DDPOs response to consultation on Government’s online harms white paper

Stay Safe East, on behalf of the London DDPO Hate Crime Partnership, have responded to the Government’s online harms white paper

On 8 April 2019 the Government published an Online Harms White Paper which set out government proposals to make companies more responsible for their users safety online, especially children and other vulnerable groups. A consultation followed and a response has been written by Stay Safe East, on behalf of the London Deaf and Disabled People’s Organisations (DDPO) Hate Crime Partnership.

The Online Harms White Paper

The Online Harms White Paper sets out the government’s plans for a package of online safety measures. It includes legislative and non-legislative measures and will make companies more responsible for their users’ safety online, especially children and other groups that can find themselves in vulnerable situations, including Disabled people.
The White Paper proposes establishing in law a new duty of care towards users, which will be overseen by an independent regulator. Companies will be held to account for tackling a comprehensive set of online harms, ranging from illegal activity and content to behaviours which are harmful but not necessarily illegal.
The consultation ran from 8 April to 1 July, asking for submissions on the proposed plans, which included:

  • the online services in scope of the regulatory framework;
  • options for appointing an independent regulatory body to implement, oversee and enforce the new regulatory framework;
  • the enforcement powers of an independent regulatory body;
  • potential redress mechanisms for online users; and
  • measures to ensure regulation is targeted and proportionate for industry.

Inclusion London submitted evidence on behalf of the London DDPO Hate Crime Partnership, following a consultation with its members to highlight the specific issues concerning Disabled people, including Disabled children.

Our key recommendations

The key recommendations in the submission are:

  • A Regulator is set up with a specific duty to ensure the online safety of specific groups, including people with protected characteristics.
  • The regulator will have the power to require non-UK based companies to appoint a nominated UK representative who is accountable for the actions of their company.
  • The Regulator’s staff receive disability equality training to understand the specific forms of online abuse against Deaf and Disabled people, including hate crime.
  • Introduction of a duty of care on companies with properly resourced legal enforcement.
  • Social media companies have a proactive duty to prevent harmful content


  • The legal enforcement should include the imposition of substantial fines if harmful online material is not removed within 24 hours after notification.
  • Business activities of social media companies are disrupted for very serious breaches.
  • Social media companies have a legal duty to support law enforcement agencies in bringing criminals to justice.

Organisations supporting complainants

  • Specific organisations are registered and publically funded to take forward ‘super complaints’.
  • A well-resourced and funded independent body is set up to provide give support to people at risk to report online harms.
  • Social media companies should fund support for complainants and the registered ‘Super complaint’ organisations. The monies obtain through fines should also be used to fund this support.

Clear legal terms

  • The terms ‘illegal, unacceptable and offensive’ are clearly defined in the legislation.
  • The term ‘accessible’ is clearly defined in the legislation.
  • The definition of ‘online harms’ includes the following:
    • Harmful materials
    • Incitement to hate crime, including on grounds that are not currently covered by the law e.g. Disability, transphobia, misogyny
    • Adult safeguarding – online grooming of adults at risk for financial or sexual abuse
    • Targeting for ‘cures’ (LGBT, Deaf and Disabled people)
    • Abuse targeted at Deaf and Disabled people
    • Trafficking
  • The online harm to Deaf and Disabled people is fully addressed by the legislation.

We also represented the London DDPO Hate Crime Partnership at a Disabled Round Table Event in June 2019 with the Home Office and social media companies to discuss in more detail what social media platforms can do to support Disabled people to tackle Hate Crime and abuse online, in relation to the White Paper. We will continue to be consulted on this issue over the coming year and will continue working with the Home Office to ensure Disabled people feel safe online.

Download our full response

You can download our full response here.

Inclusion London’s evidence on hate crime, in particular to the Commons Petitions Committee’s inquiry into online abuse (in February 2018) and the experience of Disabled people has been incorporated into this response.