Archive for the ‘Age Verification’ Category

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house of lords red logo The following four motions are expected to be debated together in the House of Lords on 11th December 2018:

Online Pornography (Commercial Basis) Regulations 2018

Lord Ashton of Hyde to move that the draft Regulations laid before the House on 10 October be approved. Special attention drawn to the instrument by the Joint Committee on Statutory Instruments, 38th Report, 4th Report from the Secondary Legislation Scrutiny Committee (Sub-Committee B)

Guidance on Age-verification Arrangements

Lord Ashton of Hyde to move that the draft Guidance laid before the House on 25 October be approved. Special attention drawn to the instrument by the Joint Committee on Statutory Instruments, 39th Report, 4th Report from the Secondary Legislation Scrutiny Committee (Sub-Committee B)

Lord Stevenson of Balmacara to move that this House regrets that the draft Online Pornography (Commercial Basis) Regulations 2018 and the draft Guidance on Age-verification Arrangements do not bring into force section 19 of the Digital Economy Act 2017, which would have given the regulator powers to impose a financial penalty on persons who have not complied with their instructions to require that they have in place an age verification system which is fit for purpose and effectively managed so as to ensure that commercial pornographic material online will not normally be accessible by persons under the age of 18.

Guidance on Ancillary Service Providers

Lord Ashton of Hyde to move that the draft Guidance laid before the House on 25 October be approved. Special attention drawn to the instrument by the Joint Committee on Statutory Instruments, 39th Report, 4th Report from the Secondary Legislation Scrutiny Committee (Sub-Committee B)

The DCMS and BBFC age verification scheme has been widely panned as fundamentally the law provides no requirement to actually protect people’s identity data that can be coupled with their sexual preferences and sexuality. The scheme only offers voluntary suggestions that age verification services and websites should protect their user’s privacy. But one only has to look to Google, Facebook and Cambridge Analytica to see how worthless mere advice is. GDPR is often quoted but that only requires that user consent is obtained. One will have to simply to the consent to the ‘improved user experience’ tick box to watch the porn, and thereafter the companies can do what the fuck they like with the data.

See criticism of the scheme:

Security expert provides a detailed break down of the privacy and security failures of the age verification scheme

Parliamentary scrutiny committee condemns BBFC Age Verification Guidelines

Parliamentary scrutiny committee condemns as ‘defective’ a DCMS Statutory Instrument excusing Twitter and Google images from age verification.

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House of Commons logo There’s a joint committee to scrutinise laws passed in parliament via Statutory Instruments. These are laws that are not generally presented to parliament for discussion, and are passed by default unless challenged.The committee has now taken issue with a DCMS law to excuse the likes of social media and search engines from requiring age verification for any porn images that may get published on the internet. The committee reports from a session on 21st November 2018 that the law was defective and ‘makes an unexpected use of the enabling power’. Presumably this means that the DCMS has gone beyond the scope of what can be passed without full parliamentary scrutiny.

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high tail hall 0300x0214 logo The website of an adult video game featuring sexualised animals has been hacked, with the information of nearly half a million subscribers stolen.High Tail Hall is a customisable role-playing game, which features what the website describes as sexy furry characters, including buxom zebras and scantily clad lionesses.

The compromised information, including email addresses, names and order histories, resurfaced on a popular hacking forum a few months later. HTH Studio has acknowledged the breach and say that it has been fixed. The company added:

Both our internal security and web team security assures us that no financial data was compromised. The security of our users is the highest priority.

It further recommended that all users change their passwords. So although credit card data is safe users are still at risk from identity fraud, outing and blackmail.

It is the latest in a long series of hacks aimed at adult sites and demonstrates the dangers for UK porn viewers when they are forced to supply identity information to be able to browse the adult web.

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house of lords red logo Pornographic Websites: Age Verification – Question

House of Lords on 5th November 2018 .

Baroness Benjamin Liberal Democrat

To ask Her Majesty ‘s Government what will be the commencement date for their plans to ensure that age-verification to prevent children accessing pornographic websites is implemented by the British Board of Film Classification .

Lord Ashton of Hyde The Parliamentary Under-Secretary of State for Digital, Culture, Media and Sport

My Lords, we are now in the final stages of the process, and we have laid the BBFC ‘s draft guidance and the Online Pornography (Commercial Basis) Regulations before Parliament for approval. We will ensure that there is a sufficient period following parliamentary approval for the public and the industry to prepare for age verification. Once parliamentary proceedings have concluded, we will set a date by which commercial pornography websites will need to be compliant, following an implementation window. We expect that this date will be early in the new year.

