Chapter 6 - Offending, prevention and education

Chapter 6Offending, prevention and education

6.1Much of the preceding chapters focus on the proliferation of child abuse material (CAM) and child exploitation online. It is important to emphasise that online CAM originated with the actual abuse of a child. Examination of these horrific crimes online should not neglect their connection to the offline world.

6.2Some context on these matters was provided by the Acting Chief Operating Officer, Office of the eSafety Commissioner (eSafety), Mr Toby Dagg:

Sexual abuse of children is something that happens at a broad level through the community. I think sometimes because of the newness of internet enabled technologies and because of the quite insidious ways they can be misused, we sometimes focus on that part of the problem as opposed to the issue of child sexual exploitation and abuse more broadly. I recall a conversation I had with a senior law enforcement colleague who said that 80 per cent of the work they do is not internet enabled technology; it is the sexual abuse of children that occurs within families and community groups and other places that were examined through the royal commission. Indeed, when we look at the issue of online child sexual exploitation material being produced, it's a consequence of the sexual abuse of a child. Those two things are not separate and shouldn't be considered separate.[1]

6.3This chapter examines key evidence relating to preventing CAM offending and improving law enforcement's engagement with the general public. It proceeds as follows:

The extent of any links between contact offending and noncontact offending, including research on the matter.

Options for offender prevention, intervention and treatment.

Education and awareness among the public of child exploitation risks.

Classification of computer games with online interactivity.

Consideration of a publicly accessible national child sex offender register.

Contact and non-contact offending

6.4In general terms, offenders can be grouped into three categories: contact offenders, noncontact offenders (i.e. CAM offenders), and 'dual offenders' who commit both forms of crime. This section examines evidence about the extent of any link between CAM offending and contact offending, including whether one form of offending contributes to the commission of the other. By distinguishing these crime types the committee is not attempting to compare the seriousness of different types of offending.

6.5The Carly Ryan Foundation expressed concern about unduly diminishing the seriousness of CAM offending by comparing it to contact offending:

If online child abuse material is considered in comparison with contact offending, then the gravity and impact of online child exploitation is diminished. Online child exploitation should be viewed in and of itself, not in comparison to a contact offence. Comparing this against contact offending also plays into the reasons why child abuse material continues to be accessed at concerning rates.[2]

6.6The committee confirms that all forms of child exploitation are heinous.

6.7This section examines key evidence as follows:

Comparing the traits of non-contact and contact offenders.

Evidence about the link between non-contact and contact offending.

Specific forms of overlap between the two types of crime.

Suggestions for further research.

Traits of non-contact and contact offenders

6.8A range of submitters referred to research suggesting that the characteristics of contact offenders tend to differ from those of non-contact offenders.[3] This includes the Australian Institute of Criminology, which cited a 2015 metaanalysis and explained that it found:

…CSAMonly [child sexual abuse material] offenders differed significantly from contact sexual offenders and dual offenders on a range of characteristics, particularly regarding access to children, sexual deviance and antisocial traits.[4]

6.9The Australian Institute of Criminology relayed some of the traits identified by this research:

Contact offenders were more likely than CSAM-only offenders to have:

access to children;

emotional identification with children;

cognitive distortions (eg a belief that 'children are sexual beings');

victim empathy deficits;

a detached approach to romantic relationships;

a greater number of prior offences;

higher scores on measures of antisociality;

greater problems with supervision;

indicators of a severe mental illness; and

childhood difficulties and abuse.

CSAM-only offenders, on the other hand, were more likely than contact offenders to:

be younger;

have a higher income and higher level of education;

have greater sexual deviancy;

have problems with sexual preoccupation and sexual self-regulation; and

have greater barriers to contact offending (eg less cognitive distortions).

The study also compared CSAM-only offenders with dual (CSAM and contact) offenders. Dual offenders were more likely than CSAM-only offenders to have:

access to children;

a sexual interest in children;

prior violent offences;

substance abuse problems; and

sexual regulation problems.

Dual offenders were also more likely to engage in low-commitment sex (eg many partners) and report childhood difficulties. However, CSAM-only offenders were more likely than dual offenders to participate in paedophilic social networks or to have other negative social influences.[5]

6.10The Australian Institute of Criminology also cited a study of policing and mental health records in Victoria, which found that 'CSAM-only offenders differed significantly to contact sexual offenders on eight out of 10 key characteristics measured'.[6]

6.11A further observation about the traits of CAM offenders was presented by Deputy Director at the Australian Institute of Criminology, Dr Rick Brown:

I will just mention something we have in the pipeline that is going through our peer review process. It's a qualitative study that looks at the intersection of child sex abuse material consumption and, to some degree, production, with domestic violence and coercive control. We've found there is quite an overlap there, as well, among male perpetrators. There is a cohort of those that are, for various reasons, coercively controlling their partners and accessing CSAM, and sometimes abusing their children as well.[7]

6.12Emeritus Professor Roderic Broadhurst and Mr Matthew Ball referred to research that suggested there are differences between contact and non-contact offenders:

CSAM offenders were predominantly white males, tended to be older than the average offender (i.e., between 35 and 45 years of age) but younger, more often single and better educated than contact sexual offenders. Very few had prior offences for contact sexual offences and generally were less likely to re-offend than contact child sex offenders. The evidence also suggested that non-contact CSAM offenders "…tend to be less assertive, less dominant and under-socialized" and "…show higher levels of sexual deviancy than contact or mixed sexual offenders and are more likely to fantasize about children". The study concluded that the 'profile' of CSAM offenders "...may be different to that of other types of sexual offenders, especially those who commit contact sexual offences against children". CSAM online offenders are better socially adjusted; have less criminal history; and score lower on factors associated with dynamic risk in contact offenders, such as general self-regulation deficits, interpersonal difficulties, and offense-supportive attitudes and beliefs.

Furthermore, online offenders displayed higher sexual deviancy, experienced more psychological barriers to acting on these deviant interests but also exhibited greater victim empathy than contact child sex offenders. These psychological barriers may be explained by an avoidance of the emotional attachment of real-life relationships - particularly with children, as this subculture knows that it is "wrong" and they cannot neutralise the problem.[8]

6.13The Cyber Security Cooperative Research Centre observed differences in 'demographic and psychological characteristics' between CAM offenders and those convicted of, or charged with, contact offences or both contact and CAM offences. It also submitted:

When it comes to CAM offending, offenders have a tendency to minimise their behaviour, with the online environment playing a key role in not only breaking down barriers in accessing CAM, but also offering a sense of anonymity and security. ACCCE [Australian Centre to Counter Child Exploitation] research indicates that 83 per cent of relevant studies show offenders often perceived the offending behaviour as harmless. It also shows the type of material viewed often escalates from the viewing of normative adult pornography to CAM and more extreme material.[9]

6.14Regarding reoffending, a review by the Australian Institute of Criminology of studies published since 2010 found 'mixed results in studies that compared CSAM offenders with contact child sexual offenders'. It submitted:

Three studies found no difference, while two studies found that contact offenders were more likely to reoffend generally and sexually than CSAM offenders. These studies also found:

dual offenders were more likely to sexually reoffend than CSAM offenders; and

producers of CSAM and those who participated in CSAM networks were more likely to sexually reoffend than other CSAM offenders.[10]

6.15Regarding the proportion of CAM offenders that also commit contact offences, the Australian Institute of Criminology submitted that '[m]ost convicted CSAM offenders do not go on to commit contact sexual offences against children'.[11] It cited several studies consistent with this view but also observed that '[w]hile most research in this area has focused on criminal justice measures of sexual offending (eg arrests or convictions), research on self-reported contact sexual offences by CSAM offenders tends to find higher rates'. For example, one project 'examined six studies based on self-reports from individuals, finding that 55percent of online sexual offenders admitted to previously committing a contact sexual offence against a child'.[12]

6.16Regarding those who produce CAM, Associate Professor Benoit Leclerc, Associate Professor Jesse Cale and ProfessorThomas Holt submitted that there is 'a crucial overlap between child sexual abuse and CEM [child exploitation material] production'. The submitters noted similarities between these groups in their risk factors, gender profile and average age, though also observed there are 'unique risk factors that may drive CEM production aside from individual motivations specific to the abuse (sexual pleasure, power etc)'. They explained some of these differences and how they may lead offenders to commit contact offences:

CEM activities including production are typically conducted for the material itself (i.e., sexual gratification), which provides a link to contact offending. CEM production is also conducted for financial gain; material can be produced with ease, without having to get involved necessarily in organised crime or human trafficking, and without ever leaving the home. Finally, group status and engaging with like-minded offenders and communities are also important motivations to consider especially for offenders engaging in CEM activities on the Open and Dark Web. It is well known that many offenders are seeking a high status in those communities by engaging actively in CEM activities, which may include administering sites and forums, providing advice on security matters, providing knowledge on how to sexually abuse children, and facilitating the access to, and distribution of, CEM. These motivations can all lead many offenders to contact offending for the first time.[13]

6.17Associate Professor Leclerc, Associate Professor Cale and Professor Holt also cited research finding 'that CEM offenders (i.e., producers, distributors, and distributors/possessors) who had previously committed a sexual offence against a child were over seven times more likely to have produced CEM than those with no previous history of contact sexual offences'. The submitters also pointed to research which found 'that the production or provision of CEM, and being an administrator of a CEM network, were also associated with contact sexual offending'.[14]

6.18Dr Mark Zirnsak, Senior Social Justice Advocate, Uniting Church in Australia, Synod of Victoria and Tasmania (Uniting Church Synod), provided a sense of the literature regarding contact and non-contact offenders, stating that it seemed to be:

…quite a debated area. One side of the literature said that there are offenders who are non-contact offenders; there's a notion that there are people who simply view material or purchase material online and that they themselves are not contact offenders, so they commit no physical offence against children. The argument has been that, sometimes, when those people get sent, for example, into a treatment course—once they're prosecuted, incarcerated and put in with contact offenders—they have a similar reaction to contact offenders to what any other member of the public would. They somehow see themselves as different to contact offenders. In their mind, they somehow justify this distorted thinking: 'I didn't do anything wrong. I was just looking at pictures. I didn't actually harm the children.'

Another side of that debate says that those people don't exist; that there aren't non-contact offenders or, if they do exist, they're a very, very small group; and that, in fact, many of those who get classified as non-contact offenders are simply contact offenders who haven't been detected for their contact offences. I've heard that view from law enforcement quite strongly.[15]

Links between non-contact and contact offending

6.19The Cyber Security Cooperative Research Centre advised that:

While some links between the use of online CAM and contact offending have been established, there is no significant evidence to indicate accessing online CAM leads to contact offending or vice versa.[16]

6.20The Centre's Director of Corporate Affairs and Policy, Ms Anne-Louise Brown, referred to 'tentative links' between contact and CAM offending, and suggested this may be due to a lack of data:

…there is a lack of data just because of the fact that this is still a relatively new class of crime. Again, this is just the crimes that are detected. Given encryption and the dark web, the amount of this crime that goes undetected is huge. So, as it goes to contact offending and online offending, it is hard to make those correlations.[17]

6.21The United Kingdom (UK) National Crime Agency referred to a direct link between contact and noncontact offending, and submitted that its research and analysis:

…identified that while some offenders may operate exclusively online or offline, there are direct links between online and offline offending, along what could be considered a continuum of offending. This includes contact abuse being enabled through online networking with other offenders to seek access to children, and offenders using online platforms to discuss offending tradecraft. The livestreaming of abuse online is also effectively contact abuse by proxy.[18]

6.22Victoria Police submitted that '[r]esearch has established a clear association between viewing child abuse material and contact offending'. It stated:

The viewing of child sexual abuse material has been demonstrated to be a high-risk activity or a precursor to contact offending, with research indicating that problematic sexual fantasies or behaviours can begin about nine years prior to the offender first being arrested for a sex crime.[19]

6.23Emeritus Professor Broadhurst mentioned that there are 'obvious signs that viewing online CSA [child sexual abuse] material does push people towards contact or wanting more'.[20]

6.24Associate Professor Leclerc described how some CAM offenders may go on to commit contact offences:

Obviously, as the number of offenders online to view content increases dramatically, what comes with that is that some offenders may never have thought of having sexual contact with a child, but because they're getting exposed to so much content, because they're able to establish relationships with other offenders interested in having sexual activities with children, per se, some offenders can start online, so to speak, and then escalate in the real world and actually sexually abuse a child, maybe just to have the experience of having sexual contact with a child or maybe to produce, to record the material and then trade it for other material, maybe to gain status. I don't think there's any research providing strong empirical evidence on that particular point, because it's too early and it's difficult to collect data on this, but we can see, and it's quite logical in the sexual offending field: there's always some sort of escalation for a number of offenders. The problem with that is that some offenders may start easy but then they may move on to produce sexually offending material themselves.[21]

6.25Associate Professor Leclerc, Associate Professor Cale and Professor Holt further submitted:

The escalation from consuming and/or distributing CEM to contact offending is of particular concern as it arguably generates CEM activities online (in the form of a cycle) as well as contact offending, putting the safety of children at greater risk of abuse.[22]

6.26International Justice Mission quoted research by Protect Children (a Finnish nongovernment organisation) based on an anonymous survey of online CAM offenders, as follows:

"CSAM use endangers not only the children depicted in the abuse material: many CSAM users try to contact a child online. Establishing contact with a child may result in further offences: CSAM users can try to lure the child to an in-person meeting or manipulate them into live-streaming or producing sexual images or videos."

