Prostasia Foundation

To compile, fund, and disseminate the results of research on the prevention of child sexual abuse, which can be used in advocacy for child protection laws, corporate policies, and enforcement procedures that are constitutional and evidence-based.

Lobbying Activity

Response to EU strategy for a more effective fight against child sexual abuse

11 Jun 2020

Prostasia Foundation firmly supports measures to more effectively combat child sexual abuse that are evidence-based. We particularly applaud the fact that the Commission's priority is "first to support Members States to prevent the sexual abuse of any child." However, we have three suggestions for the Commission's consideration that we hope will ensure that it follows an effective and evidence-based approach. First, evidence-based policy in this area should be explicitly conducted within a public health framework. Our concern with the framing of the Roadmap Ares(2020)2914579 is that it is couched in terms that suggest that addressing child sexual abuse prevention is primarily a criminal justice issue, rather than primarily a public health issue. This is suggested by the repeated reference to the problem as addressing "crimes", which suggests that the abuse has already taken place. Viewing the problem through a criminal justice lens creates the risk that too much attention will be devoted towards the criminalization of those who have already offended, and less towards the prevention of abuse. A public health approach is devoted towards prevention first, and that is the approach that we recommend. Second, we have a concern about terminology and the misuse of statistics. For example, the statement that "at any given moment, across the world there are more than 750,000 predators online," drawn from a report of the Special Rapporteur on the sale of children, child prostitution and child pornography, has no source. Although the statement is frequently repeated, its basis needs to be clearly supported in fact if it is to be taken as a guideline for evidence-based policy. Further, the term "predator" is a loaded one that does not have a precise meaning either in law or in psychology. Is the Commission referring to convicted offenders? Or to people with pedophilia, who may or may not have offended? Or something in between? The answers in each case are very different, and we need to be clear about which metrics are being used. Third, ensuring that the Commission must consult on these measures beyond the membership of the WePROTECT Global Coalition. WePROTECT members are required to "avoid partaking in any activity which could negatively impact upon the reputation of the WPGA." In the area of child sexual exploitation, it is frequently impossible to avoid work with negative reputational impacts. For example, in our prevention work, the experts on our team work with people who have pedophilia, and in our civil rights work, we advocate for safeguards to ensure that sex offense laws are balanced and effective. These activities frequently attract negative attention from online trolls. To eliminate the possibility that its work will sideline important stakeholders and result in unforeseen harms, the Commission must be inclusive enough in its work to include mainstream human rights and civil rights groups as well as established child protection networks such as WePROTECT. Following a public health approach involves primary, secondary, and tertiary prevention, which includes: 1. Community-wide primary prevention initiatives 2. Early intervention targeted at those in need of support 3. Restorative justice for those have offended and those they have harmed. We encourage the Commission to ensure that this holistic view of the problem informs its work, and that the problem of child sexual exploitation is not misunderstood as one that the criminal justice system alone can solve.
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