Pertanika J. Soc. Sci. & Hum. 29 (S2): 185 - 203 (2021)

SOCIAL SCIENCES & HUMANITIES

Journal homepage: http://www.pertanika.upm.edu.my/

Monitoring Internet Child Pornography (ICP) in Malaysia

Nabilah Hani Ahmad Zubaidi Department of Law, Faculty of Law & International Relations, Universiti Sultan Zainal Abidin (UniSZA), 21300, Kuala Terengganu, Malaysia

ABSTRACT Malaysian law enforcement authorities were previously at a disadvantage in monitoring and investigating ICP cases. They lacked online tools to detect ICP and other cases of child sexual exploitation and relied on information from their international counterparts. The discovery of Richard Huckle and Blake Johnston, two child sex offenders who abused Malaysian children, was only possible with information shared by Australia’s Argos Task Force and the US Homeland Security Investigations. While Malaysia currently practises information and intelligence exchange and collaboration in digital forensics, more action is needed to detect and monitor ICP activities. It is imperative for Malaysia to take all necessary steps to prevent, detect, investigate, punish, as well as address the root causes of ICP. This paper addresses this issue; it focuses on the dilemmas faced by Malaysian authorities in reducing the availability of ICP images and in deciding to prosecute offenders. It conducts an initial exploration of the ways in which authorities can protect children by proactively seeking out ICP images via a victim-identification database and blocking ICP images. The paper seeks to demonstrate that traditional policing methods, such as responding to citizen reports and image discovery through arrest and seizure, while still necessary, can be out-dated. Through semi-structured interviews with key-stakeholders from the Malaysian government and agencies, this study seeks to gain some insight into Malaysia’s implementation and enforcement experience in relation to ICP. The study suggests how the present-day policing response of ICP images can be realigned

ARTICLE INFO to other key intermediaries on the internet. Article history: Received: 05 May 2020 Accepted: 12 March 2021 Keywords: Child pornography, detecting and Published: 17 May 2021 monitoring ICP material, enforcement of the law, DOI: https://doi.org/10.47836/pjssh.29.S2.13 Sexual Offences Against Children Act 2017 E-mail address: [email protected]

ISSN: 0128-7702 e-ISSN 2231-8534 © Universiti Putra Malaysia Press Nabilah Hani Ahmad Zubaidi

INTRODUCTION and control in the administrative structure The Sexual Offences Against Children of regulatory agencies, limited funding, Act 2017 (SOAC) represents a significant limited digital forensic investigation landmark in protecting children from experts, a lack of coordination between ICP offenders. It marks a departure from governmental law enforcement agencies criminalising child sexual abuse images and telecommunication companies, and through the more general obscenity- limitations in detecting and monitoring ICP based approach in the Penal Code, the crimes. These problems are highlighted Communications and Multimedia Act when, in 2018, Malaysia was revealed 1998 and the Child Act 2001. SOAC now to be one of the locations favoured by covers an unlimited representation of ICP pornographers to download, transmit, and 1 in various technologically-mediated forms. distribute ICP. This include pseudo pornographic imagery The paper focuses in examining issues in and virtual images of child sexual abuse, as the detection and monitoring of ICP crimes well as other forms of non-physical sexual in Malaysia. Law enforcers especially find crimes such as child sexual grooming. it difficult to detect ICP images in mobile Sections 5 - 10 under Part II of SOAC are applications with temporary recording the main provisions governing ICP. Another features such as media streaming and significance of SOAC is the provision of a private-browsing sessions. Furthermore, the specific working definition of ICP, which possession of ICP material in an individual’s was previously absent in other legislation. portable software is almost impossible for To ensure harmonisation between SOAC the authorities to detect, and identifying and other applicable provisions, cross- offenders is not clear-cut if ICP is found on referencing clauses are explicitly provided a computer used by multiple individuals. 2 in Schedule 1 to 5. The case of R v. Richard Huckle (2016) Although Malaysia is not short of good demonstrated how the dark web was used for legislation such as SOAC, the main problem illegal activities such as the transaction of is reported to lie in its implementation and child pornography imagery; an opportunity enforcement. Criminal sanctions alone are for offenders to evade police detection. 3 insufficient to deal with the problem and will According to a Sessions Court Judge: be ineffective if enforcement is weak. This 1 As reported in Malaysia’s mainstream media and is especially important because ICP crimes confirmed by the police, The Straits Times Asia. (2018, January 30). Malaysia Tops in South-east are clearly complex and time-consuming Asia for Online Child Pornography. Retrieved and often involve multiple jurisdictions. from https://www.straitstimes.com/asia/se-asia/ RMP officers report some challenges faced malaysia-tops-in-south-east-asia-for-online-child- pornography. See also interview: Police Officer 1. and dilemmas encountered in detecting and 2 R. v. Richard Huckle London Central Criminal investigating ICP images on the internet. Court, Old Bailey (Unreported) 2016. These include a general lack of coordination 3 Interview: Judge 1.