"52% of users have felt afraid that viewing CSAM might lead to sexual acts against a child

44% of users have thought about seeking direct contact with a child online after watching CSAM

37% of users have sought direct contact with a child online after watching CSAM"[23]

6.27International Justice Mission submitted that this and other research indicates:

…there is a direct link between online offending and contact offending. Beyond perpetrators attempting to contact offend, children are often still facing in-person abuse by a trafficker, even if the online abuse is directed on the other side of the world. In addition, there is continued victimisation of the depicted children when the CSAM continues to be shared online, even after the trafficker has been arrested and the child has been rescued. CSAM offenders regularly share files with one another for years or even decades after the creation of the CSAM. A person who causes the creation of one CSAM image is contributing to the unstoppable flow of CSAM worldwide.[24]

6.28Project Paradigm highlighted the prevalence of contact offending in Australia and the ways in which it is intermingled with online offending:

Whilst there is a strong focus on online non-contact offending, in person, community contact offending is occurring right across Australia. Often online and offline child sexual exploitation offending are intermingled and present in combination with each other. This process is multidirectional, perpetrators may use devices to initiate contact, entice young people away from their protective supports, use devices to perpetrate CSAM offences, and arrange to meet up in person and also to control and manipulate young people to commit further offences against them or to procure others. Concurrently perpetrators may groom young people and then transition to CSAM production. Neither exists in a vacuum, however legislation currently focuses on online dangers only.[25]

6.29Mr Dagg, from eSafety, emphasised that child exploitation often manifests as contact abuse perpetrated by a person who is trusted by the child:

More broadly, in relation to the comment that you made about online and offline offending, the view we came to, through being exposed to such a huge flood of content over many years, is that, overwhelmingly, this occurs in private homes and is perpetrated by those who are close to the child, who are trusted by the child. We often think of child sexual exploitation in terms of remote exploitation via webcam and self-produced content and live streaming, but, overwhelmingly, the abuse of children happens within bedrooms, within bathrooms and with those who are part of their family. So all of that offending starts with a physical, real-world offence against a child, and that's important to remember and think on…[26]

6.30The Cyber Security Cooperative Research Centre reported that '[r]esearch has found a significant proportion of CAM is produced and distributed by parents who victimise their children'. It elaborated:

The AIC [Australian Institute of Criminology] has identified parental production as a major challenge to the prevention and detection of CAM. This is because, within the home environment, access to vulnerable children and opportunities for offending can lead to serious abuse, with little chance of offenders being detected. The AIC has highlighted the need for targeted research into CAM production perpetrated by parental figures to help develop strategies to prevent and detect such offending.[27]

6.31When asked about any differences in how the courts treat contact and noncontact offenders, a representative of the Commonwealth Director of Public Prosecutions, Mr Mark de Crespigny, advised that both are treated severely:

Certainly, the penalties for online offending which are available are nearly as serious if not, on occasions, more serious than contact offending. The material which I've seen during my course of involvement here from victims et cetera does indicate that the harm of online offending, particularly when it involves a recording of that offending and then the distribution of that, can be so tremendous, because it's not as if it's a single instance which has happened and stopped; it's a fact that that offending continues into perpetuity as long as that material exists on the web. That aspect of it has to be very much considered…[28]

Forms of overlap between contact and non-contact offending

6.32Submitters highlighted various ways in which CAM offending overlaps with, or can encourage, contact offending. For example, Collective Shout referred to the influence of online CAM networks when positing that there is 'a direct link between viewing abuse images and contact abuse, as well as offenders using the dark web and encryption to hide their activity and identities', with the link being that 'members must produce new material to have access to the group'.[29]

6.33The Australian Institute of Criminology cited research examples which:

…suggest that some CSAM viewers can be encouraged by like-minded individuals online to sexually abuse children in person, for the purpose of producing and distributing new material. An analysis of CSA [child sexual abuse] offenders investigated by the Australian Federal Police found that those who engaged in networking with other offenders were significantly more likely to engage in contact sexual offending than those not involved in networks.[30]

6.34The UK National Crime Agency described its investigation into TashanGallagher to illustrate 'how online activity can lead to escalation to contact abuse':

In order to join a private CSA discussion group which had a condition that new members must post brand new images of abuse, Gallagher raped a sixmonth old baby girl and sexually assaulted a two year old boy, and uploaded the footage to an encrypted app. The NCA [National Crime Agency] was notified of the offences by US Homeland Security Investigations in October 2018, immediately prioritised the case, and arrested him within 24 hours. Under interview, Gallagher said he had been looking at IIOC [indecent images of children] online for around two and a half years. In March 2019, he was sentenced to 15 years imprisonment for his offences, given an indefinite Sexual Harm Prevention Order and made to sign the sex offenders register for life.[31]

6.35A further link with contact offending arises from online grooming and sexual extortion, as described by the Australian Institute of Criminology:

Online grooming and sextortion can also lead to contact sexual abuse, where the perpetrator coerces a child to meet with them. Indeed, analysis of CyberTipline reports associated with sexual coercion and extortion received by NCMEC [National Center for Missing and Exploited Children] estimated that approximately five percent of cases were motivated by the perpetrator wanting to have sex with the child. These cases are different to other cases of CSAM reported here in that they represent CSAM producers rather than CSAM consumers, but they nonetheless show a link between CSAM and contact sexual offending, particularly when the offender demands to meet the child in person.[32]

6.36Regarding sexual extortion, Collective Shout quoted the WePROTECT Global Alliance as follows with respect to the blurry distinction between contact and non-contact abuse:

From a safeguarding perspective, distinguishing between 'contact' and 'noncontact' abuse is misleading. Where the offender is not physically present in the room but directing the conduct remotely, these victims of 'contact abuse by self-touch' may report a heightened sense of guilt and shame, making recovery difficult.[33]

6.37Collective Shout also pointed out that '[f]or contact offenders, CSAM is central to the grooming process, engendering a bond with the victim, demonstrating that there is nothing wrong or unnatural about sex acts, and providing material to potentially blackmail the victim'.[34]

6.38The Australian Institute of Criminology submitted that live streaming of child sexual abuse 'blurs the line between contact and non-contact sexual offending because offenders direct the abuse of a child in another location'.[35] Dr Brown elaborated:

You think of other forms of child sexual abuse material being pre-recorded, pre-photographed, and you're viewing material that's historic, by definition. Live streaming, by definition, is contemporary but also guided by a consumer. In that sense, it combines both contact offending by a third party that is at the other end of the live streaming and offending by the consumer who is conducting that.[36]

6.39Dr Brown discussed a recent operation that identified 256 Australians 'purchasing live streaming of child sex abuse in the Philippines', including '2,700transactions over 13 years by those individuals'. As well as observing that this group was older than typical CAM consumers, Dr Brown explained how this offending escalated over time:

We found that the frequency of transactions increased over time. The duration between transactions declined the more transactions that were made. Also, the amount that individuals were willing to pay for that abuse increased over time, which suggested that individuals were perhaps asking for more severe material over time—another aspect of the escalation—and therefore paying more for it. So it's a particularly problematic form of child sexual abuse.[37]

6.40The Australian Institute of Criminology further submitted that '[b]ecause CSA live streaming offenders (unlike other CSAM offenders) communicate and form relationships with victims and facilitators online, they may be at risk of travelling to offend in person against these children or other children'.[38]

6.41Project Karma discussed the issue of Australians travelling to Southeast Asia to sexually abuse children, including after viewing live online child sexual abuse:

An Australian offender may access live streaming or video of a child being sexually abused from such a region, do some research to find out where the information came from and attain information on how to access the information source and a particular child.[39]

Further research

6.42Notwithstanding the evidence above, several inquiry participants suggested there would be benefits from further research on the links between contact and non-contact offending. The Australian Institute of Criminology submitted that:

If we are to effectively prevent and disrupt both online and offline sexual offending against children, more research is required that examines the link between these two types of offences.[40]

6.43Emeritus Professor Broadhurst and Mr Ball proposed 'a study examining the links between offline and online/contact and non-contact offenders in the context of anonymity'.[41]

6.44Project Karma suggested that we need to better understand offenders in order to create more effective policies and procedures:

The patterns driving offender behaviors can differ greatly. Some may not fall within the legal definition of a 'paedophile' (i.e., with some level of Paedophilic Disorder - PD) which ranges across varying thoughts, behaviors, and activities. Those performing online (or otherwise) CSO [child sex offences] may have no prior convictions and have never touched a child before, or even thought about it until an opportunity arises. This does not make them a 'paedophile'. Others will have a long a history of these characteristics. There is a lack of knowledge in community at every level, around this disorder. In order to make better safer futures for children, we need to better understand the offenders of these crimes. Only then can we create effective policies and procedures that provide stronger prevention and protection.[42]

6.45Victoria Police recognised 'the importance of further research to better understand the characteristics and offending patterns of online offenders, including the link between child abuse material offending and contact offending'. Victoria Police also advised that it is participating in a related research project funded by the Australian Research Council.[43]

6.46The Queensland Police Service expressed support for further research into the link between accessing CAM online and contact offending, and explained some of the potential benefits to law enforcement:

Clarification of current assumptions regarding any nexus between accessing online child abuse material and crossover offending will be useful in better detecting these offenders. Additionally, this type of research may provide opportunities to further raise community awareness of the harm and generate discussion to educate parents and carers about risks and how to mitigate them.[44]

6.47The National Office of Child Safety explained existing research work:

The National Strategy [National Strategy to Prevent and Respond to Child Sexual Abuse 2021-2030] will address gaps in research and data relating to child sexual abuse. This work will enhance law enforcement, intelligence and research agencies' ability to identify offenders within the community, including those engaging in technology-facilitated abuse overseas, and gain insight into offending trajectories.

The Australian Government has already separately funded the first wave of the Australian Child Maltreatment Study (ACMS), which aims to determine the prevalence of all forms of child maltreatment (including sexual abuse) in Australia. The ACMS includes questions on the incidence, context and disclosure of online child sexual abuse, and its co-occurrence with other forms of child maltreatment. The ACMS commenced in January 2019, with preliminary results expected in late-2022 and final results in 2023.[45]

6.48These results were published in April 2023. This broad research considered the prevalence of different forms of child exploitation across Australia, including child sexual abuse.[46]

6.49Regarding research on CAM in general (not specifically about the links between contact and non-contact offences), Associate Professor Leclerc, AssociateProfessor Cale and Professor Holt advised that 'the majority of research and policy related to CEM [child exploitation material] seems to originate from these nations [Western Industrialized nations]'. In supporting research that relates to non-Western contexts, they submitted:

Access to the Internet and technology varies dramatically by region and country at the international level, particularly as a function of poverty and regulation of Internet connectivity. At the same time, there is evidence that CEM production on a fee-for-service basis originates from Southeast Asian nations due in part to high levels of poverty. An increase in online streaming of child sexual exploitation for financial gain in developing countries has also been observed due in part the expanding reach of 4G, and recently 5G. Thus, crucial research is needed to investigate the state of CEM production, distribution, and prevention efforts in non-Western contexts. Such insights are essential to better link law enforcement efforts around the world and assess the ways that industry bodies are actively engaging in countries with limited access to technology.[47]

6.50Associate Professor Leclerc, Associate Professor Cale and Professor Holt also suggested potential benefits in further research on other topics, some of which are examined elsewhere in this report:

It might be beneficial for academia to scientifically evaluate CEM investigation and takedown strategies, regardless of their origin with law enforcement or industry. Understanding the cost to implement a strategy and map its impact on offender displacement and CEM distribution is important to understand its utility in the field. In addition, research on assessing the impact of various CEM investigative methods on investigators to improve the mental and physical health of law enforcement officials over time could prove insightful for training and support purposes.[48]

Offender prevention, intervention and treatment

6.51This section reviews key evidence about options for offender prevention, intervention and treatment as follows:

Opportunities for these sorts of initiatives.

