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Earlier this year, the UK government published the Online Harms White Paper. The report, presented to Parliament by Home Secretary Sajid Javid and Secretary of State for Digital, Culture, Media & Sport Jeremy Wright, argued for an independent regulator to hold technology companies to account in order to protect users from harms ranging from cyber-bullying to hate-speech.

Read the Online Harms White Paper.

Although the proposals were presented as ambitious and unique, technology ethics think tank Doteveryone has drafted a response to the white paper as part of the consultation process (which ended at the beginning of July). In it, the organization highlights what’s missing from the white paper and what else should be done in order to build a safer and more accessible digital world.

What problems does Doteveryone identify in the Online Harms White Paper?

Doteveryone is direct in its criticism of the Online Harms White Paper. Writing on medium, Catherine Miller, Doteveryone’s Director of Policy, calls the white paper “a hodge-podge of Codes of Practice and initiatives with neither a clear articulation of what problem the proposals are supposed to solve, nor a clear vision for what alternative future they’re intended to promote.”

Doteveryone published a detailed response to the white paper earlier this month, but there are a couple of core issues that the charity believes the report fails to address.

Read next: Doteveryone report claims the absence of ethical frameworks and support mechanisms could lead to a ‘brain drain’ in the U.K. tech industry

There’s still no “unifying narrative” to tackling the challenges posed by tech

The report doesn’t, Doteveryone argues, offer an integrated solution to the problems it refers to. Essentially, the white paper does little more than enter a discussion that’s already confusing and fragmented by confusing the picture further.

Miller writes that it “sits alongside a proliferation of overlapping initiatives including the forthcoming Consumer Markets White Paper, ICO’s age-appropriate design-code, and the Furman Review into digital competition.” She argues that “without a unifying narrative these are almost impossible to navigate and often in potential conflict.”

Organizations must be systemic in their approach to solving problems, not reactive

Doteveryone argues that “the government must offer carrots and not just sticks.” Citing its own research that suggests that 5% of employees in tech and 16% working in AI have left their roles over concern about the impact of their products, Miller goes on to suggest that its important for the industry – or rather government – to encourage a systemic approach to tackling and minimizing online harms.

This means that tech companies would have a duty of care to their users.

By focusing on the design and decision making processes that are part and parcel of working in tech, that will not only ensure that tech companies can avoid being reactive in dealing with the consequences of their actions, it also creates a safer, more open environment for tech workers as well. In theory at least, it removes engineers and product managers from the conflict of interest that can emerge between users and employers.

The focus on ‘harm’ fails to properly protect citizens

Miller and Doteveryone also take issue with the very notion of ‘harm’ as it expressed in the report. In the white paper, ‘harm’ is something a regulator is needed to force organizations to respond to – it is never presented as a systemic problem.

The way to tackle this, Miller suggests is by focusing more on the fundamental rights of citizens. “We recommend the regulator uses the established UN human rights framework to set out public interest objectives for online services to meet.”

A further reason to shift the focus in this way is it will ensure the regulation – and, indeed, the regulator – remains “forward-looking and anticipatory.”

As Miller explains, “Digital technologies move too fast for reactive and retrospective regulation to be effective.” By moving towards a more structural way of understanding issues like harm and risk, we can ensure we are in a better position to tackle harm in the future.

So what next for the Online Harms White Paper?

The consultation period for the Online Harms White Paper has now closed – so the next move is ultimately with the government. However, with the Conservative government in turmoil and Brexit forcing just about every other issue far down the agenda, it seems unlikely that we’re going to see much movement.

However, if the digital economy really is set to be a part of a Britain that’s “going it alone”, thinking carefully about what this means for everyone from employees to users will remain immensely important. Doteveryone’s insight and expertise shouldn’t be ignored.