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The dark web needs specialised enforcement bodies, reducing the risks of and aggressive undercover agents getting captured.5 This would explain why who are equipped with thousands Huckle had managed to conduct his illegal of ICP images as a ‘ticket’ to enter activities for nine years without being the group. Our law enforcement detected. He only came to the attention can only scratch the surface. Our of the British authorities in 2014, after a expertise is not at the level to dig tip-off from Australian’s Argos Task Force into the deep web. This is why there investigators who had arrested another man has yet to be any charges against running a paedophile site. By using the dark web ICP activities. dark web to upload, distribute, advertise, and sell images of child abuse, the Crown From 2006-2014, Huckle worked as emphasised the intensity and extremity of an English teacher and church volunteer Huckle’s crime. in the Malaysian capital of Kuala Lumpur. Another case highlighted by RMP is It was later discovered that Huckle had R v. Blake Robert Johnston (2017). This systematically abused the children under involved an American child sex offender his care. Huckle would photograph and arrested by the US authorities in 2014 for film his sexual exploits of these children, ICP and child sexual grooming offences.6 In which he then edited, and posted on the 2017, US’ Homeland Security Investigations hidden ‘dark web’4 network. During his agency had identified 94 minor victims trial in London in June 2016, the Crown who were enticed online by the Johnston revealed that Huckle was an active member to engage in sexual activity, ranging in age of a heavily encrypted deep website, ‘The from as young as 12 years and coming from Love Zone’, which is now inoperative. 32 US states and six different countries. On The shift away from the public domain of his personal electronic devices the police the web to password-encrypted networks found explicit images of his own genitals has facilitated offenders to evade filtering and those of more than 300 child victims, and other detection software from law many of whom were Malaysian. His modus 4 The term ‘dark web’ refers to the ‘hard to access’ operandi was to befriend children through part of the internet, as opposed to the public domain of the internet accessible via search engines such the social media applications OoVoo, Kik, as Google, Internet Explorer, or Mozilla Firefox. and Omegle.7 He would “entice young Accessing the dark web requires the use of an anonymising browser called The Onion Router, or 5 Ibid. commonly knowns as TOR. The TOR browser routes 6 US v. Blake Robert Johnston, 2017, Northern a web page request through a series of proxy servers District of California (Unreported). operated by thousands of servers around the globe, and 7 each of these levels may be encrypted. This process OoVoo is described as being similar to Skype. Kik renders an internet protocol (IP) address unidentifiable is a secure messenger application that protects user’s and untraceable, and is often used by individuals anonymity. Omegle is a website designed to allow to hide their physical location. See Wall (2017). strangers to talk to other strangers anonymously. Crime and deviance in cyberspace. Abingdon, UK: See Ireland's Raidió Teilifís Éireann (RTE) (2017, Routledge. September 3). US Sex Offender Groomed Children

Pertanika J. Soc. Sci. & Hum. 29 (S2): 185 - 203 (2021) 187 Nabilah Hani Ahmad Zubaidi girls” and exchange pornographic images or illegal dumping are preventive measures with them.8 Even though the images in to improve road safety and protect the Huckle and Johnston’s case were initially environment. Compliance increases in distributed in a closed network, the images proportion to the degree to which the general are ultimately subjected to uncontrolled public believes that failure to comply is worldwide distribution. likely to be detected and penalised. The It is useful to chart some concerns about WePROTECT Global Alliance addresses the Malaysian law enforcement framework this issue, and demonstrates a commitment to identify further steps that that should undertaken by state parties to, among others, be taken by law enforcement agencies in investigate cases of ICP exploitation and enhancing the detection and monitoring of prosecute offenders, reduce the availability ICP material transmitted online. of ICP material, and increase public awareness of the risks posed by children’s METHOD activities online.10 For example, SOAC This research adopts a doctrinal approach. A criminalising the possession of ICP is based library research was conducted to examine on the fact that the image would not have the legal literatures from the primary been produced in the first place but for the and secondary sources which included, demand for such material on the part of but not limited to, international human those who have an interest in ICP. When the rights treaties, statutes, case-laws, extra- authorities intervene to block the supply of legal materials, books, articles, seminar images, this may deny users access to the papers and newspapers. The study was images. When image producers are aware supplemented by an empirical study through of the online presence of regulators, they semi-structured interviews conducted over a are more likely to desist. This, therefore, period of three months from 2017 to 20189. contributes to deterrence. Every image viewed represents a real RESULT AND DISCUSSION child who has been groomed and abused to meet the demand for ICP. As long as The Detection and Monitoring of Crime the material is still circulating, the child is One accepted practice for enhancing legal continuously harmed. This is particularly compliance is to increase rates of detection significant when ICP activities are difficult and prosecution. This concept is widely to detect and blocking the infringing website accepted and is used in various contexts. is the only practical immediate recourse For example, threats of a fine for speeding in preventing further re-distribution. The in Ireland. Retrieved from https://www.rte.ie/ authorities, therefore, play an important news/2017/0910/903600-johnston-abuse/. 10 8 WePROTECT Global Alliance (End Child Sexual Interview: Police Officer 1. Exploitation Online). (2015). Our Commitments: 9 Ethical approval to conduct the interviews was 15-16 November 2015. Retrieved from https://www. granted on May 2017. weprotect.org/our-commitments.

188 Pertanika J. Soc. Sci. & Hum. 29 (S2): 185 - 203 (2021) Monitoring ICP Material in Malaysia role in monitoring ICP websites to reduce The discussion of this paper confines public access to them. WePROTECT Global itself to mainly the role of RMP, and to a Alliance demonstrates that the identification certain extent, of MCMC and the Royal and blocking of ICP images is practiced by Malaysia Customs Department (Customs most national regulatory agencies. While Department). restrained by a number of enforcement challenges and thus unable to nip ICP The Policing Regime images in the bud, this strategy remains key in reducing dissemination and possession of Money and resources are always a ICP and serves to dissuade ICP offenders in chicken and egg problem, but like the long run. it or not, we just have to manage accordingly. It ought to motivate The Role of Relevant Law Enforcement us to be more innovative, and at Agencies in Malaysia the same time active and proactive, 11 Figure 1 illustrates the main agencies rather than responsive. involved in regulating ICP in Malaysia: 11 Interview: MCMC Officer 2.