Potential use of warnings and pop-ups.

Further research.

Initiatives in Australia.

Opportunities for offender prevention, intervention and treatment

6.52Some inquiry participants suggested there is opportunity for improved prevention, intervention and treatment initiatives. For instance, EmeritusProfessor Broadhurst suggested that 'a lot more attention needs to be given to the prevention aspects of what we're trying to accomplish here' [in relation to child protection].[49] He highlighted Tor, a 'large, anonymous platform', and proposed that:

…the aggressive anonymity in that environment could be flipped in a way so that we can reach CSAM offenders, online offenders and others, through that medium…it's this idea of trying to develop and deliver effective online treatment for child sex abuse online users and to try to, if you like, engage them in treatment programs.[50]

6.53The potential for prevention and treatment programs was elaborated in a written submission from EmeritusProfessorBroadhurst and Mr Ball:

Spurred by deterrence, shame, or other motivations the limited research about online CSAM offenders indicates that a significant proportion can be helped to desist: i.e., treatable. To capitalise on opportunities for treatment, self-help, helplines and education engagement by civil society actors such as specialist legal and health services (sex abuse desistance programs) with Tor 'community' forums (and other anonymous platforms) is required. The anonymity of Tor can be effectively used to reach these secretive communities and through their nascent self-help efforts explore pragmatic opportunities for harm reduction. Initiatives to improve efforts to suppress CSAM and respond to the impact of the pandemic on child protection are needed.[51]

6.54The submitters gave examples of projects that have been implemented overseas. This includes two UK prison-based treatment programs, though 'neither have been evaluated in respect to recidivism'.[52] The submitters also discussed a trial by Swedish researchers of prevent it, which is 'an anonymous online cognitive behavioral therapy (CBT) program provided via a Tor service aimed directly at active online child sex offenders'. The program targets those who access CAM and would like to stop, and it 'consists of eight weekly modules of discrete content, assignments between modules, and weekly individual therapist feedback'.[53] Moreover, Professor Broadhurst pointed to the ReDirection program that accompanied an online survey deployed by colleagues in Finland:

I think the really innovative thing about that is that, accompanying that survey, which was on a pretty well-established Tor or Onion service dictionary—that's a place you go to on the open net, type in what you're looking for: drugs, malware, child sex, or whatever it happens to be. That then flags the survey but also flags this really interesting online program that the Finns developed called ReDirection. What's astonishing about that is that since that's been running as a pop-up in relation to that survey 8,000 respondents have clicked onto that ReDirection online program, 5,000 of them through the Tor darknet market.[54]

6.55Professor Broadhurst said this suggests 'there is quite a bit of untapped need'. He elaborated:

All of this suggests to me and many of my colleagues that, if we go upstream and try to, if you like, intervene in the earlier stages of child sex abuse material consumption, we might be able to have an impact on the amount of abuse that goes on. We might be able to push people to assistance and that kind of thing, which is the model we really need to be investing in a bit more. Child sex abuse offenders are a global problem, so we have to work with our partners, which, by the way, the Australian government federal agencies seem to be doing a pretty good job of. They do some fantastic transnational policing operations…[55]

6.56Dr Brown of the Australian Institute of Criminology referred to early interventions, such as the UK's Stop It Now program, as 'an important first step', and said:

Any off-ramps that can be created to divert individuals from accessing that kind of material have got to be a good thing, but as individuals become more entrenched in accessing that kind of material, that's when other forms of treatment are going to be more important for dealing with child sex offenders. There we generally have limited options.[56]

6.57Mr Dagg, from eSafety, discussed the need for a range of prevention measures including those that target potential offenders:

I think it's often been said we can't arrest our way out of this problem, nor can we regulate our way out of this problem. Taking a prevention-first approach is fundamental to the way the eSafety Commissioner operates. That's targeting the general populace through a public health model of general awareness, then also focusing on the cohorts that are at risk or particularly vulnerable to exploitation and abuse online with prevention information. We're also supportive of efforts to create mechanisms by which those who are likely to access child abuse material are provided prevention messaging and an opportunity to disclose what's happening in their lives for the purpose of being diverted away from that path. There's a very pleasing pilot being conducted in Australia that is based on the Stop It Now! model. We're in the community of advisers that help guide the program.[57]

6.58DrZirnsak from the Uniting Church Synod suggested that the scale of child exploitation demands a broad approach:

…the sheer volume of child sexual abuse and child exploitation online is so large that the police strategy of simply arresting and prosecution is inadequate, and law enforcement agencies have repeatedly said that. So our focus has been on the need to look at measures that prevent, deter and disrupt this activity to get the volume of offending down, to prevent people entering that trajectory of getting into child sexual abuse and to also provide a safer online environment for children in the first place so there is less potential for them to be targeted. The work by the eSafety Commissioner for Safety by Design is a valuable technological contribution being made in this space.[58]

6.59Dr Zirnsak suggested that 'this problem needs a public health response' and explained:

…as much as possible we need to be looking at measures that passively, without requiring active intervention, drive down the prevalence and incidence of online child sexual abuse and make the pool of abuse that is taking place and that law enforcement need to deal with as small as possible.[59]

6.60Mr Glen Hulley of Project Karma also supported this kind of approach and suggested that the response to paedophilia should extend beyond law enforcement:

Paedophilia has been defined in DSM-5, in psychology, as being a mental disorder under paraphilias. What we know about mental disorders is that there is no cure. For any mental disorder, there is only management and treatment. I think that is the mental switch that our politicians, our law enforcement and our judiciaries need to understand.

In order to create laws that are going to be effective, we need to understand what paedophilia is. We're still of the mindset that it's just another crime. We put them in jail and we expect there'll be some sort of reform and then there's a deterrent for when they come back out. It doesn't work.

We can't lock people up forever. We can't lock people up for what they're thinking, either. There needs to be a whole different way of looking at this, is my opinion, and I think coming at it from an angle of mental health, as a public health issue, opens the door to so many more resources and strategies that can be put forward in a proactive way.[60]

6.61When asked about harm reduction strategies, Detective Superintendent JayneDoherty, Commander, Child Abuse and Sex Crimes Squad, NSW Police Force, spoke anecdotally about the usefulness of programs such as extended supervision orders for contact offenders as tools to curb offending. She suggested such programs could also be beneficial if available earlier:

Through the extended supervision orders team, we have a number of offenders come out of Corrective Services in New South Wales and we can see that they're prone to reoffend. Serious violent or serious sexual offenders, quite often, get put into programs if they're on an intensive corrections order. A lot of those programs are quite successful while they're on them. They're about building relationships, learning to deal with the triggers that lead them down those paths. I think if they were more widely available before they got into that offending—when people are starting to escalate, where they're identified as not being able to build relationships, having these thoughts—if we had the ability to put them into programs such as our extended supervision order that offenders go into, that would be very good. But they are very intensive courses and would take a lot of funding, and probably a lot of training of new people, to be able to do that. They have been successful with some of our prolific sexual offenders, in that it gives them the tools they need to curb some of their offending.[61]

6.62Detective Superintendent Doherty added that, while such programs do not seem to help all offenders, they could be a useful tool to prevent some offending:

I'm a police officer, not a psychologist, so I think that would be something that would have to be much further researched. I'm just going anecdotally from the success we have had with a number of our people through the extended supervision order. There are a number that return to jail very quickly as well, so it doesn't work for all, but stopping one offender can save hundreds of children from being offended against. It won't work for everyone. It will be a tool. It would be a very good tool to try and prevent some offending. It's not going to stop it worldwide and it's not going to stop it forever, but it may just stop that one offender and give them the tools to prevent themselves doing it.[62]

Potential use of warnings and pop-ups

6.63One method of offender intervention that arose in evidence is the use of pop-up warnings. Mr Dagg advised that eSafety had worked with the University of Tasmania to research the effectiveness pop-up interventions:

In 2019, we partnered with the University of Tasmania on this exact question, about whether or not pop-up interventions were effective in discouraging people from accessing child sexual exploitation material, and the results of that research—and, overall, this area of research is in its early days—tended to suggest that deterrence messaging worked effectively to discourage people from taking that next step of clicking through to what they thought might be child sexual exploitation material or at least some form of exploitation material. Obviously, the ethical concerns within that research project were quite sensitive. But the design demonstrated that that was, in fact, a viable approach—particularly when it is backed by a message from a perceived authority like the eSafety Commissioner that there is harm associated with the consumption of child exploitation material and that there were penalties that applied in relation to accessing it or sharing it. So that seems to have been demonstrated by this study and a couple of other studies.[63]

6.64Professor Broadhurst also referred to this research and suggested how its findings might be deployed:

There's been some research. I'm thinking of Jeremy Prichard's work, in particular, where they recently set up what I call a honey pot called Barely Legal, and people self-enrolled on that. The deeper they went into the site, or the more potentially offensive the site was, the more warnings popped up: 'If you go to this next step, you'll be traced.' I think we need to do that all over the place, on the open net. The more we can do that, the better, because Pandora's box has already, for want of a better word, opened up.[64]

6.65Mr Dagg added that eSafety had not yet adopted the pop-ups in any direct way but saw the potential for further research:

Certainly there were some avenues for further research to really understand why it was that deterrence messaging might be more effective than harm based messaging in discouraging people from accessing content. It's a promising area of technical innovation that is worth exploring right across the board.[65]

6.66Dr Zirnsak from the Uniting Church Synod discussed how pop-up messages can be used to refer people to further assistance:

I know the Australian Institute of Criminology has just released a paper that talks about pop-up message and there was work done at the University of Queensland looking at pop-up messages. They are used in other jurisdictions. You can tie it currently to where ISPs [internet service providers] are required to give people a warning message if they're trying to access a site that is on Interpol's 'worst of the worst' list. The pop-up message warns the person they're trying to access illegal material. In some jurisdictions, there is the suggestion you can offer the person a referral: if they have thoughts about child sex abuse, there are places they can go to get assistance to help them overcome those thoughts and that behaviour. They are things people are experimenting with. I know Facebook announced at the start of 2021 they were also experimenting with pop-up messages on their platform.[66]

6.67The Australian Institute of Criminology emphasised that 'more responsibility should be placed on ESPs [electronic service providers] to prevent CSAM from being uploaded in the first instance' and suggested:

These platforms should adopt evidence-based methods such as pop-up warning messages, which can deter the viewing or sharing of CSAM and refer individuals to sources of help. Deterrence messaging campaigns can also reach large numbers of individuals. These tools should also be evaluated; Meta currently uses pop-up warning messages to deter child sexual exploitation, yet there is no information publicly available on their impact or effectiveness.[67]

6.68Associate Professor Leclerc, Associate Professor Cale and Professor Holt also drew attention to warnings provided by search engines:

…many search engines provide a warning banner when individuals enter in terms associated with CEM so as to notify the user that such content is illegal. The same is true for web hosting and social media service providers, such as Tumblr, Instagram, and Snapchat…[68]

6.69A representative of Google, Ms Lucinda Longcroft, advised the committee of the measures the company takes in relation to deterrence and warnings:

We also deter abuse on our platforms in the first place. It's our policy to deindex search results that lead to CSAM or material that appears to sexually victimise, endanger or exploit children. Additionally, if someone uses a search term that makes our algorithms think they're looking for child abuse content, we filter out explicit associations and display warnings that CSAM is illegal and provide information to report CSAM. Here in Australia, we display information to report CSAM to the eSafety Commissioner.[69]

6.70Ms Emily Cashman Kirstein, also from Google, added:

On the deterrence point, as [Ms Longcroft] mentioned, we do ensure that we're elevating warnings and signposting where to report CSAM should users be searching for content or making queries that we believe, or our algorithms believe, would be searching for CSAM. A key piece of that, just to dive in a little bit further to what [Ms Longcroft] said, is to break the correlation between explicit content and children. If our algorithms believe that the query is searching for CSAM, we do not surface any explicit results whatsoever—again, breaking that correlation between explicit imagery and children.[70]

6.71Regarding Apple, eSafety advised that 'Apple will provide warnings and information to those who attempt to search for CSEM [child sexual exploitation material] using Apple services'.[71]

6.72Facebook (now Meta) reported that it has 'a range of customised interventions for users who may be looking for CSAM on our services'. It explained:

We've started by testing two new tools — one aimed at the potentially malicious searching for this content and another aimed at the non-malicious sharing of this content. The first is a pop-up that is shown to people who search for terms on our apps associated with child exploitation. The pop-up offers ways to get help from offender diversion organisations and shares information about the consequences of viewing illegal content.[72]

