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Online Safety Bill – Letter to Bristol MPs

Letter sent to all Bristol MPs on 20 April 2023

We write to you as leaders of diverse women-led and other equalities charities and groups in Bristol. Between us we support, work with, and represent thousands of Bristol-based women and girls every year, including survivors of all forms of male violence.

We write to urge you to support moves to strengthen the content of the Online Safety Bill to include a mandatory Violence Against Women and Girls (VAWG) Code of Practice.

VAWG impacts the lives of thousands of women and girls every day, and online abuse is part of this continuum. Online abuse can be a key part of domestic violence and stalking, with perpetrators using the hacking devices, and deepfakes as part of their abuse. Girls and young women are particularly at risk of cyber-flashing, one study found more than one in five girls had experienced this within the last year, [1] causing significant stress and anxiety for many. Another found 76% girls aged 12-18 have been sent unsolicited penis images.[2]

As you know, and may also have experienced, high-profile women, including Parliamentarians, are disproportionately likely to be impacted by online abuse, much of which is highly gendered, misogynistic, often racist in nature, and which, at its most extreme, involves threats of violence: 93% of women MPs report online abuse impacts negatively on their feelings about the job (compared to 76% of men); 73% of female MPs agreed that they ‘do not use social media to speak up on certain issues because of the abusive environment online’ (compared to 51% of men). [3]

We cannot tackle male violence against women and girls without addressing online abuse.

End Violence Against Women (EVAW) and other women’s safety specialists, have highlighted how the Bill in its current format does not prevent misogynistic influencers, like Andrew Tate, exploiting the lack of regulation online to promote toxic and dangerous ideas to gain popularity, widespread circulation and income. Their content is often promoted to individuals via algorithms without users seeking it.[4] Tech platforms profit immensely from such abuse, [5] and it is schools, colleges, policing, mental health services and ultimately, women and girls who are left to pay for the consequences.

The Government’s decision to place the onus on users to manage their content through the removal of adult safety duties on ‘legal but harmful’ content, rather than adopting a consent-based approach to cyber-flashing, which we feel would be a more practically and ethically robust and straightforward way of preventing and prosecuting harm,[6] leaves women further exposed and weakens the protections for children, particularly teenage girls, from this type of content. As the Bill currently stands, the onus now lies with women and girls to use ‘user empowerment tools’ to ‘filter’ out such content and abuses such as those promoted by Andrew Tate.

The “priority illegal content” contained in the Bill covers some offences which disproportionately impact women, such as stalking, harassment and the recent addition of coercive and controlling behaviour. However, there is no requirement on tech companies to make the connections between these disparate offences.

End Violence Against Women have partnered with other specialist agencies to create a VAWG Code of Practice[7] which provides a practical solution to these ills. The Code provides guidance to tech companies about best practice to prevent and address online VAWG in a holistic way. 

We call on you to advocate implementation of this as a mandatory code, to be enforced by OFCOM. This form of regulatory guidance will place tackling online VAWG on par with tackling Child Sexual Exploitation and Terrorism and will act as a similarly strong signal to tech companies that they also need to prioritise action to address VAWG online beyond taking down material that meets the threshold of a criminal offence.

This will only be effective if the Government amends the Bill to ensure that such a Code Such a Code of Practice would provide a clear route to compliance for companies to address VAWG, creating flexible standards which support both platforms and OFCOM, in their regulatory role and enforcement.

We know there is strong public support for greater measures for the Online Safety Bill to better protect women and girls online, as has been demonstrated in the volume of signatures on a petition calling for greater protections, which have amassed more than 100,000.[8]

Bristol women understand that a mandated VAWG Code of Practice has cross-party support across both Houses, consensus from the Women and Children’s sector, and support from the Domestic Abuse Commissioner.[9] We are now writing to you to ask for you to take all action possible to ensure that the commitment to tackling VAWG is a priority within the Online Safety Bill.

Yours sincerely,

1.          Katy Taylor, Director of Bristol Women’s Voice

2.          Claire Bloor, CEO of Somerset and Avon Rape and Sexual Abuse Services

3.          Kyra Bond, CEO of Womankind

4.          Alex Raikes Director (Strategic) of Stand Against Racism & Inequality

5.          Layla Ismail, Development Manager of Refugee Women of Bristol

6.          Jenny Riley, CEO of One25

7.          Penny Gane, Chair of the Bristol Women’s Commission

8.          Naomi Salisbury, Director of Self Injury Support

9.          Maria Viner, CEO of Mothers for Mothers

10.       Suad Yusuf, Founder and Director of Somali Kitchen

11.       Rosa Hui, Director of the Chinese Community Wellbeing Society

12.       Aneta Mackell, Founder and CEO of Opoka

13.       Camilla Rigby and Rachel Mostyn, Co-founders and Directors of Women’s Work Lab

14.       Dr Helen Mott, sexual harassment specialist and gender equality adviser. Commissioner – Bristol Women’s Commission


[1] Robert Booth (2022) ‘Fifth of young women and girls ‘cyber-flashed’ in past year, UK study reveals’ The Guardian

https://www.theguardian.com/society/2022/feb/09/online-sexual-abuse-cyber-flashed-young-women

[2] Clare McGlynn (2022)  A proposed new law criminalising cyberflashing is welcome – but it has one major flaw’, The Independent https://www.independent.co.uk/voices/cyberflashing-new-law-online-safety-bill-b1888633.html

[3] Fawcett Society (2023) A House for Everyone: https://www.fawcettsociety.org.uk/Handlers/Download.ashx?IDMF=66b6464e-44cb-4178-9fe3-aef1ca9cc4f6

[4] The Times (January 2023) Social media companies profit from misery spread by misogynistic influencers: https://www.thetimes.co.uk/article/social-media-companies-profit-from-misery-spread-by-misogynistic-influencers-6bzbd2g23

[5] Centre for Countering Digital Hate (2022) YouTube rakes in millions in ad revenues from videos of misogynist, Andrew Tate: https://counterhate.com/blog/youtube-rakes-in-millions-in-ad-revenue-from-videos-of-misogynist-andrew-tate/

[6] Why a Consent-Based Cyberflashing Offence will be More Straightforward, Comprehensive and Effective than the Current Proposal in the Online Safety Bill Professor Clare McGlynn QC (Hon), Durham University

[7]  This Code has been developed by End Violence Against Women Coalition, Glitch, Refuge, Carnegie UK, 5Rights, NSPCC, and Professors Lorna Woods and Clare McGlynn.  

[8] Change.org: The UK’s new Online Safety Law must protect women and girls from abuse: https://www.change.org/p/michelledonelan-the-uk-s-new-online-safety-law-must-protect-women-girls-from-online-abuse?utm_source=share_petition&utm_medium=custom_url&recruited_by_id=edbbec10-4ed1-11ec-b3af-61242eaf65fa

[9] Commissioner calls for Online Safety Bill to be more robust when it comes to domestic abuse and violence against women and girls: https://domesticabusecommissioner.uk/blogs/commissioner-calls-for-online-safety-bill-to-be-more-robust-when-it-comes-to-domestic-abuse-and-violence-against-women-and-girls/

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