[Singapore] AIC Submits Comments on Enhancing Online Safety For Users to the Ministry of Communication and Information (August 2022)

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The Asia Internet Coalition (AIC) has submitted comments to Singapore’s Ministry of Communications and Information (MCI) on the Public Consultation for Enhancing Online Safety For Users in Singapore. First and foremost, we commend the Government of Singapore’s public consultation aimed at enhancing online safety for users in Singapore. On this note, we share the Singapore Government’s concerns about the need to put in place measures to protect young users from harmful online content such as child abuse, terrorism, sexual harm, self-harm and public health that can lead to serious consequences in the real world and are supportive of the overall intention of Singapore’s proposed online safety codes. We appreciate MCI limiting the scope of the codes to only apply to designated social media services, particularly those that have high reach and impact, and that the short list of designated social media services will be made publicly available, with the possibility of adding more social media services to the list if they are deemed as high risk at a later stage.

We also appreciate MCI’s understanding and openness to work with social media services to take reasonable steps to remove harmful content as soon as reasonably practical depending on the level or type of egregious content identified by IMDA. Allowing reasonable timeframes for takedown that is proportionate to content type enables safety teams to appropriately prioritize incoming content issues, in particular, prioritizing action on Child Sexual Abuse Material (CSAM) and Terrorist and Violent Extremist Content (TVEC) type content over a less critical content.

As responsible stakeholders in this policy formulation process, we look forward to the transparent and further rounds of consultation with MCI.  We firmly believe that Codes drafted based on achieving desired outcomes, without prescriptively dictating the means of achieving that outcome, will allow services to design the most appropriate/effective solution for their particular services. Not tying compliance to a specific method/technology will also avoid stifling innovation in technological solutions to safety challenges.