6.73Facebook (Meta) submitted that the second tool is a safety alert:

…that informs people who have shared viral child exploitative content about the harm it can cause, and warns that it is against our policies and there are legal consequences for sharing this material. We share this safety alert in addition to removing the content, banking it and reporting it to NCMEC. Accounts that promote this content will be removed. We are using insights from this safety alert to help us identify behavioral signals of those who might be at risk of sharing this material, so we can also educate them on why it is harmful and encourage them not to share it on any surface — public or private.[73]

Further research

6.74Dr Brown from the Australian Institute of Criminology suggested that CAM offenders may require a different form of treatment to contact offenders:

There is a difference in time scale for this as a form of behaviour. Contact child sex abuse has probably been around forever as an issue, whereas we're talking really 30 years that this has been a problem in the online space. There is an awful lot of work still to be done to work out what works for CSAM consumers. What we do know, though, is that, when CSAM offenders participate in programs designed for contact offenders, the outcomes aren't very good for the CSAM offenders. So it's not a case of just applying the same kind of treatment. You actually need a different kind of program to deal with this. As we outlined at the outset, there are these different profiles for CSAM offenders compared to contact offenders, and it's that that you need to really home in on and focus on to develop treatments.[74]

6.75Dr Brown advised that the 'state of treatment options for child sexual abuse material offenders is less developed than it is for child sexual abuse offenders'. He explained:

In terms of CSAM offenders, particularly CSAM consumers, we are really only in the early stages of developing treatment programs. In fact, one of those programs has been developed by funding through the Australian Institute of Criminology working with Swinburne University. They've developed a program that is currently being tested in a group-work setting. Hopefully in time, we'll have Australian based programs that can deal with the growth in CSAM offenders.[75]

6.76Professor Broadhurst and Mr Ball acknowledged an 'important body of research and expertise has emerged in the past few years from the Australian Institute of Criminology's Child Sexual Abuse Material Reduction Research Program'. They submitted that '[t]his offers along with international clinical, policing and cybersecurity expertise a foundation for developing online harm reduction programs that lever the advantages of anonymity'.[76]

6.77Dr Brown also spoke about a tendency of CAM offenders to not recognise themselves as an offender which he noted as just one of the reasons why treatment is challenging:

In criminology we would call that a technique of neutralisation, which offenders will apply to their own offending to deny that it's an issue with offending. There are also other reasons that make this a difficult crime from a treatment perspective in that actually showing impact is tricky, because we're often looking at a long periods of time before reoffending occurs and most don't reappear in the criminal justice system, so it's actually quite difficult to prove beyond simply whether there is a change in attitudes and self-reported behaviour whether in fact those kinds of programs are effective. It takes quite a long time before we know whether they're effective or not.[77]

6.78Victoria Police saw value in developing early interventions, noting the need for further research to ensure effectiveness:

Victoria Police also recognises the importance of developing evidence-based early interventions for online child abuse material offenders. Intervening at the start of an individual's offending trajectory, rather than intervening after the offending has escalated to grooming or contact offending, is an important objective. Further research is required into effective early intervention for online child abuse material offending.[78]

Initiatives in Australia

6.79The Royal Commission into Institutional Responses to Child Sexual Abuse recommended that a national strategy to prevent child abuse should encompass 'information and help-seeking services to support people who are concerned they may be at risk of sexually abusing children. The design of these services should be informed by the Stop It Now! model implemented in Ireland and the United Kingdom'.[79]

6.80Subsequently, a National Strategy to Prevent and Respond to Child Sexual Abuse 2021-2030 (National Strategy) was developed. The National Office for Child Safety reported that Theme 4 of the National Strategy is 'Offender prevention and intervention'.[80] Ms Rebekah Kilpatrick, Head, National Office for Child Safety and Assistant Secretary, Attorney-General's Department, told the committee that 'the premise of the National Strategy…[is] that child sexual abuse is preventable'. She said the strategy 'aims…to shift the conversation or shift the work of governments away from the strictly tertiary end—what might be considered a law enforcement response once a crime has taken place—and move it towards primary prevention and secondary intervention'.[81]

6.81Ms Kilpatrick suggested that anecdotally, and from looking at the findings of the Royal Commission, 'an approach which only looks at a policing response is never going to be sufficient. We need to do something to move it away from just leaving it until the crime has taken place'.[82] Ms Kilpatrick highlighted that one program under the National Strategy is:

…a measure to set up a national prevention service for people who have thoughts and concerns about their own behaviour towards children but perhaps haven't yet offended. The royal commission made a recommendation that Australia set up a service similar to a UK model called Stop It Now, which is an anonymised help-seeking service where you are able ring up and discuss what might be concerning you about your behaviour, or what may be concerning you about somebody else's behaviour and get some advice about where you might be able to seek help for those thoughts and feelings. It's moving that towards early intervention or prevention.[83]

6.82The National Office for Child Safety observed that the Royal Commission found there was support for this type of service among a range of stakeholders. The National Office also advised similar services have been implemented elsewhere:

In addition to Stop it Now! in the UK and Ireland, similar services have been established internationally in other like-minded countries, including Stop it Now! in the US, Safe to Talk in New Zealand and Talking for Change in Canada. We understand from discussions with some of these services that demand for these services is high and concerns primarily relate to meeting demand.[84]

6.83At the time of providing evidence in November 2022, Ms Kilpatrick said the Australian service was still being developed:

We're going through a period at the moment of working out international best practice, including the Stop It Now model, how that translates to the Australian context and what would work best for us. We're doing that in really close partnership with states and territories and with police and colleagues.[85]

6.84In a further update, the National Office for Child Safety advised that a similar service had been rolled out in Australia and this would inform the new national service:

The National Office is aware that in 2020 Jesuit Social Services and the University of Melbourne received a nonongoing Westpac 'Safer Children, Safer Communities' grant of $900,000 over three years to develop a pilot Stop It Now! Program in Australia. The Head of the National Office sits on the pilot's advisory group, and will ensure that any relevant learnings from the time-limited pilot will be utilised for the roll out of the new national service.[86]

6.85eSafety also provided information about this pilot program, which:

…focuses on a gap identified by the Royal Commission into Institutional Responses to Child Sexual Abuse in relation to preventative interventions for potential perpetrators. The program aims to work with adults concerned about their own, or someone else's sexual thoughts or behaviours towards children and includes online behaviours. The pilot's outcomes will be considered by the Australian Government (via the National Office for Child Safety) as it designs and implements a new national child sexual abuse offending prevention program.[87]

6.86A second body of work under the National Strategy, highlighted by MsKilpatrick, is a post-custodial program:

It's looking to work with individuals who have been convicted of a child sexual abuse offence to promote accountability and prevent reoffending. It's looking more towards that reintegration into the community model. Again, that work is in the early stages and looking at international best practice and what might work in our context. It's looking to roll out a pilot in the coming year.[88]

Public awareness and education

6.87While the previous sections focused on child exploitation offenders, the evidence suggested there is also scope to respond to this problem through ongoing public awareness and education initiatives. For instance, Mrs Jen Hoey, Founder and Parent Cyber Safety Consultant, Not My Kid, explained that after her daughter was targeted online, she started to educate herself about online child exploitation:

I've discovered that it's essentially a silent problem, and by 'silent' I mean that the public at large is largely unaware of the dangers and frequently do not wish to engage with the issue.

This makes it challenging for law enforcement, who rely on among other tactics reports, to apprehend an offender.[89]

6.88This section first reviews evidence about the benefits of public education and civil society initiatives in this area. It then examines existing public awareness programs by government.

Benefits of education and existing civil society initiatives

6.89Ms Madeleine West, who gave evidence in a private capacity, emphasised the need to 'make it very clear to the population at large just how insidious this is, that it's happening everywhere'.[90] Ms West posited that parents and carers 'are largely blind to the real threats of online engagement and we frankly avoid involving police because we feel that reflects poorly on our capacity as parents. We prefer to deal with it ourselves'.[91] She emphasised the importance of education:

As parents, we all want our kids to be safe. Only education ensures we are adequately able to assess risk, and make decisions equipped with an ability to gauge who likely predators are, how they think, and where they hide.[92]

6.90Ms Kirra Pendergast, Chief Executive Officer of Safe on Social—a nongovernment organisation that delivers education programs—conveyed the need for greater and more contemporary public awareness about child exploitation:

I think the education that's being brought to schools and things is far too slow. When I speak, you literally watch the scales fall out of people's eyes when they realise what is actually going on. It seems to me that the education in schools and of the police is at least 12 months behind where it needs to be. Occasionally something will pop up about sextortion, which is the number one thing now, but the subtleties aren't delivered there…

I don't think there's enough being done to educate parents and students around eliminating the fear from speaking up. A lot of people that work in the cyber safety sector are ex-police officers. They come in with the 'don't, don't, don't, don't, don't'. Well, 'don't' doesn't work…[93]

6.91Mrs Hoey stressed the need to educate parents about child exploitation risks:

The reason I called the company Not My Kid is that is the standard response I get from parents: 'This will never happen to my children. My children are mature enough to handle this. We've had our conversations.' I have been given a whole host of explanations by parents over time. I've thought long and hard about the question: how do we educate parents?[94]

6.92Mrs Hoey recommended that there be mandatory education for parents regarding the prevention of child exploitation online.[95] On behalf of Not My Kid, Mrs Hoey provided various data to suggest that 'most parents of school aged children are unaware of the dangers in the online world for children'.[96] Not My Kid also submitted:

Parents, in most cases, are the primary carers of their children. As such they should be equipped with as much knowledge as possible to protect and guide them. Due to the lack of education those who are proactive are in the minority, which makes parenting challenging when most of their children's peers are online unsupervised. Many parents report feeling overwhelmed and not sure where or how to start. Parents require education with strategies they can implement in their homes. Education around protective behaviour is fundamental and includes using the correct names for body parts, and the discussion of safe and unsafe secrets, early warning signs and safety teams. Robust annual education about online safety is necessary if we hope to change the trajectory of online child exploitation. As mentioned previously, schools are offering education, however, attendance is poor and is usually missed by those who most need to be there.[97]

6.93Ms Pendergast similarly highlighted the need for education for parents so they can be aware of emerging trends:

There needs to be ongoing education, which may become part of an orientation when their child starts school or something along those lines. It almost needs to be like a St John Ambulance first aid certificate that a parent does to understand the absolute basics of how they're putting their child at risk online by having no education as well, and making sure that part of that is that they're not fearful to speak up to law enforcement, and there needs to be ongoing and faster training of law enforcement to keep up.[98]

6.94In addition, Ms Pendergast drew attention to risks associated with childcare centres and schools using apps to share information, and suggested parents should have more control over their child's digital presence.[99] She detailed these risks in a submission on behalf of Safe on Social:

When parents or guardians sign up for the service provider's App on behalf of their child (often being told that if they don't, they will miss out), they are also aiding in the creation and building of their child's digital footprint, which the child has no control over. Sensitive information, including medical records, is also entered into the App, which third parties can access if the App's security measures are not adequate.

Moreover, many apps allow users to invite "family" to view the child's journal, which includes other children if they are featured in the child's account. More often than not, someone else is seeing the child, someone the parent or guardian has not consented to, and the child they have permission to view. This may be a significant security issue when someone who may be a predator is invited into these photographs of children going about their day at day care, primary school, after-school care, and after-school activities such as dance classes.

