Source document: https://docs-lawep.s3.us-east-2.amazonaws.com/1697751053752.pdf (Ireland)
Oifig Náisiúnta um Fhéinmharú a Chosc HSE Straitéis agus Pleanáil Phobail Ospidéal Stewart, Baile Phámar, Baile Átha Cliath 20 National Office for Suicide Prevention HSE Community Strategy and Planning Stewarts Hospital, Palmerstown, Dublin 20 Tel: 01 6201670 Email: info@nosp.ie 11th March 2021 Harmful suicide and self-harm content online & the Online Safety and Media Regulation Bill Briefing Note, HSE National Office for Suicide Prevention 1.0 Introduction In April 2019, the HSE National Office for Suicide Prevention (NOSP) made a submission to the Public Consultation on the Regulation of Harmful Content on Online Platforms and the implementation of the Revised Audiovisual Media Services Directive.
Specifically, the Office inputted to question 3 of Strand 1 (National Legislative Proposal) as follows; Question: How should harmful online content be defined in national legislation?

Should the following categories be considered as harmful content?
Online platforms are already required to remove content which it is a criminal offence under Irish and EU law to disseminate, such as material containing incitement to violence or hatred, content containing public provocation to commit a terrorist offence, offences concerning child sexual abuse material or concerning racism and xenophobia.

Are there other clearly defined categories which should be considered?

For example: • Serious Cyber bullying of a child (i.e.
content which is seriously threatening, seriously intimidating, seriously harassing or seriously humiliating) • Material which promotes self-harm or suicide • Material designed to encourage prolonged nutritional deprivation that would have the effect of exposing a person to risk of death or endangering health NOSP Answer: Material which promotes self-harm or suicide should be considered as a clearly defined category in the context of any new national legislation.
Many cases of internet- related suicide have been reported in the popular and academic press.

The HSE National Page 1 of 8 Office for Suicide Prevention (NOSP) asserts that these highlight the potential that the internet has, to promote suicide or other related harmful practices.
Connecting for Life, Irelands National Strategy to Reduce Suicide1 places considerable emphasis on the need to “engage and work collaboratively with the media in relation to media guidelines, tools and training programmes to improve the reporting of suicidal behaviour within broadcast, print and online media” (Objective 1.4).
Four specific actions (1.4.1, 1.4.2, 1.4.3 and 1.4.4) detail a range of ways in which key stakeholders (e.g., DCCAE, BAI, Press Council of Ireland, NOSP, NGO partners) can encourage safer online environments, responsible media report and broadcasting of suicide-related content.

The HSE NOSP is of the view that a stronger legislative definition of harmful online content, which emphasises the harmful impact of pro suicide or self-harm material, should be developed.
This would assist in collective efforts to achieve objective 1.4 of Connecting for Life and other related efforts in this area.
A clearly defined list of material which promotes self-harm or suicide should be developed, to include but not limited to; • Information on how to hurt or kill oneself, including evaluations of different methods and rationale for each, and related questions and answers • Chatrooms, forums or other material that encourages suicide or assists with suicide planning • Suicide “pact” sites • Images or videos that depict acts of suicide or self-harm, or locations/materials associated with such acts • Material which promotes other suicidal behaviours e.g., behaviours that include planning for suicide, acquiring means to suicide, attempting suicide and suicide itself • Other potentially harmful information such as promoting means of concealment of self- harm activities.
It should be noted that while there is significant potential for harm from accessing pro-suicide material online (normalisation, triggering, competition, contagion) there is also the potential to exploit its benefits (crisis support, online help supports and information, reduction of social isolation, delivery of therapy, outreach) - any new legislation should give careful consideration to this balance.
1 https://www.hse.ie/eng/services/list/4/mental-health-services/connecting-for-life/publications/connecting-for-life- ireland-s-national-strategy-to-reduce-suicide.html Page 2 of 8 Research that highlights how and why pro-suicide online content is harmful: Significant increases have been noted in changes in the accessibility of suicide-related information.
For example, in a study2 analysing changes between 2007 and 2017, over 54% of hits from search terms related to suicide, contained information about new high-lethality methods of suicide.

Additional research from the University of Bristol in 20153 found that in a population survey of 21 year olds, of the 248 participants who had made suicide attempts (6% of the overall sample), almost three quarters reported some kind of suicide-related internet use at some point in their lives.
One in five had accessed sites giving information on how to hurt or kill oneself, though most of these had also visited help-sites.

In a clinical sample of over 1500 patients who presented to hospital following a suicide attempt, 8% said they had used the internet in connection with their attempt.

