Mr. Paddy McGeoghegan:

My thanks to all members for the opportunity to address the committee on this Bill, the welcome aim of which is to protect people in an ever more complex online environment. I will comment on who I am representing today. Epilepsy Ireland is the national organisation representing people with epilepsy and advocating for their needs. We provide services and supports for people with epilepsy and their families. We do this through our 11 community resource officers and nine regional offices throughout Ireland. Our vision is to achieve a society where no person's life is limited by epilepsy.

What is epilepsy? Epilepsy can be defined as the tendency to have repeated seizures in the brain. It is often described as an electrical storm in the brain. It is an individual and often misunderstood condition. Each person's journey with the condition is different but, generally speaking, almost 70% of those living with the condition will go on to become seizure-free through the right combination of medication or further treatment.

I will specifically reference photosensitive epilepsy. This is a reflex epilepsy in which sensitivity to flickering lights, such as strobes, some LEDs or other visual stimuli may provoke a seizure in a person.

Before I address our key point on the Bill there are two matters that I want to make clear with members. The first is that not all people with epilepsy are photosensitive. In fact between 3% and 5% of the overall epilepsy community live with photosensitive epilepsy. The issue which I am about to outline is one that, as far as we are aware, has not maliciously presented in Ireland as of yet. The key work is "yet". Unfortunately, we have seen in other countries how a particularly disgusting form of online trolling has targeted people with photosensitive epilepsy. This typically involves the deliberate targeting of people with photosensitive epilepsy with graphics interchange format or GIF images or videos designed to trigger a seizure in that person. The most infamous example involved a child in the UK who had set up a fundraising challenge event page in support of a UK-based epilepsy charity. When the event was shared on social media it was targeted with hundreds of flashing images by online trolls.

We note that head 49A of the general scheme, aims to define "online harmful content" and takes an enumerating approach. As currently listed it would be a criminal offence to disseminate cyberbullying materials, material promoting self-harm and material promoting eating disorders. From our consideration of the Bill one thing that does not appear to be included under the proposed definitions is the dissemination of materials which are themselves designed to cause direct harm. We are talking about flashing videos or images designed to cause seizures in a person with photosensitive epilepsy. It may or may not be the case that the use of materials in such a way is potentially already illegal under existing laws, but we believe that provision in this legislation can and should be made to add greater clarity and protect those with photosensitive epilepsy who could be seriously harmed by this type of material.

The impact these kinds of attacks can have cannot be underestimated. I emphasise to the members that seizures can be life-threatening and to target a person is such a way is a truly heinous act. We believe the definition of "online harmful content" needs to be expanded to protect people with photosensitive epilepsy when they go online. We hope committee members agree that this is a modest ask. We believe our ask fits within the ethos of what this legislation is trying to achieve. Let us ensure that targeted attacks, like the one I referenced earlier, never become an issue in Ireland. If a person does choose to engage in such behaviour, then they should be criminally liable. Thank you for the opportunity to address the committee. I look forward to the upcoming discussion on this.