[LINK] APO Open letter regarding proposed social media bans for children

[Stephen Loosley]

APO Analysis & Policy Observatory

Publisher: Australian Child Rights Taskforce

This open-letter, signed by over 140 Australian academics, international experts, and civil society organisations, addresses the proposal to ‘ban’ children from social media until the age of 16. They argue that a ‘ban’ is too blunt an instrument to address risks effectively and that any restrictions must be designed with care.

Key points

* Addressing the risks of social media requires a careful and evidence-based response that acknowledges the role that the digital world plays in contemporary childhood.

* Bans affect rights to access and participation.

* Parental consent does not fix unsafe products. 

* Parents and carers often are not ‘the experts’, but will still be asked to make informed decisions. 

* Implementing a ban effectively remains a challenge. There are not yet effective techniques for age assurance nor to verify parental consent, and privacy concerns remain.

* It creates even more risks for children who may still use platforms. 
 

https://apo.org.au/sites/default/files/resource-files/2024-10/apo-nid328608.pdf


Open letter  October 9th 2024

Dear Prime Minister and Premiers,

Re: Proposed social media bans for children under 16-year olds

We write to you about the proposal to ban children from social media until the age of
16-years-old. We understand the risks that social media has for children and young people,
and these are well documented.

Addressing those risks requires a careful and evidence-based response that acknowledges the
role that the digital world plays in contemporary childhood. The online world is a place where
children and young people access information, build social and technical skills, connect with
family and friends, learn about the world around them and relax and play. These opportunities
are important for children, advancing children’s rights and strengthening development and
the transition to adulthood.

Any restrictions in the digital world must therefore be designed with care and we are
concerned that a ‘ban’ is too blunt an instrument to address risks effectively.


Some concerns include:

● Bans affect rights to access and participation: The UN Committee on the Rights of the
Child states that ‘national policies should be aimed at providing children with the
opportunity to benefit from engaging with the digital environment and ensuring their safe
access to it.’

● Parental consent does not fix unsafe products. Placing requirements on parents to
consent to the use of ‘unsafe’ products does not drive up safety.

● Parents and carers often are not ‘the experts’, but will still be asked to make informed
decisions. Placing responsibility on parents to provide consent, without adequate guidance
and support, is unfair. Not all parents will be able to manage the responsibility of
protection in the digital world.

● Implementing a ban effectively remains a challenge. There are not yet effective techniques
for age assurance nor to verify parental consent, and privacy concerns remain.

● It creates even more risks for children who may still use platforms. Platforms would be
disincentivised from offering child safety features for any younger users that do still ‘slip
onto’ a platform via ineffective age assurance.

● It fails to drive up safety standards on platforms children will be allowed to use. Some
social media ‘type’ services appear too integral to childhood to be banned, for example
short form video streamers. But these too have safety risks like risks of dangerous
algorithms promoting risky content. A ban does not function to improve the products
children will be allowed to use.


As an alternative, systemic regulation has the capacity to drive up safety and privacy standards
on platforms for all children and eschews the issues described above. Digital platforms are just
like other products, and can have safety standards imposed. We welcome the commitment to
the development of a Children’s Privacy Code and the review of the enforceability of the Basic
Online Safety Expectations.

There also needs to be a focus on supporting and empowering children, families and carers. A
blanket ban will create a challenge for those children and young people who feel their access
has been unfairly restricted. The work of keeping platforms responsible and building
awareness of risk and responsibility amongst all users is a challenge but will provide longer
term benefits.

Regards,

● Australian Child Rights Task Force

● Professor Amanda Third, Young & Resilient Research Centre, Institute for
Culture and Society, Western Sydney University

● Professor John Tobin, Francine V McNiff Chair in International Human
Rights Law, Melbourne Law School, University of Melbourne

● Senior Professor Sue Bennett, Deputy Director of the ARC Centre of
Excellence for The Digital Child, University of Wollongong

● Emeritus Professor Graeme Turner AO, School of Communication and
Arts, University of Queensland

● Emeritus Professor Tony Bennett, Institute for Culture and Society,
Western Sydney University