• Traditional agency regulation criminal activities in general RMP • Conduct investigation and charge ICP offenders under any statutes except CMA 1998 • Position prior to and after SOAC • Conduct investigation and charge ICP offenders exclusive under CMA 1998 MCMC • Position prior to SOAC • Manage complaints on ICP, obligate ISP companies to block infringing websites under CMA 1998 and the Communications and Multimedia Content Code • Control generally harmful material stored in traditional Custom print media at Malaysia’s immigration borders and Department airports • Provide counselling and support for ICP victims • Organise awareness seminars SWD, • Provide the Nur Alert and Talian Kasih Minisry of helpline Women • The Ministry of Women establishes PACOP as the leading national policy addressing online sexual crimes against children

Prime • Spearheaded SOAC’s Task Minister’s Force Bill in 2018 Office • Organise awareness seminars

SWD: Social ׀ MCMC: Malaysia Communication and Multimedia Commission ׀ RMP: Royal Malaysia Police PACOP: National Child Cyber and Plan of Action on Child Online Protection 2015 ׀ Welfare Department

Figure 1. The role of law enforcement and regulatory agencies

Pertanika J. Soc. Sci. & Hum. 29 (S2): 185 - 203 (2021) 189 Nabilah Hani Ahmad Zubaidi

Traditional methods of conducting Kong, Germany, South Africa, Singapore, investigations, such as responding to Canada and the United States. reports and image discovery through arrest Other international police operations and seizures, will not be sufficient, as the have since resorted to a new, technology- investigation and prosecution of ICP crimes based form of policing using undercover must be swift.12 The internet medium in techniques. One example is the Sweetie which ICP offences are committed demands Operation of 2013 which was considered technological competence and sophistication “a policing success”.15 This Dutch-led on the part of law enforcement agencies. police operation identified 999 men of Earlier police operations used impersonation 71 nationalities who tried to make sexual techniques where investigators adopted contact with a life-like computer-generated a number of guises: ICP consumer; child 10-year-old Filipina girl called Sweetie. pornography collector interested in trading Sweetie was used as bait to lure child images; or user of a private P2P media predators: when adults contacted Sweetie in application such as bit-Torrent, Ares or public chat rooms, the police operated her Freenet.13 For example, Operation Starburst from an Amsterdam warehouse through a was first conducted in England in 1995, software application. The police identified yielding many prosecutions14 The operation suspects by cross-referencing their e-mail resulted in the arrest of 15 offenders in or Skype addresses, social media profiles Britain, and a number of others in Hong and other public information. The highest 12 Interview: Police Officer 1. For a commentary three groups of child sex offenders arrested on international police operations against ICP, see in this operation were from the US, the UK, Krone, T. (2005). International police operations 16 against online child pornography. Canberra: and India, and this is linked to webcam Australian Institute of Criminology. cybersex as a ‘flourishing’ ICP phenomenon 13 Adilah & Dzulkifly (2018). Experts laud new of the 21st century. Such investigations are, police system tracking child porn users. Malay Mail. Retrived from https://www.malaymail.com/news/ however, very resource intensive, complex malaysia/2018/07/10/experts-laud-new-police- and time-consuming. ICP investigations system-tracking-child-porn-users/1650523. are ultimately a race against time as the 14 Subsequent police operations include Operation technology possessed by the Malaysian Cathedral in 1998, and Operation Ore in 2002, both led by Britain’s National Crime Agency. Operation Government is reported to “often be a few Cathedral seized pornographic material from an steps behind that of the industry”.17 Special international ring called The Wonderland Club which traded child abuse images over the internet. The 15 Crawfurd (2014). Child abuse image database operation discovered one of the largest collections containing millions of images to launch. BBC News of ICP images, over 750,000 images and over 1,800 UK. Retrieved from https://www.bbc.co.uk/news/ hours of digitised videos. Operation Ore led to the technology-30175102. investigation of more than 7000 people, with almost 16 1,500 convictions. See Metcalf (2008). Policing DW News. (2013, November 7). Dutch Activists operation ore. Criminal Justice Matters, 68, 8-9. doi: Uncover Webcam Child Sex Tourists. Retrieved from 10.1080/0962725070855327, BBC News. (2001, https://www.dw.com/en/dutch-activists-uncover- February 13). Wickedness of Wonderland. Retrieved webcam-child-sex-tourists/a-17213042. from http://news.bbc.co.uk/1/hi/uk/1167879.stm. 17 Interview: Police Officer 1.

