Recommendations

Recommendations

Immediate action

Effective internet filtering in schools

¶55. At paragraphs 18 to 21, above, I have set out my concerns that at The Acorns School, AR was able to search for and view graphic imagery of degloving injuries, despite the school believing it had an effective filtering system using reputable software.

Recommendation 21: The Department for Education should review and strengthen its guidance to schools on monitoring and filtering systems, including ensuring that the systems used are appropriate and adequate from a technical perspective. The department should ensure schools understand these requirements and consider whether inspections by Ofsted should play a greater role in monitoring compliance.

Local action by Lancashire County Council

Recommendation 22: Lancashire County Council should undertake a comprehensive review of how its children’s services and Early Help teams (i.e. Children and Family Wellbeing Service) assess and manage risk and online harms to children. This review should ensure that all frontline staff have a consistent and up-to-date understanding of online risks, and that they have access to effective tools and guidance to identify and respond to these risks. It should specifically include consideration of the risks associated with the use of Virtual Private Networks, which can enable children to bypass the safeguards established under the Online Safety Act 2023. The Department of Health and Social Care should consider whether reforms to national guidance, policy or training are required.

Limits on the powers of coroners and statutory inquiries

¶56. At paragraph 54 above, I have drawn attention to the anomaly that the power under section 101 of the OSA 2023 applies only to coroners (and not to the chair of a statutory inquiry) and applies only to the online accounts of a child who has died, not to a perpetrator who may have viewed violent material.

Recommendation 23: The Department for Science, Innovation and Technology should consider extending the powers under the Online Safety Act 2023 to enable Senior Coroners to make a notification to Ofcom to obtain access to social media accounts of perpetrators (not just of a child who has died), and for statutory Inquiries to be able to make a notification to Ofcom to obtain access to the social media accounts of both a child who has died and also a perpetrator.

Recommendations for matters to be further considered in Phase 2 of this inquiry

Powers under the Online Safety Act 2023

¶57. I have considered whether I ought to make recommendations for DSIT to consider legislating, for example by amendment to the OSA, so that there is a power to require content such as the Bishop Emmanuel stabbing to be removed from platforms. This would prevent such content being visible to adults and also reduce the risk that it can be viewed by children (for example, if the content has not been recognised as sensitive or the child is able to bypass age verification checks). I have decided that this would not be appropriate. Ms Connolly described the political debates that took place during the passage of the OSA, including consideration of the balance to be struck between free speech and online protections. It was clear that the issue of whether legal but harmful content should be available to adults was investigated by Parliament, such a measure having previously been in place for video service platforms. However, Parliament considered that it should not take steps to preclude adults from viewing legal but harmful content. I do not consider, in these particular circumstances, that these are issues into which I should trespass. Moreover, I recognise that the OSA has only recently come into effect, and I acknowledge the evidence of Dr Lappin of Meta, that policymakers should give the OSA time to take effect before considering the introduction of new or amended legislative requirements.⁶⁴¹⁶⁴¹ Witness Statement of Mr Lappin META000016/§48.

¶58. I do however have a specific concern that young people may use VPNs to bypass the age verification checks imposed by the OSA. I recognise that there are some legitimate benefits in using VPNs and the balance to be struck therefore justifies further scrutiny.

Recommendation 24: Phase 2 should consider age verification for the use of Virtual Private Network (VPN) software and other options to avoid VPNs being used to circumvent the age-related protections in the Online Safety Act 2023.

¶59. I have already recommended in Chapter 1: Fundamental problems, that Phase 2 should consider whether there should be a further ability to restrict or monitor access to the internet on the part of children and young people, if a significant threshold is passed concerning the risk they pose to others.

¶E03549332 04/2026 ISBN 978-1-5286-6243-7