As we all know, predators are not looking for photos of naked children; they are just looking for children.[100]

6.95Safe on Social provided the following example and argued that mandating the use of these apps is taking control and choice away from parents:

We all sign Permission to Publish forms for our children, and there used to be a choice. If you opted out, you would be emailed the photo or given a printed copy. But lately, Safe on Social has been contacted more and more by parents that feel discriminated against. For example, a parent got us upset that she had to pull her child from an early childhood afterschool activity because she didn't agree to photos of her child being published online. She had escaped domestic violence and did not want pictures of her child online. She was told that her child could not participate if they could not be photographed and published on the business's social media pages. This must stop.[101]

6.96The risks of photographs in childcare and schools are particularly salient given the recent Australian Federal Police (AFP) investigation which led to a former childcare worker being charged with 1,623 child abuse offences against 91 children. The AFP alleges the man recorded his offending on phones and cameras while working in childcare centres.[102] Following this, the Chief Executive of the Australian Children's Education and Care Quality Authority, Ms Gabrielle Sinclair, recently said during supplementary estimates hearings:

We certainly will be making the recommendation to education ministers that personal devices, including iPads, for example, should not be allowed [in childcare centres]. We believe that taking images of children is not acceptable. We believe that only a service mobile phone or iPad should be used. Indeed, we hope anyone entering into a service—and we're going down that track, but we haven't finished the report—will not be able to bring their personal device into a service.[103]

6.97Inquiry participants also suggested that children should be educated about exploitation risks.[104] This includes Ms West, who proposed that:

…children should be educated about what predation, grooming and abuse looks like, online and off, from the age of 5. Naturally this should be delivered in an age appropriate manner and form part of the primary school curriculum, because statistics show the highest incident of children disclosing abuse occurs around the age they are introduced to sex education.[105]

6.98Safe on Social recommended that children 'need to be provided with standard online safety provisions and encouraged to talk about any concerns with a trusted adult'. Regarding online age restrictions (which were discussed with respect to social media in chapter 5), Safe on Social said it 'is important to note that there is no effective policing of user-entered age, and children need to be educated on why age restrictions are necessary'.[106] Safe on Social also raised concerns about the efficacy of some existing programs in schools, and proposed:

…comprehensive education programs should be developed and delivered by private companies with expertise in child safety and online safety. These programs should aim to empower children with the necessary skills and knowledge to keep themselves safe from harm.[107]

6.99Project Paradigm indicated that it has been 'been proactively engaged in delivering community education nationally on the issue of CSE [child sexual exploitation] through social posts, podcasts, webinars, and community conversations. This is in conjunction with comprehensive training for professionals that Project Paradigm delivers nationally'.[108]

6.100Mr Hulley of Project Karma submitted that one of the ways non-government organisations can contribute to countering child exploitation is via education and awareness work. He described a pilot program run by Project Karma in Bali for different age groups in Balinese schools, which was part of a two-year study where a 'working party consulted with communities and school authorities to come up with a program that is authorised by local culture, religion and all those types of things'. Mr Hulley added:

These are local programs that NGOs [non-government organisations] can run and they can assist by bringing in the local government resources, not necessarily national. That's where I think NGOs work very well.[109]

6.101Destiny Rescue raised concerns about Australians travelling to Southeast Asia and sexually abusing children. It supported an education campaign to counter this issue:

Australia has an obligation to continue to conduct awareness-raising campaigns directed at departing travellers bound for ASEAN [Association of Southeast Asian Nations] countries. The focus of these campaigns should be to counter the sexual exploitation of children in the context of travel and tourism.

This is one very practical way Australia can support responsible tourism in the region.[110]

6.102Destiny Rescue also said that it 'wishes to collaborate with Australian law enforcement agencies in relation to the implementation of any such awareness raising campaign'.[111]

6.103Facebook (now Meta) submitted that it has a range of 'partnerships to assist with education and empowerment of children and parents engaging online'. This includes guidance for the tools available on Instagram:

To support parents to understand the tools that are available on Instagram, we worked with ReachOut to develop an Instagram Parents Guide that contains suggested conversation starters to better understand how their teens are using Instagram and how to ensure they are using it safely and positively. We released the Guide in September 2019 and updated it in June2021.[112]

6.104Collective Shout expressed concern that there is '[p]oor public awareness of CSAM as a crime'. This includes that '[y]ounger people are less likely than ever to report sexual images of children'. In recommending that '[p]ublic awareness should be raised regarding the criminal nature of all CSAM', it submitted:

The Internet Watch Foundation recently ran a #SoSockingSimple campaign highlighting the lack of awareness and understanding among young adult males that viewing CSAM is illegal and should be reported. It has been observed that some offenders arrested for the viewing or possession of indecent imagery of children claim they have not committed any crime as there was no contact abuse. They believe no crime was committed since they weren’t involved in any coercion, especially where children have posted images and videos themselves.[113]

Work by government agencies

6.105The committee received evidence about a range of education and awareness initiatives being conducted by government. Indeed, the National Office for Child Safety advised that one of the themes under the National Strategy is 'Awareness raising, education and building child safe cultures'. It reported that under the strategy:

…the Australian Government will engage key stakeholders to prevent and raise awareness of harmful behaviours online through:

providing $3.0 million to the Office of the eSafety Commissioner to deliver targeted online education programs to support parents and families to prevent online harms to children

providing $2.95 million to help the Department of Home Affairs build relationships with the digital industry to drive a coordinated and collaborative charge against offenders' exploitation of online platforms to commit child sexual abuse-related crimes.[114]

6.106The AFP drew attention to a range of education and awareness initiatives that it leads along with the ACCCE. One longstanding program is ThinkUKnow, which is 'an evidence-based education program led by the AFP and delivered nationally to prevent online child sexual exploitation and has been delivered nationally since 2010'. The AFP explained:

ThinkUKnow aims to support parents, carers and teachers in preventing and managing safety challenges that children and young people may face online. The program was developed to assist children and young people, from kindergarten/prep to year 12, to identify safe or unsafe situations and know when and how to seek help. The content is pro-technology, encourages help seeking behaviours, and addresses topics including self-generated online child exploitation material, online grooming, image-based abuse and sexual extortion.[115]

6.107The AFP advised that it 'undertook updates to the ThinkUKnow presentation suite for 2022, to reflect trends and issues based on real reports and investigations'.[116]

6.108The AFP also advised that the ACCCE identified, through 'market research and consultation with stakeholders', that 'confusion still exists in the community around what constitutes online child sexual exploitation, where to report matters, and the work of the ACCCE'. In response, the ACCCE launched a series of 'new online animations to raise awareness and prevent child sexual exploitation'. The animations are: What is the ACCCE, What is Online Child Sexual Exploitation and How to Report Online Child Sexual Exploitation.[117]

6.109Acting Assistant Commissioner, Northern Command, AFP, MrStephenDametto, described the AFP and ACCCE's response to the need for further education initiatives:

Despite the prevalence of online child abuse offending more broadly, research shows that only 52 per cent of parents talk to their children about online safety. To combat this, the ACCCE and the AFP have developed a picture book to help start conversations about being safe online.[118]

6.110The children's picture book, titled Jack Changes the Game, was launched by the AFP and the ACCCE on 4October 2022.[119] Mr Dametto explained:

The book aims to help families and school groups to start age-appropriate conversations about online grooming. The book is based on a real report to the ACCCE and is supported by an academic reference group of experts in child protection and education. The book is complemented by a ThinkUKnow learning package, including teacher lesson plans and at-home learning for families. The AFP is preparing to distribute this book to more than 8,000 primary schools across Australia.[120]

6.111Mr Dametto also explained that the AFP and the ACCCE see the 'education and awareness piece' as part of their role:

Jack Changes the Game is part of that. We identified a gap. We didn't think there was any education material for five-to-eight-year-olds, and there's also the figure I mentioned before—a lot of parents won't speak to their children about online safety. That's just one of the programs that the ACCCE are doing about raising that awareness and making it comfortable for people to talk about. I think we see that as part of our prevention role in relation to this.[121]

6.112Key additional AFP and ACCCE initiatives raised in evidence are listed below:

The ACCCE has implemented the Stop the Stigma awareness campaign.[122] AFP Deputy Commissioner, Operations, MrBrettPointing, said the campaign was launched in September 2021 'in partnership with Australian of the Year Grace Tame and various other non-government organisations'. He said the campaign 'aims to destigmatise sexual abuse and was met with great success, with half a million views on social media'.[123] MrDagg, eSafety, observed that this campaign:

…has real victims and real parents talking about their experience and working to start a conversation about the reality of sexual abuse in our community against children, and I think that's a very important innovation in our conversation and the state of maturity in relation to this issue.[124]

In March 2021, the ACCCE launched Stop Child Abuse – Trace An Object. It explained this initiative was '[o]riginally developed by Europol' and 'engages with the community to assist with the identification of objects, clothing or surroundings taken from the background of child sexual abuse images and videos'. The images are hosted on the ACCCE website and, as at August 2021, it was 'the most viewed page on the website'.[125] The AFP reported that, as at 30 August 2023, '192,782 people have visited the ACCCE related webpages, resulting in 908 tip-offs to the AFP'.[126]

In June 2021, the ACCCE and AFP launched the Closing the Net podcast, 'a ten part series that highlights the work of law enforcement, government, academia, and non-government organisations'. The podcast 'provides tips and advice around how to protect children online, and how to identify and report offensive online behaviour'.[127] By December 2021, it had been downloaded more than 70,000 times.[128]

Noting the disturbing increase in online sexual extortion, the AFP and ACCCE have developed:

…an awareness and education package, including a new ThinkUKnow education resource aimed at teenagers from 13-17 years old on how to recognise sexual extortion and how to get help; a media and social media campaign; and video message to encourage young people to report to police. In a four-day period, it is estimated that the campaign reached 7.5 million people.[129]

In October 2022, the AFP advised that the following month the ACCCE would launch a 'pilot awareness and deterrence campaign at Brisbane International Airport, targeting travelling child sex offenders'. It submitted:

This ACCCE priority program has been designed to address the increasing prevalence of sexual exploitation of children in the context of travel and tourism, which is strongly linked to online child exploitation. Following the pilot in Brisbane, the ACCCE will look to roll out the campaign nationally in early 2023.[130]

While not solely about public awareness, the AFP recently called for the public to provide childhood photos of themselves as part of the My Pictures Matter initiative. These images will 'support the development of ethical artificial intelligence (AI) to detect child sexual abuse material in videos or photos shared on the dark web or seized during criminal investigations'. Deputy Commissioner Lesa Gale reportedly said that '[b]y having access to ordinary, everyday photographs, the AI tool will be trained to look for what is different and identify unsafe situations, flagging potential child sexual abuse material'.[131]

6.113In addition to work by law enforcement, eSafety has a legislated role to 'improve and promote online safety for Australians, which includes supporting and encouraging online safety education in Australia'. The statutory functions include:

supporting and encouraging measures to improve online safety for Australians

supporting, encouraging, conducting, accrediting, and evaluating educational, promotional and community awareness programs relevant to online safety for Australians

coordinating the activities of Commonwealth Departments, authorities and agencies relating to online safety for Australians, including children.[132]

6.114eSafety advised that its education and prevention resources are:

…evidence-based and provide extensive advice to children, young people, parents and carers, and educators about a wide variety of online safety issues. We also have specialised resources for communities that may be marginalised or at greater risk of experiencing online harm.[133]

6.115More specifically, eSafety reported:

The eSafety website includes advice about unwanted contact and grooming, how to report online exploitation (including to the AFP), and how to manage hard-to-have conversations with children about online safety. eSafety offers webinar-based training for teachers, parents and carers and young people, including in the current series 'Dealing with online harassment and image-based abuse' for parents, and 'Online boundaries: it's ok to say no' for young people. This training has reached 133,936 parents, carers, and teachers during 2021-22.[134]

6.116Further eSafety initiatives that it highlighted include:

The provision of 'a range of downloadable resources including a guide to online safety for parents and carers, a set of Early Years materials and recently released materials for 5–8-year-olds'. eSafety said that '[t]hese resources assist both parents and teachers and encourage them to stay engaged with children's online lives'.[135]

The publication of a Best Practice Framework for Online Safety Education, which is 'laying the foundation for a consistent national approach to education and prevention'.[136]

As part of the National Strategy to Prevent and Respond to Child Sexual Abuse, eSafety is 'delivering the Families Capacity Building Project' which 'delivers targeted education that supports vulnerable families to recognise and prevent harmful behaviour online with a specific focus on issues related to online child sexual exploitation and child safety'.[137]

6.117Mr Dagg of eSafety recognised the challenges of connecting with busy parents when delivering eSafety's education initiatives:

Reaching parents can be one of the most difficult parts of our job as an educator. Parents are very time poor…We provide a very extensive parents' guide at esafety.gov.au that goes into a lot of the risks—and benefits—of using immersive technologies like Roblox. We also provide a fairly extensive guide to Roblox on the website as well, and other similar environments. We also have an immersive technology position statement…which was written and published in 2020. We'll be looking to update that soon. But more broadly we also support the Trusted eSafety Provider program, where we work with private providers of online safety education to go into the community, to schools and other community spaces, to provide online safety education that we help shape through our community of practice and that is anchored to some of the key messages of the eSafety Commissioner. That's a way for us to scale our messaging. We don't have the resourcing to go into schools ourselves to reach the community more broadly, except through digital means. We also have a very extensive webinar series that is intended to reach Australian schoolchildren. But as far as the community is concerned, it's the Trusted eSafety Provider program that is our major focus.[138]

6.118Mr Dagg also explained some of the challenges regarding sexual extortion of children:

One of the challenges we have seen through the research is a split between how young people are engaging with their parents in relation to what they're experiencing online and how their parents are paying attention to what they're being told. There is about a 20-point split between the number of young people who say that they told their parents about something that was upsetting or concerning or threatening online and their parents remembering having that conversation. We continue to work on options to address parental and carer awareness and empower them with the knowledge and understanding, the tools and technologies, that they need to become familiar with to ensure that children are safer online. That's a perennial challenge for us, for law enforcement, for anyone working in this space.[139]