This percentage was higher for younger patients (12% of those aged 16-24 years) and those who had self-harmed with high suicidal intent (24%).
For most of those interviewed in the clinical sample, the main purpose for going online was to research methods of suicide, sometimes in great depth.

While researching methods of suicide online, did not always lead to action, it made individuals vulnerable by validating their feelings, legitimising suicide as a course of action, and providing knowledge about methods of suicide.
Half of those interviewed in the clinical sample planned and carried out a suicide method, based on their online research; some had purchased materials online.

However, in some instances, information about methods discovered online was found to be ‘off putting’, causing some individuals to rule out particular methods of suicide.
A more recent (2017) review4 of the evidence of the relationship between internet use, self- harm and suicidal behaviour in young people, highlights that this relationship is particularly associated with internet addiction, high levels of internet use, and websites with self-harm or suicide content.

2 Gunnell D, Derges J, Chang S-S, Biddle L. Searching for suicide methods.

Crisis, 2015.
Crisis, 2015.

36(5): 325-331. http://dx.doi.org/10.1027/0227-5910/a000326 3 Mars B, Heron J, Biddle L, Donovan J, Holley R, Piper M, Potokar J, Wyllie C, Gunnell D. Exposure to, and searching for, information about suicide and self-harm on the Internet: Prevalence and predictors in a population based cohort of young adults.

Journal of Affective Disorders, 2015.

185 p 239-245. http://dx.doi.org/10.1016/j.jad.2015.06.001 4 Marchant A, Hawton K, Stewart A, Montgomery P, Singaravelu V, Lloyd K, et al.
(2017) A systematic review of the relationship between internet use, self-harm and suicidal behaviour in young people: The good, the bad and the unknown.

PLoS ONE 12(8): e0181722.


https://doi.org/10.1371/journal.pone.0181722 Page 3 of 8 2.0 Submission on the General Scheme of the Online Safety and Media Regulation Bill, (February 2021) On review of the General Scheme of the Online Safety and Media Regulation Bill on a head-by- head basis, the NOSP does not have technical observations or a position on the design of the regulatory framework, how the Commissioner will govern new frameworks, or compliance, enforcement and sanction powers.
However, the area of online safety (particularly related to suicide and self-harm content) is of significant interest to the NOSP and has strategic synergy with actions in Connecting for Life.
Broadly, we welcome the proposed consultative approach of the Media Commission, in particular on issues as: the enumeration of categories of harmful material or behaviour; the provision of further categories of harmful online content; the preparation of online safety codes, and; the establishment of a systemic complaints scheme.

We envisage that our office will be available to input to the Commission’s work in these important areas, in the future.
Specific comments are as follows: Head 10 – Functions (1) The Commission has the following functions: (xiii) To promote public awareness, encourage research and conduct public information campaigns for the purpose of educating and providing information to the public in relation to: (a) online safety; (b) media literacy; (xiv) Promote educational initiatives and activities relating to online safety and advise, when requested, the Minister or any other Minister of the Government, Departments of State or any public body whose activities are concerned with matters relating to any of the purposes of this Act, and any educational or training institution; NOSP Comment The NOSP is a potential key collaborator and advisor to the Media Commission, in its development of public awareness, encouraging research and conducting public information campaigns related to suicide and self-harm information online.
Page 4 of 8 Head 13 – Codes of Practice (1) The Commission shall have the power to devise and implement codes [including broadcasting codes] to govern standards and practice to be observed by regulated entities.

Regulated entities will be required to provide periodic reports on their compliance or otherwise with codes.

Codes shall be reviewed and if necessary revised on a regular basis.

In devising and revising codes the Commission shall consult with relevant stakeholders.
NOSP Comment The NOSP welcomes future opportunities to consult with the Media Commission, on the development of codes of practice related to suicide and self-harm content.
Head 49A - Categories of harmful online content “harmful online content” includes – (a) material which it is an criminal offence to disseminate under Irish [or Union law], (b) material which is likely to have the effect of intimidating, threatening, humiliating or persecuting a person to which it pertains and which a reasonable person would conclude was the intention of its dissemination, (c) material which is likely to encourage or promote eating disorders and which a reasonable person would conclude was the intention of its dissemination, and, (d) material which is likely to encourage or promote [self-harm or suicide] or provides instructions on how to do so and which a reasonable person would conclude was: (i) the intention of its dissemination and (ii) that the intention of its dissemination was not to form part of philosophical, medical and political discourse.
NOSP Comment The NOSP welcomes: this inclusion of material which is likely to encourage or promote self-harm or suicide; the derogation outlined (for material that is dissemination as part of philosophical, medical or political debate), and; the general approach to enumerate definitions of categories, rather than arrive at broad-based descriptions.
Head 49B – Provision for further categories of harmful online content NOSP Comment The NOSP welcomes the allowance for the Media Commission to propose or include further categories of material from the definition of harmful online content.