190 Pertanika J. Soc. Sci. & Hum. 29 (S2): 185 - 203 (2021) Monitoring ICP Material in Malaysia units managing online investigation needs to RMP had been under heavy public be sufficiently agile to respond to the rapid scrutiny for their failure to detect Huckle’s pace of on-going technological change. activities and the complete lack of trained Despite these challenges, there are police forensic hackers in Malaysia.20. In technological initiatives which provide 2017, RMP’s Assistant Principal Director potentially viable means to help address the Jenny Ong revealed in a press statement problems of ICP. This is the approach taken by that the Malaysian police could not properly RMP, one which is underpinned by a dose of monitor encrypted paedophile networks as realism regarding the institution’s available it did not have the expertise to access and funding, facilities and human resources at navigate the dark web.21 It should be noted this point in time. RMP recently launched the Internet Crime Against Children: Child that, at that time, there was a distinct lack Online Protective Services (ICACCOPS) of urgency on the part of the government monitoring software. ICACCOPS represents and the RMP hierarchy regarding the a significant investment by the government problem of ICP. RMP’s regime underwent in the development of police services to significant change in July 2018, a year after assist ICP investigations. The government SOAC was enacted. The newly-launched recognises that direct harm to children Malaysia Internet Crime Against Children depicted in images will continue for as long Investigation Unit (MICAC) has now 18 as the image is distributed and displayed , replaced RMP’s former D11 Women and hence the need for authorities to monitor and Children Investigation Division (D11) and subsequently block access to the images. operates under D11’s supervision. MICAC A similar tool was deployed by Australia’s monitors traffic at pornographic websites, Argos Task Force and this was responsible and are tasked with using software to for detecting Huckle’s activities.19 This monitor, locate and pin-point viewers and software is a welcome addition to RMP’s disseminators of CSA material in order to suite of investigative tools to detect ICP 22 offences. obtain evidence for prosecution. MICAC’s 18 Dewan Rakyat (House of Representatives). objective is to enhance ICACCOPS and (2017). April 3 Debate (Thirteenth Parliament, Fifth expand its coverage to monitor anyone who Session). Retrieved from https://www.parlimen.gov. my/hansard-dewan-rakyat.html?uweb=dr&lang=en, accesses ICP websites. per YB Azalina Othman Said, pp. 14-16. 19 ‘Team Argos, the Australian detective unit…made 20 Interview: Police Officer 1. a startling discovery from the team’s scouring of 21 online paedophile networks…the unusual number Ibid. of internet addresses in the Kuala Lumpur area 22 Vijaindren & Sazili (2018) Communications and transmitting CSA material from the dark web”, in Multimedia Ministry to combat child pornography. Ananthalakshmi (2016). Child sex abuse crimes News Straits Times. Retrieved from https:// ‘going unpunished’ in Malaysia. Independent. www.nst.com.my/news/nation/2018/07/389324/ Retrieved from https://www.reuters.com/article/us- communications-and-multimedia-ministry-combat- malaysia-sexcrimes-insight-idUSKBN1390AT?il=0. child-pornography.

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ICACCOPS represents the use of Some Issues with Malaysia’s innovative technology as part of a package of ICACCOPS measures designed to monitor the activities The first issue is whether ICACCOPS is ICP offenders and provide evidence with monitoring ICP activities in general internet which the authorities can prosecute them traffic or is focused only on activities on the .23 It works 24 hours a day and locates dark web. In 2017, when the fieldwork was conducted, RMP reported that they were and pin-points in real time internet users still beta-testing ICACCOPS. The reporting surfing ICP sites. It builds a data library of officer mentioned that, if successful, these individuals and the Internet Protocol ICACCOPS would be able to monitor (IP) addresses they visit. The individuals the uploading and downloading of child are profiled for three data points: which abuse images to and from the dark web. portals they frequent, how long they spend The officer was, however, aware of several on the sites, and the files they upload and drawbacks of the software and spoke about download. ICACCOPS tracks in real time them candidly: 26 the IP addresses of individuals accessing With ICACCOPS, we can detect ICP and the websites they visit.24. The the traffic of IP addresses, leading key capacity of this software is its ability to whoever is downloading or to remotely monitor an offender’s use of uploading any pornographic image. known mobile phones and computers. Ong But we do not know what he does explains that MICAC is now authorised with the material, and we cannot to call suspects in for questioning or even ascertain if it is a video or an image. arrest them in their homes. MICAC also has We cannot access that because the power to seize smart phones, computers of our Data Protection Act 2010. or laptops to check for both adult and child We are trying to get full access to pornographic material.25 Sections 4 - 10 this [ICP images in the dark web], of SOAC and section 292 of the Penal however, for now, this remains a Code provide the legal underpinnings of concern. ICACCOPS investigations. This software is reported to have the 23 Ibid. For transparency in investigation, officers ability to monitor the dark web and P2P handling the system were required to log in their networks, provided that investigation teams registered credentials, in interview: Police Officer 1. can decipher encrypted pages. However, it 24 Today Online. (2018, July 9) New Malaysian is unlikely that the software will monitor Police Unit to Monitor Citizens Who Watch Pornography Online. Retrieved from https://www. regular internet usage through public todayonline.com/world/new-malaysian-police-unit- sites such as Google, Youtube, as well as monitor-citizens-who-watch-pornography-online social media sites including Facebook and 25 Ananthalakshmi, 'Child sex abuse crimes 'going unpunished' in Malaysia'. 26 Ibid. See also interview: Police Officer 1.