6.119Mr Dagg noted the recent expectation expressed by the minister that eSafety focus on awareness raising education, and indicated that 'you can expect to see an even greater focus from the eSafety Commissioner on those awareness raising activities'.[140]

6.120Mr Dagg also reported that '[a]ttitudes are changing':

We are seeing a greater awareness among young people about the options available to them to take some form of positive action when it comes to encountering content or conduct that makes them feel uncomfortable online. Now more than 90 percent of young people take some form of positive action, which includes reporting to eSafety, which is great.[141]

6.121The AttorneyGeneral's Department advised it is aware of the Online Safety Grants Program, administered by eSafety, which 'provides $10 million (over three years from 2020-2021) to non-government organisations to develop and deliver online safety education to children, young people and their communities, or training to those who work with them'.[142] The department also described its efforts to raise community awareness via screenings of a documentary called 'The Children in the Pictures', which:

…follows the investigators and operations initially of the Queensland Police Service Victim Identification Team Taskforce Argos, later located within the Australian Centre to Counter Child Exploitation (ACCCE), as they attempt to identify victims of child abuse over a 10-year period.[143]

6.122The AttorneyGeneral's Department has arranged international screenings of the documentary and, domestically, 'the department is committed to engaging with industry and non-government partners to screen and utilise the documentary to raise community awareness of the ACCCE and broader law enforcement efforts'.[144]

6.123An international example of an education campaign was provided by the UK National Crime Agency. In response to the heightened threat of child exploitation due to COVID-19 lockdown restrictions, the National Crime Agency launched its #Onlinesafetyathome campaign. It described the campaign and its outcomes:

During the first national lockdown, the NCA-CEOP [National Crime Agency – Child Exploitation and Online Protection Centre] Education team designed new guidance to help families manage some of the key challenges highlighted in a Thinkuknow survey, completed by over 300 parents / carers. The team also launched fortnightly #Onlinesafetyathome packs to support parents and carers to deliver online CSA education within the home, each comprising five activity sheets based on Thinkuknow content and other online material. Age-targeted activities across age groups from 4to 18 included safety advice around: feeling worried or upset online; gaming; online relationships; what to do if your image is shared online; the role of the bystander in nude images being shared online; and live streaming and video chatting.

A significant promotion campaign resulted in the #Onlinesafetyathome packs being downloaded over 500,000 times. Additionally, the Education Team provided updated guidance for parents, carers and children through a new Thinkuknow Parentlnfo article, on the best reporting and support routes, should they be worried about something online.[145]

6.124Some state law enforcement agencies expressed support for education and awareness initiatives. NSW Police said there is 'an ongoing role for media campaigns concerning child exploitation', and cited the example of an AFP media release under the ThinkUKnow back-to-school campaign:

As a preventative approach, this campaign raises awareness about online grooming during the back-to-school period. This had an accompanying social media component which saw a total audience reach of more than 800,000. The media release and proactive media engagement lead to an estimated audience reach of more than 8 million people.[146]

6.125A representative of Victoria Police, Ms Welsh, supported 'a systems approach' to reduce harm to children online. Among other elements, she explained:

For example, we need to broaden community awareness about the extent of the problem so that the ever-increasing harm to children enabled by technology is high profile, much like the awareness campaigns for drugs, alcohol, seatbelts, speeding and the pandemic response.[147]

6.126On 22 October 2023, the Australian Government launched a $22.4 million 'One Talk at a Time' campaign. A media release from the AttorneyGeneral, theHonMark Dreyfus KC MP, described this as 'Australia's first national campaign aimed at preventing child sexual abuse'. The campaign 'is targeted at adults who play an active role in the lives of children and young people and encourages them to have ongoing, proactive and preventive conversations about child sexual abuse'. The media release said that the campaign is:

…a key measure under the National Strategy to Prevent and Respond to Child Sexual Abuse 2021-2030 and fulfils a recommendation of the Royal Commission into Institutional Responses to Child Sexual Abuse.[148]

Classification of online games

6.127Several inquiry participants highlighted the exploitation risks facing children playing online games. This includes Mrs Hoey of Not My Kid who described her daughter's experience:

…she had been in the process of being groomed via an online game when she was nine while spending time at someone else's home. I had rules in place and this came as quite a shock to me, but I responded with empathy and reassurance. At the time she believed that the other person was also a nineyear-old girl. After numerous in-game chats with the perpetrator, she was threatened with arrest if she told anyone what they'd been doing on the game. Essentially what they had been doing was mimicking sex acts, which is a typical desensitisation technique used by online predators.[149]

6.128Ms Pendergast, Safe on Social, described a disclosure she received from an 11year old girl while at a school:

The one that sticks in the front of my brain that I will never forget was an 11-year-old describing full-blown sexual assault to her in game character in Roblox, which is a little game that targets kids in primary school from grade3. This little one was so distraught the principal said, 'Is this a mandatory report?' So, there's another layer; the principals don't know when to report what or where to report it. In this particular case, the little girl kept saying, 'It happened to me. It happened to me.' Because with the extension of their ingame character there is no distinction between online and off anymore.[150]

6.129Safe on Social suggested that this was not an isolated incident:

My team at Safe on Social has received numerous reports from children under 13 during every single session we conduct, where they have been asked to be someone's boyfriend or girlfriend in the game while playing Roblox. Some children have been asked to be the Mum or Dad in roleplaying games in exchange for free Robux, the in-game currency, to be "adopted" or to lay down on top of someone else's avatar. Parents have reported that their children have seen nude or semi-nude avatars within the platform, simulated sex and sexual acts between avatars within certain roleplaying games, and are often asked to date, other players. Sexualised and crude language is also frequently observed, which would usually be blocked or restricted by Roblox child safety filters but has somehow been bypassed.[151]

6.130A further example was provided by Ms West, who was approached by a potential predator when playing an online game with her children:

Playing alongside my then seven-year-old twins in a game called Brookhaven, within Roblox I went into a chatroom on invitation. My avatar was asked to engage in quite heinous, aggressive sexual acts. And then I was aggressively taunted by other players when I didn't.[152]

6.131One notion explored during public hearings was whether online games should receive a higher classification (such as above 'General (G)') if they enable players to go into private chat rooms. This idea received support from Ms West, who said 'I think there definitely need to be classifications that specify that these offshoots, chatrooms, et cetera, are not regulated; it's not the body of the game'.[153]

6.132Mr Dagg, eSafety, explained that currently 'we apply the guidelines to the classification code, which are focused on content as opposed to experience or as opposed to conduct'. He also outlined potential challenges in applying the classification code to future technologies such as the metaverse:

When we look at Roblox as an environment—it's kind of a prototype metaverse really. It's an immersive environment. It allows deep interaction. It allows for the creation of a parallel world. It's not like a computer game in the sense of its being subject to the usual classification processes. The challenge that we've got always when applying the classification framework is that the classification framework came out of the need to classify films on a commercial basis and then later computer games, using very similar concepts to classify computer games. They start to become quite challenged when we think about the metaverse. When we look forward to a time when we are using haptics to interact with digital environments that create not just the objective, visible, observable interactions on a platform but also a subjective sense of being there and being touched, potentially, then we start to see some of the challenges inherent in applying that traditional classification framework to an environment like a fully immersive one such as the metaverse.[154]

6.133The Department of Infrastructure, Transport, Regional Development, Communications and the Arts confirmed that currently:

…the Classification Board provides consumer advice of 'online interactivity' to alert players and parents when a game allows interaction with others online or when usergenerated content can be uploaded.

These features do not currently affect the classification rating of a game.[155]

6.134Regarding this 'online interactivity' consumer advice, the department also submitted:

This approach empowers Australians to make informed choices for themselves and children under their care. That said, the classification framework alone is not well suited to addressing concerns about interactions between children and others while gaming online.

Parents who are concerned about their children interacting with others while gaming are also able to use parental controls available on gaming platforms which can disable or restrict player interaction. Resources for parents and carers on controls in social media, games and apps are also available through the eSafety Commissioner's website at eSafety.gov.au.[156]

6.135Since the Department's evidence, the government has published the Review of Australian Classification Regulation by Neville Stevens AO (completed in May2020 and known as the Stevens Review) and announced plans to reform the classification scheme. The Minister for Communications has said that this will include, among other things, a 'second stage of classification reforms [that] will deliver comprehensive reform to the [Classification] Scheme, including potential changes to clarify its purpose and scope, and establish fitforpurpose regulatory and governance arrangements'.[157]

Public child sex offender register

6.136The committee received limited evidence about the establishment of a publicly accessible national child sex offender register.

6.137Currently, each Australian state and territory requires certain child sex offenders to report personal information to police, such as their address, though there is variation between jurisdictions. This information is generally not publicly available but there are some exceptions.[158] For example, Western Australia has allowed restricted public access to information about sex offenders since 2012. As explained by an Australian Institute of Criminology research paper:

…local residents are required to enter their name and drivers licence to request information on missing registered sex offenders and sex offenders living in their area. Parents may submit a request as to whether an individual who has contact with their child is a registered offender.[159]

6.138The question of a public registry has arisen elsewhere in Australia, such as the Northern Territory[160] and South Australia[161]. For international comparison:

The United States has had public registers of child sex offenders since the 1990s. A searchable website provides the public with the identities and locations of convicted sex offenders.[162]

The United Kingdom permits a narrower form of disclosure, with parents, carers and guardians able to ask the police if someone has a record for child sexual offences.[163]

6.139Public registers have also been considered in other contexts. In 2021, the House of Representatives Standing Committee on Social Policy and Legal Affairs recommended that:

…the Department of Social Services commission research on the potential benefits and risks to victim-survivor safety of the establishment of a publicly accessible register of convicted family, domestic and sexual violence offenders.[164]

6.140At a Commonwealth level, the Australian Criminal Intelligence Commission (ACIC) currently administers, on behalf of state and territory policing agencies, the National Child Offender System. This system is 'a web-based application that allows Australian police to record and share child sex offender information'. It consists of the:

Australian National Child Offender Register (ANCOR), which 'allows authorised police officers to register, case manage and share information about registered persons'; and

Managed Person System, which 'holds information on alleged offenders who are charged but not convicted, or after an offender's reporting obligations have been completed'.[165]

6.141The AttorneyGeneral's Department advised that the 2019-20 Budget provided $7.766 million over four years to the ACIC 'to build the system for a national public register'.[166] The budget measure said:

State and territory law enforcement agencies will be responsible for providing, vetting and managing the information to be included on the Register, with the information to include the names and known aliases of child sex offenders, photographs of the offender, their date of birth, physical description, general location and nature of offending.[167]

6.142The committee sought updates on this budget measure but it appears there has been little progress. In March 2023, the Attorney-General's Department provided a timeline of key developments which included:

In June 2019, the Former Ministerial Council for Police and Emergency Management and the Council of Attorneys-General agreed 'to convene the National Working Group on Child Sex Offenders…to assess whether a national public register is in the best interests of community safety'.

In August 2020, the working group finalised its report.

In February 2021, the Ministerial Council for Police and Emergency Management was disbanded by National Cabinet.[168]

6.143In December 2021, the committee was advised that all jurisdictions' police and justice ministers had met in October 2021 and were 'considering the working group's findings and will determine next steps from there'.[169]

6.144When the committee sought an update in February 2023, MsTaraInverarity, First Assistant Secretary at the AttorneyGeneral's Department, reported that:

…this is an area where states and territories have primary responsibility and would need to amend their legislation in order for a register to be effective. So this is an area where we have briefed the new government as to an update on what has been committed to and some of the issues that have been experienced in seeking to progress that commitment, so that further conversations can occur with the states and territories about the proposal for a national register and how that might be framed and achieved.[170]

6.145Mr Hulley of Project Karma expressed support for a national public register and was concerned about the lack of agreement between federal, state and territory governments to implement one. He said:

We've got disjointed registers around this country. Speak with the people that work on them. I have. They'll tell you first up that the state registers are not talking to the national one. It's still a problem, and I was hearing about it seven years ago. It's getting better, but the ANCOR system, in the way it's being run, is atrocious.[171]

6.146Ms West also supported a '[p]ublic sex offender register for adult perpetrators'.[172] She submitted:

When allowing kids access to a particular sports coach, if we had that registry available we'd have the opportunity at the click of a button to look it up. In Western Australia and Victoria currently you can go to the police if you have suspicions about someone who had exposure to your child, and they can confirm that. But that's not always enough.[173]

6.147Ms West proposed a model based on the MultiAgency Risk Assessment and Management Framework, which was developed in response to the Victorian Royal Commission into Family Violence.[174] Under Ms West's proposal:

…if a child is identified as being at risk, or a person [is] seeking employment which involves access to children, or a person is entering a relationship or household where children are present, a report or inquiry can be made to the relevant apparatus…and those affected (the carer/school/workplace or household) would be notified that the person of question is listed as a sex offender. This would prevent deliberate weaponization of the register as a punitive instrument or for purposes of vigilantism.

