UNICEF UK – Written Evidence (LOL0081)

UNICEF, the Children’s Fund, is mandated by the UN General Assembly to uphold the UN Convention on the Rights of the Child (UNCRC) and promote the rights and wellbeing of every child. Together with partners, UNICEF works in over 190 countries and territories focusing special effort on reaching the most vulnerable and excluded children, to the benefit of all children, everywhere. Here in the UK, we work with around two million children through our work with local authorities, hospitals and the nearly 5,000 schools in our Rights Respecting Schools Award (RRSA) network.

Unicef UK is submitting evidence to the House of Lords COVID-19 Committee with the aim of highlighting the challenges and opportunities for children and their rights in an increasingly online world. COVID-19 has shone a spotlight on the issue of digital exclusion, but also highlighted the many opportunities that exist in realising child rights through the internet.

INTRODUCTION 1. The United Nations Convention on the Rights of the Child (UNCRC) sets out every child’s right to health, education, privacy, expression, culture, play, information, and safety – all things that are both possible and problematised through the online environment. COVID-19 has shone a spotlight on this challenge and accelerated the need for action to balance empowerment and safety online, for every child.

2. While online learning was prevalent through COVID-19, the move online is unlikely to end when the pandemic subsides. As the Committee has rightly recognised, the innovations developed during lockdown can and should be built on and strengthened to provide more opportunities for children and their families throughout the UK.

3. However, to fully realise child rights online and enable long-term positive impacts for every child, the UK Government must keep a laser focus on children. It should take a child rights approach to online life, supporting, empowering, and protecting children’s inclusion, mental and physical health, and social interactions, as well as engaging constructively with businesses. The distinction of living online and offline is blurred in the lives of children today; the Government’s approaches should similarly recognise the need to support every child, everywhere, and in every way to enjoy their rights in full.

INCLUSION

4. Inclusion underpins the UNCRC, with the principle of non-discrimination clearly articulated in Article 2. As such, any approach to life online must include every child. This includes children with disabilities, young carers, ethnic and linguistic minorities, children in care, young refugees and asylum seekers, and children from disadvantaged backgrounds. In order to be effective, any intervention, legislation, or funding decision must ensure that no community is overlooked.

5. Of note is the need for the Government to recognise and address the challenges faced by some children and their families in accessing technology. While our recommendations for digital inclusion were set out in our previous submission to the Committee1, we wish to highlight here the challenge of digital skills in relation to accessing services online. Anecdotally, we know of families who rely on children to navigate the complex online service gateways utilised by Government departments in relation to their service provision. In a private roundtable held by Unicef UK and Carnegie UK Trust in November 2020, a participant noted, “In some cases, you’re relying on an 11-year-old to navigate a really complicated system, or be that go between, or man an inbox.” This suggests two distinct challenges: a. Families are struggling with English and/or digital literacy, and are thus relying on children to support access to services; and b. Service providers and civil servants may be communicating with minors without realising they are doing so.

6. The challenges of language and digital literacy can also affect young refugees and asylum seekers. Refugee Support Network notes, ‘There are…significant difficulties linked to navigating online teaching platforms, particularly for young refugees who do not have immediate family to support them or if they, or their parents/guardians, are in early stages of learning English.’2

7. RECOMMENDATION: The UK Government should invest in language and digital literacy support for families using online service gateways, taking an integrated approach across digital inclusion and social services.

8. RECOMMENDATION: Government departments using online service provision should issue guidance to civil servants in the event that they find themselves communicating with a child through a service gateway.

9. Physical infrastructure (detailed in our first submission), and digital literacy are not the only barriers to accessing online support. A sense of safety and belonging for children from all backgrounds and communities, and of all abilities, is also essential to ensure inclusion. For children with disabilities, among other things, this also means providing access to core assistive technologies.

10. RECOMMENDATION: To support full inclusion, the UK Government should ensure that online safety and empowerment the foundation to digital strategies.

11. RECOMMENDATION: The UK Government should invest in core assistive technologies for children with disabilities to enable their full participation in life online.

1 Full evidence is available at: https://committees.parliament.uk/writtenevidence/10350/html/ 2 Refugee Support Network, ‘COVID-19 crisis: emerging impact on young refugees’ education and wellbeing in the UK,’ April 2020. Available at: https://hubble-live- assets.s3.amazonaws.com/rsn/redactor2_assets/files/616/COVID- 19_crisis_and_young_refugees_Refugee_Support_Network__RSN__policy_briefing_and_recommendations.pdf PHYSICAL AND MENTAL HEALTH

12. Every child’s right ‘to the enjoyment of the highest attainable standard of health’ is enshrined in Article 24 of the UNCRC.3 Living online can both support and challenge the realisation of this right.