● Emeritus Professor David Rowe, FAHA, FASSA, Institute for Culture and
Society, Western Sydney University

● Distinguished Professor Ien Ang, Institute for Culture and Society,
Western Sydney University

● Professor Judith Bessant AM, School of Design and Social Context, RMIT
University

● Professor John Hartley AM, School of Art, English and Communications,
University of Sydney

● Professor Julian Sefton-Green, School of Education, Deakin University

● Professor Tama Leaver, ARC Centre of Excellence for the Digital Child,
Curtin University

● Professor Jeannie Marie Paterson, Melbourne Law School, University of
Melbourne

● Professor Daniel Johnson, School of Computer Science, Queensland
University of Technology

● Professor Lelia Green, School of Arts and Humanities, Edith Cowan
University

● Professor Marcus Carter, Sydney Games and Play Lab, The University of
Sydney

● Professor Gerard Goggin, Institute for Culture and Society, Western
Sydney University

● Professor Kate Douglas, College of HASS, Flinders University

● Professor Michael Dezuanni, School of Communication, Queensland
University of Technology

● Professor Philippa Collin, Young & Resilient Research Centre, Institute for
Culture and Society, Western Sydney University

● Professor Anita Harris, School of Humanities and Social Sciences, Deakin
University

● Professor Rob Watts, School of Design and Social Context, RMIT University

● Professor Sarah Maguire, InsideOut Institute for Eating Disorders, Faculty
of Medicine and Health, University of Sydney

● Professor Daryl Higgins, Director, Institute of Child Protection Studies,
Australian Catholic University

● Professor Patrik Wikstrom, Digital Media Research Centre, Queensland
University of Technology

● Professor Anthony McCosker, Director of the Social Innovation Research
Institute, Swinburne University of Technology

● Professor Catharine Lumby, Media and Communications, University of
Sydney

● Professor Axel Bruns FAHA, Australian Laureate Fellow, Digital Media
Research Centre, Queensland University of Technology

● Professor Kerry McCallum, Director, News & Media Research Centre,
University of Canberra, Australia

● Professor Sora Park, News & Media Research Centre, University of
Canberra

● Professor Ingrid Volkmer, Media & Communication, University of
Melbourne

● Professor Steven Howard, Early Start and School of Education, University
of Wollongong

● Professor Heather Horst, Institute for Culture and Society, Western
Sydney University

● Professor Peta Mitchell, Digital Media Research Centre and School of
Communication, Queensland University of Technology

● Professor Denis Byrne, Institute for Culture and Society, Western Sydney
University

● Professor Kath Albury, Department of Media and Communication, ARC
Centre of Excellence for Automated Decision-Making and Society,
Swinburne University of Technology

● Professor Bob Hodge, Institute for Culture and Society, Western Sydney
University, NSW, Australia

● Professor Louise Crabtree-Hayes, Institute for Culture and Society,
Western Sydney University

● Professor Corrinne Sullivan, Western Sydney University

● Professor Larissa Hjorth, RMIT University

● Professor Tim Corney, Youth & Community Research Group, Victoria
University

● Professor Natalya Lusty, Professor of Cultural Studies, University of
Melbourne

● Professor Daniel Angus, Digital Media Research Centre, Queensland
University of Technology

● Associate Professor Faith Gordon, Australian National University

● Associate Professor Julia Powles, Director Tech & Policy Lab, University of
Western Australia

● Associate Professor Steven Threadgold, Director of Newcastle Youth
Studies Centre, University of Newcastle

● Associate Professor Emma L. Briant, School of Media, Film and
Journalism, Monash University

● Associate Professor Anna Bunn, Curtin Law School, Curtin University

● Associate Professor Amelia Johns, School of Communications, University
of Technology Sydney

● Associate Professor Wonsun Shin, School of Culture and Communication,
University of Melbourne

● Associate Professor Caroline Fisher, University of Canberra

● Associate Professor Julia Coffey, Newcastle Youth Studies Centre,
University of Newcastle

● Associate Professor Dylan Cliff, ARC Centre of Excellence for the Digital Child, University of
Wollongong

● Associate Professor Anna Copeland, School of Law and Criminology, Murdoch University

