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The kids are going to be online

The Safe Social Media Act is a good start, but online safety needs to include literacy.

Last month, the federal government tabled, otherwise known as the Safe Social Media Act. In many ways it mirrored some of what were, in my view, the best parts of the last government's attempts at regulating online harms: the same list of harms, the same age-appropriate design code language, the same duty on platforms to act responsibly.

Two new elements in this latest attempt to make kids safer online are a reflection of the times: drawing AI chatbots into the scope of regulated technologies, and what many are calling an age ban but what is really more of a moratorium on letting users under 16 onto a platform until that platform can prove it has met the age-appropriate design requirements laid out in the bill.

The bill is, in my view, table stakes for what should be required of companies with consumer-facing products, let alone ones with a large consumer base of children. And a youth ban - especially one written as an incentive mechanism for compliance with the new rules - addresses just part of the problem. Taking youth online safety seriously requires a multipronged approach that includes C-34, but that also equips young people with the tools they need to contend with these technologies and the actors who seek to exploit them.

Literacy is a policy lever that travels with kids across the internet whether or not a given platform is captured by the legislation. That transferability matters, because in some instances the very harms C-34 sets out to tackle are happening on platforms the bill might not reach.

Take terrorism and violent extremism content, one of the the bill calls on platforms to mitigate. The RCMP is fairly explicit about where that harm is being cultivated: Roblox, Discord, Telegram and Minecraft are gaming and private-messaging environments used by the, a terrorist entity, to recruit and radicalize children in Canada. But the bill, as drafted, may not capture these platforms at all. Private messaging is carved out entirely, and whether something like Roblox counts as a regulated "social media service" is left to Cabinet to decide later.

And this isn't only about which platforms fall within scope. The UK has a fairly developed online safety regime, and still that hasn't stopped into carrying out firebombings of synagogues and Jewish ambulance services in London. Investigators in these instances highlighted how the teens were drawn into seemingly innocuous discussion on Facebook, Telegram, and Snapchat before the conversation moved into private messaging with handlers. A regime built around platform duties doesn't reach a kid at that stage. But literacy that travels with the kid might.

Finland has taught media literacy from preschool since the 1990s and now ranks first in Europe for exactly that kind of resilience; one Helsinki educator describes it as a .something similar: foreign influence succeeds by exploiting a weak domestic information environment, which makes digital literacy an investment in national security and resilience.

Further, a social media platform product doesn't stop being harmful when you turn 16: even if you've been blocked from using a platform until then, all of those harmful features will simply be waiting for you. And it's entirely possible that rather than do the work of meeting the safety requirements, platforms will just block young users outright — at which point and find their way onto a still-harmful platform anyway.

Literacy is also a hedge for the government. With the youth ban in Canada structured in a way where the regulator effectively rubber-stamps platforms it has deemed “safe,” what happens when something bad happens on one of those platforms? Literacy is the backstop for the kids who fall through the cracks of a regime meant to keep them safe online by casting as wide a net as possible.

Critics of government-funded literacy programs in Canada like to argue that education is provincial jurisdiction. There are two answers to that. The first is the reframe above: as national-resilience and security, which falls squarely on the feds. The second is that the week before tabling this bill, the government launched its national AI strategy,, with AI literacy training pitched at a million students and educators; in other words, teaching people how to navigate a powerful, fast-moving technology, at national scale. Admittedly, a strategy is not legislation: one funds and signals, the other compels. But the federal AI strategy proves the federal government already has both the appetite and the delivery channels to do literacy at scale.

C-34 does real things: it tells tech companies they can no longer put profit before the well-being of Canadian children, it brings AI chatbots into the regime, and it carries forward genuine duties around child sexual abuse material and non-consensual intimate images. In my view, it is a good bill, and as Lianna McDonald, who has spent her career on the front lines of the worst harms done to children online, has argued, we can't let perfect be the enemy of good when it comes to legislation that makes kids safer online. Notably, many of the tech companies are already seizing on the age ban as the bill's supposedly fatal flaw, in a lobbying effort to kill the whole thing.

But passing C-34 is the starting point, not the end state, for making Canadian kids safer online. A fulsome online safety regime should require safer products while also fostering the skills required to operate these products safely. Literacy, done at a national scale, also stops being a narrow child-safety measure and becomes something closer to a nation-building exercise. I have heard these are all the rage.


is an MPP class of ‘22 and a Senior Policy Advisor at Deloitte’s Future of Canada Centre. She previously spent a number of years as a Director at the Centre for Media, Technology and Democracy in collaboration with the Media Ecosystem Observatory. During her MPP, she also interned with the Global Affairs Canada Digital Inclusion Lab working at the intersection of foreign and digital policy. Phaedra has lived and worked in Canada, Hong Kong, Geneva, Colombia, the United States and the United Kingdom and is a dual citizen of Canada and Finland. Above all she is a proud mom to her twin daughters.

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