I would also recommend considered qualification around inclusion of offenses which might have otherwise fallen within the parameters of the similar age defense.[175]

6.148Ms West cautioned that a public registry would 'capture a small portion of the overall risk' as it would only include convicted sex offenders.[176] However, she commented that '[e]very [law enforcement] officer out there would agree we need a registry that law enforcers have access to and the public in the right circumstances also do'.[177] She also told the committee that:

…personally, the circumstances around my own case demonstrate that had such a registry existed 30 years ago, the perpetrator would not have been allowed the access he had, and I would not be a victim today.[178]

6.149When asked about the key benefits and risks of a national public register, the AttorneyGeneral's Department advised:

Some stakeholders have argued that making the personal information of convicted child sexual offenders public may:

aid in the safety of children by providing the geographical whereabouts of convicted offenders, and

have a deterrent effect on offenders.

Risks to implementing a public register have also been raised, including:

the inadvertent identification of victims and survivors and their families

vigilantism and community safety issues, and

potential increase in recidivism among sex offenders due to the associated psychological, social, or financial costs (for example, job loss, exclusion from residence).

Research also indicates that only one third of child sexual offenders would appear on a register, potentially creating a 'false sense of security' by focusing the community's attention away from non-convicted individuals who pose a potential threat.[179]

Footnotes

[1]Mr Toby Dagg, Acting Chief Operating Officer, Office of the eSafety Commissioner (eSafety), Committee Hansard, 20February2023, p. 25.

[2]Carly Ryan Foundation, Submission 21, [p. 3].

[3]For example, Cyber Security Cooperative Research Centre, Submission 1, p. 14; Department of Home Affairs, Submission 25, p. 20.

[4]Australian Institute of Criminology, Submission 37, p. 4.

[5]Australian Institute of Criminology, Submission 37, pp. 4–5. Also see Department of Home Affairs, Submission 25, p. 20. Also see Dr Rick Brown, Deputy Director, Australian Institute of Criminology, Committee Hansard, 15 November 2022, pp. 37, 39.

[6]Australian Institute of Criminology, Submission 37, p. 5. Also see Department of Home Affairs, Submission 25, p. 20.

[7]Dr Brown, Australian Institute of Criminology, Committee Hansard, 15 November 2022, p. 40.

[8]Emeritus Professor Roderic Broadhurst and Mr Matthew Ball, Submission 27, pp. 15–16 (citations omitted).

[9]Cyber Security Cooperative Research Centre, Submission 1, pp. 14–15.

[10]Australian Institute of Criminology, Submission 37, p. 5 (citations omitted).

[11]Australian Institute of Criminology, Submission 37, p. 10.

[12]Australian Institute of Criminology, Submission 37, pp. 5–6. Also see Australian Institute of Criminology, Submission 2, p. 5.

[13]Associate Professor Benoit Leclerc, Associate Professor Jesse Cale and Professor Thomas Holt, Submission 8, [p.11] (citations omitted).

[14]Associate Professor Leclerc, Associate Professor Cale and Professor Holt, Submission 8, [p.11] (citations omitted).

[15]Dr Mark Zirnsak, Senior Social Justice Advocate, Uniting Church in Australia, Synod of Victoria and Tasmania (Uniting Church Synod), Committee Hansard, 9 December 2021, p. 4.

[16]Cyber Security Cooperative Research Centre, Submission 1, p. 14.

[17]Ms Anne-Louise Brown, Director of Corporate Affairs and Policy, Cyber Security Cooperative Research Centre, Committee Hansard, 9 December 2021, p. 11.

[18]National Crime Agency, United Kingdom, Submission 31, p. 16.

[19]Victoria Police, Submission 30, p. 9 (citations omitted). Also see Mary-Jane Welsh, Detective Superintendent, Cybercrime Division, Crime Command, Victoria Police, Committee Hansard, 9December 2021, p. 35.

[20]Professor Broadhurst, private capacity, Committee Hansard, 9 December 2021, p. 18.

[21]Associate Professor Leclerc, private capacity, Committee Hansard, 9 December 2021, p. 26.

[22]Associate Professor Leclerc, Associate Professor Cale and Professor Holt, Submission 8, [pp.11–12].

[23]International Justice Mission, Submission 53, p. 8. Also see Emeritus Professor Broadhurst and MrBall, Submission 27, pp. 17–18; Emeritus Professor Broadhurst, private capacity, Committee Hansard, 9 December 2021, pp. 15–16.

[24]International Justice Mission, Submission 53, p. 8.

[25]Project Paradigm, Submission 54, p. 2.

[26]Mr Dagg, eSafety, Committee Hansard, 9 December 2021, p. 48.

[27]Cyber Security Cooperative Research Centre, Submission 1, p. 15.

[28]Mr Mark de Crespigny, Deputy Director, Illegal Imports and Exports and Human Exploitation and Border Protection Practice Groups, Commonwealth Director of Public Prosecutions, Committee Hansard, 10 December 2021, p. 26.

[29]Collective Shout, Submission 16, pp. 14–15.

[30]Australian Institute of Criminology, Submission 37, p. 6 (citations omitted).

[31]National Crime Agency, United Kingdom, Submission 31, p. 16.

[32]Australian Institute of Criminology, Submission 37, p. 7 (citations omitted).

[33]WePROTECT Global Alliance quoted in Collective Shout, Submission 16, p. 15.

[34]Collective Shout, Submission 16, p. 15.

[35]Australian Institute of Criminology, Submission 37, p. 7.

[36]Dr Brown, Australian Institute of Criminology, Committee Hansard, 15 November 2022, p. 36.

[37]Dr Brown, Australian Institute of Criminology, Committee Hansard, 15 November 2022, p. 37.

[38]Australian Institute of Criminology, Submission 37, p. 8 (citations omitted). Also see Coen Teunissen and Sarah Napier, Australian Institute of Criminology, 'The overlap between child sexual abuse live streaming, contact abuse and other forms of child exploitation', Trends & issues in crime and criminal justice, No. 671, May 2023.

[39]Project Karma, Submission 10, p. 11 (citations omitted). Also see Destiny Rescue, Submission 52, p.15.

[40]Australian Institute of Criminology, Submission 37, p. 11.

[41]Emeritus Professor Broadhurst and Mr Ball, Submission 27, p. 3.

[42]Project Karma, Submission 10, p. 13 (citations omitted).

[43]Victoria Police, Submission 30, p. 9. Also see Ms Welsh, Victoria Police, Committee Hansard, 9December 2021, pp.36,40–41.

[44]Queensland Police Service, Submission 29, pp. 3–4.

[45]National Office of Child Safety, Department of the Prime Minister and Cabinet (National Office for Child Safety), Submission 14, p. 3.

[46]Haslam D, Mathews B, Pacella R, Scott JG, Finkelhor D, Higgins DJ, Meinck F, Erskine HE, ThomasHJ, Lawrence D, and Malacova E, The prevalence and impact of child maltreatment in Australia: Findings from the Australian Child Maltreatment Study: Brief Report, 2023; theHonAmandaRishworthMP, Minister for Social Services, and the Hon Mark Dreyfus KC MP, Attorney-General, 'Australian Child Maltreatment Study', Joint media release, 3 April 2023.

[47]Associate Professor Leclerc, Associate Professor Cale and Professor Holt, Submission 8, [pp. 12–13] (citations omitted).

[48]Associate Professor Leclerc, Associate Professor Cale and Professor Holt, Submission 8, [p. 13] (citations omitted).

[49]Emeritus Professor Broadhurst, Committee Hansard, 9 December 2021, p. 15.

[50]Emeritus Professor Broadhurst, Committee Hansard, 9 December 2021, p. 15.

[51]Emeritus Professor Broadhurst and Mr Ball, Submission 27, p. 3, also see p. 15.

[52]Emeritus Professor Broadhurst and Mr Ball, Submission 27, p. 16.

[53]Emeritus Professor Broadhurst and Mr Ball, Submission 27, pp. 3, 16–17. Also see EmeritusProfessorBroadhurst, Committee Hansard, 9 December 2021, p. 16.

[54]Emeritus Professor Broadhurst, Committee Hansard, 9 December 2021, p. 15. Also see EmeritusProfessor Broadhurst and Mr Ball, Submission 27, pp. 17–18 and attachment 1.

[55]Emeritus Professor Broadhurst, Committee Hansard, 9 December 2021, p. 16. Also see EmeritusProfessor Broadhurst and Mr Ball, Submission 27, p. 18.

[56]Dr Brown, Australian Institute of Criminology, Committee Hansard, 15 November 2022, p. 36.

[57]Mr Dagg, eSafety, Committee Hansard, 15 November 2022, pp. 20-21.

[58]Dr Zirnsak, Uniting Church Synod, Committee Hansard, 9 December 2021, p. 1.

[59]Dr Zirnsak, Uniting Church Synod, Committee Hansard, 15 November 2022, p. 2; also see p. 6.

[60]Mr Glen Hulley, Founding Chief Executive Officer, Project Karma, Committee Hansard, 15November 2022, pp. 6–7; also see Project Karma, Submission 10, pp. 13–14, 15.

[61]Detective Superintendent Jayne Doherty, Commander, Child Abuse and Sex Crimes Squad, NSW Police Force, Committee Hansard, 10 December 2021, p. 33.

[62]Detective Superintendent Doherty, NSW Police Force, Committee Hansard, 10 December 2021, p. 33.

[63]Mr Dagg, eSafety, Committee Hansard, 9 December 2021, p. 48. Also see eSafety, answers to questions on notice, 9 December 2021 (received 24 December 2021), [pp.5–39].

[64]Emeritus Professor Broadhurst, Committee Hansard, 9 December 2021, p. 19.

[65]Mr Dagg, eSafety, Committee Hansard, 9 December 2021, p. 49.

[66]Dr Zirnsak, Uniting Church Synod, Committee Hansard, 9 December 2021, p. 1.

[67]Australian Institute of Criminology, Submission 37, pp. 9–10 (citations omitted). The United Kingdom National Crime Agency also referred to measures that technology companies could employ including user warnings and education to potential offenders, see Submission 31, p. 15.

[68]Associate Professor Leclerc, Associate Professor Cale and Professor Holt, Submission 8, [p. 9].

[69]Ms Lucinda Longcroft, Director, Government Affairs and Public Policy, Australia and New Zealand, Google, Committee Hansard, 10 August 2023, p. 1. Also see eSafety, Submission 20, p.13.

[70]Ms Emily Cashman Kirstein, Manager, Child Safety, Government Affairs and Public Policy, Google, Committee Hansard, 10 August 2023, p. 3.

[71]eSafety, Submission 20, p. 13.

[72]Facebook (Meta), Submission 24, p. 10.

[73]Facebook (Meta), Submission 24, p. 10. Also see Meta, answers to questions on notice, 10December2021 (received 14 January 2022), [pp. 3–8].

[74]Dr Brown, Australian Institute of Criminology, Committee Hansard, 15 November 2022, p. 36.

[75]Dr Brown, Australian Institute of Criminology, Committee Hansard, 15 November 2022, p. 36.

[76]Emeritus Professor Broadhurst and Mr Ball, Submission 27, p. 18.

[77]Dr Brown, Australian Institute of Criminology, Committee Hansard, 15 November 2022, p. 36.

[78]Victoria Police, Submission 30, p. 9.

[79]Royal Commission into Institutional Responses to Child Sexual Abuse, Final Report, Volume 6,Making institutions child safe, 2017, p. 108; also see pp. 92–98.

[80]National Office for Child Safety, Submission 14, p.2.

[81]Ms Rebekah Kilpatrick, Head, National Office for Child Safety, and Assistant Secretary, AttorneyGeneral's Department Committee Hansard, 15 November 2022, p. 25.

[82]Ms Kilpatrick, National Office for Child Safety, Committee Hansard, 15 November 2022, p. 26.

[83]Ms Kilpatrick, National Office for Child Safety, Committee Hansard, 15 November 2022, p. 25.

[84]Attorney-General's Department, answers to questions on notice, 15 November 2022 (received 6December 2022), [p. 2].

