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Law Commission Consultation

Our submission to the Law Commission Consultation on Intimate Image Abuse in partnership with the End Violence Against Women coalition (EVAW)

In May 2021 the Faith and VAWG Coalition partnered with the End Violence Against Women coalition (EVAW) to make a submission to the Law Commission’s consultation on Intimate Image Abuse.

Our submission noted that intimate image abuse against women and girls, and other forms of online violence against women and girls (VAWG), takes place in the context of gendered norms of popular culture that can reinforce harmful stereotypes and gender inequality. While data analysis in this area is still fairly underdeveloped, what is known is that women are 27 times more likely to be harassed online than men (source: European Women’s Lobby).

Online abuse of women and girls is compounded with multiple forms of discrimination - intersecting with racism, homophobia and ableism, etc. A September 2020 report The Ripple Effect, Online abuse during COVID-19 by Glitch and EVAW highlighted the extent of abuse women receive online and how Black and minoritised women are disproportionately victimised.

Key recommendations that our organisations believe

  • A comprehensive definition of “intimate image” which ensures all women, particularly those otherwise minoritised and marginalised, have the ability to control the boundaries of their intimate lives, and have a right to ‘intimate privacy’. This would include:
  • A straightforward single offence - this would ensure that all intimate image abuse (including upskirting and downblousing) are covered by one offence to strengthen understanding and clarity.
  • No hierarchy of offences or victim-survivors – There should be no more ‘serious’ additional offence related to motivation of perpetrator as this does not accurately reflect the overlapping, shifting motivations of intimate image abuse perpetrators and would be inconsistent with most criminal law offences.
  • Automatic anonymity for all those reporting any form of intimate image abuse and further measures to protect complainants during any trial process.
  • The establishment of a regulator with powers to order social media and porn companies to take down images, as well as supporting and funding educational and preventative initiatives.
  • A holistic, public health approach to online VAWG – This would include sufficient resourcing of specialist VAWG services, with particular emphasis on ‘by and for’ Black and minoritised women’s VAWG organisations, as well as recognition of online VAWG in the forthcoming Online Safety Bill.

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Posted on 17 Aug, 2021

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