13. While there is concern that the amount of time children spend online could prove difficult for their mental wellbeing, this is not supported by the evidence. In Worlds of Influence: Understanding What Shapes Child Well-being in Rich Countries, UNICEF Innocenti reports ‘Robust studies suggest that moderate use is key’, noting that ‘the highest mental well-being was observed not among those children who reported no screen use, but among those who used screens for less than 2 hours per day.’4

14. That is not to say that there are no challenges to mental and physical health associated with time spent online. We highlight two online harms that are of particular concern: bullying and misinformation.

15. Online bullying is a serious and deeply concerning challenge for young people. Ditch the Label reported in 2020 that 1 in 3 young people have experienced bullying on online platforms.5 This can have long-term repercussions for young people; as the Worlds of Influence report notes ‘being bullied has a lasting negative impact even up to the age of 50.’6

16. In the aforementioned Unicef UK and Carnegie UK Trust roundtable, it was noted that “natural in-person barriers are non-existent online”, which can make online interactions more difficult to undertake in a healthy manner.

17. RECOMMENDATION: The Department for Education should continue efforts to support healthy interpersonal relationships including through providing resources for educators and schools.

18. In addition to tackling bullying before it begins, providing support for children affected by bullying – or other mental health challenges – is critical in the move online. Teachers may feel unable to provide an equal level of support to students in the online teaching environment, but they are often relied on as the first port of call. Providing support, including guidance and training, for educators and practitioners to ensure they are able to deliver online mental health support for children is critical, particularly as the lines between the online and offline world continue to blur.

3 The full text of the UNCRC is available at https://www.unicef.org.uk/wp-content/uploads/2016/08/unicef- convention-rights-child-uncrc.pdf 4 UNICEF Innocenti, ‘Worlds of Influence: Understanding what shapes child well-being in rich countries’, Innocenti Report Card 16, UNICEF Office of Research – Innocenti, Florence, 2020. Available at: https://www.unicef-irc.org/publications/pdf/Report-Card-16-Worlds-of-Influence-child-wellbeing.pdf 5 Ditch the Label, ‘The Annual Bullying Survey 2020.’ 2020. Available at: https://www.ditchthelabel.org/research-papers/the-annual-bullying-survey-2020/ 6 UNICEF Innocenti, ‘Worlds of Influence: Understanding what shapes child well-being in rich countries’. 19. The benefits of online support for mental health, however, should not be underestimated. Support groups, peer support, and connecting with like-minded young people around the world can all benefit children’s mental well-being. Fostering and supporting these initiatives can help bolster the Government’s investment in mental health for children.

20. RECOMMENDATION: The Department for Education should ensure that educators and practitioners are equipped with the resources to provide mental health support online. This includes general support, such as guidance or training, on good online pedagogy.

21. A second challenge to children’s mental health online is misinformation. There is often an assumption of knowledge with digital literacy, suggesting that children have some degree of competency in the online environment. This assumption, however, can lead to a lack of comprehensive education that could allow misinformation to grow. Children continue to struggle to identify reliable sources and distinguish facts and opinions, both necessary to combat misinformation. For instance, less than half (44%) of young people aged 16-24 correctly identify advertising on Google.7 When put in the context of campaigns such as those decrying vaccinations, this can harm both the mental and physical health of children.

22. RECOMMENDATION: The Department for Education should ensure that approaches to digital and media literacy take a back-to-basics approach, addressing the continuing challenges children face in tackling misinformation.

23. Misinformation is not, of course, the fault of children. Thus, efforts must be made to tackle the problem at its source, working with businesses (in particular social media companies) to put in place measures that can combat misinformation.

24. Importantly, any online provision must be accompanied by a comprehensive assessment of which children may not have access to such support. That is why Unicef UK is calling for the Department for Education to undertake a comprehensive mapping exercise to identify which children are not online and for what reasons. The gap in provision must then be accompanied by a comprehensive strategy to tackle, and ultimately close, the digital divide.

25. RECOMMENDATION: The Department for Education should undertake a comprehensive mapping exercise to understand how many children do not have adequate access to the internet at home and what the barriers to access are.