Baroness Benjamin

I thank the Minister for his Answer. I cannot wait for that date to happen, but does he share my disgust and horror that social media companies such as Twitter state that their minimum age for membership is 13 yet make no attempt to restrict some of the most gross forms of pornography being exchanged via their platforms? Unfortunately, the Digital Economy Act does not affect these companies because they are not predominantly commercial porn publishers. Does he agree that the BBFC needs to develop mechanisms to evaluate the effectiveness of the legislation for restricting children’s access to pornography via social media sites and put a stop to this unacceptable behaviour?

Lord Ashton of Hyde

My Lords, I agree that there are areas of concern on social media sites. As the noble Baroness rightly says, they are not covered by the Digital Economy Act . We had many hours of discussion about that in this House. However, she will be aware that we are producing an online harms White Paper in the winter in which some of these issues will be considered. If necessary, legislation will be brought forward to address these, and not only these but other harms too. I agree that the BBFC should find out about the effectiveness of the limited amount that age verification can do; it will commission research on that. Also, the Digital Economy Act itself made sure that the Secretary of State must review its effectiveness within 12 to 18 months.

Lord Griffiths of Burry Port Opposition Whip (Lords), Shadow Spokesperson (Digital, Culture, Media and Sport), Shadow Spokesperson (Wales)

My Lords, once again I find this issue raising a dynamic that we became familiar with in the only too recent past. The Government are to be congratulated on getting the Act on to the statute book and, indeed, on taking measures to identify a regulator as well as to indicate that secondary legislation will be brought forward to implement a number of the provisions of the Act. My worry is that, under one section of the Digital Economy Act , financial penalties can be imposed on those who infringe this need; the Government seem to have decided not to bring that provision into force at this time. I believe I can anticipate the Minister ‘s answer but–in view of the little drama we had last week over fixed-odds betting machines–we would not want the Government, having won our applause in this way, to slip back into putting things off or modifying things away from the position that we had all agreed we wanted.

Lord Ashton of Hyde

My Lords, I completely understand where the noble Lord is coming from but what he said is not quite right. The Digital Economy Act included a power that the Government could bring enforcement with financial penalties through a regulator. However, they decided–and this House decided–not to use that for the time being. For the moment, the regulator will act in a different way. But later on, if necessary, the Secretary of State could exercise that power. On timing and FOBTs, we thought carefully–as noble Lords can imagine–before we said that we expect the date will be early in the new year,

Lord Addington Liberal Democrat

My Lords, does the Minister agree that good health and sex education might be a way to counter some of the damaging effects? Can the Government make sure that is in place as soon as possible, so that this strange fantasy world is made slightly more real?

Lord Ashton of Hyde

The noble Lord is of course right that age verification itself is not the only answer. It does not cover every possibility of getting on to a pornography site. However, it is the first attempt of its kind in the world, which is why not only we but many other countries are looking at it. I agree that sex education in schools is very important and I believe it is being brought into the national curriculum already.

The Earl of Erroll Crossbench

Why is there so much wriggle room in section 6 of the guidance from the DCMS to the AV regulator? The ISP blocking probably will not work, because everyone will just get out of it. If we bring this into disrepute then the good guys, who would like to comply, probably will not; they will not be able to do so economically. All that was covered in British Standard PAS 1296, which was developed over three years. It seems to have been totally ignored by the DCMS. You have spent an awful lot of time getting there, but you have not got there.

Lord Ashton of Hyde

One of the reasons this has taken so long is that it is complicated. We in the DCMS , and many others, not least in this House, have spent a long time discussing the best way of achieving this. I am not immediately familiar with exactly what section 6 says, but when the statutory instrument comes before this House–it is an affirmative one to be discussed–I will have the answer ready for the noble Earl.

Lord West of Spithead Labour

My Lords, does the Minister not agree that the possession of a biometric card by the population would make the implementation of things such as this very much easier?

Lord Ashton of Hyde

In some ways it would, but there are problems with people who either do not want to or cannot have biometric cards.

