1 Submission to the Standing Senate Committee on Transport and Communications BILL C-11:

An Act to amend the Broadcasting Act and to make related and consequential amendments to other Acts SUBMITTED BY: Defend Dignity October 13th, 2022 Defend Dignity exists to end all forms of sexual exploitation in Canada. As a national organization, we have worked with survivors of sexual exploitation across Canada since 2010. We focus on awareness, aid and advocacy and we partner with local and global survivor-led agencies, service providers, and non-profit organizations.

We have co-developed a youth training curriculum and hosted numerous events – including a Canadian Sexual Exploitation Summit in May 2021 - to educate over 10,000 people on relevant topics such as online safety, the impact of pornography exposure, and preventing exploitation. One of our advocacy campaigns, Choose Change, allows us to dialogue with executives from companies such as Instagram and TikTok about the need to protect children from being exposed to pornography and predators.

Our work supporting individuals who have been sexually exploited through pornography and assisting communities to strengthen prevention efforts gives us insight into the harmful impact sexually explicit material has on children. As this Committee studies how to modernize the Broadcasting Act, we request that an amendment be made to prevent children from being exposed to sexually explicit material online. Canada has recognized the importance of preventing children from being exposed to sexually explicit material that is broadcasted offline and it is essential that those protections continue in online spaces.

This is possible through various secure age verification methods to ensure only adults can access sexually explicit content online. Other countries such as Australia, France, Germany, and the UK have already implemented or started the process of implementing these measures. In addition, the European Union has directed its Member States to take measures - such as age verification - to prevent minors from being exposed to pornography online, which it categorizes as the most harmful content to minors and thus the content that requires the strictest measures1.

Canadian youth deserve these same online protections. 1 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32018L1808&from=EN 2 1. Youth exposure to pornography is associated with a broad range of harms We interact with individuals such as parents, teachers, and youth workers who support young people who are struggling with sexual addictions in the form of compulsive pornography use. A common theme is the detrimental impact exposure to pornography as a minor had on their relationships, sexuality, and mental health.

These anecdotal accounts are backed up by a plethora of research that outlines various harms connected with youth pornography exposure.2 This exposure is occurring at increasingly younger ages: most anecdotal accounts and studies show the average age of first exposure to pornography is between 7-133. Pornography exposure also increases the risk of becoming victims or perpetrators of sexual abuse4. For example, pornography exposure has been identified as a contributing factor to child-on-child sexual abuse, a tragic occurrence that is increasing5.

Pornography is also recognized as a tool used by sexual predators and traffickers to groom their targets. Defend Dignity has supported survivors who were exposed to pornography as a minor and/or named pornography as part of their abuse. This requires immediate action as child sexual exploitation is increasing at an alarming rate6. 2. The government has a responsibility to regulate industries that harm young people We interact with many parents during our education initiatives and their biggest concern is how to protect their children from the harms of viewing sexually explicit material.

Covid-19 has made acting to protect children in online spaces more urgent than ever before as they rely on the internet for school, socialization, and entertainment. Some may argue that it’s solely the parent’s responsibility to prevent their children from viewing pornography. However, society does not hold this standard when it comes to preventing youth from accessing harmful substances such as alcohol and cigarettes. Pornography is often only a few clicks away on devices that can fit in a child’s pocket, making it drastically more accessible than the government-regulated substances mentioned above.

Implementing meaningful age verification would shift some of the burden from caregivers onto online platforms. 2 Here is one helpful research database of studies on minors and pornography: https://www.echildhood.org/journal_articles 3 https://www.mdpi.com/2673-7051/1/2/9/htm and https://www.revealingreality.co.uk/wp- content/uploads/2020/01/BBFC-Young-people-and-pornography-Final-report-2401.pdf 4 https://digitalcommons.uri.edu/cgi/viewcontent.cgi?article=1284&context=dignity 5 https://link.springer.com/article/10.1007/s40429-021-00390-8 6 https://www.canada.ca/en/public-safety-canada/campaigns/online-child-sexual-exploitation.html and https://www.cbc.ca/news/politics/pandemic-child-sexual-abuse-1.5645315 3 3.

Upholding children’s digital rights includes protecting them from pornography exposure The UN Convention of the Rights of the Child (CRC) recently adopted General Comment 25 which recognizes children’s rights in the digital space. The CRC advises: “States parties should take all appropriate measures to protect children from risks to their right to life, survival and development.

Risks relating to content, contact, conduct and contract encompass, among other things, violent and sexual content,…exploitation and abuse, including sexual exploitation and abuse, and the promotion of or incitement to suicide or life-threatening activities, including by criminals or armed groups designated as terrorist or violent extremist.” “States parties should ensure that appropriate enforcement mechanisms are in place and support children, parents and caregivers in gaining access to the protections that apply.

They should legislate to ensure that children are protected from harmful goods, such as weapons or drugs, or services, such as gambling. Robust age verification systems should be used to prevent children from acquiring access to products and services that are illegal for them to own or use.”7 Implementing meaningful age verification is a step that the government can take in compliance with the CRC’s guidance to protect children from viewing sexual content online and from becoming more vulnerable to sexual exploitation and abuse.

Without these protections minors are frequently being exposed to violent and hardcore content. For example, The British Journal of Criminology recently published a study8 that found sexual violence was frequently depicted on the homepages of mainstream pornography sites. The Times commented on the findings of the study: “An analysis of 131,738 titles on the homepages of Pornhub, XHamster and XVideos found that one in eight showed non-consensual or incestuous acts, including where the subjects were described as drugged, unconscious or “very young”.

More than 8,000 titles referred to physical aggression or forced sexual activity, even when the researchers excluded representations of consensual bondage, discipline and sadomasochism (BDSM) practices.”9 Since these sites do not verify the age of their consumers, children can easily stumble upon these homepages and be instantly exposed to this content. 7 https://www.ohchr.org/EN/HRBodies/CRC/Pages/GCChildrensRightsRelationDigitalEnvironment.aspx , paragraph 14 and 114. 8 https://academic.oup.com/bjc/advance-article/doi/10.1093/bjc/azab035/6208896 9 https://www.thetimes.co.uk/article/porn-sites-used-by-children-show-criminal-sex-acts-zsl5x6rjd 4 Recommendation Amend the Broadcasting Act to include the protection of children from exposure to sexually explicit material online.

Youth deserve to be protected from pornography everywhere they are, which increasingly includes online spaces. We cannot overstress the urgency of implementing safety measures as every delay leads to more children being harmed by exposure. We are counting on you as Senators to take this opportunity to promote and protect the well-being of Canadian youth. Thank you for your work to ensure broadcasting contributes to a healthy and thriving Canadian society. Submitted by: Defend Dignity https://defenddignity.ca/ 101- 2580 Matheson Blvd. E. Mississauga, ON, L4W 4J1 Land of the Mississaugas of the Credit First Nation