EPISODE 3 SHOW NOTES: ONLINE SAFETY

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ONLINE SAFETY

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WOMEN’S EXPERIENCES ON WEBCAMMING AND PRIVATE GALLERY PLATFORMS
Back in March, when the UK entered lockdown, government-imposed social distancing protocols made it significantly harder for women to meet with clients in person. Faced with a significant drop in income, many women have moved online to connect with clients via webcamming and private gallery platforms. However, it’s important to note that not all women involved in selling or exchanging sex have access to the resources and technology required to move online (e.g. stable internet, laptop) and so have had no other option but to continue meeting with clients face-to-face throughout the pandemic.

Webcamming platforms allow women to stream live performances where they can chat and connect with viewers either in a group or one-to-one setting. Viewers typically pay in tokens to reach goals – such as removing a specific item of clothing or using a certain sex toy. Group shows are often free to watch as a means of encouraging viewers to pay for private, one-to-one shows. As a result, it is not uncommon for women to spend a significant amount of time on cam and make little to no money. Private gallery platforms allow women to upload images and videos behind a paywall which subscribers pay a fee to access. Subscribers can also chat with women via direct messaging and can request personalised content which they pay extra to access. Subscription costs can typically range between £5-£25 a month. Prior to the pandemic, some women were already using sites that offer webcamming and private gallery services (e.g. AdultWork) to advertise their face-to-face services and so have continued to use these platforms to connect with clients online. Some women have set up accounts on newer platforms like OnlyFans and AdmireMe, both of which have seen significant increases in sign-ups since lockdown began in the UK. Many women are also moving into the sex industry for the first time during the pandemic via these platforms due to losing jobs in sectors like hospitality and retail. As a result, platforms have quickly become saturated  – with many women producing content and not necessarily the same level of demand to match.

Establishing a subscriber base take a considerable amount of time, effort, and money. On top of this, platforms also take a percentage from each sale a woman makes. As a result, many women find that they often break even or operate at a loss. Rachel, a women’s worker for the Edinburgh-based service Another Way, gave some insight into the experiences of a woman she supports who connects with clients online via AdultWork:

“…One woman said to me that [performing on webcam on AdultWork] is about 99p a minute. She’d need to work for 350 minutes a day to cover what she would usually make [seeing clients face-to-face]. Plus, AdultWork takes 35% of anything they make. So, that becomes almost 400 minutes for her just to make what she was before. There’s also the waiting around aspect in terms of you might be sitting on cam, waiting for somebody to come up, and that can be really difficult for your mental health. Especially if you’re really desperate for the money and your income is down because of the pandemic. The sitting around aspect is not great.”

At CLiCK, we are hearing that women are having to take every opportunity they can to sell content as many women are finding that online selling of sex is significantly less profitable than selling sex face-to-face. This has raised concerns about women’s ability to set and maintain boundaries with subscribers due to the serious need to make an income. Women have also told us that they are concerned about women entering the industry for the first time during the pandemic and whether they will be able to access resources to support their safety planning and boundary setting.

There are also concerns about women having their content stolen by subscribers. A recent investigation by Motherboard uncovered an entire supply chain of people working to steal women’s content from platforms like OnlyFans. The content can be stolen from platforms by using screenshot and screen recording software, as well as more sophisticated scripts; code which churns in the background of the platforms to pull content directly from the site. This content is then often shared in communities established specifically to share women’s stolen content (CW: link contains explicit sexual images), posted on social media, and pirated to free tube sites like PornHub. Women take great care to control who can see their content by using tools that can block people from specific towns or cities from seeing what they post. As a result, content piracy has the potential to put women in dangerous or extremely difficult situations as the content can be used to doxx and harass women, or “out” them to their friends, family, or employer. The Revenge Porn Helpline has noted an increase in calls over lockdown from women who have had their content stolen from platforms like OnlyFans. This is something that the women Rachel supports have also experienced during the pandemic, and unfortunately women do not feel that platforms do enough to protect them or their content:

“Women don’t always feel that they’re in complete control on platforms, in terms of selling or exchanging sex, because they don’t know who is sitting on the other side of the computer screen. They don’t feel they have complete control over their images as people could screenshot them […] a few of my clients unfortunately have had people threaten to out them […] Women have said that platforms aren’t particularly helpful. They don’t feel that platforms massively care about them, in the sense of if [their content was stolen], if they were to contact the platform – they don’t think they’d have any support at all.”

The sex industry itself benefits from this content piracy. The #NotYourPorn campaign, founded by Kate Isaacs, is calling for the regulation of the commercial porn industry. Kate highlights that free tube sites, like PornHub, are built on stealing content from women and that there is now content on free tube sites tagged as “stolen OnlyFans”. We have also heard from a woman who works with CLiCK that her profile and content were ripped from one escorting site and posted on another without her consent or knowledge. She is now concerned that her content may be on other sites she is not aware of, and said:

“I should be in control of where I post.” 
WHAT IS BEING DONE TO KEEP WOMEN SAFE ONLINE?
PLATFORMS
​Women have told us that they do not feel particularly supported or protected by any of the platforms they use. We have heard from women who have directly reported abusive subscribers to platforms and have received no reply or reassurance that the subscriber’s behaviour will be addressed. As a result, even though platforms take a significant cut of women’s income, women are receiving little back in way of support and protection from abuse and harassment. However, it must be acknowledged that platforms are making some active efforts to reduce and prevent content piracy.