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open rights group 2016 logo Following the conclusion of their consultation period, the BBFC have issued new age verification guidance that has been laid before Parliament. It is unclear why, if the government now recognises that privacy protections like this are needed, the government would also leave the requirements as voluntary. Summary

The new code has some important improvements, notably the introduction of a voluntary scheme for privacy, close to or based on a GDPR Code of Conduct. This is a good idea, but should not be put in place as a voluntary arrangement. Companies may not want the attention of a regulator, or may simply wish to apply lower or different standards, and ignore it. It is unclear why, if the government now recognises that privacy protections like this are needed, the government would also leave the requirements as voluntary.

We are also concerned that the voluntary scheme may not be up and running before the AV requirement is put in place. Given that 25 million UK adults are expected to sign up to these products within a few months of its launch, this would be very unhelpful.

Parliament should now:

  • Ask the government why the privacy scheme is to be voluntary, if the risks of relying on general data protection law are now recognised;
  • Ask for assurance from BBFC that the voluntary scheme will cover the all of the major operators; and
  • Ask for assurance from BBFC and DCMS that the voluntary privacy scheme will be up and running before obliging operators to put Age Verification measures in place.

The draft code can be found here .

Lack of Enforceability of Guidance The Digital Economy Act does not allow the BBFC to judge age verification tools by any standard other than whether or not they sufficiently verify age. We asked that the BBFC persuade the DCMS that statutory requirements for privacy and security were required for age verification tools.

The BBFC have clearly acknowledged privacy and security concerns with age verification in their response. However, the BBFC indicate in their response that they have been working with the ICO and DCMS to create a voluntary certification scheme for age verification providers:

“This voluntary certification scheme will mean that age-verification providers may choose to be independently audited by a third party and then certified by the Age-verification Regulator. The third party’s audit will include an assessment of an age-verification solution’s compliance with strict privacy and data security requirements.”

The lack of a requirement for additional and specific privacy regulation in the Digital Economy Act is the cause for this voluntary approach.

While a voluntary scheme above is likely to be of some assistance in promoting better standards among age verification providers, the “strict privacy and data security requirements” which the voluntary scheme mentions are not a statutory requirement, leaving some consumers at greater risk than others.

Sensitive Personal Data The data handled by age verification systems is sensitive personal data. Age verification services must directly identify users in order to accurately verify age. Users will be viewing pornographic content, and the data about what specific content a user views is highly personal and sensitive. This has potentially disastrous consequences for individuals and families if the data is lost, leaked, or stolen.

Following a hack affecting Ashley Madison — a dating website for extramarital affairs — a number of the site’s users were driven to suicide as a result of the public exposure of their sexual activities and interests.

For the purposes of GDPR, data handled by age verification systems falls under the criteria for sensitive personal data, as it amounts to “data concerning a natural person’s sex life or sexual orientation”.

Scheduling Concerns It is of critical importance that any accreditation scheme for age verification providers, or GDPR code of conduct if one is established, is in place and functional before enforcement of the age verification provisions in the Digital Economy Act commences. All of the major providers who are expected to dominate the age verification market should undergo their audit under the scheme before consumers will be expected to use the tool. This is especially true when considering the fact that MindGeek have indicated their expectation that 20-25 million UK adults will sign up to their tool within the first few months of operation. A voluntary accreditation scheme that begins enforcement after all these people have already signed up would be unhelpful.

Consumers should be empowered to make informed decisions about the age verification tools that they choose from the very first day of enforcement. No delays are acceptable if users are expected to rely upon the scheme to inform themselves about the safety of their data. If this cannot be achieved prior to the start of expected enforcement of the DE Act’s provisions, then the planned date for enforcement should be moved back to allow for the accreditation to be completed.

Issues with Lack of Consumer Choice It is of vital importance that consumers, if they must verify their age, are given a choice of age verification providers when visiting a site. This enables users to choose which provider they trust with their highly sensitive age verification data and prevents one actor from dominating the market and thereby promoting detrimental practices with data. The BBFC also acknowledge the importance of this in their guidance, noting in 3.8:

“Although not a requirement under section 14(1) the BBFC recommends that online commercial pornography services offer a choice of age-verification methods for the end-user”.

This does not go far enough to acknowledge the potential issues that may arise in a fragmented market where pornographic sites are free to offer only a single tool if they desire.

Without a statutory requirement for sites to offer all appropriate and available tools for age verification and log in purposes, it is likely that a market will be established in which one or two tools dominate. Smaller sites will then be forced to adopt these dominant tools as well, to avoid friction with consumers who would otherwise be required to sign up to a new provider.

