and access by young people to hotlines, institutional reporting (police, social services and other authorities), and support mechanisms. Such demands have long been made by child protection organisations;
In Germany, one of the largest vaults of abuse imagery ever discovered stayed online for years because police reported not having enough human resources to take it down. Yet it took journalists investigating the issue just a couple of days to fully remove the content. Other Member States face similar issues, from the problem of closed institutions in France, to the overburdened police and public prosecutors in the Netherlands and Belgium. Structural solutions would ensure that the right authorities have the right resources to tackle the vast numbers of CSA cases that they are already unable to deal with;
Increasing both EU and national funding to hotlines, ensuring a proper legal basis for their work, and committing funding further in advance, would boost the capacity and reduce the precariousness of these vital organisations who already remove vast amounts of CSAM from the internet quickly and effectively, and also provide support to survivors;
The 2011 EU Child Sexual Abuse Directive contains many provisions requiring Member States to do more to tackle child sexual abuse on a national level, and worryingly, it has not been implemented fully despite being in force for over 11 years. The DSA further offers many new opportunities to tackle illegal content online, including CSAM;
"Abuse will continue if the root causes that allow it to exist in the first place are not challenged", we learn. The Centers for Disease Control and Prevention (CDC) advises that "Effective evidence-based strategies are available to proactively protect children from child sexual abuse, but few have been widely disseminated";
Bringing child rights groups, educators, social workers, digital rights groups, other human rights groups, will help us answer the real, pressing question: how can we keep children safe while fully upholding fundamental rights?
The CSAR lacks a sufficient legal basis, contradicts substantial portions of EU law, in particular fundamental rights law; adds significant complexity to existing processes which could hamper current national efforts to remove CSAM; and is technically impossible for service providers to implement in a way that respects rights and is effective to achieve its stated aims.
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