● Associate Professor Scott Griffiths, University of Melbourne

● Associate Professor Ivanka Prichard, College of Nursing & Health Sciences, Flinders
University

● Associate Professor Mary Anne Kenny, School of Law and Criminology, Murdoch University

● Associate Professor Howard Sercombe, Youth Work, Western Sydney University

● Associate Professor Naomi Barnes, School of Teacher Education and Leadership, Centre for
Justice. Queensland University of Technology

● Associate Professor Charles Barbour, School of Humanities and Communication Arts,
Western Sydney University

● Associate Professor Fiona MacDonald, Centre of Excellence Young People and Disasters,
Victoria University and Youth Affairs Council Victoria

● Dr Patricia Edgar AM, La Trobe University

● Dr Holly Doel-Mackaway, Macquarie Law School, Macquarie University, Sydney

● Dr Jonathon Hutchinson, Media and Communications, University of Sydney

● Dr Catherine Page Jeffery, Discipline of Media and Communications, University of Sydney

● Dr Jacinta Sassine, School of Law, Western Sydney University

● Dr Rys Farthing, Associate Investigator, ARC Centre of Excellence for the Digital Child

● Dr Aleesha Rodriguez, ARC Centre of Excellence for the Digital Child, Queensland
University of Technology

● Dr Justine Humphry, Digital Cultures, Media and Communications, University of Sydney

● Dr Lisa Archbold, School of Law, Queensland University of Technology

● Dr Hannah Jarman, School of Psychology, Deakin University

● Dr Amanda Levido, Faculty of Education, Southern Cross University

● Dr Cadhla O'Sullivan, Children's Policy Centre, Australian National University

● Dr Megan Lang, Children's Policy Centre, Australian National University

● Dr Andy Zhao, ARC Centre of Excellence for the Digital Child, Deakin University

● Dr Annisa Beta, School of Culture and Communication, The University of Melbourne

● Dr Julia Cook, Newcastle Youth Studies Centre, University of Newcastle

● Dr Shiva Chandra, Sydney Centre for Healthy Societies, University of Sydney

● Dr Jee Young Lee, Faculty of Arts and Design, News and Media Research Centre, University
of Canberra

● Dr Akane Kanai, School of Media, Film and Journalism, Monash University

● Dr Suneel Jethani, School of Communications, University of Technology Sydney

● Dr Bhuva Narayan, School of Communication, University of Technology Sydney

● Dr Paul Byron, School of Communication, University of Technology Sydney

● Dr Tiffani Apps, School of Education, ARC Centre of Excellence for the Digital Child,
University of Wollongong

● Dr Jasmine Fardouly, School of Psychology, University of Sydney

● Dr Joanne Orlando, ICS, Western Sydney University

● Dr Milissa Deitz, Western Sydney University

● Dr Luigi Di Martino, Young & Resilient Research Centre, Institute for Culture and Society,
Western Sydney University

● Dr Phillip Mar, Institute for Culture and Society, Western Sydney University

● Dr Michael Emslie, School of Design and Social Context, RMIT University

● Dr Jenna Condie, Western Sydney University

● Dr Amy Shields Dobson, Centre for Culture and Technology, Curtin University

● Dr Adam Sargent, School of Archaeology and Anthropology, Australian National University

● Dr Fiona Robards, Faculty of Medicine and Health, The University of Sydney

● Dr Rachel Morley, School of Humanities & Communication Arts, Western Sydney University

● Dr Kathryn Daley, Associate Director, Social Equity Research Centre, RMIT University

● Dr Kim Osman, School of Communication, Queensland University of Technology

● Dr Girish Lala, Young & Resilient Research Centre, Institute for Culture and Society,
Western Sydney University

● Dr Wilfred Wang, School of Culture and Communication, University of Melbourne

● Dr Patrick O'Keeffe, Social Equity Research Centre, RMIT University

● Dr Aimee Hourigan, Institute for Culture and Society, Western Sydney University

● Dr Rebecca Ng, University of Wollongong, ARC Centre of Excellence for the Digital Child

● Dr Karley Beckman, School of Education, University of Wollongong

● Dr Mahli-Ann Butt, School of Culture and Communication, University of Melbourne

