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Doing More to Address Child Sexual Abuse Materials Online

Brian Cimbolic

For all of us at Public Interest Registry, working to remove child sexual abuse content from the Internet isn't just a part of our work; it's our moral duty. As stewards of the .ORG community, addressing the problem head on is the only option compatible with our values.

Talking about Child Sexual Abuse Materials (CSAM) is challenging and uncomfortable. It's also far too important, and prevalent, of a problem to ignore. While it's impossible to know exact numbers, online CSAM is a major, rapidly growing crisis. Our partners at the Internet Watch Foundation (IWF) identified more than 132,000 global cases of CSAM in 2019 alone. Each illicit image represents an individual child's physical and emotional well-being being put at risk by abusers.

At the domain name level, PIR has limited tools to deal with abuse. Since much of the CSAM that is online is hidden away on large file sharing websites, taking down entire domains is often not feasible. Despite the challenges, we have made every effort possible to lead as an exemplary registry with the removal of CSAM. In 2018, we began our partnership with the Internet Watch Foundation, which has increased our capabilities to mitigate this abusive material and contributes to a safer .ORG community. The IWF is a global leader in identifying and removing CSAM, and one of the only non-law enforcement organizations in the world that is authorized to search for it online. Since the beginning of our partnership, PIR and the IWF have worked to remove over 1,350 links that the IWF identified as containing CSAM. We also work closely with the National Center for Missing and Exploited Children (NCMEC) the U.S.'s primary CSAM reporting agency and watchdog for CSAM. NCMEC and IWF are two worldwide leaders in addressing CSAM and recently announced an information sharing agreement to better equip both agencies to find and remove CSAM online. See: https://www.iwf.org.uk/news/landmark-data-sharing-agreement-to-help-safeguard-victims-of-sexual-abuse-imagery

Our process is simple and effective. When the IWF or NCMEC sends us a link containing abuse, we send a "de-fanged" or broken version of the URL in question to the registrar and give them a short window to ensure that the offending material is removed. In the vast majority of cases, the registrars or registrants act swiftly and the content is removed. When they don't, we do — and the domain name is suspended.

We encourage others to do more to mitigate CSAM

While we've decided to combat this crisis head on, many of our peer companies have not yet stepped up to the plate. For some, it's a matter of not knowing where to start. That's why we co-founded the Child Sexual Abuse Material Referral Discussion Group, a forum for some of the largest registries and registrars in the world to share ideas and identify the very best practices to combat CSAM via the domain name system. The meetings are held under Chatham House Rule, allowing company leaders to have honest discussions and feel comfortable asking for help from their peers. The meetings have expanded to include law enforcement and watchdog groups from across the world. We're proud of the work that has come out of these meetings and determined with our partners to continue the ongoing collaboration and information sharing that is needed. Eliminating CSAM on the web is bigger than any one company.

While some companies are simply in need of a helping hand, others are willfully not taking action. In some cases, companies won't act to remove CSAM unless specifically required to by a court order. Think about what that means. These companies are essentially requiring the child that was exploited (who likely may be located outside the United States) to hire an attorney, avail him or herself of the U.S. court system, and obtain a court order to have images of their victimization removed. Oftentimes these children are not even aware that their pictures are posted online. We think that kind of policy is essentially saying that they are fine to do nothing to mitigate CSAM. To us, that position is irresponsible and certainly unacceptable for .ORG and our other TLDs.

We think that all registries and registrars should establish relationships with organizations like the Internet Watch Foundation, the National Center for Missing and Exploited Children, the Canadian Centre for Child Protection, or their local INHOPE Network hotline to effectively and correctly identify CSAM. When organizations like these identify CSAM, registries and registrars should take steps to address the problem. It shouldn't require a court order to make this happen.

There are some organizations that focus on free expression that take the position that registries and registrars should not take action on content in any case without a court order, without exception. We think this position is misguided in the case of confirmed Child Sexual Abuse Materials. Choosing to allow Child Sexual Abuse Materials to resolve online means the ongoing and continuing victimization of children. For us, if CSAM is confirmed by an expert organization like the Internet Watch Foundation or the National Center for Missing and Exploited Children (i.e. a trusted notifier), we will take action. We have a responsibility to act if others have not (hosting provider, registrar, etc.) and will do so in limited and egregious cases, such as CSAM.

PIR will continue the fight against CSAM

We've worked tirelessly to build a stronger relationship with law enforcement and assist them with removing CSAM. Last month, PIR staff visited the Department of Homeland Security's Cybercrimes Lab to discuss their victim-focused approach and innovations in removing CSAM from the web. During our meeting, DHS restated their commitment to continued engagement with our industry discussion group. We feel that there is a lot of potential shared learnings to be made between DNS actors, law enforcement and CSAM watchdog agencies to address and remove CSAM online via the DNS.

At PIR, we're doing the right thing. From working closely with these CSAM watchdog agencies to sharing our approaches with other companies and law enforcement, we've become an industry leader in combatting Child Sexual Abuse Material via the DNS. We always want to do better to make the Internet free of CSAM. We hope others who haven't taken appropriate action will begin to take up these principles. We're always happy to discuss these tough issues and hope through dialogue the DNS community will continue to improve to address CSAM online.

By Brian Cimbolic, Vice President, General Counsel at PIR
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