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Twitter.27 This is because private activities enacted the Cyber Centre and Cyber Cafe carried out within the public internet domain Rules 2012. Its main role is to supervise are protected under the Data Protection Act the granting of professional licenses, and 2010. The RMP officer was concerned that to require licensees to keep records of the protection of individual personal data computer usage for each computer deployed, provided under the Data Protection Act 2010 including the personal identity of users. The might limit the success of ICACCOPS.28 rules are not federal law and, therefore, The second issue is that ICACCOPS only apply in Kuala Lumpur. This creates identifies websites based on IP address. gaps and discrepancies among the laws However, this is problematic in the case applicable in different Malaysian states. of public computers. IP addresses in a The third issue is that MCMC’s role family home or a cybercafé, for example, in detecting and monitoring ICP is further are generally shared. It should not be enlarged by ICACCOPS. In 2019, MCMC’s automatically assumed, therefore, that all Network Security, New Media Monitoring, traffic to and from an IP address corresponds Compliance and Advocacy Sector Chief to a single account holder. The government reported that the agency was starting has, nonetheless, undertaken to regulate to collaborate with RMP in monitoring cyber cafes and introduce liability on pornographic websites through an Artificial online publishers in an attempt to solve Intelligence (AI) system30 known as the this quandary. It has partially ordered Algorithm.31 Algorithms is practiced by internet cafe operators to take measures Microsoft’s PhotoDNA, Google Photo, against obscene, indecent or pornographic Google Cloud, and is commonly deployed materials in some territories.29 For instance, by the US and Australian police.32 This is the Federal Territory of Kuala Lumpur uncharted territory for MCMC, and the agency needs more time to explore this AI 27 Ibid. 28 in order to ensure that it does not block or Under Section 40 (1) of the Data Protection 30 Act 2010, a data user shall not process “any According to Fadhlullah Abdul Malek, in Adilah & sensitive personal data”. Sensitive personal data Dzulkifly, 'Experts laud new police system tracking includes information on physical health or any child porn users'. other information the relevant Minister deems 31 Algorithms are calculations, instructions and to be personal, including an individual’s private rules that computers and other technologies use communications data. to make decisions about what people see online. 29 United Nations Human Rights Council. (2018). Algorithms allows for the interlinking of websites ECPAT Universal Periodic Review of the Human based on similarity content and other criteria. See Rights Situation in Malaysia Submission. In End UK Department for Digital, Culture, Media & CSEC Network Malaysia & ECPAT International, Sport and Home Office. (2019). Closed consultation. Sexual Exploitation of Children in Malaysia. In Wright, J. & Javid, S., Online Harms White Paper. Geneva: OCHCR Publications. Retrieved from UK: APS Group. Retrieved from https://www.gov. https://www.ecpat.org/wp-content/uploads/2018/07/ uk/government/consultations/online-harms-white- Universal-Periodical-Review-Sexual-Exploitation- paper. of-Children-Malaysia.pdf. 32 See Interview: MCMC Officer 2.

Pertanika J. Soc. Sci. & Hum. 29 (S2): 185 - 203 (2021) 193 Nabilah Hani Ahmad Zubaidi bypass restrictions to free expression under CIRCAMP project manages investigation the Federal Constitution. The Algorithm activities in the field of child abuse material system functions in a similar to Google and the internet. CIRCAMP is initiated by Photos: it categorises pictures according to the European Police Chief Task Force under user, photographic subject, and other traits, the Comprehensive Operational Strategic and these images are continuously fed to the Planning for the Police (COSPOL) mandate. algorithm by users. The Algorithm can also For example, Ireland, Denmark, France translate images into text which could make (Gendarmerie), Norway, Sweden and Spain possible narrower searches that are beyond are tasked to monitor the different peer to the capabilities of visual tools; one could peer networks and collect evidence and search an archive of images with the search data on computers and IP addresses. These string “children and beds”, for example.33 countries disseminate evidence packages While ICACCOPS builds a database of to enable national police services to start user profiles, RMP has to work with MCMC investigations, ands such information in order to obtain internet users’ details.34 will lead to the identification of high- This raises another issue with regard to the profile targets. This practice demonstrates “fair procedure requirement”: affected users how ICACCOPS, alongside MCMC, can are not afforded the opportunity to respond or represent a workable and proactive model appeal before a blocking decision is made.35 of policing to determine the legality of a It is worth noting that a number of European material, and whether or not it should be countries rely on the police to analyse blocked. internet content and decide its potential The final issue is that, despite having illegality, and this is based on the EU-funded recourse to the ICACCOPS system, RMP COSPOL Internet Related Child Sexual still suffers from a lack of technology Abuse Material Project (CIRCAMP)36. The specialists and computer forensic experts

33 Ibid. and from inadequate staffing levels in 34 The Straits Times. (2018, July 12). MCMC Does general. To detect ICP images, RMP needs a Not Act on its Own in Combating Online Pornography highly-skilled investigation team to monitor - Gobind. Retrieved from https://www.nst.com.my/ and infiltrate heavily-encrypted websites news/nation/2018/07/390127/mcmc-does-not-act- its-owncombating-online-pornography-gobind. and P2P groups. The absence of a dedicated 35 McIntyre (2013). Child abuse images and specialist unit makes the penetration of cleanfeeds: assessing internet blocking systems. In password-encrypted webpages a challenging Brown, I. (Ed.). Research handbook on governance task and makes it inherently difficult to read of the Internet. University of Oxford, UK: Edward Elgar Publishing. large hard drives in the course of collecting 36 Other member states of the CIRCAMP project evidence. RMP have to work with limited include Belgium, Finland, Germany, Ireland, staffing resources, a crucial factor hindering Italy, Malta, and the Netherlands. See European Commission Migration and Home Affairs. (n.d.). a comprehensive enforcement of the law. Project Description: COSPOL Internet Related https://ec.europa.eu/homeaffairs/financing/fundings/ Child Abuse Material Project. Retrieved from projects/HOME _2010_ISEC_AG_INT-004_en.