● Dr Dean Farquhar, Adjunct Research Fellow, Institute for Sustainable Industries and
Liveable Cities, Victoria University

● Dr Edward Hurcombe, School of Media and Communication, RMIT University

● Dr Kate Mannell, ARC Centre of Excellence for the Digital Child, Deakin University

● Hannah Klose, PhD Candidate, School of Social Sciences, Monash University

● Brooke Ann Coco, PhD Candidate, School of Media and Communication, RMIT University

● Daniel Whelan-Shamy, PhD Candidate, Digital Media Research Centre, Queensland
University of Technology

● Ned Watt, PhD Candidate, Digital Media Research Centre, Queensland University of
Technology

● Katherine M. FitzGerald, Digital Media Research Centre, Queensland University of
Technology

● Ren Galwey, School of Culture and Communication, Faculty of Arts, University of Melbourne


International experts:

● Professor Sonia Livingstone, Digital Futures for Children centre, London School of
Economics and Political Science (LSE), UK

● Professor Eva Lievens, Law & Technology, Ghent University, Belgium

● Professor Simone van der Hof, Center for Law and Digital Technologies (eLaw), Leiden
University, The Netherlands

● Professor EJ Renold, School of Social Sciences, Cardiff University, UK

● Professor Sun Sun Lim, College of Integrative Studies, Singapore Management University,
Singapore

● Professor Elisabeth Staksrud, Department of Media and Communication, University of Oslo,
and Coordinator of the EU Kids Online research network

● Professor Dr Jessica Taylor Piotrowski, Amsterdam School of Communication Research,
University of Amsterdam, The Netherlands

● Professor Mizuko Itō, Director, Connected Learning Lab, University of California, Irvine, US

● Professor Rebecca Coleman, Bristol Digital Futures Institute, University of Bristol, UK

● Professor Manisha Pathak-Shelat, Professor of Communication, MICA, Ahmedabad, India

● Professor Justin W. Patchin, Department of Political Science and Criminal Justice, University
of Wisconsin-Eau Claire, US

● Professor Emma Rich, Department for Health, University of Bath, UK

● Professor Rosalind Gill, Goldsmiths College, University of London, UK

● Professor Sara M. Grimes, Wolfe Chair in Scientific and Technological Literacy, Department
of Art History and Communication Studies, McGill University, Canada

● Dr. danah boyd, Author of "It's Complicated: The Social Lives of Networked Teens", US

● Dr Valerie Verdoodt, Research Group Law and Technology, Ghent University, Belgium

● Dr Sunny Liu, Stanford Social Media Lab, Stanford University, US

● Dr Tijana Milosevic, UCD Centre for Digital Policy, School of Information and
Communication Studies, University College Dublin, Ireland

● Dr Magdalena Claro, Faculty of Education, Pontificia Universidad Católica de Chile, Chile

● Yalda Tehranian-Uhls, PhD, Psychology, UCLA, US

● Dr Ingrida Milkaite, Law & Technology Research Group, Ghent University, Belgium

● Dr Alice Marwick, Director of Research, Data & Society Research Institute; Research
Associate Professor, University of North Carolina at Chapel Hill, US

● Dr Ellyn Pueschel, Center for Scholars & Storytellers @ UCLA, US

● Dr Ioanna Noula, UCD Centre for Digital Policy, University College Dublin, Ireland

● Dr Sarah Coyne, School of Family Life, Brigham Young University, US

● Dr Laetitia Greeff, Department of Public Law, Faculty of Law, Nelson Mandela University,
Gqeberha, South Africa

● Mohammed Raiz Shaffique, PhD Candidate, Center for Law and Digital Technologies (eLaw),
Leiden University, The Netherlands

● Lien Stolle, Doctoral Researcher, Law & Technology research group, Ghent University,
Belgium

● Argyro Chatzinikolaou, Doctoral Researcher, Law & Technology Research Group, Ghent
University, Belgium

● Dr Amie Kim, Independent Researcher
International organisations:

● Cyberbullying Research Center, US

● The Net Safety Collaborative, US

● Centre for Social Research, India


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