Better Late than Lacking Evidence: Policymaking for Child Online Safety in Africa

In developing policy approaches to safeguarding children online, identifying the range and diversity of risks is both foundational and critical. In response to external pressures, policymakers may hastily craft policies without adequately assessing existing risks, and by so doing will formulate ineffective policies. Generally, risks faced by children on the internet are somewhat similar across different jurisdictions; maybe even more similar in countries belonging to the same continent. However, to what extent, what degree and in what form they are being faced remains an imperative question that must be answered for effective policy making.

For instance, most countries would agree that children face risks such as exposure to indecent imagery, cyberbullying, grooming or exposure to violent content. (All which can be better understood by appreciating risk classification. Previously, stakeholders widely referenced the European Union Kids Online’s1 risk classification framework which fit risks into three categories; Content Risks, Contact Risks and Conduct Risks. These categories feature commercial, aggressive, sexual and value-based risks that affect children as content recipients, participants and actors in the online world. Recent studies2 have complemented the classification to accommodate two categories; contract (also called commercial) risks and cross-cutting risks. Respectively, these are commercially exploitative risks and risks with multiple manifestations and dimensions.)

This foundational understanding of the existing risks, and perhaps how to classify them, within a policy jurisdiction is a pivotal element for any effective policymaking on this issue. However, to properly identify risks, policymakers must engage a multistakeholder approach. Parents, teachers, guardians, technologists and even children must be consulted because, as it is said, the internet does not have one stakeholder. 

The Rwandan Example

A great example of this is the Rwandan government’s multi-layered stakeholder engagement process in creating their Child Online Protection (COP) Policy.  First, the government extended a high-level invite to 5Rights Foundation and the University of East London to partner in research and consultation for the Rwanda COP Policy. The consortium then engaged with a diverse range of stakeholders including educators, lawyers, advocates, academia, and government representatives (notably, the group’s report does not indicate that any children were consulted). The stakeholders were able to identify a range of risks of different degrees. These findings fed into the creation of Rwanda’s much-praised Child Online Protection Policy.3 

Evidence-Based Policymaking

Generally and conversely, however, many African countries are not engaging a similar path. As of 2023, the Africa Committee of Experts on the Rights and Welfare of the Child (ACERWC) noted the information gap that exists on the continent regarding online harms affecting children as well as information about the violations of children’s rights online. The Committee also noted critical gaps in legislation, infrastructure as well as stakeholder capacity in addressing online harms against children in Africa.4  

Perhaps the dearth of legislation and policy on the continent addressing child online protection is a direct result of the lack of multistakeholder-backed research first identifying the risks that exist. And perhaps it is better for countries, first, to invest in research and evidence gathering before diving into policymaking. Evidence-based policymaking for online safety and trust issues faced by children as users of digital technologies is the most effective (even cost-wise) path for African governments who still have a ways to go in crafting meaningful policies that maximise opportunities and decrease risks for children online. 

One of the most effective ways for African governments to ensure evidence-based policy-making will be to leverage stakeholders within the Civil Society and Academia space who can contribute capacity, expertise and a truly right-based lens to analysing the online environment as it affects children. Just like with Rwanda, leveraging the expertise and willingness of stakeholders will help the government build quality and diverse evidence that will feed into policymaking.  Once these partnerships are entered into, then the consultation process must focus on generating and gathering quantitative and qualitative data from divergent and reliable sources. The involvement of academia will be useful to methodologically synthesize the data in a way that represents the true state of the landscape. After this, a broader-level stakeholder engagement must be facilitated to broaden perspective and finetune findings. 

The African Union is Trail-Blazing

While individual nations on the continent need to fill their policy and practice gaps in protecting children in the digital environment, the African Union (AU) is blazing the trail on a global level. This year, 2024, the AU approved the world’s first comprehensive policy for child online protection “The African Union Child Online Safety and Empowerment Policy”; reported to have been formulated with a wider range of stakeholders and in fact, relying on a framework developed by leading child’s rights non-profit organisation, 5Rights.5 

Conclusion

In conclusion, a regional policy without national policies and laws to reinforce protection for children is almost useless. African governments must formulate and implement their own laws and legislations using an evidence-based approach to ensure accurate and contextual resolution of the risks threatening children’s safe participation online and in the use of digital technologies. Furthermore, the diversity and uniqueness of each nation present an even more compelling reason for thorough evidence-gathering and stakeholder engagement to be conducted before policymaking (or policy-copying!) is carried out. 


  1. Livingstone, S, and Haddon, L (2009) EU Kids Online: Final report. LSE, London: EU Kids Online. (EC Safer Internet Plus Programme Deliverable D6.5) https://eucpn.org/sites/default/files/document/files/5._eu_kids_online_-_final_report.pdf ↩︎
  2. Livingstone, S., & Stoilova, M. (2021). The 4Cs: Classifying Online Risk to Children. (CO:RE Short Report Series on Key Topics). Hamburg: Leibniz-Institut für Medienforschung | Hans-Bredow-Institut (HBI); CO:RE – Children Online: Research and Evidence. https://doi.org/10.21241/ssoar.71817 ↩︎
  3. Republic of Rwanda, Ministry of ICT & Innovation. “Rwanda Child Online Protection Policy”. Accessible: https://rura.rw/fileadmin/Documents/ICT/Laws/Rwanda_Child_Online_Protection_Policy.pdf ↩︎
  4. African Committee of Experts on the Rights and Welfare of the Child (2023). “DAC 2023: THE RIGHTS OF THE CHILD IN THE DIGITAL ENVIRONMENT”. Accessible: https://www.acerwc.africa/sites/default/files/2023-02/DAC%20CONCEPT%20NOTE%202023_EN.pdf ↩︎
  5. 5Rights Foundation. “African Union approves pioneering Child Online Safety and Empowerment Policy, leveraging 5Rights’ Toolkit” Accessible: https://5rightsfoundation.com/in-action/african-union-adopts-pioneering-child-online-safety-and-empowerment-policy-leveraging-5rights-toolkit.html ↩︎

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