7 Ofcom, ‘Adults’ Media Use & Attitudes report 2020’, 24 June 2020. Available: https://www.ofcom.org.uk/__data/assets/pdf_file/0031/196375/adults-media-use-and-attitudes-2020- report.pdf 26. RECOMMENDATION: The Department for Education should use the results of this mapping exercise to develop a strategy for digital inclusion, online learning, and online support for every child.

27. Any service, including those relating to mental or physical health, moved online must continue to have an offline element until the above is achieved.

SOCIAL INTERACTION

28. Elements of social interaction are set out across the UNCRC, including in Articles 12 (respect for the views of the child), 13 (freedom of expression), and 15 (freedom of association). With the blurring of the online and offline worlds, these rights are now realised both in and outside of the internet.

29. During lockdown, children without adequate access to the internet were left with fewer opportunities to engage in social interactions. While many children will still have access to mobile phones, the quality and breadth of interaction will naturally be limited. Indeed, in its guidance on Elective Home Education, the Department for Education recognises that ‘factors such as very marked isolation from a child’s peers can indicate possible unsuitability [of education]. Suitable education is not simply a matter of academic learning but should also involve socialisation.’8 As such, ensuring accessible and adequate socialisation should be seen not just as delivering on the right to be heard, to expression, and to association, but also education.

30. RECOMMENDATION: The Department for Education should formally recognise the importance of social engagement through its digital inclusion work.

31. While the online environment opens children up to the challenges of bullying and misinformation as detailed above (as well as other concerns), there are many opportunities afforded by it to support social engagement. Importantly, all children should have equitable access to these opportunities.

THE WORLD OF WORK

32. Every child has the (enshrined in Article 28 of the UNCRC), and education has an instrumental role to play in affording every child the opportunity to succeed in a chosen area of work. Indeed, Article 29 articulates that education should promote ‘The development of the child’s personality, talents and mental and physical abilities to their fullest potential’.9 In an increasingly digital world, this must also mean their online skills, too.

8 Department for Education, ‘Elective home education Departmental guidance for local authorities’, April 2019. Available at: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/791527/E lective_home_education_gudiance_for_LAv2.0.pdf 9 The full text of the UNCRC is available at https://www.unicef.org.uk/wp-content/uploads/2016/08/unicef- 33. However, people do not acquire digital skills in equal measure. The Lloyds Bank UK Consumer Digital Index 2020 notes that ‘People with an annual household income of £50,000 or more are 40% more likely to have Foundation digital skills, than those earning less than £17,499.’10 Even if children themselves are overwhelmingly online and using the internet, this point indicates that children from lower socio-economic backgrounds are more likely to live in households with fewer digital skills.

34. The importance of digital skills for economic opportunity, however, has been well- recognised. For example, the Centre for Economics and Business Research reports ‘academic research shows that people in work who acquire digital skills achieve a rise in earnings of between 3% and 10%.’11 If the Government is committed to its levelling up agenda, it must invest in the digital skills of all children and families, particularly those from the lowest socio-economic backgrounds.

35. Poverty and disadvantage are not the only challenges when it comes to digital skills and work. While girls outperformed boys in science in the 2018 Programme for International Student Assessment (PISA) results, only 1% of girls are expected to work in an ICT-profession, compared to 7% of boys.12 This is particularly worrying as the world moves more online.

36. RECOMMENDATION: The UK Government must invest in and champion girls’ digital skills, supporting all children to pursue careers that require and advance IT.

OWNERSHIP OF DIGITAL TECHNOLOGY

37. The impacts of the Coronavirus pandemic, including national lockdowns, school closures and physical distancing measures has made the use of online platforms and digital technology essential to maintaining a sense of normalcy and supporting children’s rights to education, socialisation and play.