Platforms can support women by submitting DMCA takedown requests to sites where women’s content has been pirated. OnlyFans report that they have a 75% success rate in having women’s content removed from “offending image hosting sites, torrent providers, and cyber lockers”. However, once a woman’s content has been posted on sites like PornHub – or on social media – viewers can download, screenshot, and save that content to their own device. This means that women’s content can reappear just as quickly as it was removed. As a result, DMCA takedown processes are purely reactive and do nothing to actively prevent piracy behaviour occurring in the first place. However, some platforms are now investing in new technological innovations to prevent women’s content from being stolen.

The Motherboard investigation highlights that JustForFans uses digital fingerprinting technology which means that if a woman’s video is stripped from JustForFans and uploaded to PornHub, for example, it is possible to identify which subscriber was responsible. Similarly, ManyVids use unique stream links – meaning that each subscriber viewing a woman’s content has their own individual URL which can be used to trace the subscriber responsible if the woman’s content is shared elsewhere. OnlyFans have also recently announced, after this episode was recorded, that they now use technology to block screenshots on the OnlyFans app on Apple and Android devices – similar to the technology used by mobile banking apps and Netflix. However, posts on sites like The Fappening Forum (CW: explicit sexual images) highlight that subscribers are more than capable of getting around anti-screenshot software by using the OnlyFans website instead of the app. Content is also regularly pulled from ManyVids, JustForFans, and AdmireMe and shared widely in these forums. 
REGULATION
Kate Isaacs, founder of the #NotYourPorn campaign, highlights that there is currently no regulation holding platforms accountable to ensure they are doing everything they can to protect their users. Without this regulation, platforms have no incentive to improve their reporting processes or technology:

“As [platforms] grow, there’s no one holding them accountable for ensuring systems are in place – which is why I think regulation is so important. We can reason with the likes of Mindgeek, or OnlyFans, or AdmireMe but actually there’s nothing holding them accountable for that and every time a new player comes into the market, there’s nothing holding them accountable for profiting from certain imagery as well.”

One possible answer to the regulation of these platforms is the Online Harms Bill. This Bill calls for a statutory duty of care to make companies take more responsibility for the safety of their users and tackle harm caused by content or activity on their services. Revenge porn, cyberstalking, and harassment are all explicitly named as forms of harm and violence that the Bill seeks to address. As part of this regulation, platforms would have to be “safe by design” – ensuring that user safety is at the core. Examples of a platform being “safe by design” would include:
  • Ensuring terms and conditions are accessible and easy to understand - The terms and conditions (Ts&Cs) of many of these platforms are extremely long and jargon filled which can mean that women are not always fully aware of what they are signing up to. This is concerning as by agreeing to the Ts&Cs of some platforms, you are waiving your moral rights to your content. Your moral rights cover: your right to be recognised as the creator of the content, your right to object to any derogatory treatment of the work (e.g. additions, deletions, or distortions), your right to object to false attribution (e.g. your right not to be named as the creator of content you did not create), and your right to prevent content from being made available to the wider public
  • Ensuring terms and conditions are enforced effectively and consistently – Subscribers are currently not being held accountable for content piracy, abuse, or harassment
  • Taking prompt, transparent, and effective action following user reports of abuse or harassment and directing users to support services - We have heard from women that they have not received support from platforms when they have reported abuse and harassment
  • Supporting law enforcement with investigations – Platforms like PornHub have been notoriously uncooperative when supporting law enforcement with investigations in the past
  • Showing commitment to technological innovation to support the safety of users – Whilst platforms like JustForFans, ManyVids, and OnlyFans have implemented technology to prevent privacy, this technology does not currently go far enough. Under this regulation, platforms would have to continually commit to improving their technology as a way of keeping their users safe

​Whilst this may sound positive, this Bill is unlikely to pass through parliament until 2023/2024. By then, online platforms will have evolved and changed so much that the original bill will be rendered obsolete. However, it may be a positive thing that this regulation is taking such a long time to pass as the UK Government have shown that they have a fundamental lack of knowledge around the online sex industry. As part of the Online Harms Bill, the UK Government sought to introduce age-verification on porn sites. However, the UK Government originally intended to use a company owned by Mindgeek – who also own PornHub, RedTube, and YouPorn – to provide this age verification software. This problematic oversight raises questions about what other gaps exist in the UK Government’s understanding of the online sex industry. It is imperative that the Online Harms Bill – or any other attempts to regulate platforms – are informed by the voices and experiences of women who use the platforms the Bill seeks to regulate, otherwise the Bill risks doing more harm than good. 
LEGISLATION
The Abusive Behaviour and Sexual Harm (Scotland) Act 2016, which came into force in 2017, aims to protect against the non-consensual sharing of intimate images. This legislation means that anyone who shares – or threatens to share – someone’s intimate images could face up to five years in prison. Crucially, however, this legislation does not protect images which were already consensually in the “public domain”. This means that if a woman has content stolen from her OnlyFans page, her content would not be covered by this legislation – despite it being behind a paywall – as it had been made available with her consent for a section of the public (e.g. her subscribers) to purchase. Back at the start of the pandemic, the Encompass Network lobbied the Scottish Government to update this legislation to cover women’s content as we knew platforms like OnlyFans and AdmireMe would become increasingly popular. However, these calls were rejected by the Scottish Government who stated that women may be able to use existing harassment legislation (e.g. stalking legislation) instead. Kirsty Thomson, a lawyer at Scottish Women’s Rights Centre, states that women’s content needs to be protected in and of itself:

