Portugal’s Comments
14th July 2010
I) Draft document on "Child Online Protection Statistical Framework and Indicators” (WGCP/2/6)
1. Structure of the report
The report does not clearly separate the following sections: a) information collected from the
different countries; b) the analysis of the methodology; c) the recommendations. Besides,
there is some repeated information in various parts of the report, and we believe that a better
organization of its structure would make it more readable and easy to understand.
2. Content of the report
Several Internet activities undertaken by children (ex: purchasing or ordering goods or
services, playing or downloading video games or computer games etc.) are presented only as
activities of risk when they can offer many positive inputs and opportunities. The two aspects
of Internet activities (opportunities and risks) are clearly presented in the report “EU Kids
online” from Sonia Livingstone which is mentioned several times in the report. As an example,
the same can be applied on activities of our everyday life. It would be the same to classify the
action of walking, playing or the simple fact of being born as risk prone activities.
This misleading information (classifying simple activities only as risk prone activities) arises on
the Recommendations in Chapter 2 “Statistical framework for child online protection”, page
26, paragraph 85, which classifies a minimum set of risk-prone behaviors that are eventually
mere Internet behaviors that offer many opportunities. The same occurs on the
Recommendations in Chapter 5 “Measuring children’s risk-prone behavior, incidents and
children responses”, page 75, paragraph 169, Table 2, where the indicators on Internet
activities are qualified as “Recommended indicators for risk-prone behavior and incidents”
whereas these indicators could also be used for opportunity-prone activities. Therefore, we
propose to illustrate such Internet activities presented in the report as “opportunity and risk
prone activities” or “general Internet activities”.
On the Recommendations in Chapter 3 “Child online protection: measuring the conduct”, page
54, Table 1, the indicators regard the general use of the Internet and are not only child online
oriented. The title should therefore be replaced by a general one (e.g: “Recommended context
indicators regarding general use of the Internet”) in order to be more accurate.
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Furthermore, under the classification of online threats and incidents, the Recommended
indicator online encounters (page 32, paragraph 107 and page 73, paragraph 249) whether the
child has ever met anyone face to face that s/he first met on the Internet, should be refined as
it can cover situations that can be positive and not conducting only to threats and incidents.
II) Report on Online Threats (WG-CP/2/11)
Regarding the Report on the Source of Online Threats to Youth and Children, please see the
comments on track changes in the document in annex.
III) Report on Social Networking Services and Policies with regard to User-Created Content
(WG-CP-2/10)
We understand this report as a very preliminary and light approach to this thematic, as it is
stated. Once a substantive document will be presented we will be happy to contribute to the
debate with some comments, if appropriate.
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