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RMP’s Assistant Principal Director confirms investigators.39 Meanwhile, exchanging this:37 tip-offs with counterpart police forces is considered one of the best strategies to We [the division] do not only handle enhance ICACCOPS. child abuse cases, but also rape and domestic violence ones. In Definitional Dilemmas and Forensic some districts, we don’t even have Software enough investigating officers and Law enforcement agencies may be more priority has to be given to murder willing to pursue cases if clear digital cases. In other countries, they have evidence of the crime confirms its severity, teams visiting the crime scene, and this increases the likelihood of a recording statements and holding successful prosecution.40 In determining meetings, but that is rarely the case the severity of an image, the authorities here because everyone is bogged are required to determine: whether actual down...We should have a case- children are depicted; the identity of the by-case team to allow us to run children; and their location in anticipation through each case effectively. Some of future testimony. Each defendant enjoys cases had to be dropped due to a “built-in defence of reasonable doubt inexperienced police investigators. as to the actual existence of the depicted child at each step in that process”.41 These All stakeholders agree that Malaysia prosecutorial burdens are onerous and the is held back by manpower and budget obvious difficulties in meeting them render constraints in addressing crimes against the enforcement of existing ICP laws children, including ICP. A police officer practically impossible. From a practical explains that it costs a lot to keep up standpoint, law enforcement and prosecuting with rapidly-changing technology and, authorities may not always be able to at the moment, there is a lack of funding determine whether or not children in images to purchase state-of-the-art investigation fit statutory definitions. Some prosecutors 38 technology. While RMP admits that may be hesitant to move ahead with cases in investigation of the dark web can be which the only images available depict older particularly expensive; to tackle the ICP 39 issue seriously would require significant Interview: Police Officer 1. 40 institutional will to invest in sending United Nations Office on Drugs and Crime (UNODC). (2015). Study on the Effects of New staff overseas to train as digital forensic Information Technologies on the Abuse and Exploitation of Children. Vienna, Austria: United 37 New Straits Times (2018, October 6). Child Nations Office on Drugs and Crime. Retrieved from Abuse: We are Not Doing Enough About It. https://www.unodc.org/documents/Cybercrime/ Retrieved from https://www.nst.com.my/news/ Study_on_the_Effects.pdf. exclusive/2018/10/418676/child-abuse-we-are-not- 41 Armagh (2001). Virtual child pornography: doing-enough-about-it. Criminal conduct or protected speech. Cardozo Law 38 Ibid. Review, 1993, 23(6), p. 2.

Pertanika J. Soc. Sci. & Hum. 29 (S2): 185 - 203 (2021) 195 Nabilah Hani Ahmad Zubaidi children, while others may give priority to suspected to contain videos or images of child these cases.42 In many instances, prosecutors abuse. MCMC and Cybersecurity Malaysia are hesitant to arrest an offender if the (CSM)47 have developed Prototype A to image depicts adolescent children and they identify suspects from surveillance videos, anticipate problems proving that the image and this prototype could be used to identify depicts a minor.43 a child depicted in an image.48 Regulators RMP and MCMC officers argue that it from MCMC and CSM report that RMP was thought a better use of police resources have been requesting assistance in digital to tackle crimes involving images depicting forensics from them.49 While RMP has an grave acts with obviously underage children in-house forensic lab, it is insufficient, and as they were the most vulnerable group. to a certain extent, outdated from the point This is due to the assumption that harm of view of MCMC and CSM. A prosecutor to younger children is greater. There also reports that RMP is often delayed because exists the risk of wasting resources in they have an extremely large number of investigating images which may turn out images to extract: “For cases charged today, to be individuals who are aged 18 or over we may not even get a forensic report within but may appear younger.44 Moreover, if the three-months’ time”.50 This is why forensic images do not depict actual children, it is analysis is often outsourced to MCMC and important to consider the “civil liability” CSM. Representatives of both agencies are for law enforcement agencies who conduct currently unaware if their product has been search-and-seize operations in violation used in ICP investigations since SOAC is of protected speech rights.45 An RMP fairly recent. officer reports that RMP has thus far only The main drawback of Prototype A is responded to reports of ICP involving actual that RMP can only use it to analyse images children.46 It relies on forensic resources already detected and the authorities also to determine the age of the child before need to secure copies before the software can deciding to proceed with a legal action be used. A CSM officer confirms that, while against an offender and to assist with the this software can render a clearer image of a investigation of ICP cases. person in a photograph or video, it is not yet It is pertinent that discussion now turn sufficiently sophisticated to distinguish older to forensic software that examines material 47 42 Cyber Security Malaysia (CSM) is an advisory Wells et al. (2007). Defining Child Pornography: and consultative arm of the government. It provides Law Enforcement Dilemmas in Investigations of support for the government’s cyber-security policy Internet Child Pornography Possession. Police and cyber-forensics support to law enforcement Practice and Research, 8(3), 278. agencies and is not involved in regulating ICP in 43 Ibid. Malaysia. 44 Interview: MCMC Officer 2. 48 Interview: MCMC Officer 2. 45 Armagh, 'Virtual child pornography: Criminal 49 Interviews: MCMC Officer 1 and MCMC Officer conduct or protected speech'. 2. 46 Interview: Police Officer 1. 50 Interview: Police Officer 1.

