EIGHT years after an independent inquiry exposed deep failings in the way children in care were protected by the system, a new report has warned that the Island still hasn’t learned those lessons – but this time, in the digital world.
Published today, the Children, Education and Home Affairs Scrutiny Panel’s review has said Jersey’s online-safety system is “fragmented” and “lacking an overarching framework,” leaving children more exposed to exploitation, abuse and harmful content than their peers in the UK.
The panel found that young people who are already vulnerable offline “are often more exposed in digital spaces” and that, without reform, the Island’s weaker safeguards will continue to put them at risk.
Here are seven of the key changes the report has said are needed to protect children online.
A comprehensive online safety strategy
One of the panel’s “core recommendations” is for the government to create “a comprehensive online safety strategy” that brings every department under a single plan.
At present, the report says, “various government policies touch on aspects of online safety, but there is no overarching framework connecting them”.
It said the new strategy should be “grounded in a rights-based framework,” promote “cross-government collaboration,” and be “forward-looking and capable of addressing current challenges while remaining adaptable to the evolving digital environment.”
A legal ‘gap analysis’
The panel has called for a full audit of Jersey’s laws to expose where protections against online harm are missing.
It said the government should “conduct and publish a comprehensive gap analysis of existing legislation addressing online harms, with particular attention to the range of types of harm currently covered”.
The review would show where current laws fall short and where new or updated legislation may be needed.
The report reads: “This analysis should also consider the absence of child-specific protections in emerging frameworks such as the VAWG legislation and reflect the enforcement challenges faced by a small jurisdiction operating in a global digital environment.”
The report says that while existing laws such as the Sexual Offences (Jersey) Law 2018 and the Computer Misuse Law cover some online offences, “the scope of this legislation appears to be disjointed, addressing only certain types of harm and lacking comprehensive coverage of the full range of risks children and young people face in the digital environment”.
Default filtering
Another recommendation is for internet service providers to introduce network-level filtering – a default block on harmful websites such as pornography or self-harm forums unless an adult chooses to opt out.
The report recommends: “The Minister for Sustainable Economic Development should explore and undertake a public consultation on the development of legislation that would require all on-Island internet service providers to introduce network-level filtering that is active by default and customisable by the contract holder.”
Child-friendly reporting
The report calls for “clear, child-friendly reporting pathways for online harm” allowing young people to seek help quickly and safely if they see or experience abuse online.
It reads: “Data from the Jersey Children and Young People’s Survey indicates that some young people are hesitant to report experiences of exploitation.
“The panel recommends developing a simple, accessible system for reporting harmful online content, supported by community learning initiatives that empower children, parents, and professionals to respond effectively.
“A simple, accessible system for Islanders to report harmful online content, accompanied by clear guidance on what to report, where to report it, and who handles it, should be developed.”
Technology-neutral laws and AI guardrails
The panel said Jersey must move away from reactive laws that target specific platforms or technologies and instead focus on the type of harm caused.
“Any legislation aimed at providing protection should focus on the harm itself rather than the technology through which it occurs,” the report reads.
“A technology-neutral approach ensures laws remain effective as new digital threats emerge, while technology-specific laws risk becoming outdated.”
It also recommends that government “develop policy and legislative guardrails to ensure the safe and ethical use of artificial intelligence, particularly in systems that interact with or profile children.”
It adds that those guardrails “should balance innovation with ethical safeguards” to protect children and young people.
Stronger accountability and cross-border enforcement
One of the most significant gaps identified in the review is the lack of clear rules requiring large online platforms to be accountable for the content and conduct on their services.
The panel said that “the absence of government-defined standards or regulations in Jersey for platform-led content governance suggests an implicit acceptance that decisions about potentially harmful content, particularly affecting children, are determined by corporate policies rather than by local legislative oversight or public authority”.
In contrast, the UK’s Online Safety Act requires companies such as Meta, X (Twitter) and TikTok to prevent children from accessing harmful material and to remove illegal content swiftly – obligations that do not currently exist in Jersey law.
The report notes that the decision not to seek inclusion under the UK Act “appears to have been made solely by the Minister for Sustainable Economic Development, without formal documentation, engagement with the Council of Ministers, States Assembly or Scrutiny”.
It warns that “the lack of process presents limited opportunities for democratic oversight and public accountability.”
The panel said this approach has left the Island without a clear mechanism to hold global tech firms to account.
“Concerns remain regarding the practical challenges of enforcement, particularly given Jersey’s position as a small jurisdiction,” it reads. “The panel also noted the complexities of legislating independently on an issue that is inherently international in nature, where influence over global digital platforms may be limited.”
It has therefore recommended that the government “establish a formal process for considering permissive extent clauses, including a requirement for ministerial decisions and scrutiny” to ensure that future decisions of this scale are properly documented and examined.
Updating online-safety policies in schools and care homes
GAPS in basic safeguards are leaving some children without consistent protection online, the panel found.
It said the Education Department’s Online Safety Policy, which was last updated in 2021, is out of date and that several parts are “no longer operational practice”.
“The Online Safety Policy and safety features such as filtering and monitoring software are only applicable to devices that are connected to the school network or wi-fi,” the report added. “If an individual uses data on a mobile device to access the internet, the CYPES filtering software will not apply.”
In care settings, the panel found that internet filters were missing entirely in some residential homes.
It added that the policy “does not apply to the Children’s Residential Service” and that while residents are given internet-use rules and individual safety plans, “the panel found that internet filtering software was not in place at the two Children’s Short Breaks Homes” – although the government said work is underway to address this issue.
Putting responsibility in the right hands
Finally, the panel called for online-safety policy to sit under the Children’s Minister rather than within the economic portfolio that currently oversees digital matters.
“Responsibility for the digital economy currently sits with the Minister for Sustainable Economic Development, while the Minister for Children and Families has responsibility for coordinating policies to safeguard children and support children’s wellbeing,” it read. “Given the centrality of child protection to online safety, the panel recommends assigning ministerial responsibility for this area to the Minister for Children and Families.”