[85]Ms Kilpatrick, National Office for Child Safety, Committee Hansard, 15 November 2022, p. 25. Also see Attorney-General's Department, answers to questions on notice, 15 November 2022 (received 6December 2022), [p. 2].

[86]AttorneyGeneral's Department, answers to questions on notice, 15 November 2022 (received 6December 2022), [p. 2].

[87]eSafety, answers to questions on notice, 15 November 2022 (received 2 December 2022), [p. 4].

[88]Ms Kilpatrick, National Office for Child Safety, Committee Hansard, 15 November 2022, p. 26.

[89]Mrs Jen Hoey, Founder and Parent Cyber Safety Consultant, Not My Kid, Committee Hansard, 20February 2023, p. 9.

[90]Ms Madeleine West, private capacity, Committee Hansard, 20 February 2023, p. 12.

[91]Ms West, private capacity, Committee Hansard, 20 February 2023, p. 11.

[92]Ms West, answers to questions on notice, 20 February 2023 and 24 February 2023 (received 9March2023), [pp. 1–4].

[93]Ms Kirrily (Kirra) Pendergast, Chief Executive Officer, Safe on Social, Committee Hansard, 20February 2023, p. 12. Also see Safe on Social, Submission 50.1, p. [2]; Safe on Social, answers to questions on notice, 20 February 2023 and 24 February 2023 (received 6March 2023), [pp. 1–2].

[94]Mrs Hoey, Not My Kid, Committee Hansard, 20 February 2023, p. 12.

[95]Mrs Hoey, Not My Kid, Committee Hansard, 20 February 2023, p. 12; Not My Kid, answers to questions on notice, 20 February 2023 and 24 February 2023 (received 3March2023), [p. 1].

[96]Not My Kid, answers to questions on notice, 20 February 2023 and 24 February 2023 (received 3March2023), [p. 3].

[97]Not My Kid, answers to questions on notice, 20 February 2023 and 24 February 2023 (received 3March2023), [p. 5]. Also see Mrs Hoey, Not My Kid, Committee Hansard, 20 February 2023, p. 12.

[98]Ms Pendergast, Safe on Social, Committee Hansard, 20 February 2023, p. 16.

[99]Ms Pendergast, Safe on Social, Committee Hansard, 20 February 2023, p. 13.

[100]Safe on Social, Submission 50, p. [2]. Also see Safe on Social, Submission 50.1, [pp. 2–7].

[101]Safe on Social, Submission 50, p. [2]. Also see Safe on Social, Submission 50.1, [p. 7].

[102]Australian Federal Police, 'Man charged with rape and sexual assaults at childcare centres', Media release, 1 August 2023.

[103]Ms Gabrielle Sinclair, Chief Executive Officer, Australian Children's Education and Care Quality Authority, Proof Committee Hansard, Senate Education and Employment Legislation Committee, Estimates, 26October 2023, p. 104.

[104]See, for example, Not My Kid, answers to questions on notice, 20 February 2023 and 24February2023 (received 3March2023), [p. 6].

[105]Ms West, answers to questions on notice, 20 February 2023 and 24 February 2023 (received 9March2023), [pp. 4–5].

[106]Safe on Social, answers to questions on notice, 20 February 2023 and 24 February 2023 (received 6March 2023), [p. 2].

[107]Safe on Social, answers to questions on notice, 20 February 2023 and 24 February 2023 (received 6March 2023), [p. 2].

[108]Project Paradigm, Submission 54, p. 19.

[109]Mr Hulley, Project Karma, Committee Hansard, 9 December 2021, p. 27.

[110]Destiny Rescue, Submission 52, p. 16.

[111]Destiny Rescue, Submission 52, p. 16.

[112]Facebook (Meta), Submission 24, p. 14.

[113]Collective Shout, Submission 16, p. 17.

[114]National Office for Child Safety, Submission 14, pp. 2, 3.

[115]Australian Federal Police, Submission 18, pp. 11–12.

[116]Australian Federal Police, Submission 38, p. 4.

[117]Australian Federal Police, Submission 38, p. 3.

[118]Mr Stephen Dametto, Acting Assistant Commissioner, Northern Command, Australian Federal Police, Committee Hansard, 15 November 2022, p. 23.

[119]Australian Federal Police, Submission 38, p. 3.

[120]Mr Dametto, Australian Federal Police, Committee Hansard, 15 November 2022, p. 23.

[121]Mr Dametto, Australian Federal Police, Committee Hansard, 15 November 2022, p. 26.

[122]Australian Federal Police, Submission 18, p. 5.

[123]Mr Brett Pointing, Deputy Commissioner, Operations, Australian Federal Police, Committee Hansard, 10 December 2021, p. 35.

[124]Mr Dagg, eSafety, Committee Hansard, 9 December 2021, p. 48.

[125]Australian Federal Police, Submission 18, pp. 9–10 (emphasis omitted).

[126]Australian Federal Police, 'Help us trace an object and stop child sexual abuse', Media release, 4September 2023.

[127]Australian Federal Police, Submission 18, p. 10.

[128]Mr Pointing, Australian Federal Police, Committee Hansard, 10 December 2021, pp. 34–35.

[129]Australian Federal Police, Submission 38, p. 3.

[130]Australian Federal Police, Submission 38, p. 4.

[131]Australian Federal Police, 'AFP launches call to action to help combat child sexual abuse', Media release, 6September2023.

[132]eSafety, Submission 44, p. 4.

[133]eSafety, Submission 44, p. 4.

[134]eSafety, Submission 44, p. 4. Also see eSafety, Submission 20, p. 4.

[135]eSafety, Submission 44, p. 4.

[136]eSafety, Submission 44, p. 5.

[137]eSafety, Submission 44, p. 5.

[138]Mr Dagg, eSafety, Committee Hansard, 20 February 2023, pp. 22–23.

[139]Ms Dagg, eSafety, Committee Hansard, 20 February 2023, p. 26.

[140]Mr Dagg, eSafety, Committee Hansard, 20 February 2023, p. 26.

[141]Mr Dagg, eSafety, Committee Hansard, 20 February 2023, p. 26. Also see Mr Dagg, eSafety, Committee Hansard, 15 November 2022, p. 20.

[142]Attorney-General's Department, answers to questions on notice, 20 February 2023 (received 7March 2023), [p. 3]. Also see Mr Dagg, eSafety, Committee Hansard, 15 November 2022, p. 20; Correspondence from the eSafety correcting evidence given at the public hearing on 15November2022, received 8 December 2022.

[143]Attorney-General's Department, Submission 43, p. 10.

[144]Attorney-General's Department, Submission 43, p. 10.

[145]National Crime Agency, United Kingdom, Submission 31, pp. 9–10 (citations omitted).

[146]NSW Police Force, Submission 26, p. 13.

[147]Ms Welsh, Victoria Police, Committee Hansard, 9 December 2021, p. 35.

[148]The Hon Mark Dreyfus KC MP, Attorney-General, ‘National campaign launched to prevent child sexual abuse’ Media release, 22 October 2023.

[149]Mrs Hoey, Not My Kid, Committee Hansard, 20February2023, p. 9.

[150]Ms Pendergast, Safe on Social, Committee Hansard, 20 February 2023, p. 10. Also see Safe on Social, Submission 50, [p. 1].

[151]Safe on Social, Submission 50.1, p. 1.

[152]Ms West, private capacity, Committee Hansard, 20 February 2023, p. 10.

[153]Ms West, private capacity, Committee Hansard, 20 February 2023, p. 14.

[154]Mr Dagg, eSafety, Committee Hansard, 20 February 2023, p. 22.

[155]Department of Infrastructure, Transport, Regional Development, Communications and the Arts, answers to questions on notice, 28 February 2023 (received 21 March 2023), [p. 1].

[156]Department of Infrastructure, Transport, Regional Development, Communications and the Arts, answers to questions on notice, 28 February 2023 (received 21 March 2023), [p. 1]. Also see MrDagg, eSafety, Committee Hansard, 20 February 2023, p.22–23.

[157]The Hon Michelle Rowland MP, Minister for Communications, 'Next step in modernising Australia's Classification Scheme' Media release, 22 June 2023. Also see the HonMichelleRowlandMP, Minister for Communications, 'Albanese Government outlines key reforms to National Classification Scheme' Media release, 29 March 2023.

[158]Sarah Napier, Christopher Dowling, Anthony Morgan and Daniel Talbot, Australian Institute of Criminology, 'What impact do public sex offender registries have on community safety?', Trends & issues in crime and criminal justice, No. 550, May 2018, p. 3; Australian Criminal Intelligence Commission, 'Protection services', Webpage, undated, https://www.acic.gov.au/protection-services (accessed 23May 2023).

[159]Napier, Dowling, Morgan and Talbot, Australian Institute of Criminology, 'What impact do public sex offender registries have on community safety?', Trends & issues in crime and criminal justice, No.550, May 2018, p. 4. Also see 'Access registered sex offender information' Webpage, last updated 14 May 2019, https://www.wa.gov.au/service/security/law-enforcement/access-registered-sex-offender-information (accessed 23 May 2023).

[160]Napier, Dowling, Morgan and Talbot, Australian Institute of Criminology, 'What impact do public sex offender registries have on community safety?', Trends & issues in crime and criminal justice, No.550, May 2018, p. 4.

[161]Duncan Evans, 'South Australia prepares new public registry for child sex abuse offenders', News.com.au, 4 September 2023.

[162]Napier, Dowling, Morgan and Talbot, Australian Institute of Criminology, 'What impact do public sex offender registries have on community safety?', Trends & issues in crime and criminal justice, No.550, May 2018, p. 4; United States Department of Justice, 'Dru Sjodin National Sex Offender Public Website: About NSOPW', Webpage, undated, https://www.nsopw.gov/en/About (accessed 24 May 2023).

[163]Jacqueline Beard, 'Registration and management of sex offenders', Research Briefing, United Kingdom House of Commons Library, 11 January 2023, p. 4. Also see United Kingdom Government, 'Guidance: Find out if a person has a record for child sexual offences', Webpage, last updated 3 April 2023, https://www.gov.uk/guidance/find-out-if-a-person-has-a-record-for-child-sexual-offences (accessed 24 May 2023); Napier, Dowling, Morgan and Talbot, Australian Institute of Criminology, 'What impact do public sex offender registries have on community safety?', Trends & issues in crime and criminal justice, No. 550, May 2018, p. 3.

[164]House of Representatives Standing Committee on Social Policy and Legal Affairs, Inquiry into family, domestic and sexual violence, March 2021, Recommendation 83, p. 343.

[165]Department of Home Affairs, Submission 25, p. 11. Also see Australian Federal Police, Submission18, p. 12.

[166]Attorney-General's Department, answers to questions on notice, 28 February 2023 (received 14March2023), [p. 2].

[167]Commonwealth of Australia, Budget Measures: Budget Paper No. 2 2019-20, p. 113.

[168]Attorney-General's Department, answers to questions on notice, 28 February 2023 (received 14March2023), [p. 2].

[169]Ms Ciara Spencer, First Assistant Secretary, Law Enforcement Policy Division, Department of Home Affairs, Committee Hansard, 10 December 2021, p. 37.

[170]Ms Tara Inverarity, First Assistant Secretary, International and Security Cooperation Division Attorney-General's Department, Committee Hansard, 20 February 2023, p. 18.

[171]Mr Hulley, Project Karma, Committee Hansard, 9December2021, p. 31. Also see Mr Hulley, Project Karma, Committee Hansard, 15 November 2022, p. 8.

[172]Ms West, answers to questions on notice, 20 February 2023 and 24 February 2023 (received 10March2023), [p. 1].

[173]Ms West, private capacity, Committee Hansard, 20 February 2023, p. 13.

[174]Ms West, answers to questions on notice, 20 February 2023 and 24 February 2023 (received 9March2023), [p. 5]. Also see Victorian Government, 'Family Violence Multi-Agency Risk Assessment and Management Framework', Webpage, reviewed 31 January 2022, https://www.vic.gov.au/family-violence-multi-agency-risk-assessment-and-management (accessed 24May2023).

[175]Ms West, answers to questions on notice, 20 February 2023 and 24 February 2023 (received 9March2023), [pp. 5–6].

[176]Ms West, answers to questions on notice, 20 February 2023 and 24 February 2023 (received 10March2023), [p. 1].

[177]Ms West, private capacity, Committee Hansard, 20 February 2023, p. 13.

[178]Ms West, answers to questions on notice, 20 February 2023 and 24 February 2023 (received 9March2023), [p. 5].

[179]Attorney-General's Department, answers to questions on notice, 28February2023 (received 14March2023), [p. 3] (citations omitted).