This kind of market for age verification tools will provide little room for a smaller provider with a greater commitment to privacy or security to survive and robs users of the ability to choose who they trust with their data.

We already called for it to be made a statutory requirement that pornographic sites must offer a choice of providers to consumers who must age verify, however this suggestion has not been taken up.

We note that the BBFC has been working with the ICO and DCMS to produce a voluntary code of conduct. Perhaps a potential alternative solution would be to ensure that a site is only considered compliant if it offers users a number of tools which has been accredited under the additional privacy and security requirements of the voluntary scheme.

GDPR Codes of Conduct A GDPR “Code of Conduct” is a mechanism for providing guidelines to organisations who process data in particular ways, and allows them to demonstrate compliance with the requirements of the GDPR.

A code of conduct is voluntary, but compliance is continually monitored by an appropriate body who are accredited by a supervisory authority. In this case, the “accredited body” would likely be the BBFC, and the “supervisory authority” would be the ICO. The code of conduct allows for certifications, seals and marks which indicate clearly to consumers that a service or product complies with the code.

Codes of conduct are expected to provide more specific guidance on exactly how data may be processed or stored. In the case of age verification data, the code could contain stipulations on:

  • Appropriate pseudonymisation of stored data;
  • Data and metadata retention periods;
  • Data minimisation recommendations;
  • Appropriate security measures for data storage;
  • Security breach notification procedures;
  • Re-use of data for other purposes.

The BBFC’s proposed “voluntary standard” regime appears to be similar to a GDPR code of conduct, though it remains to be seen how specific the stipulations in the BBFC’s standard are. A code of conduct would also involve being entered into the ICO’s public register of UK approved codes of conduct, and the EPDB’s public register for all codes of conduct in the EU.

Similarly, GDPR Recital 99 notes that “relevant stakeholders, including data subjects” should be consulted during the drafting period of a code of conduct – a requirement which is not in place for the BBFC’s voluntary scheme.

It is possible that the BBFC have opted to create this voluntary scheme for age verification providers rather than use a code of conduct, because they felt they may not meet the GDPR requirements to be considered as an appropriate body to monitor compliance. Compliance must be monitored by a body who has demonstrated:

  • Their expertise in relation to the subject-matter;
  • They have established procedures to assess the ability of data processors to apply the code of conduct;
  • They have the ability to deal with complaints about infringements; and
  • Their tasks do not amount to a conflict of interest.

Parties Involved in the Code of Conduct Process As noted by GDPR Recital 99, a consultation should be a public process which involves stakeholders and data subjects, and their responses should be taken into account during the drafting period:

“When drawing up a code of conduct, or when amending or extending such a code, associations and other bodies representing categories of controllers or processors should consult relevant stakeholders, including data subjects where feasible , and have regard to submissions received and views expressed in response to such consultations.”

The code of conduct must be approved by a relevant supervisory authority (in this case the ICO).

An accredited body (BBFC) that establishes a code of conduct and monitors compliance is able to establish their own structures and procedures under GDPR Article 41 to handle complaints regarding infringements of the code, or regarding the way it has been implemented. BBFC would be liable for failures to regulate the code properly under Article 41(4), [1] however DCMS appear to have accepted the principle that the government would need to protect BBFC from such liabilities. [2]

GDPR Codes of Conduct and Risk Management Below is a table of risks created by age verification which we identified during the consultation process. For each risk, we have considered whether a GDPR code of conduct may help to mitigate the effects of it.

