FOSI Response to Kids Online Health and Safety Task Force Report

Today the interagency Kids Online Health and Safety Task Force released a report with guidance for families, industry, researchers, and policymakers. After a year of hosting listening sessions with various stakeholders, reviewing existing research, and receiving hundreds of formal comments, this report is a welcome contribution to the collective efforts of increasing children's online safety.

FOSI has worked with the Task Force throughout the past year, submitting comments through the NTIA, contributing during an online listening session, and attending another discussion in person at Stanford. Our own research informed the Task Force's work and was cited in the report multiple times. We are glad to see this report take so many of our comments and recommendations into consideration.

While most of its guidance focuses on best practices for families and industry, it also addresses the importance of continued research in this space, as well as the important responsibility of policymakers.

The report speaks directly to parents and families, offering overall recommendations as well as specific advice and conversation starters that mirror our own Good Digital Parenting work. The 5C's outlined in the report acknowledge that each child is different, and that digital parenting and online safety practices change as children develop. Further recommendations include clear and frequent family conversations about navigating apps and platforms, starting such conversations early, and warnings about sharenting practices and how technology use can interfere with sleep and development. We agree with these thoughtful approaches and encourage this task force to continue to develop resources in this field, including resources that help caregivers better understand newer digital developments, such as AI and genAI.

The report recommends that industry, among other things, design age-appropriate experiences for youth users, make privacy protections for youth the default, and reduce and remove features that encourage excessive or problematic use by youth. The first point is essential in that we do not want to simply age-gate the internet but must instead encourage the creation of enriching and entertaining content and online experiences for children and young people. Higher privacy and safety protections by default are great steps toward a safety by design approach for apps and platforms, and some aspects are already required in certain countries, such as the UK's Age Appropriate Design Code. Excessive use is a top concern for youth's online health and safety, and while some state laws try to to address this, there are certainly some quick wins available in terms of limiting the hours and frequency of notifications and alerts.

Much of the guidance for industry is realistic and seeks to protect young people online without limiting their access to content and spaces. As with any sweeping guidance, the devil is in the details, but we are optimistic that the Task Force understands which actions are possible, practical, and achievable.

The report also highlights the importance of research, on which to base policies, guidance, and recommendations. FOSI appreciates the acknowledgement that social media use can be problematic for certain youth populations, and that further research is needed to identify what areas of social media may be problematic. While the task force lists a great deal of further research suggestions about how digital life can negatively impact youth, FOSI would also like to acknowledge that more research is needed about the inverse - how can digital life positively impact young people? We are currently working on a study related to wellbeing in the digital age, from which we will gain a better understanding of the ways in which digital life affects teens and parents' wellbeing - both positively and negatively.

FOSI is pleased to see the task force's recommendations for both longitudinal and core components of technology research. FOSI has recently developed a bi-annual survey that aims to better understand parents' and kids' approach to online safety. The included questions will be relevant for years to come, and we hope to continue this survey year after year. Finally, we agree with the recommendation to ensure that youth are part of the research process. When attempting to make the online world a better place for young people, their opinions and experiences should shape how we approach this goal.

Policymakers are also addressed in the report, as the Task Force calls on Congress to enact federal legislation to protect online health, safety, and privacy, encourage industry to implement age-appropriate best practices, increase transparency and researchers' access to data, fund further research, and incorporate youth voices in policymaking. FOSI has long called for a federal data privacy law as it would also serve as an important baseline for a subsequent online safety law and an age assurance guardrail, in addition to directly addressing youth online privacy. State and federal online safety legislative efforts have improved recently, with updates to the Kids Online Safety Act and Age Appropriate Design Code Acts making it more likely that they will both hold up in court and be effective in improving youth online safety.

The report also recognizes that for all the progress that needs to occur in the US, online safety is an international issue that will take global cooperation. The report recommends the US join the Global Online Safety Regulators Network as one example of how to work across oceans and borders to share information, best practices, and important takeaways. National actions will be buoyed if we are able to learn from others around the world, both sharing successes and learning from mistakes.

It is vital that online safety continue to be a focus of the administration, as true cooperation across the federal government will be required to improve online safety policy and practices. As the report concludes, "addressing health, safety, and privacy concerns for youth online must involve an on-going, whole-of-society approach in which industry, parents and caregivers, schools, health providers, other community-based organizations, and policymakers play their roles, informed by insights from a robust research community, and from engaging with youth voices." We remain excited to work with the Task Force on implementing its recommendations.

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