Ms Kathryn Walsh:

Good afternoon. We are here, as the Irish Heart Foundation, because Irish research shows that 85,000 children across this island will die prematurely because of childhood obesity. The crisis in children’s diet-related health is linked to unhealthy food environments, which are omnipresent in every aspect of their lives. We are here because of this growth in the obesogenic environment, but more specifically, the digital obesogenic environment. We are concerned with junk food marketing to children and how it is harming children’s health. For the purposes of this Bill, we are concerned with how digital marketing, and the mechanisms that fuel it, are a real and significant threat to children’s health.

We are members of the Children’s Rights Alliance. We support its submission to this committee. However, today specifically, I wish to address the need for online safety and online harm to include concerns related to digital marketing and data protection and privacy. Moreover, harmful digital marketing should be identified as a safety risk for children. Children should be effectively protected from all exposure to all forms of digital commercial advertising and marketing which negatively affects many Convention on the Rights of the Child rights.

"Thumbs up", "like", "share", "subscribe", "tag a friend" and "comment below” - a chorus that is familiar to children across social media platforms. It is nudge, nudge, nudge. With social media, we see persuasive technology in action where psychological levers are nudged, often without our conscious awareness. We do not click randomly. We do not see posts at random. Technology is shaping where we place our attention and it is influencing what we believe is true, our relationships, and the development of our children. It is commercialising childhood and capitalising on their status as digital natives. Far from being neutral spaces for social interaction, entertainment and expression, digital platforms are structured to optimise engagement, foster habitual behaviours and maximise the impact of marketing messages on brand loyalty and product sales. Already, we see that children as young as 18 months old know junk food brands to see.

Constant immersion in digital culture has exposed children to a steady flow of marketing for fast foods, soft drinks and other unhealthy products, much of it under the radar of parents and teachers. Digital media is now ground zero for advertising and junk food, employing a growing spectrum of new strategies and high-tech tools to penetrate every aspect of young peoples’ lives.

Every child has the right to grow up free from the undue influence of advertising of products likely to be detrimental to their health and well-being. However, this is not happening. As a result, we are at risk of losing a generation of children to obesity-related disease. Canadian research, for example, shows that Canadian kids are exposed to nearly 6,000 food adverts a year on apps such as Facebook, Instagram, Snapchat, Twitter and YouTube. That is 15 per day. Some 97% of those were for high in fat, sugar or salt foods. In 2018, research found that exposure to just 4.4 minutes of food advertising would increase a child’s food consumption by 60 calories on average, while placing advergames with food cues for five minutes increased consumption by 53.4 on average. This is just a small snapshot of the research that is out there.

Unlike television, where ads can be monitored and analysed, native advertising, influencer marketing, machine learning and many other techniques enable brand promotion and marketing to be woven seamlessly into young peoples’ digital ecologies and everyday experiences. Big data-driven digital food marketing relies on operations that make it impossible for a parent to control the processes, such as use of machine learning, artificial intelligence, AI, and algorithmic decision-making. Personalised recommendations use data not just to predict but also to influence actions, turning children into easy prey. The threats posed to young people’s health, privacy and autonomy are real and they must be addressed. Some 85,000 lives across this island, 55,000 of those on this side of the Border, depend on it.

While legislation cannot fix everything, it can bring about systemic change. Tackling the marketing and advertising of junk food and harmful products is part of that. It cannot be neglected in this Bill. If we hope to significantly improve children’s prospects for a healthy, safe life, policymakers will need to assert responsibility to regulate these sectors. We should be demanding a ban on junk food marketing. We should dismantle the digital obesogenic environment.