Risk CoC Appropriate? Details
User identity may be correlated with viewed content. Partially This risk can never be entirely mitigated if AV is to go ahead, but a CoC could contain very strict restrictions on what identifying data could be stored after a successful age verification.
Identity may be associated to an IP address, location or device. No It would be very difficult for a CoC to mitigate this risk as the only safe mitigation would be not to collect user identity information.
An age verification provider could track users across all the websites it’s tool is offered on. Yes Strict rules could be put in place about what data an age verification provider may store, and what data it is forbidden from storing.
Users may be incentivised to consent to further processing of their data in exchange for rewards (content, discounts etc.) Yes Age verification tools could be expressly forbidden from offering anything in exchange for user consent.
Leaked data creates major risks for identified individuals and cannot be revoked or adequately compensated for. Partially A CoC can never fully mitigate this risk if any data is being collected, but it could contain strict prohibitions on storing certain information and specify retention periods after which data must be destroyed, which may mitigate the impacts of a data breach.
Risks to the user of access via shared computers if viewing history is stored alongside age verification data. Yes A CoC could specify that any accounts for pornographic websites which may track viewed content must be strictly separate and not in any visible way linked to a user’s age verification account or data that confirms their identity.
Age verification systems are likely to trade off convenience for security. (No 2FA, auto-login, etc.) Yes A CoC could stipulate that login cookies that “remember” a returning user must only persist for a short time period, and should recommend or enforce two-factor authentication.
The need to re-login to age verification services to access pornography in “private browsing” mode may lead people to avoid using this feature and generate much more data which is then stored. No A CoC cannot fix this issue. Private browsing by nature will not store any login cookies or other objects and will require the user to re-authenticate with age verification providers every time they wish to view adult content.
Users may turn to alternative tools to avoid age verification, which carry their own security risks. (Especially “free” VPN services or peer-to-peer networks). No Many UK adults, although over 18, will be uncomfortable with the need to submit identity documents to verify their age and will seek alternative means to access content. It is unlikely that many of these individuals will be persuaded by an accreditation under a GDPR code.
Age verification login details may be traded and shared among teenagers or younger children, which could lead to bullying or “outing” if such details are linked to viewed content. Yes Strict rules could be put in place about what data an age verification provider may store, and what data it is forbidden from storing.
Child abusers could use their access to age verified content as an adult as leverage to create and exploit relationships with children and teenagers seeking access to such content (grooming). No This risk will exist as long as age verification is providing a successful barrier to accessing such content for under-18s who wish to do so.
The sensitivity of content dealt with by age verification services means that users who fall victim to phishing scams or fraud have a lower propensity to report it to the relevant authorities. Partially A CoC or education campaign may help consumers identify trustworthy services, but it can not fix the core issue, which is that users are being socialised into it being “normal” to input their identity details into websites in exchange for pornography. Phishing scams resulting from age verification will appear and will be common, and the sensitivity of the content involved is a disincentive to reporting it.
The use of credit cards as an age verification mechanism creates an opportunity for fraudulent sites to engage in credit card theft. No Phishing and fraud will be common. A code of conduct which lists compliant sites and tools externally on the ICO website may be useful, but a phishing site may simply pretend to be another (compliant) tool, or rely on the fact that users are unlikely to check with the ICO every time they wish to view pornographic content.
The rush to get age verification tools to market means they may take significant shortcuts when it comes to privacy and security. Yes A CoC could assist in solving this issue if tools are given time to be assessed for compliance before the age verification regime commences .
A single age verification provider may come to dominate the market, leaving users little choice but to accept whatever terms the provider offers. Partially Practically, a CoC could mitigate some of the effects of an age verification tool monopoly if the dominant tool is accredited under the Code. However, this relies on users being empowered to demand compliance with a CoC, and it is possible that users will instead be left with a “take it or leave it” situation where the dominant tool is not CoC accredited.
Allowing pornography “monopolies” such as MindGeek to operate age verification tools is a conflict of interest. Partially As the BBFC note in their consultation response, it would not be reasonable to prohibit a pornographic content provider from running an age verification service as it would prevent any site from running their own tool. However, under a CoC it is possible that a degree of separation could be enforced that requires an age verification tools to adhere to strict rules about the use of data, which could mitigate the effects of a large pornographic content provider attempting to collect as much user data as possible for their own business purposes.

[1] “Infringements of the following provisions shall, in accordance with paragraph 2, be subject to administrative fines up to 10 000 000 EUR, or in the case of an undertaking, up to 2 % of the total worldwide annual turnover of the preceding financial year, whichever is higher: the obligations of the monitoring body pursuant to Article 41(4).”

[2] “contingent liability will provide indemnity to the British Board of Film Classification (BBFC) against legal proceedings brought against the BBFC in its role as the age verification regulator for online pornography.”

