Dr. T.J. McIntyre:

I will comment briefly on Deputy Mythen’s point regarding communications systems for children. Although companies already offer communications services that are limited to children and that have parental controls, explicit filtering and so on, and there is nothing in the law to stop that, one of the problems when trying to legislate for it is that there a very large number of edge cases. For example, there is sometimes the proposal that there should be child-only services, which sounds great but, of course, these do not deal with the problem of the 17-year-old being in a very different age bracket from a 12-year-old, nor do they deal with the problem of the 17-year-old who turns 18 and would like to talk to his or her friends, to take his or her friends’ messaging details with him or her, but finds he or she has now been aged out of the service. While companies are working on child-only or child-friendly messaging services, at this stage at least we are not in the position to enshrine that in law.

The second point the Deputy made and which I would like to respond to briefly is the impact of this on political organisation. There are two points I would make on that. One is that a concerning aspect of these rules is that they would apply across the board. They would, therefore, restrict what elected representatives say on their Facebook pages, Twitter pages or on their blogs that are hosted by Blogger or by WordPress. It is an across-the-board form of control. It is not restricted to what goes on through traditional, large broadcast media. The second point related to private communications is that this would also potentially impact private communications between a constituent and an elected representative. It would essentially require technology firms to look inside private communications and the cloud files representatives store in, for example, their Microsoft 365 storage or their Google Drive storage. Again, as currently proposed, it seems this would be done without any requirement or judicial authorisation and based only on some possible source of internal authorisation within the commission. I would regard this as very concerning.