“You would need to tie [content piracy] to another type of criminal activity. For instance, if there is stalking or harassment – and [content piracy] is part of it – then maybe it could be brought into that […] But what we’re talking about, this reposting and this sharing, it might fall within another crime but often it won’t. What women really are wanting, or need, is for [their content] to protected by and of itself”

The Scottish Government also stated that – due to the global nature of platforms like OnlyFans and AdmireMe and the fact that subscribers can be from anywhere in the world – updating the legislation to protect women’s content and enforcing this legislation would generate an enormous amount of work for Police Scotland and the Crown Office and Procurator Fiscal Service. However, as we are living in an increasingly digital world, our approach to policing, legislation, and regulation must reflect this.

Although it can be upsetting and unnerving to hear about the gaps in legislation, it is important to stress that these gaps do not mean that there are no legal options. Each women’s experience of abuse, harassment, and content piracy is different – there is no one size fits all legal solution.

​We encourage any women who use platforms like OnlyFans or AdmireMe to get in touch with Scottish Women’s Rights Centre for free, confidential advice about your rights on these platforms and your legal options if you experience content piracy.
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If you have experienced content piracy, you can also get in touch with the Revenge Porn Helpline for free and confidential legal advice, support with issuing DMCA takedown requests, and emotional support to talk through the impact of having your content stolen.
CHALLENGING THE BEHAVIOUR
There will always be people with the technological know-how to get around anti-screenshot software and legislation is never enough in of itself to deter someone from causing harm. As a result, improvements in technology and legislative change need to go hand in hand with changes in societal attitudes towards women who use these platforms. Kat Revenga, the vice president of FanCentro, stated in the Motherboard investigation:
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"There’s a social bias against sex workers that’s made this more permissible. Those stealing the content feel that it’s their right to take it, that the creators deserve the violation by virtue of the work they do."
WHAT NEEDS TO CHANGE?
​There needs to be holistic change and progress that is inclusive of the Government, platforms, and services which provide support to women to ensure that women – and their content – are better protected. 
GOVERNMENT
  • Government regulation is necessary to ensure that platforms are held accountable – without this regulation platforms have no incentive to improve the safety and security that they offer to their users
  •  Regulation must be timely and flexible to ensure the approach to holding platforms accountable is in step with the changing nature of the online sex industry
  • Awareness of women’s experiences on webcamming and private gallery platforms must be raised among policy makers, legislators, and politicians to ensure any future regulation of platforms meets the needs and rights of women who sell/exchange sex or images online. Women with lived experience must be directly and actively involved in this awareness raising. Through campaigns like #NotYourPorn, these conversations are already happening and women are encouraged to be part of this campaign in any way that suits them
  • Women with lived experience of women who sell/exchange sex or images must be directly and actively involved in any amendments to existing misuse of sexual images legislation, or the creation of new legislation, to ensure women and their content are protected in a way which is appropriate and relevant
PLATFORMS
  • Platforms should make active efforts to improve the accessibility of their terms and conditions to ensure women are aware of exactly what they are signing up to
  • Platforms should improve the vetting procedure for subscribers to establish a stronger paper-trail for future investigations should any abuse or harassment occur
  • Platforms should be open and transparent about how they tackle piracy and should be continually horizon scanning and innovating to develop new technologies to limit piracy behaviour 
SERVICES
  • ​Services have the potential to carry out effective prevention work in the community which challenges public stigma towards women who sell/exchange sex or images in order to tackle abuse, harassment, and content piracy at the core and drive attitudinal and behavioural change
  • Services have a responsibility to upskill their staff with an awareness of the experiences of women who use webcamming and private gallery platforms to ensure staff can inform women of their rights and help women to develop effective safety plans if they need support in doing so
  • Any prevention work carried out by services – and any training staff receive – must be directly informed by the lived experience of women who sell/exchange sex or images online
IF YOU NEED SUPPORT
If you have been affected by anything we have discussed in this episode, there is support available.  We encourage any women who use platforms like OnlyFans or AdmireMe to get in touch with Scottish Women’s Rights Centre for free, confidential advice about your rights on these platforms and your legal options if you experience content piracy.
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If you have experienced content piracy, you can also get in touch with the Revenge Porn Helpline for free and confidential legal advice, support with issuing DMCA takedown requests, and emotional support to talk through the impact of having your content stolen.

For emotional and practical support you can get in touch with CLiCK, other Encompass Network services, or sex-worker led networks like Umbrella Lane.