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DCMS logo As far as I can see if a porn website verifies your age with personal data, it will probably also require you tick tick a consent box with a hol load of small print that nobody ever reads. Now if that small print lets it forward all personal data, coupled with porn viewing data, to the Kremlin’s dirty tricks and blackmail department then that’s ok with the the Government’s age verification law. So for sure some porn viewers are going to get burnt because of what the government has legislated and because of what the BBFC have implemented.So perhaps it is not surprising that the BBFC has asked the government to pick up the tab should the BBFC be sued by people harmed by their decisions. After all it was the government who set up the unsafe environment, not the BBFC.

Margot James The Minister of State, Department for Culture, Media and Sport announced in Parliament:

I am today laying a Departmental Minute to advise that the Department for Digital, Culture, Media and Sport (DCMS) has received approval from Her Majesty’s Treasury (HMT) to recognise a new Contingent Liability which will come into effect when age verification powers under Part 3 of the Digital Economy Act 2017 enter force.

The contingent liability will provide indemnity to the British Board of Film Classification (BBFC) against legal proceedings brought against the BBFC in its role as the age verification regulator for online pornography.

As you know, the Digital Economy Act introduces the requirement for commercial providers of online pornography to have robust age verification controls to protect children and young people under 18 from exposure to online pornography. As the designated age verification regulator, the BBFC will have extensive powers to take enforcement action against non-compliant sites. The BBFC can issue civil proceedings, give notice to payment-service providers or ancillary service providers, or direct internet service providers to block access to websites where a provider of online pornography remains non-compliant.

The BBFC expects a high level of voluntary compliance by providers of online pornography. To encourage compliance, the BBFC has engaged with industry, charities and undertaken a public consultation on its regulatory approach. Furthermore, the BBFC will ensure that it takes a proportionate approach to enforcement and will maintain arrangements for an appeals process to be overseen by an independent appeals body. This will help reduce the risk of potential legal action against the BBFC.

However, despite the effective work with industry, charities and the public to promote and encourage compliance, this is a new law and there nevertheless remains a risk that the BBFC will be exposed to legal challenge on the basis of decisions taken as the age verification regulator or on grounds of principle from those opposed to the policy.

As this is a new policy, it is not possible to quantify accurately the value of such risks. The Government estimates a realistic risk range to be between 2£1m – 2£10m in the first year, based on likely number and scale of legal challenges. The BBFC investigated options to procure commercial insurance but failed to do so given difficulties in accurately determining the size of potential risks. The Government therefore will ensure that the BBFC is protected against any legal action brought against the BBFC as a result of carrying out duties as the age verification regulator.

The Contingent Liability is required to be in place for the duration of the period the BBFC remain the age verification regulator. However, we expect the likelihood of the Contingent Liability being called upon to diminish over time as the regime settles in and relevant industries become accustomed to it. If the liability is called upon, provision for any payment will be sought through the normal Supply procedure.

It is usual to allow a period of 14 Sitting Days prior to accepting a Contingent Liability, to provide Members of Parliament an opportunity to raise any objections.

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resist av video Niche porn producer, Pandora Blake, Misha Mayfair, campaigning lawyer Myles Jackman and Backlash are campaigning to back a legal challenge to the upcoming internet porn censorship regime in the UK. They write on a new ResistAV.com website:

We are mounting a legal challenge.

Do you lock your door when you watch porn 203 or do you publish a notice in the paper? The new UK age verification law means you may soon have to upload a proof of age to visit adult sites. This would connect your legal identity to a database of all your adult browsing. Join us to prevent the damage to your privacy.

The UK Government is bringing in age verification for adults who want to view adult content online; yet have failed to provide privacy and security obligations to ensure your private information is securely protected.

The law does not currently limit age verification software to only hold data provided by you just in order to verify your age. Hence, other identifying data about you could include anything from your passport information to your credit card details, up to your full search history information. This is highly sensitive data.

What are the Privacy Risks?

Data Misuse – Since age verification providers are legally permitted to collect this information, what is to stop them from increasing revenue through targeting advertising at you, or even selling your personal data?

Data Breaches – No database is perfectly secure, despite good intentions. The leaking or hacking of your sensitive personal information could be truly devastating. The Ashley Madison hack led to suicides. Don’t let the Government allow your private sexual preferences be leaked into the public domain.

What are we asking money for?

We’re asking you to help us crowdfund legal fees so we can challenge the new age verification rules under the Digital Economy Act 2017. We re asking for 2£10,000 to cover the cost of initial legal advice, since it’s a complicated area of law. Ultimately, we’d like to raise even more money, so we can send a message to Government that your personal privacy is of paramount importance.