196 Pertanika J. Soc. Sci. & Hum. 29 (S2): 185 - 203 (2021) Monitoring ICP Material in Malaysia children from adults.51 This is particularly EU Directive 201154 emphasise victim problematic when it cannot determine the protection and support as key elements age of post-pubescent teenagers depicted of ICP. One of the recognised issues in in an image, for example those aged 14 supporting victims of ICP is the difficulty and above. A sexually explicit image of a of identifying them.55. Once identified, 15-year-old victim may be overlooked as the authorities can take steps to search for, grounds for a police investigation because rescue, and safeguard the child. They could the child appears to be an adult. In a lot of also provide medical or psychological instances, much also depends on the quality support to help victims overcome trauma. of CCTV recording.52 Given the cost of The images acquired essentially provide mobile devices with high-end cameras, evidential leads contributing to successful most amateur ICP images are of low quality prosecution in court. and, therefore, it is beyond the capacity of The general lack of formal complaints Prototype A to make forensic use of them. made to RMP and MCMC are among the Prototype A, nonetheless, is a useful tool pressing issues which makes the detection to detect young children in pornographic and investigation of ICP cases difficult. images or video provided that the recorded Without some form of ICP monitoring image is clear. These are some of the main or a victim identification system, there is limitations of Prototype A, and its exact maximum reliance on public reporting, and reliability remains to be seen. interview respondents unanimously argue that this has not always been dependable. Exploring the Victim Identification Agencies in charge of coordinating the take Technology downs of ICP websites such as the UK’s Having a software such as ICACCOPS is a Internet Watch Foundation (IWF) report positive development, but it is only the first that the overall volume of global ICP is step in detecting and identifying offenders. increasing.56 While this could mean that It is equally important for law enforcement more children are abused and exploited for to use detected ICP images as evidence to children in the education, health, social protection, identify, rescue, and protect child victims judicial and law-enforcement sectors and in areas who may remain at risk of ongoing sexual relating to sport, culture and leisure activities. abuse. International instruments such 54 EU Directive 2011 Article 23(3): Member States as the Lanzarote Convention53 and the shall promote regular training for officials likely to come into contact with child victims of sexual abuse 51 Interview: MCMC Officer 2. or exploitation, including front-line police officers, 52 Ibid. aimed at enabling them to identify and deal with child victims and potential child victims of sexual 53 Lanzarote Convention Article 5: Recruitment, abuse or exploitation. training and awareness raising of persons working 55 in contact with children (1) Each Party shall take the Interviews: Police Officer 1 and 2. necessary legislative or other measures to encourage 56 UK Internet Watch Foundation (IWF). (2018). awareness of the protection and rights of children Annual Report. Retrieved from https://www.iwf.org. among persons who have regular contacts with uk/report/2018-annual-report.

Pertanika J. Soc. Sci. & Hum. 29 (S2): 185 - 203 (2021) 197 Nabilah Hani Ahmad Zubaidi the purposes of producing these images, it (CVIP). CVIP allows analysts to perform could also be true that the increase in images a review of copies of seized images and may reflect higher rates of duplication of an videos and determines which images contain already existing image stock.57 Although previously identified child victims.60 Since duplicates may seem to be less worrying in 2002, NCMEC has reviewed more than the sense that no child is subject to a new 160 million images and videos. CAID and instance of abuse when duplication takes CVIP are examples of national ICP image place, it is nevertheless a serious issue. databases that represents a national law This is because the existence of the image enforcement effort to locate and rescue child on the internet entails continuing harm to victims depicted in ICP images. They are the victim, and further proliferation of the especially useful in stopping any ongoing image needs to be stopped where possible. It abuse and exploitation of children. would be useful, therefore, to explore victim There are some practical concerns identification as a method of policing where relating to data protection and data retention the authorities identify duplicate images in implementing any victim identification and prevent their redistribution, effectively software in Malaysia. In commenting on the responding to and preventing the crime. success of CVIP in the US, an RMP officer Through its National Crime Agency, observes:61 England and Wales have launched a similar Their software is of course much system known as the Child Abuse Image more sophisticated. Unfortunately, Database (CAID)58 as part of its commitment we do not have it yet. Even if we to identify and protect victims. By November do, I doubt we can use it with our 2015, all forces in the UK were connected present Data Protection Act 2010. to CAID and the system is fully compatible Because of this 2010 Act, we do not with INTERPOL’s ICSE.59 The US National have image datasets suitable for the Centre for Missing & Exploited Children necessary training and testing of (NCMEC) developed a similar system, this kind of software. the Child Victim Identification Program

57 Nair (2018). The Regulation of Internet The officer is sceptical about the Pornography: Issues and Challenges. Abingdon, effectiveness of such a system in the UK: Routledge. 60 US Department of Justice. (n.d.) National Strategy 58 INTERPOL. (n.d.). International Child Sexual for Child Exploitation Prevention and Interdiction. Exploitation Database. Retrieved from https:// Retrieved from https://www.justice.gov/psc/ www.interpol.int/en/Crimes/Crimes-against- national-strategy-child-exploitation-prevention- children/International-Child-Sexual-Exploitation- and-interdiction. database, UK Prime Minister’s Office. (2013). News 61 FBI Services. (2003). Privacy Impact Assessment story: Internet safety summit at Downing Street: (PIA) Child Victim Identification Program (CVIP) communique. Retrieved from https://www.gov.uk/ Innocent Images National Initiative (IINI). Retrieved government/news/pm-hosts-internet-safety-summit. from https://www.fbi.gov/services/information- 59 Brown (2017). Online risk to children: Impact, management/foipa/privacy-impact-assessments/ protection and prevention. UK: John Wiley & Sons. cvip.