This would allow the NOSP (and other interested parties) to propose or submit items related to suicide and self-harm, in the future.
Page 5 of 8 Head 50A – Online safety codes (4) in preparing online safety codes the Media Commission may consult with any persons or bodies it sees fit, including members of advisory committees established in accordance with Head 32.

NOSP Comment The NOSP welcomes this consultative approach and envisages opportunities for productive engagement with the Media Commission in this regard.
Head 51A – Online safety guidance materials (4) in preparing online safety guidance materials the Media Commission may consult with any persons or bodies it sees fit, including members of advisory committees established in accordance with Head 32.

NOSP Comment The NOSP welcomes future opportunities to consult with the Media Commission on the development of relevant safety guidance materials related to suicide and self-harm content.
Head 52B – Systemic complaints scheme (1) The Media Commission shall establish a scheme wherein it can receive notice of systemic issues with relevant and designated online services from nominated bodies.
(2) the Media Commission shall outline the functioning of such a scheme, including the process for nominating bodies, the process for removing such nominations and the process to be followed and standards to be met by nominated bodies in notifying the Commission of systemic issues with relevant and designated online services.

NOSP Comment The NOSP welcomes future opportunities to explore this scheme.
The Office could have a potential role to work as a ‘nominated body’ to assist the notification of systemic issues related to suicide and self-harm content.

Page 6 of 8 3.0 Additional information of note Since our submission 2019, the NOSP commissioned the National Suicide Research Foundation to undertake a literature review, to summarise the evidence of The Harmful Impact of Suicide and Self Harm Online Content (2020).
This review has helped to inform our current position on the harmful impact of suicide and self- harm content online and has outlined implications for internet service providers and social media platforms, for policy makers and statutory bodies, and for others who provide help online.

Recommendations are summarised as follows; 1.

Internet service providers should be encouraged to regularly review content and advisory notices (Moreno et al.
2016), remove pro-suicide sites promoting the use of high-lethality methods (Gunnell et al.

2015) and take appropriate measures for preventing online social contagion (Brown et al.

2018).

Monitoring and regulating online information on methods may also be beneficial (The Samaritans,2020 ; Chang et al.

2015).

2.

The internet may provide an important pathway for accessing information and perceptions valuable in clinical settings (Whitlock, Powers & Eckenrode 2007).
It may be beneficial to include use of prosuicide and self-harm websites and viewing of harmful content online as a standard item during clinical assessment (Shafi et al.

2020; Padmanathan, 2018 ; Marchant et al.

2017).

3.

Protection and safety frameworks, in addition to voluntary industry codes of conduct to prevent normalisation of harmful behaviour related to suicide and self-harm should be considered (The Lancet, 2019).

4.
4.

Guidelines and protocols to support communities in managing clusters should be updated to reflect the extensive use of communication technologies in modern society (Fu et al.

2013 ; Robertson et al.

2012).

It would be beneficial for guidelines to include preventative measures that a community should take to minimize the potential for contagion using mobile phones and the internet (Swedo et al.

2020 ; Robertson et al.

2012).

5.


It is important that suicide deaths are reported sensibly and responsibly in the media in compliance with the media guidelines for reporting suicide (Ortiz et al.

2018 ; Ueda et al.

2017 ; The Samaritans 2013).

Implementation of guidelines should form part of the curriculum of journalists and editors, and warrant inclusion in press codes of conduct for journalists (McTernan et al.

2018).

Page 7 of 8 6.


Early detection of coercions related to suicide and mental health is required and further research to identify emerging harms in real time is needed (Sumner et al.

2019).

7.

Focused psychoeducation on the harmful aspects of online activity may be beneficial for vulnerable adolescents (Memon et al.

2018).

8.

Further evaluation of the association between problematic use of social media/internet and suicide attempts in young people through longitudinal studies (Sedgewick et al.
2019) and tailored, methodologically rigorous high-quality multidisciplinary research is needed (The Lancet, 2019; Lupariello et al.

2019; Daine et al.

2013).

9.

It may be advantageous to examine the therapeutic benefit of connections users make online (Marchant et al.

2017; Robinson et al.

2016 ; Dyson et al.

2016) as this may act as a vehicle to reach those who engage in self-harm (Lewis & Baker, 2011) and encourage them to seek professional help (Memon et al.

2018).
2018).

The NOSP will work to address health-related items and research gaps that have been highlighted in this literature review, and looks forward to engaging with the Media Commission (once established) in any actions that are supportive of its functions and objectives.

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