After a successful first day, the second day of the European Virtual Forum was kicked off by Abby Roberts, Project Manager at INHOPE. She recapped the most critical takeaways from previous sessions and outlined the focus for day two - identifying action steps for all stakeholders to tackle Child Sexual Exploitation Material (CSEM), which refers to sexualised content depicting children that is exploitative but does not fall within the classification of nationally illegal child sexual abuse material. It can also include non-illegal images in a series with CSAM as exploitation material, due to its investigative relevance and the context of exploitation in which it was generated.

Nordic Cooperation

"I would truly encourage all the hotlines to try to establish close cooperation with the hotlines in your region because it is great to strengthen the child protection network in your area," said Þóra Jónsdóttir from Barnaheill - Save the Children Iceland during her presentation. She emphasised the importance of collaboration in globally combatting CSAM and CSEM and guided participants through a prime example of successful hotline cooperation among the Nordic countries. Besides close cooperation with the Icelandic police, Barnaheill collaborates with Save the Children Finland, Save the Children Denmark and ECPAT Sweden to strengthen legal protections for children online. At the upcoming Nordic Conference on child protection taking place in May, the hotlines will dive into a comparison of CSEM legislation and prepare a joint statement.

CSEM Reports and the National Police

Continuing the theme of collaboration, Karin Sadam, an Officer at the Estonian National Criminal Police, explained how local law enforcement handles reports of CSEM in cooperation with the Estonian hotline. She stressed that working with the hotline is a critical crime-preventative activity, as it prevents the further distribution of illegal and harmful material.

In Estonian legislation, illegal content in this context refers to material (photos, videos and text) that depicts the sexual exploitation of children, including material that depicts minors in erotic or pornographic situations. While what constitutes ‘erotic’ isn’t defined in the legislation, court rulings have demonstrated this category includes exploitative and sexualized content. Estonia’s unique legislation requires a court evaluation on a case-by-case basis for reports of CSAM and CSEM to determine illegality, but Karin reported that this system works well in a country with a lower level of hosting and strong relationship with national hosting providers.

Responsibilities of Hosting Providers

GoDaddy, represented by Security Analyst Robert Strauss explored their responsibilities as a hosting provider in tackling illegal material and addressed the most common challenges in removing it. GoDaddy is the European part of the globally operating web hosting company godaddy.com that offers shared and dedicated-server hosting mainly across Germany and France.

"Most of the complaints we receive come from national hotlines such as eco, IWF and Cybertip hotline," explained Robert, "generally the cooperation with eco works very well thanks to dedicated contact persons for questions regarding specific abuse cases." But they also receive reports directly from local law enforcement. "Luckily for us, German legislation clearly outlines which content is forbidden and which needs an age verification," he shared. In Germany, there is no reason to differentiate between CSEM and CSAM when handling reports, as the German criminal code covers all types of offences against minors in the media.

Most common removal challenges:

• In cases of dedicated server hosting (when one customer leases an entire server not shared with anyone else) the customer needs to cooperate to remove harmful content from their server. In cases of non-compliance, the server is shut down within twenty-four hours.
• Some content is only visible in a specific country and a proxy is needed to access the material.
• Certain content is hidden behind a forum registration and therefore only visible to registrants.
• Some bad actors use a fast flux technique, a popular technique used by cybercriminals, that entails rapidly changing target IP addresses to avoid being detected.
  
  

Incoming complaints/reports go through a validation process - reports submitted by associated hotlines like eco are validated immediately. Afterwards, a timeframe is communicated to the customer to remove the content before their server is shut down. Robert shared that following this procedure it is determined whether or not the server and customer need to be removed, based on a case-by-case basis.

Network Strategies for Combatting CSEM

INHOPE's global network of member hotlines exchanges ideas on network strategies for combatting CSEM in private breakout sessions. The groups were facilitated by Daniela Calvillo from Te Protejo Mexico, Tanja Simola from Save the Children Finland, Meltini Christodoulaki from SafeLine Greece and Grete Raidma, from INHOPE.

Key takeaways from the breakout rooms:

• Terminology remains a critical and challenging subject: appropriate and respectful terminology used among hotlines is mostly not reflected in current legislation. To this day problematic and inaccurate terms like "child pornography" are used, which can complicate collaboration with government and law enforcement agencies.
• It is very important for us to speak the same language through an EU Directive, that clarifies what CSEM means.
• We need clearer definitions for CSAM and CSEM. Currently, most countries do not have clear legislation defining these terms. Deviation in legislation across different countries can slow and even hinder removal processes.
• Hotlines expressed a need for a separate ICCAM category for CSEM.

Closing the EVF

After a last successful round of discussions, the two-day event was closed by Abby Roberts. She expressed her gratitude to all attendees, speakers, and breakout room facilitators for their support, questions, knowledge exchange and participation. "For member hotlines attending this event today, this is just the beginning of many conversations - we will be using all of the things learned within the last two days to prepare for future activities over the next two years."


If you are a registered attendee and would like more information on any topics discussed during the EVF, or to access the slides of the presentations, please reach out to communications@inhope.org.

This event is funded by the European Commission as part of the Better Internet for Kids Programme under the Connecting Europe Facility of the Directorate-General for Communications Networks, Content and Technology.