Enhancing TechCoalition’s Efforts to Protect Children Online: Bridging Gaps with Practical Solutions

As I read through the TechCoalition’s latest report, “Developer Good Practices: Combating Online Child Sexual Exploitation and Abuse (OCSEA),” I couldn’t help but feel a visceral wave of frustration. Despite the bright minds behind this document, I fear it will do little to change actual behavior. As someone deeply embedded in the world of child safety, privacy, and global data protection laws, my perspective comes from the lens of an independent third-party auditor. For the past three years, I’ve been translating legal principles into actionable frameworks for companies to build safer digital experiences for children.

In this context, the TechCoalition’s well-intentioned report misses a critical mark. While it offers recommendations, it does not provide a clear, binary path to operationalizing safety. At KidsTethics, we advocate for Governance Through Design, Safety By Innovation — a rigorous yet practical approach that embeds safety into every facet of product development. We deliberately avoid the “By Design” moniker, believing that safety should be achieved through continual, structured processes, not as a tick-the-box afterthought. The frustrating part is that these processes don’t have to be difficult or burdensome. So, why aren’t tech companies adopting these simpler, more effective steps?

This led me to ask a simple question: Why do tech leaders continue promoting safety measures that won’t significantly reduce harm? This article explores that question and offers a clear, actionable path forward — one that could help tech companies truly protect children, rather than just talk about it.

Your frustration seems valid, and it stems from the gap between the rhetoric of tech companies on safety and the actual effectiveness of their actions, especially regarding child protection. The Tech Coalition’s focus on policy frameworks, reporting, and transparency reports can feel like surface-level solutions that do not address the systemic and operational changes required to protect children at scale.

Here are some key points to consider in your article to clarify where their approaches might be lacking and how the issue could be more effectively tackled:

1. Safety vs. Scale: The Gap in Execution

While the guidelines TechCoalition presents — like developing external standards, internal policies, and reporting mechanisms — are steps in the right direction, they tend to focus on reaction rather than prevention. There’s a need for more systemic measures, such as:

• Mandatory, not voluntary, transparency and reporting: Transparency reports are listed as “voluntary,” which means companies have no obligation to disclose how well they’re combatting child exploitation. You could argue for the need for mandated reporting under a neutral auditing body.
• Proactive operational measures: Merely placing reporting mechanisms and flagging systems within an app won’t address the issue unless accompanied by real-time moderation, sophisticated AI tools, and dedicated teams that actively monitor and prevent content before it surfaces.

2. Safety by Design: What’s Missing?

The TechCoalition promotes a “Safety by Design” approach, but they lack practical steps on implementing this beyond high-level advice. A truly proactive system would include:

• Mandatory Age Verification: Tech companies avoid enforcing robust age verification, citing privacy or user experience concerns. Yet, age verification is essential to keep children out of adult spaces where much of this exploitation occurs. You could propose that proper age verification (not just self-declared) is a starting point.
• Content Vetting and Community Management: A detailed discussion on AI-driven tools is needed here. How do these systems continuously update their models to tackle evolving threats like live-streamed abuse or “self-generated” content? Discuss how industry must go beyond detection technologies and provide real-time intervention.

3. Moving Beyond Policy Documents

The TechCoalition’s focus on internal standards, guidelines, and training tools, though helpful, often becomes an administrative checkbox. What’s missing is an external accountability mechanism that ensures:

• Third-party audits and independent monitoring: These guidelines should not just exist within the tech company itself. Companies must open themselves up to regular, independent audits to ensure they’re actually implementing what they claim to be. This would reinforce that the industry is not just paying lip service to child safety, but actively addressing risks.
• Sanctions and Enforcement: Beyond voluntary compliance, your article could argue for regulatory bodies to introduce penalties or operational bans for companies failing to meet child safety standards — something far more impactful than just suggesting improvements in transparency reports.

4. Technological Fixes without Systemic Solutions

The reliance on hash-matching technologies (like PhotoDNA), keyword filtering, and other AI classifiers, while effective in some instances, isn’t sufficient to handle dynamic abuse patterns such as grooming or sextortion, which require more human involvement and sophisticated pattern recognition.

• Limitations of AI: AI tools can only work well if continuously updated and moderated by humans. Many smaller platforms or less-regulated spaces lack the resources for this kind of oversight. What’s needed is more cooperation between tech companies, law enforcement, and third-party agencies to ensure the latest developments in AI technology are applied to all platforms.
• Investing in Human Moderation: You could call out the need for platforms to invest more in human moderation teams, especially in high-risk areas like gaming platforms, messaging apps, and social media, where AI cannot fully grasp nuance.

5. Failing to Address Loopholes

One point of concern in the TechCoalition’s recommendations is the reactionary posture towards OCSEA. There is no clear strategy on how to handle new and emerging threats like child abuse happening on encrypted platforms (think WhatsApp) or decentralized spaces. These spaces remain dark zones for regulation and need more proactive regulation.

Conclusion: A Call for Operationalizing Safety

Your article could push the conversation towards a realignment of priorities, emphasizing that:

• Companies must move from paper policies to action, operationalizing safety through robust technological systems, age verification, mandatory reporting, and third-party audits.
• There is an urgent need for mandatory transparency and enforcement by regulatory bodies.
• Collaborative efforts between tech companies, law enforcement, and NGOs must expand beyond reporting frameworks into operational partnerships that ensure resources are in place to combat child sexual exploitation in real-time.
• Ultimately, the measures tech companies take should prioritize the prevention of harm — not just documenting responses to it.

It’s possible that your bias might be rooted in seeing how little these systems seem to change behavior in tech companies, but that doesn’t necessarily mean it’s clouding your judgment. The reluctance of these companies to embrace stronger operational measures is well-documented and could indeed reflect deeper industry resistance to fully committing to child safety, likely due to financial, logistical, or reputational challenges.