38. Whilst digital solutions provide opportunities for sustaining and promoting children’s rights, these same technologies can also increase children’s exposure to online risks. In ‘Children’s Rights and Digital Business during COVID-19 and Beyond’,13 UNICEF identified ten key issues facing children in the digital environment and the

convention-rights-child-uncrc.pdf. 10 Lloyds Bank, ‘Lloyds Bank UK Consumer Digital Index 2020’, 2020. Available at: https://www.lloydsbank.com/assets/media/pdfs/banking_with_us/whats-happening/lb-consumer-digital- index-2020-report.pdf. 11 Centre for Economics and Business Research, ‘The economic impact of Basic Digital Skills and inclusion in the UK’, November 2015. Available at: https://cebr.com/wp/wp-content/uploads/2015/11/The-economic- impact-of-digital-skills-and-inclusion-in-the-UK_Final.pdf. 12 OECD, ‘Programme for International Student Assessment (PISA) Results from PISA 2018’, 2019. Available at: https://www.oecd.org/pisa/publications/PISA2018_CN_GBR.pdf. 13 UNICEF, Children’s rights and digital business during COVID-19 and beyond: 10 core messages, 2020, available at https://www.unicef.org/csr/css/Digital_CRB_and_COVID-19_-_10_Core_Messages.pdf. role, and responsibility, of businesses to promote and protect children’s rights. Of particular note are misinformation, children’s data protection and privacy, cybersecurity, digital marketing and innovation.

39. In line with the UN Guiding Principles on Business and Human Rights14 and the Children’s Rights and Business Principles,15 all businesses have a responsibility to respect children’s rights, and these include digital technology companies. However, the recent Digital Inclusion Benchmark notes that only 16% of the companies assessed have published an explicit high-level statement on child digital safety.16

40. Protecting children online is important, but such protection needs to be framed within a child rights-based approach. This means that mitigation of risks should be balanced with children’s rights to freedom of expression, access to information, and privacy as outlined in the UNCRC. For example, Unicef UK welcomed the recent publication of the Age-Appropriate Design Code which placed children’s rights at the heart of its approach.

41. Unicef UK welcomed the UK Government’s commitment in 2019 to introduce the Online Harms Bill which would develop an approach to online safety that supports the UK’s democratic values which promotes a free, open, and secure Internet and the desire to work with other countries to build an international consensus to this approach. Unicef UK supports the notion that online safety is a shared responsibility between companies, Government and users.

42. However, the Bill has not been published yet and concerns remain about the regulatory approach to this piece of legislation. Unicef UK believes it is critical that any regulatory framework for digital technologies is based on international human and child rights frameworks and takes a holistic and comprehensive approach to child rights. It should: . Be informed by evidence; . Set clear expectations for businesses; . Strike the right balance between process and outcomes that lead companies to take meaningful action while also preserving freedom of expression and the right to access to information; and . Be aligned with the due diligence approach, as outlined int the UN Guiding Principles on Business and Human Rights.

43. RECOMMENDATION: The Department for Culture, Media and Sport should ensure that evidence collated on online harms, and the solutions to prevent these, inform the regulatory framework of the forthcoming Online Harms Bill.

14 OHCHR, UN Guiding Principles on Business and Human Rights, available at https://www.ohchr.org/documents/publications/guidingprinciplesbusinesshr_en.pdf. 15 UNICEF, Save the Children, UN Global Compact, Children’s Rights and Business Principles, available at https://www.unicef.org/csr/css/PRINCIPLES_23_02_12_FINAL_FOR_PRINTER.pdf. 16 World Benchmarking Alliance, Digital Inclusion Benchmark, 2020, available at https://www.worldbenchmarkingalliance.org/publication/digital-inclusion/. 44. RECOMMENDATION: The UK Government should ensure that any regulatory approach for digital technologies is based on the international human rights framework and take a holistic approach to child rights.

45. RECOMMENDATION: A Child Rights Impact Assessment should be conducted on the Online Harms Bill to accompany its’ publication.

46. RECOMMENDATION: The regulatory framework in the Online Harms Bill should: a. Clearly define “harm” based upon international human and child rights standards; b. Ensure companies operating in this space understand the nature of “harms” and their liability for these by providing clear guidance to business on acceptable and unacceptable content and actions, both online and offline; and c. Strike the right balance between process and outcome to ensure companies take meaningful action whilst avoiding excessive censorship which could negatively affect children’s right to information and freedom of expression.

47. One further effective way for businesses to respect both human, and children’s rights, is to conduct human rights due diligence (HRDD). HRDD has become a standard of conduct for rights-respecting companies which requires them to take a proactive approach to identify risks, and take action to prevent or mitigate them, and remedy them if abuses occur. Human rights due diligence must also extend to a company’s products and services. This is highly relevant for digital technologies, as human rights harms are mostly manifested through their use.

48. RECOMMENDATION: The UK Government should require businesses to conduct human rights due diligence, in line with international standards, that also integrates child rights.

11 December 2020