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Malaysian context due to data protection work to identification and blocking laws under the Data Protection Act 201062 strategies implemented by ISPs as internet and this echoes her earlier concerns about intermediaries. ISPs, because of their the implementation of ICACCOPS. In light technical capacities, are better placed than the of this, there is an urgent need to provide law police to act as regulatory agents and content enforcement agencies with the legislative assessors in the detection and blocking of mechanisms they require to investigate ICP ICP material. It is prudent to consider how offending. For example, legislation that identification and blocking strategies by forces ISPs to retain data would increase ISPs are fundamental to effectively regulate law enforcement agencies’ investigative the flow and dissemination of ICP. capabilities. While provisions on mandatory ISP traffic is monitored by dedicated data retention is not provided under the agencies such as IWF and NCMEC. These Malaysian law63, it can be justified up to agencies dispatch ICP reports to ISPs who, a limit that respects rights to privacy; this in response, issue take-down orders to ICP would constitute a solution that addresses websites where possible and block public the officer’s concerns. Due to constraints access. While this approach is intended of space and time, this issue is beyond the to prevent the cross-border flow of ICP scope of the paper, but it should be the content, Malaysia’s current implementation subject of future research exploring possible of the identification and blocking strategy avenues to increase the effectiveness of can only censor ICP content within local applying ICP offender detection and victim network servers. The strategy is regulated identification technology in Malaysia. under the Content Code which currently regulates local ISPs as its licensees.64 In A Collaborative Recommendation: theory, the Content Code should limit ISP Extending the Responsibility to Internet immunity by placing on such companies Intermediaries extra liability for the distribution of and This paper discusses how law enforcement access to all forms of pornographic content. has been extended from traditional police However, uncoordinated efforts by MCMC in the broader enforcement scheme has 62 Under Section 40 (1) of the Data Protection Act 2010, a data user shall not process “any sensitive largely protected ISPs’ legal immunity in personal data”. Sensitive personal data includes terms of content. information on matters such as health or any other personal data as determined by the relevant MCMC is also not required to work Minister. This would include an individual’s private with other international bodies, such as communications held on his personal devices. In IWF and NCMEC, in the taking down interview: Police Officer 1. 63 “I was there in AGC when they wanted to make 64 See section 213 (1) of the Communications and a law on data retention. It was extremely difficult as Multimedia Act 1998: “A content code prepared by there were a lot of interests to consider. Until now, we the content forum or the Commission shall include cannot decide what data should and can be retained model procedures for dealing with offensive or by the ISPs”, in interview: MCMC Officer 2. indecent content”.

Pertanika J. Soc. Sci. & Hum. 29 (S2): 185 - 203 (2021) 199 Nabilah Hani Ahmad Zubaidi of ICP content. As a consequence, the CONCLUSION identification and blocking strategy is not England, Wales, and the US may have being used to its maximum potential. To dedicated police units with specially trained address this, the paper proposes the drafting officers and private specialists dealing with and passing of a clearly-defined substantive ICP such as CAID, IWF, and NCMEC. law on the duty of care of ISPs to regulate However, other countries such as Malaysia the consumption and dissemination of ICP lack specialist units within their police images on its platforms. Furthermore, it forces. This inevitably means that the law argues for the reinforcement of MCMC’s cannot be effectively and efficiently enforced role as an independent regulator to oversee at the global level. It is commendable that and enforce ISPs’ duty of care to their RMP has now adopted ICACCOPS as an ICP users in relation to ICP material. As per online monitoring system. RMP and MCMC section 23 of SOAC, MCMC can act as an can now monitor the traffic of internet users independent regulator with the power to by IP address on Malaysian internet servers, issue substantial fines and impose liabilities as well as identify duplicate images of on senior members of ISP companies should child abuse and prevent their redistribution. take-down notices be disregarded. This These systems should be sufficiently agile to would undoubtedly be a financial challenge, respond to the rapid pace of technological nevertheless it should be introduced as a development. A continuous evaluation of standard feature of MCMC’s regulatory Malaysia’s regulatory responses should practice. According to this arrangement, boost the capacity of MCMC and RMP MCMC would evolve in its role as the main to keep pace with developments on the regulator, as per CMA 1998, into a body internet and effectively detect, identify, which provides monitoring, support and and block ICP images. These initiatives enforcement. This would permit ISPs to take demonstrate the government’s paradigm a leading role in regulating and censoring shift in their perception of the severity of ICP content. ISPs would actively develop the ICP problem as well as a strengthened and maintain software for the acquisition, political will to ensure that children remain storage, and dissemination of monitoring, safe from the harms of ICP. control, and surveillance data, taking into In reality, current levels of police account the public’s rights to data protection. Coordinating its monitoring efforts with resourcing and traditional policing INTERPOL’s ICSE victim database should techniques of arrest and seizure are also facilitate the discovery of ICP victims. inadequate to the task of combatting ICP Law enforcers could exploit this information crime. There is so much ICP content to block public access to websites with available that the police, despite these potential matches, integrating an extensive initiatives, cannot entirely stem its flow. In detection and monitoring approach to curb the complex, risky, and rapidly changing the crime of ICP. world of crime and technology, placing

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