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ESC is an alliance of European organisations that strives to reduce the
impact of modern communications and electricity use on health and the environment. We are not against technology, but we are pro safe technology and safe connections.

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    Have your say – Protection of minors

    You can also get involved in forming EU laws. The European Commission offers a platform “Have your say” with the list of all new EU initiatives open for public consultation. You need to register to write your feedback: ec.europa.eu/info/law/better-regulation/have-your-say

    Protection of minors – guidelines

    About this initiative: The Digital Services Act aims to make the online world safer for children and it requires providers of all online platforms accessible to them to put in place measures to ensure a high level of privacy, safety and security as part of their service.

    Feedback period: for stage 2 is 31 July 2024 – 30 September 2024

    Link: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14352-Protection-of-minors-guidelines_en

    Feedback from Europeans for Safe Connections

    We, “Europeans for Safe Connections” (ESC), welcome the online protection of children. We have the following suggestions:

    • Online platforms shall not be accessible for children via free internet, e.g. Wifi4EU. Children using internet platforms must always be supervised to some degree. At home parents are responsible, at school teachers are responsible, parents are responsible for (not) buying mobile data. The specification of Wifi4EU is: no-password, charge-free, unlimited and children know that and will take the opportunity to use it.
    • Online platforms should contain warnings using similar systems to the ones on cigarettes. E.g. “You should prefer real people over our platform” or “You should use our platform via cable rather than wirelessly“. Moreover the platform should provide a counter on a visible place informing about the time already spent on that platform and a CO2 footprint.
    • Platforms should minimise data collection.
      Children must not be monetised by data collectors without the informed consent of parents or legal guardians. All informed consents must be facilitated. The child and guardian must be able to easily understand the data collection and be able to very easily set up an opt-out.
    • Platforms should not be allowed to process automatically the data of children below 18 years old. An artificial intelligence shall not process the data of children below 18 years, and people above 18 should give an explicit agreement (opt-in) to process their data automatically or by AI.
      The functionality of the system must not be conditional on consent.
    • Platforms aimed at children should be transformed into ethical platforms that do not display unhealthy attitudes, unhealthy behaviour, violent or otherwise inappropriate content and should not manipulate the identity of the child.
    • Regarding educational platforms, the rules must be even more strict. We welcome very much the 2023 Global Education Monitoring Report of UNESCO (https://gem-report-2023) and we would like to refer to:

    PDF page 183:

    Countries have banned the use of specific applications from education settings because of the privacy concerns they raise when they collect user data unnecessary for the applications to work.

    In Denmark, a data protection impact assessment conducted by the Elsinore municipality in relation to Google Workspace for Education and Chromebooks led to banning their use in schools (Schmiedt, 2022).

    France’s Ministry of Education and Youth has banned free versions of Microsoft Office 365 and Google Workspace in schools (UC Today, 2022).

    In Germany, Microsoft products have been banned in the states of Baden-Württemberg and Hessen because they do not comply with the GDPR (Schneider, 2022).

    The Dutch Data Protection Authority proposed to ban Chromebooks and Google Workspace for Education from schools until August 2023 because of non-compliance with children’s data protection and privacy regulations (Toulas, 2022).

    PDF page 164:

    The biggest economic concern related to sustainability is how giant technology firms, despite significant efforts to regulate their activities, use their dominant position to enter education and further strengthen their near monopoly on the market. Google Workspace for Education and Google Classroom, which play the role of a learning management system, are being used to extract student personal data for advertising purposes (Krutka et al., 2021).

    Explanation

    Now, the EU is promoting digitalisation, but fails to take measures to prevent the many negative side effects shown in scientific studies, like addiction to screens reducing social behaviour and causing development disorders. Nowadays it is not uncommon for children to have a screen time up to 6 hours a day. This has a great impact on both the child involved and society as a whole.

    Although the negative side effects of digitalisation is known in science for more than a decade, Europe is not yet beginning to act on this knowledge. Also the industry involved has not taken any action to counter side effects of the beautiful technology they sell. Side effects that can be devastating, as can be seen from the title of a book by Prof. Dr. Manfred Spitzer: Digital Dementia. Children may suffer from very early dementia due to use of digital media, leading to disturbed and reduced brain development.

    We would like to draw attention to those EU member states that already protect their minors and students at their schools:

    Other states outside EU:

    Best regards
    Europeans for Safe Connections
    This feedback was sent from a wired internet connection
    – No use of harmful radiation
    – Less electricity consumption
    – Increased data securit
    y

    Link to our feedback: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14352-Protection-of-minors-guidelines/F3496365_en

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